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Manufacturing Best Practices Editors

For the manufacturing work force, selecting and requiring the use of personal protective equipment (PPE) is one of the most important elements of assuring a safe and healthful work environment. What PPE to wear, who pays for it and how to determine which is the right PPE to protect against a known hazard in the workplace are all critically important issues, both from the perspective of an employee’s personal safety and an employer’s freedom from allegations of non-compliance. Eliminating the guesswork and ensuring compliance in this area just became a bit easier, as on Feb. 15, 2011, the Occupational Safety and Health Administration (OSHA) issued a revised directive that provides enforcement guidance on determining whether employers have complied with OSHA’s PPE standards. The Enforcement Guidance for Personal Protective Equipment in General Industry, CPL 02-01-050, is the latest word from OSHA on PPE, and is a must read for employers and employees alike.

Significant Standards

Over the years, OSHA has issued several significant standards and rules pertinent to employee PPE. These standards have understandably evolved to keep pace with scientific advances in detecting and eliminating workplace hazards and significant developments in the type of materials and fabrics that can be used to abate hazards, as well as the range of respiratory protection and personal protection tools.

PPE has become more sophisticated as a result of these advances and the scope of the standards’ reach has expanded over time.

The general industry standards for PPE were revised in 1994 when OSHA added provisions that required employers to select appropriate PPE based on the nature of the hazard present, or likely to be present, in the workplace, to prohibit the use of damaged or defective PPE in the workplace, and to require that employees be trained so that they use appropriate PPE properly.

Previous Updates

In 2007, OSHA issued a rule requiring employers in general industry, shipyard employment, longshoring, marine terminals and construction to pay for most types of required PPE. Two years later in 2009, OSHA issued a final rule to revise the PPE standards based on national consensus standards regarding requirements for eye- and face-protective devices, head protection and foot protection.

Given these significant changes and enhancements, OSHA prepared new enforcement guidance to support OSHA’s efforts in general industry employment.

The new guidance replaces In­spection Guidelines for 29 CFR 1910 Subpart I, the Revised Personal Pro­tective Equipment Standards for General Industry, issued in June 1995, and reflects the changes set forth in the 2007 and 2009 rules noted above. The new guidance became effective on Feb. 10, 2011.

Key Changes

Among the most significant changes in the new guidance include the six following areas. First, the guidance clarifies what type of PPE employers must provide at no cost to workers and when em­ployers are required to pay for PPE, in­cluding respirators, personal fall protection, hearing protection, hard hats, fire firefighting equipment and meta­tarsal protective footwear.

The new guidance also clarifies when employers are not required to pay for PPE. OSHA’s guidance contains a de­tailed list of PPE items that an employer is required to provide at no cost to employees under the PPE payment rule in complying with an OSHA standard. OSHA explains that the list notes that it is not intended to be exhaustive.

Second, the directive clarifies the PPE payment requirements for PPE worn off the job, what PPE must remain at the job site, and provides guidance for employee-owned PPE. The guidance provides a list of examples of PPE and other items exempted from the employer payment re­­quirements. The list includes, for example, travel time and related expenses for employees to shop for PPE and clothing items worn to keep employees clean for purposes unrelated to safety or health (denim coveralls, aprons and related items).

Third, the guidance sets forth enforcement policies that reflect court and Review Commission decisions concerning PPE. Contained at Appendix A is a useful chart that lists, by standard number and date, a summary description of all interpretation letters that address 29 C.F.R. Sections 1910.132-.138.

Another chart lists each OSHA standard that requires PPE. The chart is presented in a useful web-based format that links to the interpretation letters and related enforcement and compliance information.

Four, the guidance provides information that allows employers to use PPE selected in accordance with the most recent national consensus standards. This information is especially useful for employers as sometimes it is difficult to select the most appropriate PPE for a workplace hazard given the number and diversity of national consensus standards available.

Fifth, OSHA amended the provision that requires safety shoes to comply with a specific American National Standards Institute (ANSI) standard. Now employers may select footwear that is at least as effective as footwear that is constructed in accordance with ANSI standards.

Finally, the guidance provides a useful reference to the citation policy for PPE payment, including a question and answer component. 

A typical question and answer is:  “Are employers required to pay for lineman belts and hooks when used to comply with an OSHA standard? Yes. Lineman belts and hooks provide protection to employees from falls while climbing and/or performing work. This equipment is considered PPE and employers must pay for it when used to comply with an OSHA standard.”

Be In The Know

According to OSHA, the new guidance is important for a number of other, more general reasons. The guidance supports the U.S. Department of Labor’s National Strategic Plan Outcome Goal 3A for increased emphasis on reducing workplace injuries, illness and fatalities. The guidance provides OSHA compliance officers and interested others in the government and private sectors with valuable information about PPE selection and guidance useful to prevent injury to workers. 

The guidance also supports the Site-Specific Targeting (SST) program for general industry employment and it provides available general industry PPE safety and health information in a web-based format with electronic links to related information.

The new directive is well-written, de­tailed, useful and clear. Employers will find review of this document is essential to ensure compliance with standards addressing PPE. 

In that the document instructs the agency’s enforcement personnel on both OSHA’s interpretations of those standards and the procedures for enforcing them, a manufacturer’s thorough review of the guidance is the best protection against allegations of non-compliance and thus potential penalties and other enforcement implications. 

It also is important to note that em­ployees will be sure to read the directive to ensure they know what their rights, duties and obligations are — another reason why employers are well-advised to be in the know on this important new en­forcement directive.

OSHA does not release new enforcement guidance all that often. When it does, it generally signals the agency is primed and ready to go in citing employers for behaviors that fall below OSHA’s clear expectations and enforcement standards. 

Accordingly, manufacturers should take some time to review this new directive and be well-situated to be in compliance with the law. Do so, and you’ll be comforted that your employees are protected from workplace hazards.

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