The Occupational Safety and Health Administration’s (OSHA) Personal Protective Equipment (PPE) Standard on general requirements [29 CFR 1910.132] specifies that employers must determine if hazards are present in the workplace that require the use of PPE. Both physical and health hazards need to be considered when making this determination.
OSHA requires that the evaluation be made in the form of a documented PPE hazard assessment. It’s not enough to do an informal review to identify what protective equipment might be needed.
How are Hazard Assessments Conducted?
Conducting a hazard assessment involves a walkthrough of all workplace areas to determine potential physical and health hazards. All job tasks must be evaluated. The review should identify the types of hazards that are present including, but not limited to, those listed below.
- Electrical
- Radiological
- Impact, motion, compression (i.e., roll-over)
- Thermal (hot/cold)
- Excessive noise
- Hazardous chemicals (vapors, mists, dusts) and biologicals
- Optical radiation (e.g., lasers, UV lights, welding)
- Falling, rolling, or pinching objects
- Sharp items that could cut or puncture
The written assessment must be certified and indicate the workplace evaluated, the date of the assessment, and the name of the person(s) conducting and certifying it.
If engineering and administrative controls cannot eliminate or sufficiently mitigate the hazards present to levels where protective equipment is not required, the type of PPE needed must be identified. Necessary equipment might include safety glasses/goggles, face shields, gloves, respirators, hearing protection, and/or protective footwear.
Required PPE must be made available at no cost to employees. In addition, employees need to be trained on its fit, use, care, and maintenance, as well as any potential limitations of the equipment. Employers are also required to periodically review and evaluate the effectiveness of their PPE program and update it when needed.
When are Hazard Assessments Required?
PPE hazard assessments are required for facilities that fall under the OSHA Hazard Communication Standard [29 CFR 1910.1200]. However, for organizations that are regulated by Occupational Exposure to Hazardous Chemicals in Laboratories (Lab Standard) [29 CFR 1910.1450], these requirements are covered by the sections of their Chemical Hygiene Plan that address PPE selection.
In addition, for those labs that work with potentially infectious human source materials, the training and hazard assessment requirements found in the Bloodborne Pathogens Standard [29 CFR 1910.1030] also comply with 29 CFR 1910.132.
Clarification on the applicability of both the Lab and Bloodborne Pathogens standards is outlined by OSHA in a Letter of Interpretation.
Typically, our clients are regulated by either the Hazard Communication Standard or the Lab Standard. It’s also not uncommon for them to be covered by both standards as well as the Bloodborne Pathogens rule. However, it should be noted that hazard assessments are required in workplaces not covered by these regulations if they are required to comply with the OSHA PPE Standard.
Although not specifically required for most labs, for highly hazardous tasks, a formal PPE hazard assessment is often appropriate and considered best practice.
Additional information on hazard assessments, and how and when to perform them, can be found in OSHA’s Personal Protective Equipment guidance document. Safety Partners is also available to conduct and document PPE hazard assessments at your facility and conduct the required training too—contact us!
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.
