Why? In my experience, many companies do not really understand OSHA regulations as they apply to PPE.

OSHA 1910.132(d) Hazard Assessment and Equipment Selection, for example, mandates employers assess the workplace for hazards and select the proper PPE to address the hazards identified. OSHA 1910.132(f) requires that employers properly train employees regarding PPE.

A recent accident investigation demonstrates what can happen when a hazard assessment is not done right. In this case, an employee had a forklift run over her foot. She was wearing steeltoed shoes at the time. Her foot was so badly mangled that it had to be amputated. There are other issues to be considered here, such as not having proper separation between pedestrians and forklifts, but that is for another column. In any event, this was a foreseeable hazard that should have been evaluated and addressed.

Some companies, such as constructionequipment maker Bobcat Co., do a good job of meeting OSHA regs. Recently, the company hired six of us to teach a 10-hr OSHA course. Their hazard assessment found steel-toed shoes would not sufficiently protect employees. This is because such shoes only protect the front inch or so of the foot. Bobcat went the extra step and required that employees wear metatarsal shoes. During the course of the training, I learned that a number of employees had feet saved by wearing these metatarsal shoes. This demonstrated the need not only to perform a hazard assessment, but also to do it carefully and in depth.

Another OSHA regulation says that PPE must be maintained in a "sanitary and reliable condition." "Defective or damaged personal protective equipment shall not be used."

Consider safety glasses. New safety glasses generally meet the requirements of ANSI Z87.1. With use, however, safety glasses become pitted and scratched. This can weaken lenses to the point that they no longer meet the original spec. Users should regularly examine safety glasses for pitting and scratching and replace them when damaged.

Ditto for hardhats, which, other than so-called bump hats, are covered by ANSI Z89.1. OSHA suggests not plastering hardhats with stickers that could cover up damage that potentially renders the equipment less effective. My former employer received an OSHA citation for such an infraction. Similar reasoning explains why wooden ladders cannot be painted.

Though it may seem obvious, OSHA says to wear PPE as it is intended. Hardhats cannot be worn backwards, for instance. The reason: The practice is not addressed in the ANSI standards so hardhat manufacturers do not test them in this manner.

PPE technology is progressing rapidly, and suppliers of the equipment do a good job of explaining its benefits. It's up to companies and workers to listen.
