It’s National Preparedness Month

September is National Preparedness Month. Preparedness is usually associated with emergency plans, evacuation routes, and disaster supplies. For employers, it also means making sure the equipment matches the hazard, required credentials are current, and compliance records will hold up when someone asks to see them.

Those details matter before the emergency – or the inspector – arrives. A hard hat can meet an OSHA-recognized standard and still not be the best protection for the work being performed. A company can complete lead-safe work and still face a substantial penalty because required disclosure documents were missing. A worker can have years of experience and still create a compliance problem because a certification quietly expired.

This month, we are looking at the common thread running through those situations: the word compliant does not always end the conversation. Sometimes it is where the better questions begin.

Is Your PPE Right for the Worker and the Work?

A compliance marking can tell you that a piece of equipment meets a particular standard. It cannot, by itself, tell you that the equipment is right for the task, addresses the hazards present, or fits the employee who will wear it.

That distinction matters in construction. OSHA now explicitly requires employers to select personal protective equipment that properly fits each affected employee. The rule also requires PPE to be of safe design and construction for the work being performed. In other words, having compliant equipment in the supply room is not enough. It has to be the right equipment for the work and the worker.

Three questions, not one:

1. Does the equipment satisfy the applicable OSHA requirement?
2. Does it provide the right protection for the actual hazard?
3. Does it properly fit the individual worker?

Proper Fit Is an OSHA Requirement

Poorly fitting PPE is more than an inconvenience. Oversized gloves or protective clothing can become caught in equipment. Undersized equipment may restrict movement or leave part of the body exposed. Uncomfortable equipment is also less likely to be worn consistently.

Fit should be evaluated on the employee while the employee performs the work. Employers may need more than one size or model, and they should check whether hard hats, eye protection, hearing protection, respirators, and other equipment remain effective when worn together.

Head Protection: Match the Protection to the Hazard

OSHA’s construction head-protection standard recognizes ANSI Z89.1 editions from 1997, 2003, and 2009. It also permits other head protection when the employer can demonstrate that it is at least as effective. A newer consensus-standard edition is not automatically an OSHA requirement, and equipment made to an older recognized edition is not automatically unsafe.

The distinction between Type I and Type II protection is also important. Type I helmets are primarily tested for impacts to the top of the head. Type II helmets are tested for impacts from additional directions. That does not mean every worker automatically needs a Type II helmet. It means the choice should come from the hazards of the work, not from whatever happens to be in the supply room.

Eye Protection: Read Beyond the Z87 Mark

Safety glasses are not all designed for the same hazards. Current markings can communicate whether equipment is rated for impact, dust, splash, or other exposures. A pair of glasses that is adequate for general shop work may not be appropriate for grinding, drilling, chemical handling, or dusty cleanup.

Supervisors and employees should know where the markings are located and what they mean. If the only selection criterion is ‘they are safety glasses,’ the hazard assessment has not made it all the way to the employee’s face.

A Related Preparedness Check: First Aid Kits

OSHA’s nonmandatory appendix for first aid kits still identifies ANSI Z308.1-1998 as an example of minimum contents for a generic kit at a small worksite. The current ANSI/ISEA consensus standard is newer and reflects changes in workplace needs and available supplies.

The practical point is not that every kit bearing an older reference must immediately be discarded. OSHA already tells employers to assess the specific needs of the worksite and add supplies when the size, location, or hazards of the operation require more. A generic kit intended for a small workplace may be a poor match for a remote project, a large crew, or higher-risk work.

A Five-Question PPE Review

1. What hazards and tasks are we protecting against? Start with the work being performed, not the equipment already on the shelf.
2. What does OSHA actually require? Determine the applicable rule and whether a consensus standard is incorporated, recognized, or offered as nonmandatory guidance.
3. Does the equipment meet the required standard or provide equivalent protection? Check product markings and the manufacturer’s documentation.  
4. Does it properly fit this employee and work with the other PPE being worn? Evaluate fit, coverage, movement, comfort, and compatibility during the task.
5. Do employees understand what they are using? Teach workers and supervisors to recognize relevant markings, limitations, inspection criteria, and replacement triggers.

Bottom line: A label may establish that equipment conforms to a standard. It does not prove that the equipment fits the worker or matches the hazard. Start with the requirement, then evaluate the task, the worker, and how the equipment will actually be used.

Source: OSHA construction PPE selection and proper-fit requirements

Source: OSHA announcement: Proper fit requirements for PPE in construction

On Our Radar: OSHA Respirator Proposals

OSHA completed public hearings in August on a group of deregulatory proposals, including proposed revisions to substance-specific respirator requirements for asbestos and lead. OSHA says the proposals are intended to allow different respirator options and better align those standards with the general Respiratory Protection standard.

A separate proposal would remove some medical-evaluation requirements for employees required to use filtering facepiece respirators or loose-fitting powered air-purifying respirators.

Nothing has changed yet. These remain proposed rules. Employers should continue following the current asbestos, lead, and respiratory-protection requirements unless and until OSHA issues a final rule with an effective date. UND-ETI will continue monitoring the rulemaking and explain the practical effect if the requirements change.

Source: OSHA deregulatory rulemaking page

 

Enforcement Snapshot: $359,069 Over 11 Leases

EPA recently announced a settlement involving alleged Lead Disclosure Rule violations at a Connecticut apartment complex. The case involved 11 units and a penalty of $359,069.

According to EPA, the alleged violations included failure to provide the required lead hazard pamphlet, include the lead warning statement in leases, disclose known information or document that none was known, and provide available lead reports or indicate that no reports were available. The inspection followed resident complaints, and EPA determined that children were living in the affected apartments.

This was not an RRP enforcement case, and the allegations did not involve improper abatement. The lesson is that lead compliance does not begin and end with finding or removing lead. Required paperwork can create substantial liability even when no renovation is taking place.

Practical takeaway: Owners and property managers should audit the lead documents used with leases for pre-1978 housing. Do not assume that leasing software or a standard form automatically contains every required disclosure.

Source: EPA settlement announcement

Compliance Alert: EPA Checking Lead RRP Jobsites

EPA representatives have contacted UND-ETI several times recently to report that they are actively visiting construction sites, particularly residential projects, to check compliance with the Lead Renovation, Repair and Painting Rule. Recent visits have included communities in South Dakota, Wyoming, and Montana, with visits planned in North Dakota. According to the EPA representatives who contacted us, inspectors are finding widespread noncompliance.

If your company performs renovation, repair, or painting work in pre-1978 housing or child-occupied facilities, this is a good time to check more than the date on one employee’s card. The RRP Rule requires the firm to be certified and a certified renovator to be assigned to each covered project. Other workers who disturb painted surfaces must be certified renovators or trained on the job by one. Firms must also follow the required work practices, provide pre-renovation education, and maintain the required records.

Check Now

• Is the firm’s EPA or authorized-state certification current?
• Are the certified renovator credentials current for the employees who need them?
• Are certified renovators being assigned to covered projects?
• Are required work practices, cleaning verification, occupant information, and records consistently being completed?

If your company works in older homes or child-occupied facilities but has never added Lead RRP certification, this may also be the right time to expand your capabilities. Initial training is a much better business decision when it is planned than when an inspector is already standing on the jobsite.

Action: Check your credentials, review your procedures, and register for an upcoming Lead RRP initial or refresher course if training is needed.

Source: EPA RRP firm certification and responsibilities

CLOSING THOUGHT

Preparedness is rarely about having a perfect answer for every situation. More often, it means taking care of the ordinary details before they become urgent: PPE that fits, credentials that are current, records that are complete, and people who understand what is expected.

Most compliance problems are easier to prevent than explain. Take a few minutes this month to check the things everyone assumes are already covered.

About UND Environmental Training Institute

UND Environmental Training Institute provides nationally recognized certification training in asbestos, lead, and environmental health and safety. Our experienced instructors deliver hands-on training that meets EPA and OSHA requirements while preparing professionals to work safely and effectively in the field.

Contact Information:

Website: https://und-eti.com

Training Schedule: https://und-eti.com/upcoming/

UND Tech Accelerator
4201 James Ray Drive – Stop 8391
Grand Forks, ND  58202

(701) 777-0384
info@und-eti.com
www.und-eti.com