More on PPE

E. Lessard

October 25, 2997

PPE General Issues Observed by the Lab ESH Committee

• Information on PPE is contained in SBMS, 29 CFR 1910 and its referenced standards, and takes time to locate

• PPE for cryogenic safety is not the same for the same level of hazard throughout the lab

• Some small volume users want BNL to consider Leidenfrost Effect, no gloves, short-sleeved shirts, safety glasses only

SBMS Rules for Cryogenic Liquids

• 1.4 Transferring and Handling• Step 1 … Eye protection must be used whenever handling or

transferring cryogenics: Full-face shield, in combination with splash goggles or safety glasses with side shields, should be used when transferring liquids to an open container.

• All parts of the body must be protected from uninsulated pipes or vessels containing cryogenic liquids…

• Tongs must always be used to withdraw objects immersed in liquid.

SBMS Rules for Cryogenic Liquids

• 1.4 Transferring and Handling• Step 3 Wear gloves when handling objects that are in contact with

cryogenic liquid. Gloves should be designed to provide protection from cryogens …

• Gloves should either be designed to prevent cryogens from flowing into the glove, or be loose fitting so the glove can be easily be shaken off in accidental contact with cryogens

• Note: When handling liquids in open containers, it is advisable to wear high-top shoes. Trousers (which should be cuffless, if possible) should be worn outside the shoes.

OSHA Requirements

• For handling cryogenic liquids, OSHA requires CGA rules in Pamphlet P-1-OSHA (29 CFR 1910.101(b)):– Wear hand protection such as insulated gloves

• Gloves should be loose fitting

– Wear eye protection such as face shield plus safety glasses or safety goggles

– Wear long sleeve shirt– Wear cuffless trousers over (outside) high topped

shoes

Does OSHA require BNL to provide PPE for employees? Yes.

• BNL must provide PPE for eyes, face, head and extremities, protective clothing, respiratory devices, and protective shields and barriers wherever the hazards in your workplace require them

• 29 CFR 1910.132(a), (c)

Must BNL employees use PPEwhen necessary? Yes.

• When mandated by workplace conditions, employees must use PPE

• 29 CFR 1910.132(a)– This OSHA requirement is deliberately vague and consequently

broad– Many specific work practices, such as welding, managing waste,

cryogenic handling and chemical handling require specific PPE use

– Although the need for PPE in a given situation is usually clear, the sophistication of the necessary equipment can vary greatly

How does one select appropriate PPE for the workplace?

• OSHA regulations require each employer to do the following:– assess the workplace to determine if hazards are present, or are

likely to be present– select PPE that will protect employees from the hazards in the

workplace– select PPE that properly fits each affected employee– communicate PPE selections to each employee– ensure that affected employees use the PPE that has been

provided

• 29 CFR 1910.132(c)

Has BNL certified a workplace PPE assessment? Not sure.

• OSHA regulations require you to produce a written certification that verifies your workplace hazard assessment

• This certification must do the following:– identify the workplace– identify the person who certifies that the evaluation was performed– give the date of the hazard assessment– identify the document as a certification of hazard assessment

• Note: This written document certifies only that you have performed the hazard assessment. It need not include any portion of the hazard assessment.

• 29 CFR 1910.132(d)

Must BNL train employees about PPE use? Yes.

• BNL must provide training to each employee required by OSHA regulations to use PPE

• BNL must train each affected employee to know at least the following:– 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

Must BNL test employees before allowing work with PPE? Yes.

• Before BNL allows affected employees to perform work requiring the use of PPE, each worker must demonstrate an understanding of the training, as well as the ability to use PPE properly

• Note: OSHA regulations do not stipulate the form of this demonstration

• 29 CFR 1910.132(f)(2)

What if an employee fails the test?

• If BNL believes that an employee who has received training does not have the understanding and skill required to safely use PPE, then BNL must retrain that employee

• 29 CFR 1910.132(f)(3)

When must BNL retrain employees?

• Circumstances where retraining is required include, but are not limited to, the following situations:– changes in the workplace render previous training obsolete– BNL introduces new types of PPE to the workplace– inadequacies in an employee’s knowledge or use of PPE

indicate that an employee does not understand its use

• 29 CFR 1910.132(f)(3)• There is no specific refresher training for PPE use;

however, many other training requirements address PPE use (e.g., HAZWOPER) and specify annual refresher training

Has BNL certified its PPE training program? Not sure.

• OSHA regulations require BNL to produce a written certification that verifies that BNL has provided each affected employee with PPE training, and that the employee understands the training

• This certification must include the following:– name of each employee trained– the date(s) of the training– identification of the training subjects

• 29 CFR 1910.132(f)(4)

Do special provisions apply to electrical and respiratory protection? Yes.

• OSHA regulations include special workplace safety assessments and worker training requirements for respiratory and electrical hazards

• 29 CFR 1910.132(g)