“The hardest choices in life aren’t between what’s right and what’s wrong but between what’s right and what’s best.” — Jamie Ford
Most of the chemical plants I’ve ever worked in or visited required specific kinds of personal protective equipment (PPE). Usually, hard hats, safety shoes, and safety glasses with side shields were the minimum PPE required for entering a production area. It wasn’t head to toe, but it was head and toes.
Rarely was there any discussion of the type of PPE, which could easily lead someone to believe that there were no choices to consider. A hard hat is a hard hat. Safety shoes are safety shoes. And so on.
It’s not true. In addition to deciding what kind of PPE should be worn, safety professionals also need to make conscious choices about the type of PPE that is most appropriate. The wrong choices can render the PPE useless or even be dangerous.
The Basics: Hard Hat and Steel-Toed Shoes
Until the Covid-19 pandemic, when the facemask became the PPE most people thought of, the term PPE typically referred to what are technically known as industrial helmets and protective footwear. OSHA defines its expectations for PPE in Subpart I of 29 CFR 1910. Specifically, 29 CFR 1910.135 incorporates ANSI Z89.1 to address head protection and 29 CFR 1910.136 incorporates ASTM F2413 to address foot protection.
Most hard hats that I have ever encountered in the chemical process industries (CPI) are Type I, Class E hard hats. Is that appropriate? ANSI Z89.1 mentions several types of hard hats, which are different from bump caps. Hard hats can be Type I, which protect against top impact, or Type II, which protect against lateral impact as well as top impact. Class E hard hats provide protection through the hard hat against at least 20,000 volts. (E = Electrical). Class G hard hats provide protection against at least 2,200 volts. (G = General). Anything that is Class E is also Class G. Class C hard hats are conductive, typically of metal construction. (C = Conductive). Type I, Class E hard hats seem like a good choice for the CPI, although a case could be made for Type II.
Protective footwear also comes with a variety of features. All safety shoes must provide minimum impact resistance and minimum compression resistance to protect toes. This is provided by a protective cup built into the shoes, usually made of steel but not necessarily. Safety shoes can have other features as well, some mutually exclusive. Puncture resistant (PR) shoes protect the soles of the feet as well as the toes. Metatarsal (Mt) shoes protect the foot bones—metatarsals—as well as the toes. Safety shoes can also be designed to provide one of several mutually exclusive levels of electrical protection. They can be Conductive (Cd), meaning that there is less than 0.5 MΩ resistance through the shoe’s soles. Electrical Hazard (EH) shoes are electrically insulating, with more than 1,000 MΩ resistance through the soles of the shoe. Static Dissipative (SD) shoes fall in between, with at least 1 MΩ resistance but less than 100 MΩ resistance.
Obviously, there are choices to be made, and the wrong choice can be deadly.
Gloves and Chemical Suits
OSHA has a specific regulation for hand protection: 29 CFR 1910.138. There is a standard for hand protection, ANSI/ISEA 105, but OSHA does not incorporate it by reference. Instead, OSHA requires that gloves be selected to suit the job. Gloves can be used to protect hands against
- Skin absorption of harmful substances
- Severe cuts or lacerations
- Severe abrasions
- Chemical burns
- Thermal burns
- Harmful temperature extremes
There is no glove that can address all these hazards, so selection is very important. Even when the concern is skin absorption of harmful substances or chemical burns, no glove identified as “chemical resistant” is resistant to all chemicals.
Chemical suits are even more difficult to select than gloves, and OSHA has no regulation in Subpart I that is specific to “body protection”. There is a section in 29 CFR 1910.120, Hazardous Waste Operation and Emergency Response Standard (HazWOpER), that describes what HazMat suits at Levels A, B, C, and D should be able to do, but it does not tell users about the construction of chemical suits. The first thing to consider when selecting a chemical suit is the fabric and whether it is resistant to the specific chemical or chemicals of concern. No fabric is resistant to all chemicals.
The next to consider is how seams are constructed. Depending on the application, they might be
- Serged (stitched),
- Stitched and bound,
- Stitched and taped,
or seamed with a newer technology, like ultrasonic welding. The choice will be driven by whether the suit is intended to withstand exposure to light aerosols, airborne dusts, chemical sprays, or chemical jet sprays.
Finally, selection of a chemical suit must consider the form of the suit. In some cases, an apron may be sufficient. However, the application may require pants and jacket, pants and hooded jacket, overalls and jacket, overalls and hooded jacket, coveralls, or hooded coveralls. Moreover, the form of the suit may require accommodation of an air-supplying respirator.
There are a lot of considerations that should go into selecting a chemical suit; no one design, no matter what it is, will serve in all applications.
General PPE Requirements
When OSHA promulgated the regulations that comprise Subpart I, they addressed seven specific types of PPE:
- 29 CFR 1910.133 Eye and face protection
- 29 CFR 1910.134 Respiratory protection
- 29 CFR 1910.135 Head protection
- 29 CFR 1910.136 Foot protection
- 29 CFR 1910.137 Electrical protection
- 29 CFR 1910.138 Hand protection
- 29 CFR 1910.140 Personal fall protection systems
In many cases, these specific regulations incorporate an industrial standard by reference. In some cases, though, they don’t. In all cases, whether there is a regulation for a specific body part or not, all PPE is governed by 29 CFR 1910.132, General requirements.
The general requirements in Subpart I expect employers to carefully assess the hazards in their workplace and then select PPE accordingly. If there is no assessment or the wrong PPE is selected, it is a violation of the regulation. Likewise, when PPE is required, OSHA expects employers to train employees who must use it on the when, why, what, and how of that PPE. So, even something as simple as a hard hat requires training, if for no other reason than to explain the limitations of the PPE. For instance, Type I hardhats don’t protect against lateral impacts.
Do the Assessment and the Training
It may be that the PPE in use at your facility is completely appropriate. But it may be that it is not. Without a documented assessment of the hazards and corresponding documentation of the selection criteria and specification of the PPE, it would be difficult to demonstrate to anyone that it is. Likewise, even a documented assessment of the hazards and selection of the PPE is not a substitute for training employees on the use of that PPE. If the practice in your organization is limited to issuing employees PPE and reminding them relentlessly to wear it, that is not enough. Make sure that all employees are trained on the when, why, what, and how of that PPE.