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When should you implement a personal protective equipment (PPE) policy?

When should you implement a personal protective equipment (PPE) policy?

Yosie Saint-Cyr LLB, Managing Editor, HRinfodesk, published by First Reference, December 2014

Personal protective equipment (PPE) is equipment worn by a worker to minimize exposure to specific occupational hazards, i.e., respirators, gloves, aprons, fall protection, and full body suits, as well as head, eye and foot protection. However, it is not easy to understand when PPE should be implemented.

According to a recent HRinfodesk poll, out of 230 respondents 153 (67%) agreed that it was to minimize exposure to serious workplace injuries and illnesses. Another 53 (23%) believe it is when a hazard is identified, while 20 (9%) stated it should be implemented anytime you want regardless of an existence of a hazard or serious workplace injuries and illnesses.

What does the law require?

While the practice of wearing PPE is regularly used for certain trades (i.e., construction), legal requirements for PPE are included in various degrees and appropriate sections of Occupational Health and Safety legislation or Regulations across Canada as a measure to prevent or minimize exposure to specific occupational hazards. These PPEs are required and should be part of an occupational health and safety program.

For example, in Ontario, sections 25 and 27 of the OHSA makes employers and supervisors responsible for ensuring that required PPE is worn by the worker. The employer must also provide the PPE and maintain it in good condition. Under section 28 of the Act, workers have a duty to wear or use the PPE required by law as well as any PPE required by the employer. The construction regulation broadly requires that such protective clothing, equipment, or devices be worn “as are necessary to protect the worker against the hazards to which the worker may be exposed.” It also requires that the worker be trained in the use and care of this equipment.

In addition, PPE also varies according to individual, jobs and worksite.

Moreover, personal protective equipment acts as a barrier to guard workers against hazards such as blows to the body, loud noise, heat, chemicals and infection. Personal protective equipment includes protective clothing, helmets, shoes, goggles, respirators and other safety gear worn by workers

According to the Canadian Centre for Occupational Health and Safety, when hazards have been identified in the workplace, these hazards should be eliminated, controlled at the source or reduced through administrative measures. When all other methods are either not available or impossible to implement, personal protective equipment (PPE), the last level of protection, may be used so that work can continue safely.

PPE should be used:

  • when no other control method is possible;
  • while other controls are being installed or implemented;
  • for emergencies and during maintenance activities;
  • for situations where other control methods don't provide enough protection.

What does this mean?

PPE does not remove or reduce workplace hazards and does not replace effective engineering or administrative control methods such as substitution or ventilation. PPE is the last line of defense when the hazard cannot be removed or controlled adequately. Proper selection, use and care of the equipment are vital to provide the proper level of protection. A health and safety program should state the standards the company wants to meet in the use of PPE, as well as the legislative requirements it needs to meet.

Many occupational health and safety legislative standards require employers to provide PPE to their employees or to ensure the use of such equipment. Some standards indicate in broad performance terms when PPE is to be used, and what is to be used.

It is important for employers to know who must provide and pay for workers' personal protection equipment. In general, health and safety legislation, regulations and standards that require PPE state that the employer is to provide the equipment. However, these provisions do not always specify that the employer must provide such PPE at no cost to the employee. Only some jurisdictions specify that the employer must pay for this equipment; however, the health and safety legislation of all jurisdictions require employers to ensure that workers wear and use personal protection equipment when required by law. Most jurisdictions also require employers to provide all or at least some kinds of protective equipment in certain circumstances (for instance, where noise exposure limits are exceeded).

In addition, the rule does not require employers to provide PPE where none has been required before. Instead, the rule merely stipulates that the employer must pay for required PPE, except in the limited cases specified in the standard.

British Columbia, Manitoba, Quebec, Saskatchewan and Yukon spell out who must pay for which kind of PPE. The other nine jurisdictions don't specify who pays for the equipment. Employers are recommended to review the requirements in their specific jurisdictions to ensure that they are protecting their workers appropriately. Employers can consult our PPE quick reference chart via the link at the bottom of the article.

Notwithstanding the above, here are certain elements employers need to consider:

  • The employer must provide equipment, materials and protective devices required by law
  • The employer must make sure that the PPE is used as prescribed
  • If the company pays for the PPE, it belongs to the company and employees may not be allowed to take these items home or anywhere else not approved by the company
  • All PPE provided by the company must meet proper safety codes and standards
  • The employer must also ensure the PPE is maintained in good condition
  • If employees supply their own equipment, the company is still responsible for ensuring all equipment meets safety codes

To know which protective equipment you need in your workplace, you first need to identify and assess the hazards that come with a particular job or work process. You need to determine the:

  • Source of the hazard
  • Nature of the hazard (physical, biological or chemical)
  • Duration of exposure to the hazard-long-term versus short-term
  • Exposure level of the hazard

Where a hazard is identified, try to control that hazard at the source or between the source and the worker. If engineering controls are neither feasible nor result in completely eliminating the hazard, PPE must be used. Before turning to PPE, consider the following:

  • Eliminate the hazard through engineering controls at the source-this could mean modifying or replacing equipment
  • Substitute hazardous materials or substances with less- or non-hazardous alternatives
  • Redesign the work process-e.g., modify the sequence of tasks to improve safety
  • Isolate the hazardous agent-e.g., use a designated room or local ventilation
  • Develop administrative controls-e.g., limit the time an employee is exposed to the hazard

Consider steps taken by workers and supervisors in doing the job to identify hazards that require PPE, procedures for selection and fitting, maintenance, storage, monitoring use and training.

Criteria for choosing PPE should be that they:

  • Provide adequate protection for the worker
  • Comply with applicable laws and regulations
  • Meet company standards
  • Not cause undue discomfort and don't create new hazards

You should also consider the:

  • Nature and size of the hazard
  • Degree of protection the PPE will provide
  • Ease of use of the PPE and how well the worker will accept using the PPE

Employees using personal protective equipment should receive appropriate training on its use and maintenance, as well as any legislative requirements that may apply, among other things.

Employers must monitor and enforce the use of PPE for the equipment to be effective in protecting workers. Management should set the example by also wearing PPE when required. Immediate supervisors/managers should monitor PPE use regularly and the health and safety committee members or representatives should perform regular inspections.

See our personal protective equipment quick reference chart here (login required).

Also, the CSA group has standards on various types of PPE on their website that are helpful.