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Voice of Experience: The Definition of Personal Protective Equipment

I can remember a day when I would ask employees to name the five topics of a job briefing and why personal protective equipment (PPE) is the fifth point on the list of topics. Since the second part of the question was always a greater challenge for everyone to understand, I’d like to take some time to discuss the differences between protective equipment and PPE. Employees sometimes consider PPE to be system safety grounds, cover-up equipment, traffic vests and other equipment. As you can see in the excerpt below, 29 CFR 1910 Subpart I defines and identifies PPE as well as the body parts that are required to be protected while performing work.

“1910.132(a)
Application. Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.”

Please note that protective equipment – including PPE – is identified in the opening statement of the general industry performance standard. There is a difference between the two. The employer shall provide all protective equipment and PPE that employees need to perform work.

Fifth on the List
Let’s get back to why PPE is fifth on the list of job briefing topics. In reality, if employees recognize and identify all hazards, utilize all work practices they have been trained to use and identify all special precautions, PPE will most likely never come into play. Don’t get me wrong – I’m not saying it’s not needed, but I honestly believe that employees rely on and use PPE more than it is intended to be used. Primary protection is acquired by identifying hazards and using approved tools and work practices. Dielectric gloves are certainly the exception to the rule.

PPE is furnished by the employer at no charge to the employee as a result of a court case and a final rule implemented by the U.S. Department of Labor. The final rule became effective on February 13, 2008, and was implemented by May 15, 2008. After May 15, 2008, employers must supply all PPE to employees at no charge. This should be easy to understand. Following are a few exceptions to the rule.

“1910.132(h)(2)
The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job-site.”

Eye Protection
The employer shall furnish eye protection, but is not required to furnish prescriptive corrective safety lenses – just safety glasses and eye protection.

“1910.133(b)(1)
Protective eye and face protection devices must comply with any of the following consensus standards:

“1910.133(b)(1)(i)
ANSI Z87.1-2003, ‘American National Standard Practice for Occupational and Educational Eye and Face Protection,’ which is incorporated by reference in § 1910.6 …”

The employee is responsible for the prescription. To meet the consensus standard, the employer shall furnish goggles that can be worn over the glasses or an equivalent that protects the employee’s eyes.

Steel-toe boots or shoes may be required in a written PPE hazard assessment, but only for the task that requires protection. Many companies subsidize the employees’ boot and prescription eyewear program. The amount, negotiated in labor agreements, will vary from company to company and is not required by the U.S. Department of Labor. You can read more about the subject in 29 CFR 1910.333(a).

Anticipated Change
One of the anticipated changes in the upcoming revision of 29 CFR 1910.269 is the possible clarification of clothing requirements for lineworkers working on or near energized electrical equipment and conductors. At press time, the standard states what types of clothing an employer shall not let an employee wear if the employee may be exposed to arcs. As you can see below, it says nothing about what is required.

“1910.269(l)(6)(iii)
The employer shall ensure that each employee who is exposed to the hazards of flames or electric arcs does not wear clothing that, when exposed to flames or electric arcs, could increase the extent of injury that would be sustained by the employee.

“Note: Clothing made from the following types of fabrics, either alone or in blends, is prohibited by this paragraph, unless the employer can demonstrate that the fabric has been treated to withstand the conditions that may be encountered or that the clothing is worn in such a manner as to eliminate the hazard involved: acetate, nylon, polyester, rayon.”

NESC Rule 410.A.3
A National Electrical Safety Code 2007 consensus standard, Rule 410.A.3, states the following: “Effective January 1, 2009, the employer shall ensure that an assessment is performed to determine potential exposure to an electric arc for employees who work on or near energized parts or equipment. If the assessment determines a potential employee exposure greater than 2 cal/cm² exists, the employer shall require the employee to wear clothing or a clothing system that has an effective rating at least equal to the anticipated level of arc energy.”

So does the employer have to currently supply arc-rated clothing for employees? No, as of now, arc-rated clothing is not considered PPE. The employer shall not let an employee wear types of clothing that would further contribute to an injury as currently stated in the performance standard. If the employer doesn’t supply or require arc-rated clothing for the protection of the employee and an injury occurs, at the very least a 5(a)(1) General Duty Clause citation will likely be issued. Granted, most companies now supply arc-rated clothing with the anticipation of the pending rule change sometime in the near future. Some companies charge employees for their uniforms or arc-rated clothing. This change will be a significant expense if the performance standard is revised.

Employee-Owned PPE
Can an employee furnish their own PPE? Yes, employee-owned PPE may be used as long as the employer inspects and approves it and the PPE meets or exceeds the latest ANSI consensus standards and specifications.

“1910.132(h)(6)
Where an employee provides adequate protective equipment he or she owns pursuant to paragraph (b) of this section, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment. The employer shall not require an employee to provide or pay for his or her own PPE, unless the PPE is excepted by paragraphs (h)(2) through (h)(5) of this section.”

A Common Mistake
A final thought: One common mistake made by many companies is not having a written PPE hazard assessment as required in 29 CFR 1910.132(d)(2), which reads: “The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.”

OSHA also requires that employers identify all hazards or potential hazards; provide all PPE that is required to protect from the hazards; and train employees on when PPE is needed, how to put it on and take it off, how to care for it and how to replace it when necessary.

About the Author: Danny L. Raines, CUSP, safety consultant, distribution and transmission, retired from Georgia Power after 40 years of service and opened Raines Utility Safety Solutions, LLC, providing compliance training, risk assessments and safety observation programs. He is also an affiliate instructor at Georgia Tech Research Center OSHA Outreach in Atlanta. For more information, visit www.electricutilitysafety.com.

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