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| Personal protective equipment, or PPE, helps reduce the employees'
health and safety risks. The employer must provide such equipment if it is needed. It is
the employee's responsibility to use the PPE as it is intended to be used in order to
ensure that it is, indeed, protective. |
| What are the employer’s responsibilities
in regard to providing personal protective equipment (PPE)? |
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 | to assess hazards in the workplace that may require employees to wear PPE |
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| to organize and analyze the findings of the assessment |
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| to provide written certification of the assessment |
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| to train employees in the use and limitations of PPE |
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| The employer is required to perform an assessment of the workplace to determine
if hazards are present, or likely to be present, that require the use of personal
protective equipment (PPE). |
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| A workplace walk-through survey should identify all potential hazards. Hazards from
machining operations using MRF may include |
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| metal removal fluids that may contact skin |
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| cleaning compounds, such as parts cleaning liquids |
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| sharp-edged parts |
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| hot parts |
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| heavy parts that pose a risk to feet if dropped |
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| Additional hazards common to industrial workplaces may include |
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| sources of motion that could result in impact or penetration |
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| sources of high temperature that could result in burns, ignition, or eye injury |
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| sources of harmful dust or chemical exposures
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| sources of light (optical) radiation, such as from welding, brazing,
cutting, furnaces, high intensity lights, etc.
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| sources of falling objects
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| sources of rolling or pinching objects that could crush feet
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| electrical hazards
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Findings
| The employer is also required to organize and analyze hazard assessment findings. The
employer should review each hazard category, and for each hazard present, should determine |
| the type of hazard |
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| the level of risk |
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| the seriousness of potential injury from each hazard present in the workplace. |
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PPE appropriate to each hazard must
then be selected.
Written
certification
| The employer must verify, with a written certification, that the workplace hazard
assessment has been performed. A written certification must identify |
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| the workplace evaluated |
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| the person certifying that the evaluation has been performed |
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| the date(s) of the hazard assessment |
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| the document as a certification of hazard assessment |
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Employee training
The employer must train employees in the following:
| when PPE must be worn |
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| what PPE is necessary |
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| the limitations of PPE |
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| procedures for fitting, adjusting and using PPE |
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| proper care, maintenance, useful life and disposal of PPE |
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| The employer must also provide written certification that employees
have received training and that they understand it. The training log should contain a
statement from each employee acknowledging that he or she has received training. Basic
demographic information must also be kept on each employee, such as name, social security
number, department, shift, and date. |
What are the
various types of PPE?
| Employees may be required to wear eye and face protection, protective clothing,
gloves, respiratory protection, head protection, foot protection, or hearing protection,
or some combination of these. |
Eye and Face Protection (29CFR1910.133)
| Eye and face protection must be worn to protect employees from hazards such as flying
particles, molten metal, chemicals (liquids, gases and vapors), caustics, and light
radiation (such as from welding). Such protection may be required for employees working
near operating metal removal processes or transferring as-received MRFs and other
materials, such as additives, to the machine tool or fluid sump or reservoir. |
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Side shields on glasses are mandatory when a hazard from flying
objects exists. |
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| Shade specifications for lenses for welding operations. |
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| Selection criteria must comply with ANSI Z87.1 - 1989. See supplier for specific
guidance. |
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Clothing and Gloves (29CFR1910.138)
Hand protection must be worn to protect
against hazards such as
| chemicals absorbed through the skin |
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| sharp objects that cause cuts, lacerations or abrasions, or puncture wounds |
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| chemical and thermal burns |
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| temperature extremes |
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See supplier for specific guidance on PPE
selection.
Respiratory Protection (29CFR1910.134)
| Before requiring the use of respiratory protection, the employer should institute
engineering and work practice controls, as necessary, to reduce employee exposures to
metal removal fluids and associated contaminants. If these controls fail to reduce and
maintain employee exposures, then the employer must provide respiratory protection.
Requirements concerning the use of respirators in the workplace can be found in OSHA 29
CFR 1910.134. |
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| The OSHA respiratory protections standard contains provisions too numerous to list in
this guide. In summary, the standard classifies respirator use into two types: |
| required (to protect the health of employees or by employer) |
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| not required or voluntary (provided by the employer or the employee and worn voluntarily
by the employee) |
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When respirators are required,
the employer must
| establish a written, site-specific respiratory protection program |
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| medically evaluate employees to ensure the employees' ability to use a respirator |
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| fit test negative-pressure respirators to ensure minimal leakage between the respirator
facepiece and the employee's face |
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| establish procedures for routine and emergency use of respirators |
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| establish procedures for cleaning, maintenance, and storage of respirators |
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| train employees in respiratory hazards and proper use, care, fitting, and limitations of
respirators |
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Where respirator use is voluntary, the
employer must
| ensure that respiratory use will not in itself create a hazard |
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| establish a written program |
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| medically evaluate employees |
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| ensure roper cleaning, maintenance, and storage of respirators |
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| When employees voluntarily use only "filtering facepieces" (formerly
referred to as "dust masks" or "single use respirators"), the employer
is not required to implement a respiratory protection program. Instead, employees
must be provided annually basic information on respirators, contained in Appendix D of
the standard |
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| Particulate respirator filters are classified into three types, depending on the
resistance of the filters to oil: |
| N (not resistant) |
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| R (oil resistant) |
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| P (oil proof) |
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Use of P-type filters is suggested for
protection against MRF-containing aerosols.
Head Protection (29CFR1910.135)
Head protection must be worn to protect from
hazards such as falling objects or electrical shock.
Selection criteria must comply with ANSI
Z89.1 - 1986.
Foot Protection (29CFR1910.136)
| Foot protection is needed against hazards such as electrical shock, rolling or falling
objects, and objects that may puncture feet. |
Selection criteria must comply with ANSI Z41
- 1991
Hearing Protection (29CFR1910.95)
| Many machining operations generate sound pressure (noise) levels that may result in
hearing loss to employees exposed during a working lifetime. Hearing protectors must be
worn when employees’ 8-hour TWA exposure exceeds 90 dBA. If an employee has
experienced hearing loss, hearing protection must be worn when exposure exceeds 85dB(A).
It is strongly recommended that employers require hearing protection for all employees
whose exposure exceeds an 8-hour TWA of 85dB(A). |
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Contact Chris Roman, 