One new supervisor, keen to curry favour with both staff and management, ordered PPE new kit bags for all technicians. The kits turned up with identical goggles, gloves, ear defenders, bump caps and high vis jackets. The bump caps had peaks which reduced the technician’s view upwards, such that they were more likely to hit their heads on low beams in the plant rooms. They were worn only once. The goggles were never used, as eye protection was not relevant to 80% of the technicians, and these were not suitable for welding. The ear defenders had too high an SNR (a measurement of hearing protection). Too much protection, and workers can’t hear important sounds – an alarm, a shouted warning, a reversing vehicle. Hearing protection that overprotects is less likely to be worn.
The key to using the right PPE on the job is a suitable risk assessment, following the HSE 5 steps:
STEP 1. IDENTIFY THE HAZARD
If a risk assessment states the hazard is “hazardous chemicals” the controls are likely to be similarly vague. What chemicals are being used, how often and for what task? Washing up liquid now carries an “irritant” symbol and must therefore be regarded as a “hazardous chemical” but the controls needed for using it twice a day will be different from a cleaner using bleach or drain cleaner throughout an eight-hour shift. If noise is the hazard, include the measured noise levels and the source of the noise.
STEP 2. DECIDE WHO MIGHT BE HARMED & HOW
Some employees might be more sensitive to substances than others, and need additional protection. For some person even washing up liquid may cause skin irritation and soreness, whilst others are allergic to sticking plasters. Even the PPE provided can cause an issue, with some people unable to wear latex gloves. New or expectant mothers might be exposed to additional risks, and the HSE that all risk assessments should consider this possibility. To consider risks from chemicals to a new or expectant mother or her child look at the safety datasheets (also known as MSDS or SDS) and watch out for hazard statements H360, H361 and H362 – see the HSA website for details.
STEP 3. EVALUATE THE RISKS & DECIDE ON PRECAUTIONS
Before suggesting PPE, go through the hierarchy – can the noisy equipment, the chemical or other hazard be eliminated? Can it be reduced, or substituted for something less dangerous? Can fewer people be exposed? Is there any way of protecting all people in an area rather than relying on PPE? When PPE is necessary to control the residual risk, don’t just write down “PPE as appropriate” or even “protective gloves” – be clear what type of gloves are to be used, what sort of eye shield, and what level of hearing protection.
STEP 4. RECORD YOUR FINDINGS & IMPLEMENT THEM
As soon as a control has been specified in the risk assessment, make sure it happens. In the case of PPE controls, you need to be able to prove that the protection specified is available to the people carrying out the task, that they have been trained in its use, inspection and storage, and that where PPE needs to be replaced periodically, it is in date. Having a system like Engage EHS in place to track training and PPE provision will make this easier. The Engage EHS risk assessment software allows items of PPE to be selected from those available and included on the Method statement – this way there will always be consistency with what you call an item across all your documents, avoiding confusion between goggles and spectacles, hard hats and bump caps, or ear muffs and ear plugs. Where more than one type of hearing protection is available, specify the SNR required for each task or location.
STEP 5. REVIEW YOUR RISK ASSESSMENT & UPDATE IF NECESSARY
Risk assessment reviews should consider whether there is a better means of controlling each hazard. Although this was considered in step 3, things change – a year later, there might be a less hazardous substance available, or automation might be more cost-effective (think about the equivalent of using a dishwasher instead of a sink full of soapy water)? Make sure too that employees are encouraged to give feedback about any problems with using PPE – do goggles mist up? Do gloves make it difficult to do a delicate task? If problems are ignored, staff won’t be protected.
For more information as to how Engage EHS can help you with the management of your organisations PPE, Risk Assessments or Method Statements why not request a Callback from one of our product experts. They will run through your existing health and safety management processes and tailor a solution to your specific needs.