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PPE Hazard Assessment & Employee Involvement Alyssa Duncan CSP, OHST Jayhawk Gas Plant [email protected] Agenda • • • • • • Introduction Review of PPE Standard Review of Training Requirements How To: ABC’s of PPE Hazard Assessment PPE Hazard Assessment Examples Discussion PPE & Worker Protection Personal Protective Equipment PPE comes in at third place in OSHA’s Hierarchy of means to protect workers. “Eliminate Control and Protect” PPE is the Last Line of Defense The OSHA Standard: 1910.132(a) Protective Equipment 1910.132(a) Application. Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact. The OSHA Standard: 1910.132(b), (c) Employer Responsibility, Design • 1910.132(b) Employee-owned equipment. Where employees provide their own protective equipment the employer shall be responsible to assure its adequacy, including proper maintenance, and sanitation of such equipment. 1910.132(c) Design. All personal protective equipment shall be of safe design and construction for the work to be performed. OSHA Standard: 1910.132(d) Hazard assessment and equipment selection. 1910.132(d)(1) The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). OSHA Standard: 1910.132(d) Hazard assessment and equipment selection. • If such hazards are present, or likely to be present, the employer shall: • 1910.132(d)(1)(i) Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment; OSHA Standard: 1910.132(d) Hazard assessment and equipment selection. 1910.132(d)(1)(ii) Communicate selection decisions to each affected employee; and, 1910.132(d)(1)(iii) Select PPE that properly fits each affected employee. Note: Non-mandatory Appendix B contains an example of procedures that would comply with the requirement for a hazard assessment. 1910.132(d) Hazard assessment and equipment selection 1910.132(d)(2) The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment. What if OSHA Asks? Demonstrate Compliance OSHA Standard: 1910.132(e) Hazard assessment and equipment selection. 1910.132(e) Defective and damaged equipment. Defective or damaged personal protective equipment shall not be used. OSHA Standard: 1910.132(f)(1) Training 1910.132(f)(1) The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following: 1910.132(f)(1)(i) When PPE is necessary; 1910.132(f)(1)(ii) What PPE is necessary; 1910.132(f)(1)(iii) How to properly don, doff, adjust, and wear PPE; 1910.132(f)(1)(iv) The limitations of the PPE; and, 1910.132(f)(1)(v) The proper care, maintenance, useful life and disposal of the PPE. 1910.132(f)(2) Training 1910.132(f)(2) Each affected employee shall demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE. 1910.132(f)(3) Training 1910.132(f)(3) When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (f)(2) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where: 1910.132(f)(3) Training 1910.132(f)(3)(i) Changes in the workplace render previous training obsolete; or 1910.132(f)(3)(ii) Changes in the types of PPE to be used render previous training obsolete; or 1910.132(f)(3)(iii) Inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill. 1910.132(3)(f)(4) Training 1910.132(f)(4) The employer shall verify that each affected employee has received and understood the required training through a written certification that contains the name of each employee trained, the date(s) of training, and that identifies the subject of the certification. PPE Hazard Assessment Examples http://nasupplierhsse.bpglobal.com PPE Selection • Based on the task performed • Based on hazards present • Physical state – gas, liquid, solid • Concentration Where do I get this information? • Material Safety Data Sheet? – List of constituents and composition – “Wear gloves.” “Wear respiratory protection.” • Websites – Ansell Edmont (glove example); 3M respiratory protection • Take field measurements of concentrations Example Condensate, NGL, Produced Water, Rich Glycol SOURCE OF EXPOSURE / ACTIVITY Tank cleaning, piping replacement, gauging Benzene [Skin] HAZARD (0.5 ppm BP 8-hr TWA, 2.5 ppm BP STEL; 1 ppm OSHA 8-hr TWA, 5 ppm STEL 1910.1028) ["Skin" denotes hazards that can be absorbed through the skin.] CONCENTRATION / ROUTE OF ENTRY Less than 0.5 ppm 0.5 - 50.0 ppm No respiratory Full-facepiece protection respirator + organic 1910.134(d)(3)(i)(A) Assigned Protection Factor: Full facepiece air purifying - 50 required. vapor cartridge CONTROL MEASURES Greater than 50.0 ppm Clothing / gloves Supplied air respirator/SCBA Nitrile, viton, neoprene gloves Task: operation of equipment pump trucks • Diesel engines Midday: diesel particulates not highly visible despite multiple operating engines Early a.m. diesel emission cloud visible above work area due to Tyndall effect from stationary lighting sources Task: Chemical truck operator • Chemicals contained in plastic carboys, direct connections made to blender truck via mixing manifold. Workers well protected, dermal, respiratory protection used appropriately, work operations occur in open area. How To: PPE Hazard Assessment Basics Make a list: A Simple Spreadsheet will work • List the different types of tasks: – Use JSA’s, Incidents, Near Misses, Industry Data • • • • • • • List the potential hazards within the tasks List the PPE needed to help protect Research the specific PPE needed Involve the employees performing the work Add a certification and date Most effective are Craft Specific Make it a living document and Post it – Use it to develop better JSA’s – Continually Improve the list – Use it for training Bringing On/Shutting In a Well Checking Separator Sight Glass Repair/Replacing Dump Valve Lighting a Reboiler Working on a Chemical Pump Changing Glycol Filters Starting a Compressor Conducting Compressor Maintenance Shutting Electrical Breaker Loading/Unloading Chemicals Transferring Chemicals Rigging Slings Using Electrical/Air Driven Tools Housekeeping Spill Cleanup Basic Workover Operations Gauging a Tank Meter Testing Plate Inspection Well Testing Choke Change Replacing Rupture Disc Loading/Unloading Pipe Climbing Ladder Handling NORM Material Chemical Storage Area Basic Drilling Operations Hard Hat Safety Glasses X X X Steel Toed Boots Hearing Protection Rubber Gloves Cotton Gloves Leather Gloves Splash Apron Face Shield X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Kevlar Sleeves Ground Fault Interrupters Respirator FRC X X X X X X X X X X X X X X X X X X X X X X X X X X X X LOTO Equipment X X X X X X X X X X X X Safety Harness X X X X Goggles X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Note: Not all Personal Protective Equipment will be required if a hazard assessment was conducted and it identifies that certain hazards are not present. The PPE associated with the non-present hazard may not be utilized. X X X X X X X X X X X X X X X X X X X X X HAZARD ASSESSMENT/CERTIFICATION FORM FOR PERSONAL PROTECTIVE EQUIPMENT (PPE) ___________________________________________________ Installation (Operation Center Facility) Source of Hazard to Employees (Operation) Assessment of Hazard (Agent) ____________ Date Head Protection Hand Protection IMPACT: Grinding, chipping, chiseling, sawing. Flying fragments, objects, large chips, slag, PENETRATION: Glass, hand tools, metal rods, board road nails, etc. Objects with the potential to penetrate the hands or feet. Material/Equipment handling, compression, etc. Objects falling, dropping, or rolling. CHEMICAL: Acid, caustic, and other chemical handling, contact with chemical handling equipment, etc. Splash, spray, coating on surface of equipment. Hard-hats meeting ANSI Z89.1 - 1986. Goggles, eyecup and cover type. Inhalation, ingestion, skin contact, systemic effects, and birth defects. For spray or overhead chemical handling a slicker with hood is recommended. Use of face shield and goggles is required when handling open containers and/or splash potential exists. Refer to MSDS for specific material requirements of gloves that must be used. Safety glasses with side shields at all times. Insulated gloves, designed for heat. HEAT: Boiler operations steam equipment, hot crude oil/water, production, fired heater equipment, reboilers and piping, welding, etc. Hot sparks contact with high temperature equipment. Contact with high temperature fluids. Hard-hats meeting ANSI Z89.1 - 1986. Eye & Face Protection __________________________________________ Signature (Individual certifying evaluation) General (blowing dust, loose particles) - Safety glasses w/side shields (Z87.1) Grinding/chipping etc. Safety glasses with side shields and a full face shield are required. Hard-hats meeting ANSI Z89.1 - 1986. Raised temperature operations - Face shields, goggles/ spectacles with side shields. (Operations involving heat may also involve light radiation) For light work a cotton or canvas glove. Rough or abrasive material requires leather or leather reinforced metal stitching. Gloves should be selected based on the type of chemicals used. Foot Protection Metatarsal foot guards where compression and material handling may warrant guards. Footwear that provides puncture protection. Incidental contact - Work shoes or boots that provide a continuous barrier against absorption (no holes/reactive synthetics) Prolonged/significant quantity contact - Rubber boots. Non-synthetic material that maintains a continuous barrier against absorption (no holes). Approver: Duane Allman, President Document owner: Barry Oakley Management Statement: My Company is committed to following the OSHA General Duty Clause, protecting our employees from recognized hazards. The PPE Hazard assessment is designed to not only list recognized hazards in our operations, but to give each employee an opportunity to provide input as new or potential hazards are recognized. Due to our diverse business, a separate PPE Hazard Analysis worksheet will be completed for separate types of work we do. My Company JSA program is always to be used for recognizing and mitigating hazards encountered in daily operations at work sites. The PPE Hazard assessment is similar to JSA, but is a more formal way to capture hazards, and proposed changes will be reviewed by the HSE committee at regular meetings, with accepted changes formally added as decided by committee with management approval. PPE identified on the Hazard Assessment will be provided and included in the My Company training program. My Company management encourages employee involvement and participation. Definitions: PPE: Personal Protective equipment. A device designed to protect a specific body part from a known or potential hazard. Hazard: Something which if not eliminated or controlled would potentially cause harm to people or damage to the environment. Energy examples include: Gravity, Chemical, Thermal, Pressure, Biological, Motion, Radiation & Electrical Type of work: Job task Hazard Energy Reviewed by: __________________ Date: __________ Revised: ______________ Approved by: ________________ Signed: _____________ Date:________ Body Part PPE Employee Involvement Recap • Part 1 – – – – Review JSA’s Give them a checklist to fill out for a week Bring back ‘stuff’ from the VPPPA Conference Don’t just observe, talk, talk, talk! • Part 2 – Consider reviewing the hazard assessment & annual training & inspection at the same time – Review the final hazard assessment before certification • Part 3 – Post PPE Hazard Assessment – Highlighter Idea Discussion What do you do? What do you think you might try?