SAFETY STANDARDS
OSHA ’ s Personal Protective Equipment
Many OSHA regulations require employers to provide personal safety equipment , such as respirators and hard hats , to protect employees from job-related injuries and illnesses . Specifically , OSHA ’ s personal protective equipment ( PPE ) standard mandates that general industry , construction , and maritime employers must provide all required PPE at no cost to employees . However , there are several exceptions :
• Employers must pay for replacement PPE , except when the employee has lost or intentionally damaged the PPE .
• To accommodate employees who frequently move from job to job , employees may use their own equipment if the employer approves . The employer is not required to reimburse the employees for the PPE . However , employers cannot require employees to provide or pay for their own PPE .
• Employers are not required to pay for ordinary toe-safety footwear ( including steel-toed shoes ) if the employer allows the employee to wear them off the jobsite or for shoes with built-in metatarsal protection as long as the employer provides and pays for metatarsal guards that attach to the shoes .
OSHA RECOGNIZES THAT THERE ARE CERTAIN CIRCUMSTANCES WHERE LONG-SLEEVE SHIRTS , LONG PANTS , STREET SHOES , NORMAL WORK BOOTS , AND OTHER SIMILAR TYPES OF CLOTHING COULD SERVE AS PPE . HOWEVER , THE STANDARD EXCLUDES EVERYDAY CLOTHING FROM THE EMPLOYER-PAYMENT RULE .
Employers are not required to pay for ordinary equipment used solely for protection from weather , such as winter coats and gloves , sunscreen , or sunglasses . In the rare case that special equipment or extraordinary clothing is needed to protect the employee from unusually severe weather conditions , the employer is required to pay for such protection . Clothing used in artificially controlled environments with extreme hot or cold temperatures , such as freezers , is not considered part of the weather-related gear exception .
IT IS IMPORTANT TO NOTE SEVERAL DETAILS CONTAINED IN OSHA ’ S PPE STANDARDS .
PPE for the eyes , face , head , and extremities ; protective clothing ; respiratory devices ; and protective shields and barriers must be provided , used , and maintained in sanitary and reliable condition . When employees provide their own equipment , the employer is responsible for assuring its adequacy , including proper maintenance and sanitation .
Employers are responsible for assessing the workplace to determine if hazards are present or are likely to be present . This will determine the use of PPE . If hazards are present , or likely to be present , the employer should do the following :
• Select and enforce the use of proper PPE that will protect the affected employees from the specific hazards identified in the hazard assessment .
• Communicate selection decisions to each affected employee .
• Select PPE that properly fits affected employees .
• Verify that the required workplace hazard assessment has been performed through a written certification identifying the workplace area evaluated , the person
BY : ERIC P . WOKAS , CSP ARM SENIOR RISK ENGINEER JGS INSURANCE , A BALDWIN RISK PARTNER
certifying that the evaluation has been performed , and the date of the hazard assessment .
• Provide training to each employee who is required to use PPE . Each employee should know when PPE is necessary ; how to properly use , remove , adjust , and wear PPE ; the limitations of PPE ; and the proper care , maintenance , useful life , and disposal of PPE .
Each affected employee should demonstrate an understanding of PPE training and the ability to use PPE properly before being allowed to perform work .
When an employer has reason to believe that any affected employee that has already been trained does not understand or have the skill required to use PPE , the employer should retrain such employee . Retraining is required when changes in the workplace make previous training obsolete and especially when inadequacies in an affected employee ’ s knowledge or use of assigned PPE indicate that the employee has not been trained properly . +
Eric P . Wokas has over 25 years of experience as a risk management consultant working for various major property / casualty insurance carriers including Continental , Zurich and Gerling as well as Aon an international insurance brokerage firm . At JGS Insurance Eric Wokas continues to assist clients in development and implementation of practical solutions in reducing risk .
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