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PPE Program Development

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One of the requirements of OSHA General PPE Requirements Standard  29CFR1910 Subpart I and Wisconsin COMM Chapter 32 is a written PPE program.  What does a program look like?  For all PPE programs, the following are minimal components that are required:

1.  Hazard assessment

The purpose is to identify sources of hazards to workers. Per OSHA Standard 29CFR1910.132(d)(1)(i), employers must assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE. If so, the employer must:

  • Select, and have each affected employee use the types of PPE that will protect him or her from the hazards identified in the hazard assessment

  • Communicate selection decisions to each affected employee

  • Select PPE that properly fits each affected employee.

Managers and supervisors should conduct a walk-through survey of all the work areas, considering possible employees exposure to:

  • blood and other potentially infectious material (OPIM).

  • impact injuries

  • penetration injuries

  • compression injuries

  • light radiation

  • heat

  • chemicals

  • harmful dust

Resources:

PPE Hazard Assessment  (Word, 124 KB)

Infection Control Practices by Disease (Word, 238 KB)

2.  Equipment selection and use

After completion of the Hazard Assessment, the general procedure for selection of protective equipment is to:

  • Become familiar with the potential hazards and the type of protective equipment that is available, and what it can do; i.e., splash protection, impact protection, etc.

  • Compare the hazards associated with the environment; i.e., impact velocities, masses, projectile shape, radiation intensities, potentially infectious materials with the capabilities of the available protective equipment.

  • Select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from the hazards.

  • Fit the user with the protective device and give instructions on care and use of the PPE. It is very important that end users be made aware of all warning labels for and limitations of their PPE.

  • Fit the device. Careful consideration must be given to comfort and fit. PPE that fits poorly will not afford the necessary protection. Continued wearing of the device is more likely if it fits the wearer comfortably. Protective devices are generally available in a variety of sizes. Care should be taken to ensure that the right size is selected.

Common PPE:

  • Eye and Face Protection (29 CFR1910.133)

    • Protection against impact, dust, splash, radiation

    • Includes safety glasses/, side shields, goggles, and face shields

  • Respiratory Protection (29CFR1910.134)

    • Masks and Respirators

      • Surgical masks help protect your nose and mouth from splattered of body fluids, respirators filter the air before you inhale it.

    • If an agency is using respirators, a written Respiratory Protection Plan must be in place also.  The components of the Respiratory Protection Plan include:

      • Voluntary use

      • Protection factors

      • Cartridge change

      • Medical evaluation

      • Fit testing

      • Facepiece seal

      • Cleaning & disinfecting

      • Storage

      • Inspection

      • Evaluation

      • Recordkeeping

  • Head Protection (29CFR1910.135)

    • Protection against falling objects

      • Hardhats

  • Foot Protection (29CFR1910.136)

    • Protection against falling or rolling objects, or objects piercing the sole, and where such employee's feet are exposed to electrical hazards

      • Chemical overboots, steel toed shoes

    • Shoe and head covers provide a barrier against possible exposure within a contaminated environment

      • TyvekŪ shoe covers

  • Hand (29CFR1910.138)

    • Skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes

      • Nitrile chemical gloves

    • Gloves help protect you when directly handling potentially infectious materials or contaminated surfaces.

      • Non latex or Nitrile gloves

  • Ear (29CFR1910.195)

    • Exposure limit of 90db with an action level of 85 db.

    • Log scale, sound level doubles w/ every 5 db (90dB is twice the level of 85dB)

    • Hearing Conservation Program required for exposure greater than 85 db.

      • Earplugs

  • Other protective clothing

    • Gowns help protect against the contamination of clothing with potentially infectious material.

    • TyvekŪ suits help protect against potentially infectious materials and other unknown environmental hazards

3.  Reassessment of hazards

It is necessary to reassess the workplace hazard situation periodically by identifying and evaluating new equipment and processes, reviewing accident records, and reevaluating the suitability of previously selected PPE.

4.  Training Standard 29CFR1910.132 (f)(1)

The employer shall provide training to each employee who is required to use PPE. Each employee shall be trained to know at least the following:

  • When PPE is necessary

  • What PPE is necessary

  • How to properly don, doff, adjust, and wear PPE

  • The limitations of the PPE

  • The proper care, maintenance, useful life and disposal of the PPE

  • When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill, the employer shall retrain the employee. Circumstances where retraining is required include, but are not limited to, situations where:

    • Changes in the workplace render previous training obsolete

    • Changes in the types of PPE to be used render previous training obsolete

    • Inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.

  • The employer shall verify that each affected employee has received and understood the required training through a written certification that contains the name of each employee trained, the date(s) of training, and that identifies the subject of the certification.

5. Payment for PPE Standard 29CFR1910.132 (h)(1)

Except as provided by paragraphs (h)(2) through (h)(6) of this Standard, the, PPE used shall be provided by the employer at no cost to employees.

  • 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.

Model Plans and Templates

Wisconsin Tuberculosis Program website includes a TB infection control plan and a model respiratory protection plan for local public health agencies:  Respiratory Protection Plan:  http://www.dhs.wisconsin.gov/tb/resources/provider_resources.htm

OSHA Bloodborne Pathogen Exposure Control Plan Template (PDF, 521 KB)

If you have any questions, e-mail Gwen Borlaug at gwen.borlaug@wisconsin.gov 

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Last Revised: February 20, 2014