Personal Protective Equipment Policy
This section has been reviewed and updated as needed: April 2014
Environment, Health and Safety
It is the responsibility of EHS to ensure all employees are properly protected from workplace hazards through engineering controls, administrative controls, or personal protective equipment. PPE and other hazard controls will be assessed during annual EHS inspections, incident investigations, Job Safety Analysis development, and complaints from university employees.
It is the supervisor’s responsibility to properly train their employees in the personal protective equipment they will need for their job specific duties. It is also the supervisor’s responsibility to ensure the employee is provided the proper personal protective equipment and that the employee uses their PPE properly while working. If it is determined by the supervisor or EHS that the employee is not using the PPE appropriately, then the employee must be retrained by the supervisor in the use of the PPE. If an employee is injured on the job because of not wearing the appropriate PPE, then the employee must be retrained by the supervisor in the use of the PPE. Supervisors should inspect all PPE at least once a month to ensure that it is safe to use.
Employees are responsible for using the appropriately issued personal protective equipment for the job they are doing. Different PPE may be required for different jobs. Employees are responsible for inspecting their PPE before and after each use. If the PPE is used infrequently, then it should be inspected at least once a month as well as before each use. Employees are also required to be properly trained in using PPE initially upon employment.
When PPE is Required
The University will provide, at no cost to the employee, all personal protective equipment which the employee does not wear off the job site or use off the job. OSHA 1910.132 (h) (1) states that payment is required for any PPE used by an employer to comply with one of the PPE requirements in OSHA’s standards. If the PPE is not required, then the employer is not required to pay for it. However, when an employer selects a specific type of PPE to be used at the workplace to comply with a standard, the employer is required to pay for it.
Safety-Toe Footwear and Prescription Safety Eyewear
OSHA 1910.132 (h) (2) states that the employer is not required to pay for non-specialty safety-toe protective footwear, and non-specialty prescription safety eyewear if the employer permits the items to be worn off the job-site. This includes steel-toe shoes or steel-toe boots. If the employer requires employees to keep non-specialty safety-toe protective footwear, and non-specialty prescription safety eyewear at the workplace, then the employer must pay for the items. If the safety-toe protective footwear, and prescription safety eyewear are non-standard “SPECIALTY” items, the employer must pay for them. This includes steel-toe shoes and steel-toe boots. (Examples of “specialty” items – Prescription eyeglass inserts for full-facepiece respirators, or non-skid shoes for floor strippers.)
Everyday Clothing and Weather/Temperature Issues
Under OSHA 1910.132 (h) (4), the employer is not required to pay for everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots. This also applies even when the employer requires employees to use these items, and the clothing provides protection from a workplace hazard. (OSHA 1910.132(h) (4) ) Under OSHA 1910.132 (h) (4), the employer is not required to pay for ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen. If ordinary weather gear is not sufficient to protect the employee, and special equipment or extraordinary clothing is needed to protect the employee from unusually severe weather conditions, the employer is required to pay for the protection. Clothing used to protect employees from artificial heat or cold is not part of this exception. (Example: Employees working in a freezer warehouse may need heavy coats. In this particular situation the employer is require to pay for the PPE.)
Replacement of PPE
OSHA 1910.132 (h) (5) states that the employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE. (Replacement of PPE is determined by each standard that requires PPE to be used.)
Where an employee provides adequate protective equipment which he or she owns and brings to the worksite, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment. However, the employer shall not require an employee to provide or pay for his or her own PPE, unless the PPE is excluded by another paragraph. In the event an employee brings their own PPE it must be under the following conditions:
- The employee’s use of their own PPE must be completely voluntary.
- The employee can withdraw use of their own PPE at any time.
- If the employer allows an employee to use PPE they already own, the employer is still held responsible for making sure the PPE is adequate, properly maintained, and sanitary under the applicable PPE standard.
- Select and have each affected employee use the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
- Communicate selection decisions to each employee;
- Select PPE that properly fits each affected employee;
- 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, and the dates of the hazard assessment. (Refer to “Certificate for Personal Protective Equipment”.)
Each employee must be trained to know the following information:
- When PPE is necessary
- What PPE is necessary
- How to properly don, doff, adjust, and wear PPE
- The limitations of the PPE
- The proper care, maintenance, useful life and disposal of the PPE
Retraining is required when there are changes in the workplace and in the type of PPE to be used. Retraining is also required when an affected employee’s knowledge or use of the assigned PPE indicates that the employee has not retained the understanding or skill needed to use the PPE properly.
Hard hat protection is effective only if the hat is adjusted to fit properly and is worn squarely on top of the head and not cocked at an angle or perched on the back of the head. Severe lacerations from relatively light blows have been incurred by workers wearing hard hats in unusual positions.
The hair shall be protected against being caught on moving machinery, subjected to sparks or snagging objects. Long hair should be protected by compacting it into the hard hat shell or by use of hair nets or ties so that it is not loose.
The hard hat protects in five basic ways:
- The hard shell is the basic impact protection against falling and flying objects and walking into objects.
- The curved shell allows an object to ricochet or slide off, reducing the force of impact.
- The space maintained between the shell and the head (minimum of 1 1/4 inch) by the suspension within the helmet minimizes the shock and prevents the shell from striking the head solidly upon impact.
- The space between the suspension and the shell on the side of the head softens the effect of lateral blows. This space should also be sufficiently ventilated.
- The bill protects the face and the outwardly curved bottom edge allows for the protection of the ears and the nape of the neck.
Supplementary hard hat equipment includes winter liners for cold, sweat bands for heat, chin straps for high wind, and sloth caps for radiation exposure. When using a face shield, welding hood or sandblasting hood, the type, which combines with the hard hat, is recommended. If work must be done in small areas and the hard hat will not fit, a soft cap will be an acceptable substitute, i.e., a welding sock hood. These must have prior approval from the Environment, Health and Safety Office. If a worker must work in an inverted position subject to falling or flying particles, ear protectors and a chin strap should be used. Do not modify hard hats without the approval of the Environment, Health and Safety Office. (ex. Holes should never be drilled into the hard hat. This weakens the structure and reduces the protectiveness of the hard hat.)
Within a safety shoe/boot you will find the American National Safety Standard ANSI Z41 PT 91 on the inner flap. Also, ASTM F 2412-05 and ASTM F 2413-05 may be found on these inner flaps of newer safety shoes since the ANSI Z41 PT 91 no longer exists. The information on this inner flap will tell you exactly what hazards the employee is protected against.
An employee’s personal work clothes are to fit his/her work assignment. The minimum protection required is a full short sleeve “T” shirt. Tank tops and cut-off T-shirts are prohibited from being worn. Other minimum protection that is required includes long pants which help to prevent sunburn, plant rashes, abrasions and insect bites, and to afford some protection against flying particles and accidental spills of liquids. Shorts may be approved for some work duties (e.g. jobs that do not consist of hazards that have the potential of damaging skin on the legs). Any exceptions must be approved by work unit supervisors, the department management, and the Environment, Health and Safety Office.
When working with or around acids or alkalis, a full acid suit may be needed. However, the degree of exposure may permit use of rubber two-piece suits or a rubber apron with rubber sleeves. In some cases rubber boots may be sufficient.
When material or equipment is going to be carried on the shoulder for a period of time, shoulder pads should be used. These can easily be made by folding sections of burlap together.
Coast Guard approved life vests are to be worn when working near water. Fluorescent vests are to be worn to direct traffic at night and at busy intersections.
University employees are required to use appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially hazardous light radiation. Employees are required to wear eye protection that provides side protection when there is a hazard from flying objects. Detachable side protectors (i.e. clip-on or slide-on side shields) meeting the requirements of this section are acceptable. When applicable, secondary protective devices such as face shields are required in conjunction with primary protective devices during severe exposure to impact hazards, heat, and chemicals. When an employee is working in a dusty area, either eyecup or cover-type safety goggles should be worn in the area. Further information can be found on the OSHA website.
It is the university’s responsibility to ensure that each affected employee who wears prescription lenses while engaged in operations that involve eye hazards wears eye protection that incorporates the prescription in its design, or ensures the employee wears eye protection that can be worn over the prescription lenses without disturbing the proper position of the prescription lenses or the protective lenses.
Eye and face PPE must be distinctly marked to facilitate the identification of the manufacturer of the PPE.
It is the responsibility of the university to ensure that each affected employee uses equipment with filter lenses that have a shade number that is appropriate for the work being performed for protection from injurious light radiation.
The following tables list appropriate shade numbers for a variety of operations:
|Operations||Electrode Size 1/32 in.||Arc Current||Minimum(*) Protective Shade|
|Shielded metal arc welding||Less than 3
More than 8
|Less than 60
|Gas metal arc welding
and flux cored arc welding
|Less than 60
|Gas Tungsten arc welding||less than 50
|less than 500
|Plasma arc welding||less than 20
|Plasma arc cutting||(light)(**)
|less than 300
Carbon arc welding
|Operations||Plate thickness: in||Plate thickness: mm||Minimum(*) Protective Shade|
⅛ to ½
3.2 to 12.7
1 to 6
25 to 150
**As a rule of thumb, start with a shade that is too dark to see the weld zone. Then go to a lighter shade which gives sufficient view of the weld zone without going below the minimum. In oxy fuel gas welding or cutting where the torch produces a high yellow light, it is desirable to use a filter lens that absorbs the yellow or sodium line in the visible light of the (spectrum) operation.
***These values apply where the actual arc is clearly seen. Experience has shown that lighter filters may be used when the arc is hidden by the workpiece.
Eye Protection Criteria
ANSI Z87.1-2003 sets forth criteria related to the description, general requirements, testing, marking, selection, care, and use of protectors to minimize or prevent injuries, from such hazards as impact, non-ionizing radiation, and chemical type injuries, in occupational and educational environments including, but not limited to, machinery operations, material welding and cutting, chemical handling, and assembly operations.
Protective eye and face devices purchased after July 5, 1994 shall comply with ANSI Z87.1-1989, “American National Standard Practice for Occupational and Educational Eye and Face Protection,” which is incorporated by reference as specified in Sec. 1910.6.
Eye and face protective devices purchased before July 5, 1994 shall comply with the ANSI “USA standard for Occupational and Educational Eye and Face Protection,” Z87.1-1968, which is incorporated by reference as specified in Sec. 1910.6, or shall be demonstrated by the employer to be equally effective.
If prescription glasses are required, the employee will need a current prescription (less than one year). Prescriptions cannot be copied from current prescription eyewear. Scheduling and payment of eye examinations are the employee’s responsibility.
When the departmental contact calls for service, the Environment, Health and Safety Office will determine the availability of appointment times.
FI/75 C/75 MT/75
Cd 1 EH
ANSI Z41 PT91. This line identifies the ANSI Z41 standard. The letters PT indicates the protective section of the standard. This is followed by the last two digits of the year of the standard with which the footwear meets compliance (1991)
FI/75 C/75 MT/75. This line identifies the applicable gender (M or F) for which the footwear is intended. It also identifies the existence of impact resistance (I), the impact resistance rating (75, 50, or 30 foot-pounds). This line can also include a metatarsal protection designation (MT) and rating (75, 50, or 30 foot-pounds).
Lines #3 and 4
Cd 1 EH; PR. Line 3 and 4 are designated for conductive properties (Cd) and type (1 or 2), electrical hazard (EH) and puncture resistance (PR), if applicable.
Employees are expected to wear footwear appropriate for the duties of their employment. Sandals or other open-toe style shoes are not permitted to be worn in laboratories, shops, or other job locations where glass, caustic or corrosive chemicals, or hot materials are used or handled.
Employees will be required to obtain safety shoes before starting employment if their duties require them to wear safety shoes.
Students are expected to wear appropriate footwear while participating in laboratory exercises, or other instructional activities involving the use of glass, caustic or corrosive chemicals, or hot materials. Generally, sandals or other open-toe style shoes should not be worn in laboratories or during activities which would require the use of eye protection devices. (See: Environment Health and Safety Manual Chapter 5: Eye and Face Protection.)