OSHA's Top Ten - #9 PPE - Eye and Face

Coming in at #9 on OSHA’s annual top 10 list of their most frequently cited standards, with around 2,000 violations is 29 CFR 1926.102, the standard governing the use of eye and face protection in the construction industry. If you’re surprised to see this standard appearing in the annual list, don’t be because it’s made the list annually for at least the past 10 years.

Interestingly enough, out of all the citations issued for violations of this standard, only about 2% had anything to do with the eye protection itself, like not having ANSI rated eye protection, a lack of side shields and not properly protecting workers who wear prescription glasses. The overwhelming majority of citations (98%!) were issued because workers weren’t wearing the eye protection they were provided, which can be a cultural problem and a bit harder to resolve.

Why aren’t workers wearing their safety glasses? What’s motivating workers to choose risking injuring or even losing an eye over donning that pair of safety glasses sitting on top of their heads? There may be several!

Possible Reason #1: It’s the Safety Glasses

If safety glasses aren’t reasonably comfortable for all day wear, if they’re ill fitting, fog up easily, restrict vision or if the quality doesn’t garner a feeling of confidence that they’ll hold up when needed most, workers won’t wear them.

How do companies make sure they’re buying safety glasses people will actually wear? For starters, they can ensure that whoever selects the safety glasses be someone who also has to wear them all day. If you wouldn’t allow a non-coffee drinker to select coffee for the break room, don’t allow someone who doesn’t wear safety glasses to choose them for everyone who does. Instead, ask workers for their help in the selection process, making sure to be transparent about the reasons for the collaboration, about any pricing parameters and about timelines. Then find a couple of different styles, buy a dozen or so of each (or ask the vendor for a trial sample) and have workers try them out and provide feedback. While you may not get unanimous agreement on any one pair, you will find a pair or two that appeal to most workers. What you’ll also find is that workers will be much more likely to use something they helped choose which was always the end goal.

Possible Reason #2: It’s the Process

Another reason workers may not be wearing their safety glasses is because the rules about wearing them don’t make sense or they haven’t been explained. Sure, you can take the stance of “do it because we said so”—but adults generally react very poorly to that mentality. Eventually this mentality fosters an “us versus them” environment where any changes are automatically rejected, even if they will positively impact the workforce. Sometimes employers forget that their workforces are the ones who make change successful so alienating them is never a good idea.

When it comes to safety glasses or really any PPE, deciding to have a “wall to wall” PPE program that requires certain PPE at all times and in all areas of a facility really needs to be backed up with data to prove necessity. For a lot of companies, having wall to wall PPE requirements may seem easier to manage however, it’s in direct conflict with OSHA’s intent which was for employers to determine the necessity for PPE by assessing the workplace for hazards (real or potential). Many employers seem to think blanket PPE policies negate the assessment requirement—but it doesn’t. Even though the construction industry doesn’t have a similar standard to 29 CFR 1910.132 which requires general industry employers to formally asses and certify the need for PPE, 29 CFR 1926.28 does require appropriate PPE in hazardous areas, which means assessing both the area for hazards and the PPE for appropriateness first.

At the very least, having something to back up the reasons for that PPE requirement always goes a long way to building credibility with workers. If you haven’t done these assessments and need help, our free PPE assessment template can help get you started.

Possible Reason #3: It’s the Culture

Another reason workers may not be wearing their safety glasses is because the culture allows it. PPE policies are some of the easiest to comply with because all they require are workers to have PPE and to put it on where and when it’s required. As such, it’s really simple to determine whether a problem exists just by randomly walking into an area where PPE is required. When you walk into that area, what do you notice? If you notice workers not wearing any PPE or if you notice employees who immediately move to put PPE on when they spot you, there’s a problem, especially if supervisors are present. There are generally two distinct things that may be going on, and we can help with both.

The first one is a cultural issue perpetuated by poor leadership. When workers only don required PPE after seeing you, it means they know the policy and up until you arrived, they were choosing to ignore it. This happens because it’s allowed to happen. Workers aren’t worried about consequences because there haven’t been any thus far and in fact, their supervisor doesn’t wear PPE either so it must be ok.

In this case, the best way to improve this situation is to start with a clean slate and do the following:

• Retrain the entire workforce on the PPE policies, giving workers ample time to bring up questions and concerns and making sure to discuss consequences for non-compliance
• Set an unconditional compliance date & communicate it frequently
• On that date, have management ready to hold people accountable—and then actually do it.

It will usually take a week or two before workers get the message and start complying with the policy. You could also consider creating a temporary KPI to track PPE disciplinary actions & tie it to supervisor performance evaluations. When a supervisor or manager realizes their own performance evaluation will be affected by people on their team not complying with the safety rules, it can be quite motivating, especially if evaluations are tied to incentives.

When workers simply aren’t wearing their PPE, regardless of whether you’re there or not, it’s a sign that further investigation is needed. The first step is to ask them why they aren’t wearing it. Maybe they’re not wearing it because they didn’t know the rules or maybe it’s because there’s a problem with it. For example, if safety glasses fog up really quickly and it interferes with being able to see what they’re doing, that’s a legitimate problem that needs to be addressed. When you address things like this, it builds trust and that’s what’s needed to prevent things like this from further decaying the culture.

Prescription Safety Glasses & Side Shields

When safety glasses are required, figuring out the best way to protect the eyes of those workers who have to wear prescription glasses can be a struggle. Companies generally have two options:

1. They can implement a fully or partially funded prescription safety glasses program
2. They can provide safety glasses that go over regular prescription glasses

Of these two options, the first one is the best one because no one likes to wear what amounts to two pairs of glasses all day, no matter how custom the fit of the glasses going over their regular glasses may be. These are fine for temporary use, but when needed long term, prescription safety glasses are really the way to go. If you don’t currently have an RX safety glasses program because of the costs, reach out to your vision insurance provider or to a national vision vendor and ask if they can help.

If you’re wondering why we didn’t include the option to provide Z87.1 rated side shields that snap onto the sides of regular glasses—it’s because this is NOT an option. Putting Z87.1 rated side shields onto regular prescription glasses doesn’t make them impact resistant. Regular prescription glasses will shatter upon impact, regardless of whether there are rated safety shields on them or not—so don’t do that and if you are doing it, stop doing it.

What’s Next?

In our next installment of the 10 part series about OSHA’s annual top 10 list, we will discuss the ins and outs of 29 CFR 1926.451, the construction scaffolding standards. While you’re waiting, why not check out all the solutions EHS Insight has to offer and give us a call? We’d love to hear from you!