Is PPE readily available to workers?

By: Ray Chishti

Publication: Construction Regulatory Alert

Date Posted: 07/06/2020

OSHA’s Personal Protective and Lifesaving Equipment Standard, 1926.95, requires companies to provide workers with personal protective equipment (PPE) when their exposure to a hazard may injure or impair any part of their body. Evaluate the project for hazards, and determine what PPE is necessary to protect workers.

PPE needs to be readily available at the job site for workers to use. Here are questions that job sites should answer to determine if PPE is readily available onsite:

  • Is there enough PPE onsite for every worker?
  • Do the job site's vendors have enough PPE in stock?
  • Do workers have access to the correct size of PPE?

Readily available doesn’t mean that job sites need to provide PPE to their workers within 3-5 minutes, like with first-aid supplies. It also doesn’t mean that PPE needs to be available to workers within 55 seconds, like with an eyewash station when they’re using corrosive materials. PPE should be available for workers to use before they can become exposed to a hazard. If control methods aren’t effective in protecting workers, PPE will then be needed.

Is there an adequate stock of PPE?

Maintaining an adequate supply of PPE can be challenging for a project because it must balance supply and demand with workforce changes. Depending on what phase the project is in, workers could be hired, or their employment can be terminated suddenly. It’s inefficient to use a shipping container on-site to store PPE. Stuffing the crew’s toolboxes with PPE isn’t practical either. Buying PPE from the local hardware store is expensive because the project probably isn’t taking advantage of volume discounts. There is a better choice for contractors to use while managing and storing their PPE on the project.

Jobsites should instead consider using vending systems that allow the project to pay for PPE as workers need it. With this choice, a vending machine is placed inside a centralized office or garage. For larger projects, many suppliers have a semitrailer that they can park on the project. The job site is only charged for PPE that is used. This prevents worries about enough PPE being available. Also, using a vending system allows PPE to be tracked. This can help to reduce PPE theft and misuse. If workers know that their PPE usage is being checked, they may take better care of it.

Are supply chains able to keep PPE in stock?

Unless there’s a unique situation, like with the recent pandemic, suppliers should be able to keep common types of PPE in stock. Forecast the job site's PPE needs, and make sure vendors can supply the project with what it needs.

Recently, with the N95 shortage in the U.S., OSHA published PPE guidance for employers, saying that it’s more effective to use a foreign-certified respirator, rather than using a homemade mask, bandanna, or surgical mask. For instance, KN95 masks certified using Chinese standards would be acceptable for workers to use while there is an N95 shortage. The reason OSHA is allowing this is because the Chinese certification standard offers similar certification scrutiny that the National Institute of Occupational Safety and Health follows when certifying respirators made in the U.S. OSHA also lists several other countries that have acceptable respirator certification standards that employers can use respirators from.

Jobsites should keep a line of communication open with their vendors so they can be notified about supply-chain issues quickly. Apart from U.S. related impacts to the supply chain, current affairs overseas can also influence PPE’s availability.

Do workers have access to the correct size of PPE?

PPE isn’t one-size-fits-all. Jobsites may need to place a special order for uncommon sizes, like extra small. For some PPE, like fall protection systems, there’s a load rating that workers must not exceed. For example, a regular body harness has a load limit of 250 pounds. Workers that need a larger limit will need to have a special harness ordered for them.

Standardized PPE sizes don’t guarantee workers a snug fit either. They will need to choose between sizes that are either smaller or larger than their actual size. Most PPE is designed to accommodate people within the 5th to 95th size percentile. This range covers the 5th percentile female to the 95th percentile male. Manufacturers assume if their product fits 5 percent of the smallest women, and 95 percent of the largest men, their PPE size ranges will fit most of the average population. This is the main reason extra small and extra-large sizes are a special order.

Key to remember: PPE needs to be readily available for workers to use. Projects should keep a line of communication open with their vendors, so they can stay ahead of supply-chain issues.

About the author
Ray Chishti - EH&S Editor

Ray is an editor at J. J. Keller & Associates, Inc. and has over 12 years of EH&S experience in a variety of industries, including EPC projects, fossil fuel power plants, gas distribution and transmission, and electrical transmission work.

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