May 31, 2022
Question: We recently moved to a “wall to wall” PPE policy at our location. For us, this means safety glasses, earplugs, and steel-toed shoes must be worn at all times while inside our facility. This new policy has started to cause issues with the office staff who have to don PPE just to use the restrooms and break rooms which are located inside the actual facility. We really don’t want to have multiple policies or include a bunch of confusing exceptions. Is there anything we can do to make this work?
On the surface, this might appear to be a simple question about how to make everyone happy but if you look a bit more closely, you’ll notice just how deep of a question this really is. When companies have trouble with their PPE policies, many times it’s because the policy is based on arbitrary needs and lingering misconceptions and doesn’t reflect a legitimate safety need. Understanding whether your PPE policy fits into either of these categories is pretty simple. Just ask yourself how the policy came into being. Did you develop your current PPE policy based on the results of a workplace evaluation to identify potential and actual hazards or did you develop your current PPE policy based on arbitrary things like making everything uniform so it would be easier to manage?
If the PPE requirements in your policy are based on the results of hazard assessments showing potential and actual hazards that couldn’t be eliminated or adequately mitigated by other means, then the best way to manage these issues is to sit down with the workforce and show them the results of those assessments and explain why PPE is necessary. However, if the PPE requirements in your policy are based on something arbitrary like wanting to make things easier to manage or because you think “more PPE is better”, you may have a larger issue to deal with than worker complaints. In fact, you may have a PPE policy that’s not really in compliance with federal PPE standards.
If this caught you by surprise and you’re a bit skeptical, let us explain.
OSHA’s Recurring Themes
Throughout the federal workplace safety standards, OSHA has embedded a series of “recurring themes” that you might not even know were there if you’ve not spent a lot of time reading and interpreting the standards. One such theme is the notion that before a company can protect its workers, it has to know what to protect them from. This particular “theme” can be found in several spots within the General Industry and Construction standards and one of those places is in the general PPE requirements found in 29 CFR § 1910.132.
If you read this standard you’ll notice that OSHA has constructed it so that employers are forced to identify potential and actual workplace hazards before they put workers in any sort of PPE. What this is supposed to do is to help make sure employers acknowledge workplace hazards and also prevent employers from establishing arbitrary PPE requirements. As a result, this can be a significant blow to many “wall to wall” PPE policies which have been implemented for no other reason but because “it’s just easier to manage things that way.” In other words, the PPE your workers are expected to wear should be chosen based on the type of hazards present or that could be present in your workplace and not just because it’s easier to make everyone wear the same stuff.
Additional Themes
As much as we’d like to say that this is all an employer needs to consider when drafting a PPE policy, there is actually one more piece of information to share—and it’s kind of important. After the hazard assessments have been completed and a company better understands what hazards are and could be present in their workplaces, they still can’t just select PPE and call it a day.
Why? It’s because when a company identifies hazards (actual or potential) they are required to take steps to either eliminate that hazard or sufficiently reduce the risk through substitutions, engineering, and/or administrative controls. This is part of what OSHA calls the “Hierarchy of Controls” and when hazard assessments are performed, information about how a company worked through this process should ideally be included in the documented process.
If you notice, PPE is at the very bottom of the Hierarchy of Controls because PPE doesn’t eliminate or really reduce the risks associated with hazards. Instead, it simply reduces worker exposure to certain hazards which isn’t the same thing. So, it should be understood that PPE should only be used as a last resort form of protection and in conjunction with other risk reduction measures such as substitution, engineering, and/or administratively controlling the hazard.
Finding a Solution
So, how do you solve the conflict you’re experiencing? Our best advice is to work through it systematically. Start with developing a plan for assessing specific areas of the facility for hazards and subsequent PPE use that includes buy-in from both the leadership teams, the office staff, and the hourly workforce. (If you’re not sure where to begin, take a look at our new Hazard Assessment templates.) Once your assessment process is assembled, work with all three groups to get the assessments completed and then review the assessments as a group. Work through the hazard elimination and reduction process as a team and with whatever hazards are left that can’t be sufficiently reduced and will require the addition of PPE to protect workers, let the workforce have some say in the type and style of PPE. After all of this is done, rewrite your PPE policy to include the information from your assessments and PPE selection process, and then educate the entire workforce on the new policy and how it was developed. (On a side note, if you have money in the budget, you might also consider having posters printed showing what PPE is required in each area to make things more visible.)
While you probably won’t make everyone happy, you’ll at least have a more compliant PPE program that can be backed up and supported with data collected from a solid process.
