Walk the floor of any trade show dedicated to occupational safety and health and you'll see hundreds of vendors of personal protective equipment (PPE). From gloves and hearing protection to hard hats, foot protection, safety eyewear, fall protection, respirators, protective clothing and more, there are thousands and thousands of different styles, brands, sizes, colors and protection levels from which to choose.

Most EHS professionals try to marry job tasks to the type and protection level of PPE, often with guidance from OSHA regulations. But when an employee is badly injured, or a particular type of injury seems to be trending, managers and many safety professionals up the ante by increasing protection levels. For example, you notice a recent trend in hand injuries. Your gloves are an ANSI cut level 2. Your knee-jerk reaction might be to go to an ANSI cut level 4. But is this the right choice for the right reasons?

Unintended Consequences

Griff Hughes, the president of Banom, says that PPE choices often are made with the best intentions, but without considering unintended consequences.

He cites a sheet metal manufacturer who experienced an increase in employee cut injuries as an example. That manufacturer noted the trend and immediately started looking for a glove and protective sleeve that are integrated as a way to eliminate any gaps in hand/arm protection.

"There is a reason why you don't want the glove and the sleeve sewn together," said Hughes. "If the glove gets caught in a machine, there's no hope of pulling the hand out of the glove and a sleeve. As the machine pulls on the glove, the knit sleeve will tighten down [around the arm], trapping it and creating the potential for very serious injuries."

Gloves in particular are tricky, experts note, because there is a variance in cut tests and some of the cut tests don't mimic real-world applications. For example, an ANSI test involves drawing a knife-blade across the glove to determine the cut level. In real life, an employee might be more likely to be cut or stabbed with the point of the knife.

Hughes said he finds that some safety departments are over-specifying protection levels, calling it "a disturbing trend."

"They go up a level without understanding the hazard," he said. "There was a metal manufacturer using cut level 2 gloves who had a cut-through. They immediately specified ANSI level 4 gloves."

Hughes said he performed an edge test at their facility and showed how a level 2 glove worked and level 4 failed for their particular hazard simply by changing the components in the level 2 glove.
Larry Garner, CMO at MCR Safety, noted that in site visits he's made, he finds that underprotection is more of an issue than overprotection. Making the proper choices "requires a thorough understanding of prevailing industry standards. For example, while cut protection is currently focused on ISEA/ANSI numerical ratings (1-5), the gram performance attached to each of those numbers is a much more accurate point of reference for determining levels of cut protection. Current ANSI/ISEA performance levels can range up to as much as 2,000 grams."

Proposed changes for 2016, Garner said, could include up to nine levels of cut protection, which is an improvement because it reduces the gram range for each level.

"However, consumers will be challenged to make the most appropriate PPE choices without understanding the significance of gram level performance," Garner added.

He said the International Glove Association (IGA) agreed to eliminate their cut protection guidelines in hopes of minimizing industry confusion regarding the selection process. "Going forward their efforts will focus on other ways to influence safety awareness by engaging with organizations such as International Safety Equipment Association (ISEA)," said Garner. "A collaborative effort between such groups could leverage the science and technical expertise of ISEA and industry experience from glove manufacturers within the IGA. This model can be extended across product categories."

Jumping on the Overprotection Bandwagon

So if more or higher isn't necessarily better, why do companies overprotect workers?

Hughes and Garner agree that companies overprotect employees for several reasons: the employers haven't thoroughly evaluated the hazards; any increase in injuries looks like it could be a failure of the protection, rather than the more likely scenario of a lack of appropriate training for employees; and finally, as a way for employers to "protect" themselves from any liability associated with employee injuries. Garner noted that government regulations such as Prop 65 have affected not only the safety products industry but all industries "by legislating the necessity of providing potential warning with very low probability of hazard."

And lack of protection and overprotection not only are "glove" issues. Donald J. Garvey, CIH, CSP, CET, of 3M Co., recently offered some startling statistics about hearing conservation in the construction industry.

Citing a recent study, Garvey noted, "Depending on the trade, one study of more than 1,300 noise measurements indicated approximately 70 percent of the construction workers had a full-shift, time-weighed average (TWA) exposure at or above the NIOSH-recommended exposure limit (REL) of 85 dBA. About 10 percent of those workers had full-shift average exposures above the current OSHA construction permissible exposure limit (PEL) of 90 dBA."

The actual and effective use of HPD typically is poor, Garvey noted. He attributed that to the transient nature of the workforce; the painless nature of noise-induced hearing loss; the lack of an immediate cause/effect loop; the annoyance and potential discomfort caused in some cases by wearing HPD; and the use of overprotective HPD.

"HPD frequently is selected solely on the basis of high noise-reduction ratings (NRR)," said Garvey. "However, around 90 percent of TWA occupational noise exposures are 95 dBA or less. An HPD that delivers 10 dB of actual attenuation will cover the majority of exposures and reduce noise exposure below 85 dBA."

Overprotection can cause employees to be unaware of warning sirens and backing alarms, and can complicate voice communication. And what is the first thing employees do if they can't hear? They remove their HPD, which exposes them to noise.

In many cases, Garvey said, only one type of HPD is provided. "Any single product can overprotect workers or be uncomfortable for some people to wear. Ear canal size and shape varies significantly from person to person," said Garvey.