COMPLIANCE GUIDELINES FOR HAZARD ASSESSMENT AND PERSONAL PROTECTIVE EQUIPMENT SELECTION

This Appendix is intended to provide compliance assistance for Cheyenne Drilling management and employees in implementing requirements for a hazard assessment and the selection of personal protective equipment.

1.0 Controlling Hazards

PPE devices alone should not be relied on to provide protection against hazards, but should be used in conjunction with guards, engineering controls, and sound practices.

2.0 Assessment and Selection

It is necessary to consider certain general guidelines for assessing the foot, head, eye and face, and hand hazard situations that exist in an occupational or educational operation or process, and to match the protective devices to the particular hazard. It should be the responsibility of the safety officer to exercise common sense and appropriate expertise to accomplish these tasks.

3.0 Assessment Guidelines

In order to assess the need for PPE the following steps should be taken:

3.1 Survey – Conduct a walk-through survey of the areas in question. The purpose of the survey is to identify sources of hazards to workers and co-workers. Consideration should be given to the basic hazard categories:

Impact

Penetration

Compression (roll-over)

Chemical

Heat

Harmful dust

Light (optical) radiation

3.2 Sources – During the survey the safety officer should observe:

Sources of motion; i.e., machinery or processes where any movement of tools, machine elements or particles could exist, or movement of personnel that could result in collision with stationary objects.

Sources of high temperatures that could result in burns, eye injury or ignition of protective equipment, etc,

Types of chemical exposures

Sources of harmful dust

Sources of light radiation; i. e., welding brazing, cutting, furnaces, heat treating, high intensity lights, etc.

Sources of falling objects or potential for dropping objects.

Sources of sharp objects which might pierce the feet or cut the hands

Sources of rolling or pinching objects, which could crush the feet.

Layout of workplace and location of co-workers.

Any electrical hazards.

In addition, injury/accident data should be reviewed to help identify problem areas.

3.3 Organize Data – Following the walk-through survey, it is necessary to organize the data and information for use in the assessment of hazards. The objective is to prepare for any analysis of the hazards in the environment to enable proper selection of protective equipment.

3.4 Analyze Data – Having gathered and organized data on a workplace, an estimate of the potential for injuries should be made. Each of the basic hazards should be reviewed and a determination made as to the type, level of risk, and seriousness of potential injury from each of the hazards found in the area. The possibility of exposure to several hazards simultaneously should be considered.

4.0 Selection Guidelines

After completion of the procedures in section 3, the general procedure for selection of protective equipment is to:

4.1 Become familiar with the potential hazards and the type of protective equipment that is available, and what it can do; i.e., splash protection, impact protection, etc.

4.2 Compare the hazards associated with the environment; i.e., impact velocities, masses, projectile shape, radiation intensities, with the capabilities of the available protective equipment.

4.3 Select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from hazards

4.4 Fit the user with the protective device and give instructions on care and use of the PPE. It is very important that end users be made aware of all warning labels for and limitations of their PPE.

5.0 Filling the Device

Careful consideration must be given to comfort and fit. PPE that fits poorly will not afford the necessary protection. Continued wearing of the device is more likely if it fits the wearer comfortable. Protective devices are generally available in a variety of sizes. Care should be taken to ensure that the right size is selected.

6.0 Devices with Adjustable Features

Adjustments should be made on an individual basis for a comfortable fit that will maintain the protective device in the proper position. Particular care should be taken in fitting devices for eye protection against dust and chemical splash to ensure that the devices are seated to the face. In addition, proper fitting of helmets is important to ensure that it will not fall off during work operations. In some cases a chinstrap may be necessary to keep the helmet on an employee’s head. (Chin straps should break at a reasonably low force, however, so as to prevent a strangulation hazard). Where manufacturer’s instructions are available, they should be followed carefully.

7.0 Reassessment of Hazards

It is the responsibility of the safety officer to reassess the workplace hazard situation as necessary, by identifying and evaluating new equipment and processes, reviewing accident records, and reevaluating the suitability of previously selected PPE.

8.0 Selection Chart Guidelines for Eye and Face Protection

Some occupations (not a complete list) for which eye protection should be routinely considered are:

Toolpushers

Shop Mechanics, Shop Hands

Drillers

Derrick men

Floor hands

Drilling Managers

Carpenters

Electricians

Machinists

Mechanics and Repairers

Plumbers and Pipe Fitters

Sheet Metal Workers and Tinsmiths

Grinding Machine Operators

Lathe and Milling Machine Operators

Welders

Laborers

Chemical Process Operators and Handlers

Appendix C provides general guidance for the proper selection of eye and face protection to protect against hazards associated with the listed hazard "source" operations.

9.0 Selection Guidelines for Head Protection

All head protection (helmets) is designed to provide protection from impact and penetration hazards caused by falling objects. Head protection is also available which provides protection form electric shock and burn. When selecting head protection, knowledge of potential electrical hazards is important. Class helmets, in addition to impact and penetration resistance, provide electrical protection from low-voltage conductors (they are proof tested to 2,200 volts). Class B helmets, in addition to impact and penetration resistance, provides electrical protection from high-voltage conductors (they are proof tested to 20,000 volts). Class C helmets provide impact and penetration resistance (they are usually made of aluminum which conducts electricity), and should not be used around electrical hazards.

Where falling object hazards are present, helmets must be worn. Some examples include:

Working below other workers who are using tools and materials which could fall

Working around or under conveyor belts which are carrying parts or materials

Working below machinery or processes which might cause material or objects to fall

Working on exposed energized conductors

10.0 Selection Guidelines for Foot Protection

Safety shoes and boots which meet the ANSI Z41-1991 Standard provide both impact and compression protection. Where necessary, safety shoes can be obtained which provide puncture protection. In some work situations, metatarsal protection should be provided, and in other special situations electrical conductive or insulating safety shoes would be appropriate.

Safety shoes or boots with impact protection would be required for carrying or handling materials such as packages, objects, parts or heavy tools, which could be dropped; and for other activities where objects might fall onto the feet. Safety shoes or boots with compression protection would be required for work activities involving skid trucks (manual material handling carts) around bulk rolls (such as paper rolls) and around heavy pipes, all of which could potentially roll over an employee’s feet. Safety shoes or boots with puncture protection would be required where sharp objects such as nails, wire, tacks, screws, large staples, scrap metal etc., could be stepped on by employees causing a foot injury.

11.0 Selection Guidelines for Hand Protection

Gloves are often relied upon to prevent cuts, abrasions, burns and skin contact with chemicals that are capable of causing local or systemic effects following dermal exposure. OSHA is unaware of any gloves that provide protection against all potential hand hazards, and commonly available glove materials provide only limited protection against many chemicals. Therefore, it is important to select the most appropriate glove for a particular application and to determine how long it can be worn, and whether it can be reused.

It is also important to know the performance characteristics of gloves relative to the specific hazard anticipated; e.g., chemical hazards, cut hazards, flame hazards, etc. Using standard test procedures should assess these performance characteristics. Before purchasing gloves, the employer should request documentation from the manufacturer that the gloves meet the appropriate test standard(s) for the hazards(s) anticipated.

Other factors to be considered for glove selection in general include:

11.1 As long as the performance characteristics are acceptable, in certain circumstances. It may be more cost effective to regularly change cheaper gloves than to reuse more expensive types

11.2 The work activities of the employee should be studied to determine the degree of dexterity required, the duration, frequency, and degree of exposure of the hazard, and the physical stresses that will be applied.

With respect to selection of gloves for protection against chemical hazards:

11.3 The toxic properties of the chemical(s) must be determined; in particular, the ability of the chemical to cause local effects on the skin and/or to pass through the skin and cause systemic effects

11.4 Generally, any "chemical resistant" glove can be used for dry powders

11.5 For mixtures and formulated products (unless specific test data are available), a glove should be selected on the basis of the chemical component with the shortest breakthrough time, since it is possible for solvents to carry active ingredients through polymeric materials

11.6 Employees must be able to remove the gloves in such a manner as to prevent skin contamination.

12.0 Cleaning and Maintenance

It is important that all PPE be kept clean and properly maintained. Cleaning is particularly important for eye and face protection where dirty for fogged lenses could impair vision.

For the purposes of compliance with §1910.132 (a) and (b), PPE should be inspected, cleaned, and maintained at regular intervals so that the PPE provides the requisite protection.

It is also important to ensure that contaminated PPE, which cannot be decontaminated, is disposed of in a manner that protects employees from exposure to hazards.