Personal Protective EquipmentPS-EHS-01
This policy applies to Indiana University employees who:
- receive compensation, including faculty and staff; temporary agency employees working for Indiana University and student workers; and
- work in any location on behalf of Indiana University where hazardous conditions may reasonably occur; and
- work in any activity that could reasonably pose a hazard to the individual and that requires the use of personal protective equipment.
Indiana University Environmental Health and Safety (IUEHS) is responsible for ensuring that all University departments comply with the standards established by this policy regarding Personal Protective Equipment (PPE). IUEHS is designated to maintain standards related to PPE in order to comply with external requirements such as those set by the American National Standards Institute (ANSI) and the Occupational Safety and Health Administration (OSHA). University departments must evaluate hazards and provide PPE in accordance with this policy and as necessary to minimize the risks to employees presented by the work environment. IUEHS has the authority to stop work on jobs where lack of compliance with this policy presents a danger to university employees.
Reason for Policy
Indiana University will maximize the protection of individuals from workplace hazards. In many cases, risks can be eliminated or mitigated by the use of Personal Protective Equipment (PPE). All PPE must meet American National Standards Institute (ANSI) standards when required by the Occupational Safety and Health Administration (OSHA) or in accordance with the programs developed by Indiana University Environmental Health and Safety (IUEHS). Although individual units are free to go above and beyond the requirements of this document, compliance with this policy will ensure that a minimal level of protection is provided to all workers.
All University departments will complete a job hazard assessment utilizing information provided by IUEHS and submit the compiled information to IUEHS for their respective campus.
IUEHS will review the information and conduct follow-up investigations as necessary to determine the necessity for PPE in each department. IUEHS will maintain written job hazard assessments in compliance with the OSHA Standard.
PPE devices alone shall not be relied on to provide protection against hazards, but shall be used in conjunction with guards, engineering controls, administrative controls and sound safety practices.
Safety programs that provide for specialized protective equipment remain in effect and their requirements must still be complied with even if they are not specifically linked or mentioned in this policy.
The following factors shall be considered when selecting PPE:
- Chemical hazards
- Physical hazards
- Environmental Conditions
- Task requirements
- Potential for PPE failure
- Maintenance requirements
- PPE durability
- Duration of use
- Regulatory requirements/certification
- User’s size and physical abilities (for fit, comfort and individual needs)
- User acceptance
Indiana University is not required by regulation to provide personal items, such as safety shoes, prescription safety glasses, and cold-weather outer wear, unless the use of such items is restricted to use only while on the job at Indiana University.
Appropriate PPE will be selected by the department with assistance from IUEHS if necessary (See “Related Information” section). IUEHS has the authority to ensure the PPE selected is appropriate.
The department may purchase the selected PPE from any vendor, in compliance with IU procurement processes. Exception: Prescription eyewear, in order for the University to pay for it, must be obtained from the University designated prescription eyewear provider. IUEHS will maintain information regarding vendors of PPE.
When an employee separates from Indiana University, any Indiana University purchased PPE shall be returned, unless otherwise granted permission by the department director or designee.
If an employee reports for work without required PPE, the employee shall not be allowed to perform the work that requires PPE until the PPE has been secured. Failure to have appropriate PPE when necessary can subject the employee to progressive disciplinary action in accordance with policies identified by Indiana University Human Resources located at www.hr.iu.edu/relations/uwide_ca_index.htm.
PPE shall be inspected, cleaned and maintained by employees at regular intervals and as recommended by the manufacturer so it can be discarded, changed and/or decontaminated as deemed necessary. Excluded from this requirement would be PPE that is laundered and maintained under contract with an outside vendor. At a minimum, all PPE shall be discarded when it has become irreversibly contaminated, damaged, or has other integrity problems.
It is important to ensure that contaminated PPE which cannot be decontaminated is disposed of in a manner that protects employees from exposure to hazards while ensuring compliance with appropriate regulations.
Disposable PPE shall be disposed of properly after use in accordance with governing programs for the contaminants being handled and shall not be re-used.
Note: Inspect PPE before each use for tears, punctures, holes, cuts, cracks, embedded foreign objects and texture changes (e.g., swelling, softening, hardening, becoming sticky or inelastic).
Environmental Health and Safety is responsible for:
- Ensuring departments are aware of and monitoring compliance with the Indiana University Personal Protective Equipment Policy.
- Providing consultation to departments in assessing the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE;
- Communicating selection decisions to each affected employee and supervisor;
- Selecting and recommending PPE that properly fits each affected employee;
- Providing training in the proper use and care of PPE;
- Documenting aforementioned hazard assessment components;
- Reviewing, updating and evaluating the effectiveness of the PPE policy annually; and
- Verifying that job hazard assessments have been performed.
Departments are responsible for:
- Conducting specific job hazard assessments to determine hazards which necessitate the use of PPE and providing documentation to IUEHS;
- Advising employees as to the required PPE for their job tasks;
- Providing proper PPE as required;
- Ensuring PPE is available;
- Ensuring PPE is being used by each affected employee during all job tasks which require such protection;
- Ensuring employees are properly trained on the use of the PPE;
- Documenting purchase and distribution of all PPE;
- Contacting Environmental Health and Safety when a hazard or process has changed with may render previously used PPE ineffective; and
- Ensuring defective or damaged PPE is removed from use.
Employees are responsible for:
- Inspecting all PPE prior to each use;
- Wearing PPE upon the direction of their immediate supervisor;
- Participating in mandatory PPE training;
- Notifying their supervisor when new PPE is necessary or of defective or damaged PPE; and
- Notifying their supervisor of any changes which might impact the type of PPE they utilize.
Specific PPE Requirements
Eye and Face Protection
Suitable eye or face protection shall be provided where there is a potential for injury to the eyes or face from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, potentially injurious light radiation, or a combination of these.
Use of eye and face protection shall be in accordance with the IU Eye and Face Protection Program.
In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering, work practice, and administrative control measures (for example, enclosure or confinement of the operation, general and local ventilation and substitution of less toxic materials). When effective engineering, work practice and administrative controls are not feasible, or while they are being instituted, appropriate respirators shall be used.
Respirators shall be provided when such equipment is necessary to protect the health of the employee. The respirator shall be applicable and suitable for the purpose intended.
Indiana University EHS has developed a Respiratory Protection Program which includes all the requirements for respirator use. Use of respirators shall be in accordance with the IU Respiratory Protection Program.
Foot protection shall be worn when there is a potential for injury to the feet from falling or rolling objects, or objects piercing the sole, and where such employee's feet are exposed to electrical hazards.
Use of foot protection shall be in accordance with the IU Foot Protection Program.
Hearing protection devices shall be made available to all employees exposed to an 8-hour TWA of 85 dB or greater at no cost to the employees and shall be replaced as necessary. Types of hearing protection include formable and preformed ear plugs, canal caps, and ear muffs.
Hearing protection devices shall be worn by any employee who is exposed to an 8-hour TWA of 85 dB or greater, and who has not yet had a baseline audiogram or has experienced a standard threshold shift. Employees shall be given the opportunity to select their hearing protection from a variety of suitable hearing protection devices.
Use of hearing protection shall be in accordance with the IU Hearing Conservation Program.
Appropriate hand protection is required when hands are exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes.
The type of hand protection used shall be based on the performance characteristics of the hand protection relative to the task(s) to be performed, conditions present, duration of use, and the hazards or potential hazards identified.
Torso protection shall be provided when there is a potential for bodily injury (e.g., legs, arms, back, chest) from cuts and radiation; temperature extremes; hot splashes from molten metals and other hot liquids; potential impacts from tools, machinery and materials; and hazardous chemicals.
Employees who face possible bodily injury of any kind that cannot be eliminated through engineering, work practice or administrative controls, shall wear appropriate body protection while performing their jobs.
Body protection includes laboratory coats, coveralls, vests, jackets, aprons, surgical gowns and full body suits.
Head protection shall be worn in areas where there is a potential for injury to the head from impact, flying or falling objects, or electrical shock.
Protective helmets shall comply with ANSI Standards Z89.1-1997, "American National Standard for Personnel Protection-Protective Headwear for Industrial Workers-Requirements", Z89.1-2003, and Z89.1-2009, "American National Standard for Personnel Protection-Protective Headwear for Industrial Head Protection.” Helmets for protection against electrical shock shall comply with ANSI Z89.2-1971.
Training and Recordkeeping
Initial training shall be provided by Environmental Health and Safety through E Training or by the appropriate department for each employee who is required to use PPE. Each employee shall be trained in at least the following:
- When PPE is necessary;
- What PPE is necessary;
- How to properly don, doff, adjust, and wear PPE;
- The limitations of the PPE; and
- The proper care, maintenance, useful life and disposal of the PPE.
Each affected employee shall demonstrate an understanding of the aforementioned training and the ability to use PPE properly before being allowed to perform work requiring the use of PPE.
When there is reason to believe that any affected employee who has already been trained does not have the understanding and skill as required above, Environmental Health and Safety or the affected department shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where:
- Changes in the workplace render previous training obsolete;
- Changes in the types of PPE to be used render previous training obsolete; or
- Inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.
Indiana University Environmental Health and Safety and departments 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. Records of PPE hazard assessments will be maintained by the respective EHS department for each campus.
Administrative Controls: Methods of controlling employee exposure to hazards by means of operating procedures or work scheduling.
Audiogram: Hearing test.
Biological Hazard: Living organisms that can cause infectious diseases and allergies.
Chemical Hazard: Gases, vapors, liquids, fumes, or dusts that can result in poisoning, lung disease, skin irritation, or damage to other parts of the body.
Contamination: The presence of an unwanted material that may cause injury or illness to an exposed employee.
Damaged: Change to PPE through event, wear-and-tear, and/or age which reduces its ability to provide the level of protection required under the governing ANSI or ASTM standards.
Employee: Any faculty member, staff member, or student who receives compensation from Indiana University for a job performance.
Engineering Controls: Methods of controlling employee exposure to hazards by modifying the source or reducing the quantity of contaminant released into the work environment.
Hazard Assessment: An evaluation of hazards in the workplace.
Impact: Workplace hazards resulting from flying fragments, objects, sand, dirt, etc.
Job Hazard Assessment: An assessment of hazards in the workplace, evaluating the nature of the hazard, the probability of an accident or exposure, and the consequences of the event.
Personal Protective Equipment: Devices worn by the worker to protect against hazards in the work environment. Examples are gloves, safety shoes, safety eye wear, hard hats, hearing protectors, and respirators.
Physical Hazard: A chemical for which there is scientifically valid evidence that it is a combustible liquid, compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or water reactive.
Standard Threshold Shift (STS): A change in hearing threshold relative to the baseline audiogram of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear.
Temporary Agency Employee: An employee working for Indiana University on a temporary basis, through an agency, that has been contracted to provide said employees.
Time Weighted Average (TWA): Average exposure over a specified period of time.
Failure to use the selected PPE in a proper manner can subject the employee to progressive disciplinary action, up to and including dismissal. Failure of the employee's supervisor to enforce the proper use of PPE subjects the supervisor to progressive disciplinary action, in accordance with University policies.
|University Environmental Health and Safetyfirstname.lastname@example.org|
|Rebecca Spratt, Director, Environmental Health and Safety,
Indiana University-Purdue University Indianapolis
|Dan Derheimer, Director, Environmental Health and Safety,
Indiana University Bloomington
|Kathryn Manteuffel, Regional Director of Environmental Health
This policy was established in October 2014.