Safety Tidbit 4.12 – PPE Assessment
This week’s Safety Tidbit comes from a text I received yesterday from an attorney. “Are PPE Assessments or their certifications due annually?” I replied “Quick answer No.” But then went on to validate my answer on the OSHA website.
Under OSHA’s General Industry Standards, Subpart I, Personal Protective Equipment 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). If such hazards are present, or likely to be present, the employer shall:”
And 1910.132 (d)(1)(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.”
I don’t see where OSHA defines a frequency that the assessment must be reassessed. Going a little further, I took a look the respirator standard. Paragraph 1910.134(d)(1)(iii) states “The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form.” Again, I don’t see a frequency of reevaluation.
Interestingly, the respirator standard does have a provision in paragraph 134(l) for overall program evaluation which states “… requires the employer to conduct evaluations of the workplace to ensure that the written respiratory protection program is being properly implemented, and to consult employees to ensure that they are using the respirators properly.”
And further in the subsequent paragraph (1910.134(l)(1)) “The employer shall conduct evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective.” The respirator standard does require annual fit-testing and training of respirator users, so it seems logical to conduct a program evaluation and ask users for their input on program effectiveness at that time. However, as you can see, OSHA does not explicitly require it annually.
If I was to hazard a guess, OSHA does not specify a frequency for reassessment or revaluation to keep the implementations cost down. Because each time they specify a frequency their economists must factor that in and it takes time and therefore money. After all, we are trying to reduce paperwork, aren’t we? But how OSHA determines the economic feasibility of their standards is a topic for a future Safety Tidbit.
Hope this was helpful and thank you for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan
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