3.6 Personal Protective Equipment (PPE) Selection & Maintenance (OSHA 1910 Subpart I)

Personal Protective Equipment: Selection and Maintenance

As established in the Hierarchy of Controls, Personal Protective Equipment (PPE) is the last line of defense against workplace hazards. When engineering and administrative controls are insufficient or unfeasible, PPE becomes the critical barrier between the worker and injury or illness. OSHA regulates PPE extensively under General Industry Subpart I (29 CFR 1910.132 - 138).

The Foundation: The Hazard Assessment

The cornerstone of any PPE program is the Hazard Assessment. OSHA standard 1910.132 requires employers to formally assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE.

If such hazards exist, the employer must:

1. Select the types of PPE that will protect the affected employee from the identified hazards.
2. Communicate selection decisions to each affected employee.
3. Select PPE that properly fits each affected employee.

Crucially, this assessment cannot merely be a verbal agreement; OSHA requires a written certification of the hazard assessment that identifies the workplace evaluated, the person certifying the evaluation, and the date(s) of the assessment.

Employer Payment for PPE

As a general rule under OSHA standards, the employer must pay for PPE used to comply with OSHA standards. There are limited exceptions where employers are not required to pay, such as:

• Non-specialty safety-toe protective footwear and non-specialty prescription safety eyewear, provided the employer permits these items to be worn off the job-site.
• Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots.
• Ordinary clothing used solely for protection from weather.

Specific Types of PPE and Standards

Safety technicians must ensure that selected PPE meets specific consensus standards incorporated by reference in OSHA regulations (typically ANSI or ASTM standards).

Eye and Face Protection (1910.133)

Eye protection is required when workers are exposed to flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation (e.g., welding).

• Standard: Protective eye and face devices must comply with ANSI Z87.1 (American National Standard Practice for Occupational and Educational Eye and Face Protection).
• Markings: Compliant eyewear is physically stamped with "Z87" on the frame or lens. A "+" mark (e.g., Z87+) indicates high-impact resistance.
• Face Shields: Face shields are secondary protectors and must only be worn in addition to primary eye protection (safety glasses or goggles), never alone.

Head Protection (1910.135)

Head protection (hard hats) must be worn when there is a potential for injury to the head from falling objects or exposure to exposed electrical conductors.

• Standard: Hard hats must comply with ANSI Z89.1.
• Types:
  • Type I: Reduces the force of impact resulting from a blow only to the top of the head.
  • Type II: Reduces the force of impact from a blow to the top or sides of the head.
• Electrical Classes:
  • Class G (General): Proof-tested at 2,200 volts.
  • Class E (Electrical): Proof-tested at 20,000 volts (maximum electrical protection).
  • Class C (Conductive): Provides no electrical protection.

Foot Protection (1910.136)

Safety shoes or boots are required when working in areas where there is a danger of foot injuries due to falling or rolling objects, objects piercing the sole, or electrical hazards.

• Standard: Protective footwear must comply with ASTM F-2412 and F-2413 (formerly ANSI Z41).
• Shoes may feature steel or composite toe caps for impact resistance, and metatarsal guards for the upper foot.

Hand Protection (1910.138)

Employers must base the selection of hand protection on an evaluation of the performance characteristics of the hand protection relative to the task(s) to be performed, conditions present, duration of use, and the hazards and potential hazards identified. There is no single ANSI standard for gloves; selection requires analyzing chemical compatibility charts, cut-resistance ratings, and thermal protection specs.

Respiratory Protection (1910.134)

Respiratory protection is perhaps the most complex and stringently regulated area of PPE. If respirators are required to protect worker health, the employer must establish a formal, written Respiratory Protection Program administered by a suitably trained program administrator.

Key Components of a Respiratory Program

1. Medical Evaluation: Breathing through a respirator puts physical stress on the cardiovascular and respiratory systems. Before a worker is allowed to wear a respirator, they must be medically cleared by a Physician or Other Licensed Health Care Professional (PLHCP).
2. Fit Testing: A respirator cannot protect a worker if it leaks. All tight-fitting respirators (both negative and positive pressure) must be fit-tested prior to initial use, whenever a different respirator is used, and at least annually thereafter.
   • Qualitative Fit Test (QLFT): A pass/fail test relying on the user's senses (taste, smell, or irritation) to detect a challenge agent (e.g., bitrex, saccharin, banana oil, or irritant smoke) leaking into the facepiece.
   • Quantitative Fit Test (QNFT): Uses a machine to physically measure the actual amount of leakage into the facepiece, providing a numerical "fit factor." This is required for high-level protection.
3. Facial Hair Policy: Tight-fitting respirators rely on a tight seal against the skin. OSHA strictly prohibits any facial hair (beards, stubble, long sideburns) that comes between the sealing surface of the facepiece and the face.
4. Cleaning and Maintenance: Respirators must be cleaned, disinfected, stored, inspected, and repaired in accordance with OSHA guidelines to ensure they remain sanitary and functional.