PPE Hazard Assessment

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PPE Hazard Assessment Employee Involvement
Alyssa Duncan CSP, OHSTJayhawk Gas
Plantalyssa.duncan_at_bp.com

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Agenda

• Introduction
• Review of PPE Standard
• Review of Training Requirements
• How To ABCs of PPE Hazard Assessment
• PPE Hazard Assessment Examples
• Discussion

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PPE Worker Protection

• Personal Protective Equipment
• PPE comes in at third place in OSHAs
  Hierarchy of means to protect workers.
• Eliminate Control and Protect
• PPE is the Last Line of Defense

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The OSHA Standard 1910.132(a) Protective
Equipment

• 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.

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The OSHA Standard 1910.132(b), (c) Employer
Responsibility, Design

• 1910.132(b) Employee-owned equipment. Where
  employees provide their own protective equipment
• the employer shall be responsible to assure
  its adequacy, including proper maintenance, and
  sanitation of such equipment.
• 1910.132(c) Design. All personal protective
  equipment shall be of safe design and
  construction for the work to be performed.

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OSHA Standard 1910.132(d) Hazard assessment and
equipment selection.
1910.132(d)(1) The employer shall assess the
workplace to determine if hazards are present, or
are likely to be present, which necessitate the
use of personal protective equipment (PPE).
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OSHA Standard 1910.132(d) Hazard assessment and
equipment selection.

• If such hazards are present, or likely to be
  present, the employer shall
• 1910.132(d)(1)(i) Select, and have each affected
  employee use, the types of PPE that will protect
  the affected employee from the hazards identified
  in the hazard assessment

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OSHA Standard 1910.132(d) Hazard assessment and
equipment selection.

• 1910.132(d)(1)(ii) Communicate selection
  decisions to each affected employee and,
• 1910.132(d)(1)(iii) Select PPE that properly
  fits each affected employee.
• Note Non-mandatory Appendix B contains an
  example of procedures that would comply with the
  requirement for a hazard assessment.

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1910.132(d) Hazard assessment and equipment
selection

• 1910.132(d)(2) 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.

What if OSHA Asks? Demonstrate Compliance
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OSHA Standard 1910.132(e) Hazard assessment and
equipment selection.

• 1910.132(e) Defective and damaged equipment.
  Defective or damaged personal protective
  equipment shall not be used.

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OSHA Standard 1910.132(f)(1)Training

• 1910.132(f)(1) The employer shall provide
  training to each employee who is required by this
  section to use PPE. Each such employee shall be
  trained to know at least the following
• 1910.132(f)(1)(i) When PPE is necessary
  1910.132(f)(1)(ii) What PPE is necessary
  1910.132(f)(1)(iii) How to properly don, doff,
  adjust, and wear PPE 1910.132(f)(1)(iv) The
  limitations of the PPE and, 1910.132(f)(1)(v)
  The proper care, maintenance, useful life and
  disposal of the PPE.

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1910.132(f)(2)Training

• 1910.132(f)(2) Each affected employee shall
  demonstrate an understanding of the training
  specified in paragraph (f)(1) of this section,
  and the ability to use PPE properly, before being
  allowed to perform work requiring the use of PPE.

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1910.132(f)(3) Training

• 1910.132(f)(3) When the employer has reason to
  believe that any affected employee who has
  already been trained does not have the
  understanding and skill required by paragraph
  (f)(2) of this section, the employer shall
  retrain each such employee. Circumstances where
  retraining is required include, but are not
  limited to, situations where

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1910.132(f)(3) Training
1910.132(f)(3)(i) Changes in the workplace render
previous training obsolete or 1910.132(f)(3)(ii
) Changes in the types of PPE to be used render
previous training obsolete or 1910.132(f)(3)(ii
i) Inadequacies in an affected employee's
knowledge or use of assigned PPE indicate that
the employee has not retained the requisite
understanding or skill.
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1910.132(3)(f)(4) Training

• 1910.132(f)(4) 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.

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PPE Hazard Assessment Examples
http//nasupplierhsse.bpglobal.com
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PPE Selection

• Based on the task performed
• Based on hazards present
• Physical state gas, liquid, solid
• Concentration

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Where do I get this information?

• Material Safety Data Sheet?
• List of constituents and composition
• Wear gloves. Wear respiratory protection.
• Websites Ansell Edmont (glove example) 3M
  respiratory protection
• Take field measurements of concentrations

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Example
SOURCE OF EXPOSURE / ACTIVITY Condensate, NGL, Produced Water, Rich Glycol Tank cleaning, piping replacement, gauging Condensate, NGL, Produced Water, Rich Glycol Tank cleaning, piping replacement, gauging Condensate, NGL, Produced Water, Rich Glycol Tank cleaning, piping replacement, gauging Condensate, NGL, Produced Water, Rich Glycol Tank cleaning, piping replacement, gauging
HAZARD"Skin" denotes hazards that can be absorbed through the skin. Benzene Skin(0.5 ppm BP 8-hr TWA, 2.5 ppm BP STEL 1 ppm OSHA 8-hr TWA, 5 ppm STEL1910.1028) Benzene Skin(0.5 ppm BP 8-hr TWA, 2.5 ppm BP STEL 1 ppm OSHA 8-hr TWA, 5 ppm STEL1910.1028) Benzene Skin(0.5 ppm BP 8-hr TWA, 2.5 ppm BP STEL 1 ppm OSHA 8-hr TWA, 5 ppm STEL1910.1028) Benzene Skin(0.5 ppm BP 8-hr TWA, 2.5 ppm BP STEL 1 ppm OSHA 8-hr TWA, 5 ppm STEL1910.1028)
CONCENTRATION / ROUTE OF ENTRY Less than 0.5ppm 0.5 - 50.0ppm Greater than 50.0ppm Clothing / gloves
CONTROL MEASURES1910.134(d)(3)(i)(A) Assigned Protection Factor Full facepiece air purifying - 50 No respiratory protection required. Full-facepiece respirator organic vapor cartridge Supplied air respirator/SCBA Nitrile, viton, neoprene gloves
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Task operation of equipment pump trucks

• Diesel engines

Midday diesel particulates not highly visible
despite multiple operating engines
Early a.m. diesel emission cloud visible above
work area due to Tyndall effect from stationary
lighting sources
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Task Chemical truck operator

• Chemicals contained in plastic carboys, direct
  connections made to blender truck via mixing
  manifold. Workers well protected, dermal,
  respiratory protection used appropriately, work
  operations occur in open area.

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How To PPE Hazard Assessment Basics

• Make a list A Simple Spreadsheet will work
• List the different types of tasks
• Use JSAs, Incidents, Near Misses, Industry Data
• List the potential hazards within the tasks
• List the PPE needed to help protect
• Research the specific PPE needed
• Involve the employees performing the work
• Add a certification and date
• Most effective are Craft Specific
• Make it a living document and Post it
• Use it to develop better JSAs
• Continually Improve the list
• Use it for training

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Employee Involvement Recap

• Part 1
• Review JSAs
• Give them a checklist to fill out for a week
• Bring back stuff from the VPPPA Conference ?
• Dont just observe, talk, talk, talk!
• Part 2
• Consider reviewing the hazard assessment annual
  training inspection at the same time
• Review the final hazard assessment before
  certification
• Part 3
• Post PPE Hazard Assessment
• Highlighter Idea

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Discussion What do you do? What do you think
you might try?