21.2 Personal Protective Equipment, Fall Protection & Bloodborne Pathogens
Key Takeaways
- Personal protective equipment is the last line of defense in the hierarchy of controls, below elimination, substitution, engineering controls, and administrative controls.
- Fall protection is generally required at six feet in construction and four feet in general industry, and open tanks and basins are fall hazards regardless of height.
- A personal fall arrest system requires an anchorage capable of supporting 5,000 pounds per worker or a system with a safety factor of two under a qualified person's supervision.
- Prompt rescue after a fall is mandatory because suspension trauma can become life threatening within minutes of hanging in a harness.
- Wastewater exposure carries real pathogen risk, and hepatitis B vaccination must be offered at no cost to employees with occupational exposure to blood or other potentially infectious material.
21.2 Personal Protective Equipment, Fall Protection & Bloodborne Pathogens
The Hierarchy of Controls
PPE is listed last for a reason.
| Rank | Control | Example |
|---|---|---|
| 1 | Elimination | Remove the hazard entirely — eliminate the confined space entry |
| 2 | Substitution | Replace gas chlorine with sodium hypochlorite |
| 3 | Engineering controls | Ventilation, machine guarding, guardrails, remote actuators |
| 4 | Administrative controls | Procedures, training, rotation, signage |
| 5 | PPE | Respirator, gloves, harness |
[!IMPORTANT] PPE protects only the person wearing it, only if it is worn correctly, and only if it does not fail. The higher controls protect everyone regardless of behavior. An exam question asking for the "most effective" control is asking about the hierarchy, and the answer is never PPE when a higher control is available.
PPE by Category
| Category | Equipment | Selection notes |
|---|---|---|
| Head | Hard hat — Type I (top impact) or Type II (top and lateral); Class E (electrical, 20 kV), G (general, 2.2 kV), C (conductive, no electrical protection) | Class C offers no electrical protection; never use near energized equipment |
| Eye and face | Safety glasses with side shields, goggles, face shield | A face shield alone is not eye protection — wear primary protection under it. Chemical handling requires splash goggles plus a face shield |
| Hearing | Earplugs, earmuffs | Required above an 8-hour time-weighted average of 85 dBA; blower rooms and jetting operations commonly exceed it |
| Respiratory | Filtering facepiece, half or full face APR, PAPR, SCBA | SCBA required for IDLH atmospheres; air-purifying respirators must never be used in oxygen-deficient or unknown atmospheres |
| Hand | Nitrile, neoprene, butyl, PVC, cut-resistant, insulated | Match the glove material to the chemical using the SDS and a compatibility chart; latex is a poor chemical glove and an allergen |
| Foot | Safety-toe, metatarsal, electrical hazard, slip-resistant, chemical-resistant boots | Puncture-resistant soles for debris |
| Body | High-visibility apparel, chemical suits, arc-rated clothing | High-visibility Class 2 or 3 for roadway work |
| Fall | Full-body harness, lanyard, self-retracting lifeline | Body belts are not acceptable for fall arrest |
Respirator use requires a written program: hazard assessment, medical evaluation, fit testing, training, cartridge change schedules, cleaning, and storage. Facial hair that crosses the sealing surface prevents an adequate seal and disqualifies a worker from a tight-fitting respirator.
Fall Protection
Trigger heights: generally 6 feet in construction and 4 feet in general industry. Beyond height triggers, any open tank, basin, clarifier, wet well, or opening is a fall hazard — and falling into a clarifier or wet well means drowning and entrapment, not just impact injury.
Systems
| System | Description |
|---|---|
| Guardrails | Top rail at about 42 inches, midrail, and toeboard — a passive engineering control, and the preferred approach |
| Safety nets | Below the work surface |
| Personal fall arrest system (PFAS) | Anchorage, body harness, connector — the ABC of fall arrest |
| Positioning system | Holds a worker in place; limits free fall to 2 feet |
| Travel restraint | Prevents reaching the fall hazard at all — better than arrest |
| Covers | Over holes and openings, secured and marked |
Fall Arrest Requirements
- Anchorage: capable of supporting 5,000 lb per worker, or designed with a safety factor of at least two under the supervision of a qualified person.
- Full body harness only — body belts are prohibited for fall arrest because they concentrate arresting forces on the abdomen.
- Maximum arresting force limited to 1,800 lb with a harness.
- Free fall limited to 6 feet, and never to a distance that allows contact with a lower level.
- Clearance calculation must account for free fall distance, deceleration distance, harness stretch, and the worker's height below the D-ring.
- Inspect before every use; remove from service permanently any component that has arrested a fall.
[!WARNING] A rescue plan is mandatory, and it must be prompt. A worker hanging in a harness can develop suspension trauma — orthostatic intolerance from blood pooling in the legs restricted by the harness straps — and it can become life threatening within minutes even though the fall itself caused no injury. "Call 911 and wait" is not a rescue plan. Suspension trauma relief straps that let the worker stand in the harness are inexpensive and effective.
Ladder safety: maintain three points of contact, extend an extension ladder 3 feet above the landing, set at roughly a 4 to 1 angle, secure the top, and never stand on the top two rungs of a stepladder. Fixed ladders on tanks and towers require cages, wells, or ladder safety systems depending on height and installation date.
Biological Hazards
Water and wastewater work carries genuine biological exposure. Raw wastewater contains bacteria (E. coli, Salmonella, Shigella, Leptospira), viruses (hepatitis A, norovirus, enteroviruses), protozoa (Giardia, Cryptosporidium, Entamoeba), and parasites.
The Core Protection Is Hygiene
- Wash hands before eating, drinking, smoking, or using the restroom — the single most effective control.
- No eating, drinking, or smoking in work areas.
- Keep work clothing separate from street clothing; do not launder contaminated clothing at home.
- Cover cuts and abrasions before work; treat any break in the skin as an exposure route.
- Vaccinations: tetanus kept current; hepatitis A and hepatitis B recommended for wastewater workers.
Bloodborne Pathogens
The OSHA bloodborne pathogens standard applies where workers have reasonably anticipated occupational exposure to blood or other potentially infectious material. In collection systems that exposure is real — discarded hypodermic needles are recovered routinely from wet wells, screens, and manholes.
| Requirement | Detail |
|---|---|
| Exposure control plan | Written, reviewed annually |
| Universal precautions | Treat all blood and body fluids as infectious |
| Engineering and work practice controls | Sharps containers, mechanical debris removal, no hand-sorting of screenings |
| PPE | Gloves, eye protection, face protection provided at no cost |
| Hepatitis B vaccination | Offered at no cost to employees with occupational exposure, within 10 working days of assignment |
| Post-exposure evaluation | Confidential medical evaluation and follow-up at no cost |
| Training | At assignment and annually |
| Labeling | Biohazard labels on regulated waste containers |
Needlestick response: wash the wound immediately with soap and water, flush mucous membranes with water, report immediately, and seek confidential medical evaluation. Do not delay reporting — post-exposure prophylaxis for some pathogens is time sensitive.
Other biological hazards in this industry include Legionella in aerosols from cooling towers and warm water systems, hantavirus from rodent droppings in vaults and dry wells, valley fever (coccidioidomycosis) from soil-disturbing work in Arizona's endemic region, and rabies and animal bites during field work.
A utility is evaluating how to protect operators from falls into an open clarifier. Which option best reflects the hierarchy of controls?
A worker falls and is successfully arrested by a personal fall arrest system, hanging suspended and uninjured approximately 15 feet above grade. Why must rescue occur promptly rather than awaiting emergency services?
A collection system operator is stuck by a discarded hypodermic needle while clearing debris from a wet well. What is the correct immediate response?