Everyone has become familiar with the term PPE (Personal Protective Equipment) over the past few years. Primarily, that comes from the COVID-19 outbreak in 2020. So many news stations were telling us to mask up if we value life, while others said it’s a foolish effort to protect against disease. Regardless of what each of us believed, most of us expected medical professionals to mask up if they were going to practice on us.
Being in the construction industry for years, for me, PPE is a term synonymous with preparing to get to work. Although it’s the last line of defense, it’s the first thing companies expect to protect us as a job begins. It makes sense that PPE is considered the last line of defense. When you think of PPE protecting you, in order for it to do so, something had to go wrong and you nearly got hurt.
I hate getting hurt – it’s so painful. Shouldn’t there be defenses in place that come into play far before PPE? Obviously, yes.
Hierarchy of hazard controls
When relating this topic, I share the “Hierarchy of Controls” for removing hazards. There are five controls, or at least that’s what I was taught. Apparently, somebody identified a sixth control somewhere along the line, so let’s go with six. It’s agreed the least-effective control is PPE. The others – Elimination, Substitution, Isolation (the added one), Engineered Controls and Administrative Controls – are more effective. That’s why PPE is the last line of defense.
By the way, while PPE may be required by standards and regulations, its use is a personal choice. The irony is, people often tend to go without protection until they themselves are impacted. It’s then that people become believers. Hopefully, it’s not too late.
I’ve never had a worker come up to me, as their safety professional, and ask, “Is what I’m wearing too much protection?” More often, they will ask, “Can I get away with what I’ve got on, or do you require more?” My response is, “Do you feel protected?” After all, at this point, I’m not the one who’s getting hurt.
Increasing PPE use
At my job, I’m tasked with improving and aligning safety culture. After spending time in the field at companies across the country, a less-than-consistent amount of PPE stood out to me.
While workers utilized some protection, it wasn’t sufficient based on my experience. At first, I wondered how we might align everyone across the system. While the rules are the same everywhere, people have different experiences and different levels of understanding. It’s not totally the fault of a worker if they aren’t properly protected. Supervision and leadership are required to prompt compliance.
Keep in mind, injury count is a numbers game. With fewer people, we likely have fewer injuries. That’s why OSHA bases injury experience on rates, not counts.
OSHA standard 1910.132
When I looked to OSHA, I keyed in on standard 1910.132 Personal Protective Equipment. I noticed four aspects clearly described. Beyond that, there isn’t more specific guidance. The four aspects are:
- Application
- Hazard Assessment
- Training
- Payment
I feel payment is pretty clear. The company is required to provide gear to protect from hazards the company creates. There are a few loopholes most people don’t like, but the better companies step up to the plate and provide gear. Why argue, right?
Application is a topic that doesn’t need much guidance. Any part of the human body that could get hurt because of the work needs to be protected. It is interesting, though, when you start to consider the various ways various parts of the body require protection.
Take, for instance, the eyes. They not only need protection from flying debris and impact, but many of us are equally concerned about harmful rays of the sun and ensuring long-term exposure to UV light doesn’t degrade vision.
Two aspects of the standard that stood out are Hazard Assessment and Training. After research, hazard assessment quickly made more sense. It was the training requirement that took more thinking. For crying out loud, what kind of training is needed? Do I need to show workers how to wear safety glasses?
However, after working through the process, all four aspects became clear – and necessary – to me.
Company-wide assessment
I decided to conduct a company-wide PPE hazard assessment. I determined there were important aspects outlined by OSHA.
The first was creating a spreadsheet identifying parts of the body that require protection, head to toe and in between. Then we identified various tasks we repeatedly experience. From this I created a spreadsheet with a grid.
We charted what type of PPE we might need for the various tasks, including how each part of the body could be protected. I knew it was important to provide flexibility for workers. Keep in mind, we are required to accept some risk, or we might never get any work done. Another aspect was to gain buy-in from local leadership. They had to sign off on the agreed-upon approach.
I learned that leadership in various locations were at different places in their efforts to create a safety culture. Most expressed that they were already working safely but couldn’t put their finger on how that was happening. I felt it was obvious – getting hurt is painful, and nobody likes pain.
Meet them where they are
After completing the PPE hazard assessments, I noticed similar findings. Everyone was in a different place but felt protected. One conversation came from an experienced field leader. This guy had been doing the job for years and had moved into supervision.
When I got pushback from him on the idea of wearing work gloves whenever a worker has a tool in their hands, he gave an interesting explanation. He felt gloves weren’t necessary, because their hands were toughened up and calloused from years of work. The injury, callouses, were protection, eliminating the need for work gloves.
Obviously, I disagreed but realized it wasn’t a battle I would win in the short term. I figured over time they might learn that disposable work gloves are more reliable protection than callouses.
It was lessons like these that helped me be more accepting of where people are on the journey. We moved forward, allowing the program to meet everyone where they were. Over time, I noticed the groups evolve. Some decided on their own to wear work gloves.
Training
The last topic was training. What does it mean to train people on PPE? I was certain it didn’t mean to show them how to wear safety glasses. Looking closer, I realized the training was about letting people know how the PPE protected them.
As I mentioned about safety glasses, it’s not just the idea of something impacting the eyes. People are concerned about the impact of UV light over long-term exposure. Other workers believe adding side shields will protect them.
There’s also the benefit of explaining what ANSI does regarding testing and establishing requirements for gear. There are many ways the gear we use protects us, not all intuitive.
The last thing I would mention is from a well-known leadership speaker. We’ve got to tell workers “why” we’re putting controls in place. They may make sense to you, but not all of the reasons are obvious. Give your workforce respect by explaining the reason you’ve identified these expectations.
We are required to train our workers. If they don’t receive training from us, where is it going to come from?
When we include the workforce in the decision-making, we might learn something from the workforce.
Tim Ayers, Certified Utility Safety Professional (CUSP), is a regional safety manager at MYR Group, a utility-contract company based in Thornton, Colorado. He is also a former Certified Treecare Safety Professional (CTSP) and safety & performance manager with accredited TCIA member Kramer Tree Specialists.
