Hazard assessments are required under OSHA regulations for deciding what personal protective equipment controls may be needed for hazards on the job. A literal reading would even suggest that they be completed for work tasks that may not require the use of personal protective equipment. This would be necessary simply to make the determination that personal protective equipment is not needed.
While the requirement for hazard assessments has been with us since 1994, I suspect that many workplaces have not complied or do not have the necessary documentation to prove that hazard assessments were adequately performed. This documentation could become especially important should a serious injury occur.
In this article, I will review the OSHA regulatory requirement for hazard assessments for personal protective equipment use. I will then provide a suggested approach for conducting these assessments that includes a simple risk analysis scheme. I will end the article with a brief discussion on some of the more difficult issues related to hazard assessments.
OSHA Regulations
The requirements for personal protective equipment for General Industry are contained in 29 CFR Part 1910.132. In this context, personal protective equipment refers to head, eye and face, respiratory, body, hand and foot protection. Personal protective equipment for construction, shipbuilding, longshoring and other distinctly regulated sectors are covered in those sector regulations. Hearing protection, fall protection and other special types of personal protective equipment are covered under other sections of OSHA standards. The General Industry section of the OSHA regulation states, in part:
"The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE)."
"The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the dates(s) of the hazard assessment; and which identifies the document as a certification of hazard assessment."
The hazard assessment requirement (contained under paragraph d) and a paragraph on training requirements (paragraph f) apply to sections 1910.133 (Eye & Face Protection), 1910.135 (Head Protection), 1910.136 (Foot Protection), and 1910.138 (Hand Protection) While not explicitly stated, it would also apply to protection of the body (e.g., protective clothing). The hazard assessment and training requirements in this part of the OSHA standards do not apply to sections 1910.134 (Respiratory Protection) and 1910.137 (Electrical Protective Equipment), because each of these has its own selection scheme.
OSHA requires a written certification that the hazard assessment has been performed. However, there is no requirement that the hazard assessment itself be in writing. Most professionals would suggest that written documentation of the actual assessment, although not literally required, would be a best practice.
Appendix B of the standard contains some general guidance (nonmandatory) for assessments that include the following steps: conduct a walk-through survey observing hazards; organize the data; analyze the data (type, level of risk, seriousness of potential injury); selection (based on the hazard); and reassessment of the hazard. The appendix is very general; thus, the information is only somewhat helpful. Consider the following guidance to augment what is listed in Appendix B:
- Perform all of the hazard assessments in writing and maintain these records.
- Use a job hazard analysis (JHA) or job safety analysis (JSA) approach that identifies potential physical, chemical, biological or other hazards for each work task.
- Include an evaluation of the relative risk for each hazard and the controls proposed, including hazard controls other than PPE.
- Include copies of the references (e.g., manufacturers' literature) used for the selection or note what was relied upon for the selection. Do not rely solely on material safety data sheets.
- Document JSA or JHA for jobs not requiring PPE due to low risk or where resolved through other types of hazard control.
- Include training requirements for workers and others in the assessment.
- Establish a means to validate the selection and use of PPE through measures such as medical surveillance for higher risk applications.
- Establish a suspense date to re-evaluate the job or task (3 to 12 months from initial evaluation) to reaffirm the effectiveness of the PPE (re-evaluation is required if the job or hazards change).
- Document protective equipment failures, determine the root causes for the failures, and document corrective actions to resolve these incidents.
Performing the Job Safety or Job Hazard Analysis
The basic principle of JSA or job hazard JHA is to break down the work to be performed into distinct tasks, and then analyze each distinct work task for potential safety risks or hazards. For our application, we would also be interested in information on the performance requirements of PPE. JSA may also include other elements such as property damage and product quality. Here, we will only consider what could happen to the worker and what performance requirements are needed in PPE for purposes of this analysis. JSA/JHA should also include "what if" analysis for nonroutine and upset conditions. It is important to include a "what if" or fault tree approach to the job analysis, because accidents commonly result from deviations from work practices and normal operations.
For these scenarios, consider what is possible, but not what is very unlikely (e.g., the process explodes or the building collapses). To illustrate this approach, let's use a simple industrial truck battery-charging example. Many of you will be familiar with this work task.
The Battery Charging Process (work tasks and approximate duration):
1. Put on Neoprene apron, gloves, face shield (5 minutes).
2. Use a hand-operated electric hoist to move the battery from the industrial truck to the charging area. Place a charged battery into the industrial truck and connect terminals (5 minutes).
3. Remove a battery cap and sample the specific gravity of the battery acid solution (2 minutes).
4. Add acid (sulfuric), as needed, using a bulk dispensing hose with squeeze spigot (2-10 minutes).
5. Clean the battery top using baking soda, water and an acid-resistant fiber wooden brush (4 minutes).
6. Clean tools by rinsing with water in basin (2 minutes).
7. Place the battery on charge, using connecting terminals (2 minutes).
8. Remove and rinse protective clothing or repeat for another battery
In this example, the average cycle (total task) time is approximately 25 minutes. Now consider some of the hazards and things that could go wrong in these simple work tasks.
Inspection of PPE is required before putting it on (knowledge and skill required). The face shield may limit visibility and create a safety hazard; the worker may use the wrong equipment; and the equipment may be missing, damaged or contaminated.
When using the hoist, there is a chance the battery could be dropped or damaged, which could result in a splash or spill. There is a chance of contact with battery acid. The gloves could fail if they do not have adequate abrasion resistance. There is a potential for a electrical shock from battery damage, shorts or excess water. There is a possibility for hydrogen buildup from charging; hence, a potential for explosion from sparks.
Remove cap and sample acid: Chance for splash; chance for battery acid contact; need gloves that are not slippery and allow some dexterity.
Add acid: Potential for leak, splash, and spill. Potential for direct contact with sulfuric acid.
Clean battery top: Contact with acid; electrodes require gloves that can handle abrasion and allow water and baking soda contact. There could be accidental contact with a terminal and, the ground, resulting in a shock or a short.
Clean tools: Could be splashed (need face shield?).
Place battery on charge: Electrical shock? Cut resistance for gloves. Wrong polarity could create a problem. Battery could boil over.
Remove PPE/repeat: Requires decontamination of PPE. PPE must have ability to be washed and air-dried without degradation; need procedure to reduce risk of cross-contamination; need storage that is adequate.
This is a simple example that has been limited to some of the most likely undesirable events or performance requirements for the equipment. Obviously, there are other, more remote hazards, such as being hit by the industrial truck or environmental conditions. Nevertheless, this example demonstrates the general concept.
This approach can be applied to work already being performed or work that is planned. The obvious advantage for work that is being performed is that you can gather valuable information from the worker and supervisor. This should be done using a Socratic dialogue. In simpler terms, ask questions and pose "what if" scenarios. The process can also be organized by simply developing a three-column form. To illustrate the use of the form, I have included one step (No. 6) from the battery charging example.
Determining the Relative Risks For Each Hazard
From JSA/JHA, a relative risk analysis can be performed. The concept is simple: What is the likelihood of injury? How severe is the injury likely to be? Relative risk is conceptual and is based, in principle, on frequency and severity. It incorporates the probability of injury. While relative risk means determining the risk relative to something else, in this case I am suggesting risk relative to other work risks (an educated guess).
Acceptable risk is usually a very small chance of a severe injury or a more likely chance of a minor injury. Acceptable risk is not definitive and not a truly quantifiable value; however, general guidance and common sense can be followed. For the most severe injuries or death, the probabilities must be very low: hence, the quality of the hazard assessment is critical.
Fig. 2 above shows a four-by-four risk matrix. The Y axis (left side) shows an increasing probability of an event with a scale from very unlikely to very likely. The X axis (bottom) shows increasing severity, such as from a very minor to a very serious injury. From these estimations, one can find where the two values intersect (in one of the 16 boxes). The relative risk can be estimated from the intersecting box (very low risk to very high risk). A larger matrix, such as six-by-six, can be used to suit the situation or the pleasure of the person doing the risk analysis. The trick is to simply pick the graduations on each scale.
Using our battery charging example, you might estimate that the likelihood of a battery acid splash from removing the battery cap is low and the severity or consequence of such an event is minor (assumes that the face shield is being worn). This would give a relative risk level that is low (hence, the face shield and other equipment is adequate).
An example of a situation where personal protective equipment might not be appropriate is where the likelihood of the adverse event is probable or highly probable and the consequence or severity is severe. Results of the risk analysis can be shown by incorporating this aspect in the third column in Fig. 1 or adding an additional column.
Selection
Performance characteristics, including ergonomic considerations, required from PPE are derived from the hazard assessment. The potential for PPE failures that could result in severe injury or illness must be carefully considered and controlled (e.g., What could go wrong? How can this likelihood be reduced?). If the risk is high, even with the use of PPE, an approach other than the use of PPE will need to be developed to control the hazard. It is also recommended that the selected PPE be used on a trial basis to determine user acceptability, job limitations and effectiveness.
Training is also required under the standard for PPE. This training should be based on the selection, the hazard and what to do in the event of a failure or emergency. OSHA requires a written certification that the users have been trained in:
- When PPE is necessary.
- What PPE is necessary.
- How to properly don, doff, adjust and wear PPE.
- Limitations of PPE.
- Proper care, maintenance, useful life and disposal of PPE.
There may be additional training requirements under the OSHA Hazard Communication standard, depending on the hazard.
Complicating Factors
This approach to risk assessment seems easy enough. However, Murphy"s Law says that if the solution seems simple, you have obviously overlooked something. There are likely to be times when there is no clear choice to fit all of the requirements of the work task. There are also likely to be issues related to user discomfort or medical limitations, user misuse or misapplication of the equipment, ergonomic constraints, decontamination issues, inspection and end- of-life complications, and the issue of cost (your specific equipment choice vs. the cost choice made in purchasing).
Beyond these complications, there are other issues, such as when would you possibly have time to do 400 hazard assessments theoretically suggested for hundreds of jobs that include the use of routine and mundane safety shoes and safety glasses?
While I have no easy answers to any of the questions posed, please allow me to answer the last one. For jobs that involve simple hazards and relatively low risk, you may not need to do a formal documented JSA and risk assessment (other than certifying one was done). You could treat an area or similar jobs as one hazard assessment (e.g., safety glasses and safety shoes for a machine shop). Just be sure that your colleague at your sister plant does not come to some other conclusion (a serious or willful violation in waiting).
Contributing Editor Zack Mansdorf , Ph.D., CIH, CSP, QEP, has more than 25 years of technical and strategic experience in safety and health management. He is a past president of the American Industrial Hygiene Association and a director of the Board of Certified Safety Professionals. He can be reached via e-mail at [email protected].