Personal Protective Equipment (PPE) Hazard Assessment Instructions This document provides guidance on completing a PPE hazard assessment. It includes the process for identifying hazards and PPE for the eyes, face, head, hands, feet, torso, respiratory system, and hearing. Personal protective equipment is the least effective hazard control. If possible PPE should be used in conjunction with other controls such as substitution to a lesser hazardous substance, engineering controls, warnings, and administrative controls. Based on the hierarchy of controls, PPE is a last resort. The Occupational Safety and Health Administration (OSHA) requires that a hazard assessment be conducted of workplaces (laboratories) to identify hazards and how to control those hazards. Potential hazards may be physical or health-related. A comprehensive hazard assessment should identify hazards in both categories. Examples of physical hazards include moving objects, fluctuating temperatures, high intensity lighting, rolling or pinching objects, electrical connections, sharp edges, etc. Examples of health hazards include overexposure to harmful dusts, chemicals, radiation, etc. There are two pages to the University of Notre Dame’s PPE Hazard Assessment, which is available on the RMS web site at this link. The first page documents the hazards while the second provides the PPE requirements. Once completed, the second form must be signed by the individual completing the PPE hazard assessment. This is to satisfy the OSHA Standard, 29 CFR 1910.132 Subpart I‐ Personal Protective Equipment. When completing the assessment, if necessary contact Risk Management and Safety (RMS) at 631-5037 if you have any questions regarding the process, identifying hazards or the proper PPE. Completed assessments must be accessible to employees and inspectors (RMS or regulatory agency). General Guidelines The PPE hazard assessment can be conducted for an area, a specific task, or specific hazard. The assessment must be updated when changes occur that may affect the PPE requirements. In addition to completing the PPE hazard assessment, it is also a requirement to: • Identify and provide appropriate PPE for workers • Train workers in the use and care of the PPE • Maintain PPE, including replacing worn or damaged PPE • Periodically review, update and evaluate the effectiveness of the PPE program Page 1 of 6 The first page of the PPE hazard assessment identifies the types of hazards and what body part could potentially be affected by those hazards. When reviewing the remainder of these instructions, you will note circles with numbers. These will be used as reference guides in this document and are not on the working forms. Figure 1 Page 2 of 6 PPE HAZARD ASSESSMENT INSTRUCTIONS STEP 1: Inform Affected Employees of the Process Affected personnel from the work area/lab that is being assessed should be involved in the process. Discuss the reasons for the survey and how the assessment will be conducted. Inform them that the review will include applicable procedures, a walkthrough of the area/lab to identify potential hazards and a discussion on the PPE currently in use, to determine if it is appropriate. Step 2: Review Relevant Safety Alerts for Information Reports of work‐related injuries or illnesses, near‐miss events and reported safety concerns are sources of data that can provide helpful information for assessing hazards. A number of safety alerts are available on the Risk Management and Safety web site at this link. Step 3: Conduct a Walkthrough Survey The purpose of the walkthrough is to identify sources of hazards to employees. Observe the workplace for the: • Layout of the workplace • Location of the employees • Work operations • Hazards • Places where PPE is currently used including the device and reason for use Using the PPE Hazard Assessment form on page 1, identify the type of hazard(s) present and associate the hazard by body part. Consideration should be given to the following basic hazard categories: • • • • Physical Hazards – Mechanical, Thermal, Radiation, Electrical Chemical Hazards – Particulate, Liquids, Gases Biological – Bacteria, Viruses, Fungi, Parasites, Human Tissues or Body Fluids Other – Hazards Not Identified on the Worksheet Complete the first page of the form by entering: • The laboratory by Building and room number • The PI responsible for the lab • Providing a description of the task, hazard or area as appropriate • The name of the person completing the assessment Place a checkmark (√) in the column with the identified hazard and the row identifying which body part(s) could be affected by the hazard. Each body part has been identified with a number 1 in this training document (See Figure 1 and 2). The circled number corresponds to a section on page 2 of the PPE Hazard Assessment to assist Page 3 of 6 in the use of this training information (See Figure 3). If there is a hazard affecting the eyes 1 identify PPE for the eyes 1 on page 2. Identify all the body parts that could credibly be affected by the hazard. Example During the walkthrough it is noted that liquid nitrogen must be transferred from a large container to a smaller one. There is a potential splash hazard from the nitrogen during transfer resulting in a thermal cold contact hazard. On the first page of the PPE Hazard Assessment: 1. Identify the appropriate hazard in the columns. For this example it would be: • PhysicalThermalCold • Chemical LiquidSplashes, Sprays 2. Place a check mark in the column for the hazards corresponding to the body part that the Chemical LiquidSplashes, Sprays and the PhysicalThermalCold could credibly impact. For this example the liquid nitrogen could splash and have a thermal impact on the following body parts: • Eyes • Face • Hands/Fingers • Whole Body / Torso • Legs and feet Figure 2 Page 4 of 6 Step 4: Select PPE After considering and planning for other controls from the list of the hierarchy of controls select the PPE which provides at least the minimum level of protection required to protect employees from the hazards. Engineering Controls may alleviate some PPE requirements. Using page 2 of the PPE Hazard Assessment form (Figure 3), place a checkmark (√) in the appropriate body part section identifying the appropriate PPE. For help with proper PPE selection, consult the CHP, the glove compatibility chart on the RMS web site or other internet resources, contact Unit/Department Safety Coordinator, or contact RMS at 1-5037. Example – Refer to Figure 3 Continuing with the example of transferring liquid nitrogen, we noted that there are hazards affecting four (4) body parts. PPE should be identified for these body parts as noted below: • Eyes – Chemical googles should be selected and used because safety glasses do not provide adequate protection from chemical splashes. • Face – A face shield should also be selected due to the hazard being to the entire face. Please note that face shields are considered secondary protection and chemical googles must be used with the face shield when there is a chemical splash hazard. • Hands/Fingers – Thermal cold contact is the concern in this example so a thermal cryogenic glove should be used. • Whole Body/Torso – The splash could credibly impact the torso so a standard lab coat is required. • A splash could credibly impact the foot or leg, additional protection is not necessary if the minimum PPE as describe in the CHP is worn. This includes: closed-toed / heeled shoes with a substantial sole as well as ankle length pants or with fabric similar to denim or twill. Finally the bottom of page 2 requires a signature and date of the person completing the PPE Hazard Assessment. This is a regulatory requirement. Step 5: Document Accessibility and Communication Once the PPE hazard assessment(s) are completed and signed/dated, store them either electronically or as a hard copy in a location easily accessible to students, lab workers, and inspectors. Ensure that affected laboratory personnel are made aware of the required PPE and sign a PPE certification form. This form is available on the RMS web site this link. Page 5 of 6 Step 6: Revise Protocols If the PPE hazard assessment identifies different PPE requirements, update the appropriate lab protocols with this information. Step 7: Reassess the workplace as necessary. The PPE Hazard Assessment is required to be updated when the hazards change through new/modified experiments or processes or where there were injuries with inadequate PPE noted. The PPE hazard assessment should be periodically reviewed to ensure accuracy. Figure 3 Signature and Date Required by OSHA Page 6 of 6
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