TT Talk - Personal protective equipment: A last line of defence

Board Press Release (33)

As supply chain operations seek to control risk, managers often turn to personal protective equipment (PPE) as a control measure to reduce the risk of personal injury to operational workers. Additionally, many national regulators and health and safety authorities require employers to control exposure to workplace hazards by providing workers with PPE, often free of charge. It is important that employers understand when it is appropriate to require PPE in the workplace and how to choose the correct PPE for the operation. This article is a brief exploration of the use of PPE as a risk control measure.

Risk assessment 

The first step to implementing PPE as a risk control measure is to complete risk assessments analysing the risks involved in the operation. It can be helpful to complete task-based risk assessments focused on each operational task. Where the risk assessment methodology indicates that the level of risk is unacceptable, then it is necessary to implement control measures to lower the risk to an acceptable level. It should be noted that physical controls that prevent workers from coming into contact with a hazard are preferable to controlling risk by adopting the use of PPE. For example, preventing workers from coming into contact with heavy machinery is a more effective control measure than requiring workers to wear boots with protected toes. PPE is a final line of defence when other control measures have failed or where implementing physical control measures is not practicable. Where best industry practice dictates that a physical control measure is practicable then PPE alone is not a sufficient control measure.  

Risk assessments should identify what hazards exist and anticipate how injuries might occur or how health might be impacted. Hazards could include exposure to extreme temperatures, chemicals or electricity, in addition to moving or sharp objects. Additionally, dust, radiation and noise are all hazards that might require PPE to control risk of injury or ill health. 

Selection of PPE 

Once a risk assessment determines that a PPE control measure is necessary, it is important to choose PPE that is appropriate for the hazard. Many jurisdictions require that employers supply PPE that meets a certain standard. It is important to choose PPE that fits well and, where multiple items of PPE are worn together, that they do not impede one another. For example, where safety goggles and hard-hats are worn at the same time, it is important that each fits well. Additionally, PPE that is excessively uncomfortable or is not the correct size will discourage workers from wearing it.  

Selection of PPE should take account of the hazards faced by workers as they carry out tasks. Not all PPE suitably protects against all hazards. For example, safety gloves are used to protect against many different hazards, such as cuts from sharp or jagged edges, temperature extremes and exposure to chemicals. Most safety gloves are designed to protect workers from specific hazards and the choice of safety gloves is very important.  Safety gloves are often designed to protect workers from certain specific chemicals and may be ineffective against contact with other chemicals. Sometimes a safety feature that protects from one hazard may increase the risk of injury from a different hazard. For example, workers who are exposed to electrical hazards should wear non-conductive footwear. However, workers exposed to explosive atmospheres are advised to wear conductive footwear to prevent a build-up of static electricity. Researching what PPE is appropriate for a particular operational environment is an important step towards ensuring the safety of workers. 

Training and maintenance 

Following selection of appropriate PPE, it is important to ensure that workers are trained in its use. Many operations are highly complex, and it should not be assumed that workers understand why the use of PPE is important or how to wear items of PPE correctly to guard against operational hazards. It is equally important to ensure that workers understand the limitations of PPE. PPE is not a redundant operational control measure and workers should not bypass or circumvent other control measures while wearing it. Many jurisdictions require employers to evidence that workers have been issued with required PPE and that they have been trained in its use. Even where this is not a legal requirement, a failure to keep adequate records of PPE issuance and training may lead to complications when defending against claims in court arising from workplace injuries. 

Training should also cover proper care and maintenance of PPE. It is reasonable to expect workers to maintain PPE to a standard by, for example, ensuring that the equipment is clean and functional. However, it is important to communicate the standard to workers and this should form part of the training. It is also reasonable to expect workers to request replacement PPE when equipment is no longer in fit condition. However, it is advisable that employers maintain some control over replacement by defining a reasonable PPE useful life, keeping records of PPE issuance and performing periodic PPE inspections. Additionally, some types of PPE should be replaced after an incident even when there is no apparent damage to the equipment. For example, a hardhat that has sustained a blow should not remain in use even if there is no visible damage. 

Summary 

In conclusion, while PPE serves as a crucial last line of defence in mitigating workplace hazards, it should not be the sole reliance for ensuring worker safety. Effective risk management begins with thorough risk assessments and the implementation of physical control measures wherever feasible. When PPE is necessary, selecting the appropriate equipment and ensuring proper training and maintenance are essential to its effectiveness. Employers must recognize the limitations of PPE and strive to create a comprehensive safety culture that prioritizes proactive hazard control measures alongside the use of PPE. By doing so, they can better protect their workforce and comply with regulatory requirements, ultimately fostering a safer and more productive work environment

 

Josh Finch

TT Club

Date05/11/2024