CSAC Excess Insurance Authority LOSS PREVENTION BEST PRACTICES PERSONAL PROTECTIVE EQUIPMENT CAL/OSHA WRITTEN CERTIFICATION ASSESSMENT REQUIREMENTS Introduction Cal/OSHA personal protective equipment (PPE) requirements have been in force since the early 1970s. But, as of April, 13, 2011, Cal/OSHA amended CCR 3380, Personal Protective Devices, which now requires California employers to conduct a PPE assessment of their workplace and verify the assessment was conducted through a written certification process. This assessment is vital in determining if PPE can be workers using basic hazard categories, such as impact, eliminated. penetration, compression (roll‐over), chemical, heat, harmful dust, and light/radiation. Sources of hazards PPE is the least effective method for protecting your may include: employees because PPE does not eliminate or reduce . Motion, such as machinery or processes where the hazard. One of the basic principles of safety any movement of tools, machine elements or management is called the Hierarchy of Controls. It particles could exist, or movement of personnel prioritizes control methods that remove or reduce a that could result in collision with stationary hazard in the workplace, rather than rely on human objects behavior. Types of Controls from most to least effective include: . High temperatures that could result in burns, eye injury or ignition of protective equipment, . Elimination of the Hazard/Substitution – Substitute etc. with safer alternatives . Chemical/harmful dust exposures includes gas, . Engineering Controls – Implement physical change liquids, and solids to the workplace, which eliminates/reduce the hazard . Light radiation, such as welding, brazing, . Administrative and Work Practice Controls – cutting, furnaces, heat treating, high intensity Establish efficient processes or procedures to avoid lights, etc. over exposure . Falling objects or potential for dropping objects . PPE – Use of protection to reduce exposure to hazard . Sharp objects which might pierce the feet or cut the hands The scope of the regulation . Rolling or pinching objects which could crush covers PPE requirements the feet for the head, eyes/face, . Layout of workplace and location of workers hands, feet, and body; however, as a best practice, . Electrical hazards you are encouraged to Potential sources may also be identified by analyzing include all applicable PPE in accident/injury data. your assessment, such as respiratory protection, hearing protection, and fall protection. Analyzing the Assessment Once the information is gathered, each of the basic Conducting the PPE Assessment hazard categories should be reviewed and a In order to assess the need for PPE, the entity should determination made as to the source of the hazards and conduct a walk‐through survey of the work areas where potential injury from the hazards. In many cases, there the entity believes PPE may be necessary. The purpose may be several hazards identified. of the survey is to identify sources of hazards to www.csac‐eia.org 916.850.7300 Loss Prevention Best Practices PPE – Cal/OSHA Written Assessment Requirements Certifying the Assessment Training Requirements The entity must verify that the required workplace The entity must provide training to each employee who hazard assessment has been performed through a is required to use PPE. Training must include, at least, written certification that identifies the workplace the following: evaluated, the person certifying that the evaluation has . When PPE is necessary been performed, and the date(s) of the hazard assessment. The evaluator should have knowledge of . What PPE is necessary the tasks and operations performed within the . How to properly don, doff, adjust, and wear PPE assessment. Sample PPE Assessment Form . The limitations of the PPE PPE Selection Guidelines . The proper care, maintenance, useful life and After completing the analysis, Cal/OSHA recommends disposal of the PPE the following procedure for selecting PPE: Employees must demonstrate an understanding of the . Become familiar with the potential hazards and training and an ability to use the PPE properly before the type of protective equipment that is performing work requiring the use of the PPE available, and what it can do; i.e., splash The entity must re‐train affected employees when: protection, impact protection, etc.; . Changes in the workplace render previous . Compare the hazards associated with the training obsolete; environment; i.e., impact velocities, masses, . Changes in the types of PPE to be used render projectile shape, radiation intensities, with the previous training obsolete; and capabilities of the available protective equipment; . There are inadequacies in an affected employee's use of assigned PPE which indicates . Select the protective equipment which ensures the employee has not retained the required a level of protection greater than the minimum understanding or skill. required to protect employees from the hazards; and A written certification is required that confirms the employee received and understood the training. Fit the user with the protective device and give Documentation should include employee name, training instructions on care and use of the PPE. It is date(s), and subject. Sample PPE Training Form very important that end users be made aware of all warning labels for and limitations of their Cleaning and Maintenance PPE. It is important that all PPE be kept clean and properly maintained. Cleaning is particularly important for eye PPE Selection Resources and face protection where dirty or fogged lenses could Cal/OSHA has developed a PPE Guide which provides impair vision. detailed guidance on selecting PPE for the eyes, face, head, feet, and hands. PPE should be inspected, cleaned, and maintained Additional Cal/OSHA resources: at regular intervals so that ‐ 8 CCR 3381, Head Protection the PPE provides the ‐ 8 CCR 3382, Eye and Face Protection requisite protection. ‐ 8 CCR 3383, Body Protection ‐ 8 CCR 3384, Hand Protection Contaminated PPE which ‐ 8 CCR 3385, Foot Protection cannot be decontaminated must be disposed of in a manner that protects employees from exposure to hazards. 2 .