OSHA
Personal Protective Equipment (PPE)
Training Requirements & Considerations
Training requirements for
Personal Protective Equipment are addressed in Subpart I of OSHA 1910 -
OSHA 1910.132
First, OSHA requires the
employer to assess the workplace to determine which hazards are or are
likely to be present which necessitate the use of PPE.
Then, for those hazards
identified,
OSHA requires the employer to select the appropriate PPE.
OSHA 1910.132(d)(1)
states: "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:
OSHA 1910.132(d)(1)(i)
further states: "Select, and have each affected employee use, the
types of PPE that will protect the affected employee from the hazards
identified in the hazard assessment;
Then, OSHA outlines
training requirements for PPE:
OSHA 1910.132(f) Training
OSHA 1910.132(f)(1) The
employer shall provide training to each employee who is required to this
section to use PPE. Each employee shall be trained to know at
least the following:
OSHA 1910.132(f)(1)(i)
When PPE is necessary;
OSHA 1910.132 (f)(1)(ii)
What PPE is necessary;
OSHA 1910.132 (f)(1)(iii)
How to properly don, doff, adjust and wear PPE;
OSHA 1910.132 (f)(1)(iv)
"The limitations of the PPE; and"
OSHA 1910.132 (f)(1)(v)
"The proper care, maintenance, useful life and disposal of the PPE."
It
is not sufficient to simply provide instruction to employees, the
employees must demonstrate an understanding of the training provided, as
OSHA explains in OSHA 1910.132(f)(2): "Each affected employee shall
demonstrate an understanding of the training specified in paragraph
(f)(1) of this section, and the ability to use PPE properly, before
being allowed to perform work requiring the use of PPE."
And further, in OSHA
1910.132 (f)(3), OSHA states: "When the employer has reason to
believe that any affected employee who has already been trained does not
have the understanding and skill required by paragraph (f)(2) of this
section, the employer shall retrain each such employee.
Circumstances where retraining is required include, but are not limited
to, situations where:"
OSHA 1910.132 (f)(3)(i)
"Changes in the workplace render previous training obsolete;
or"
OSHA 1910.132 (f)(3)(ii)
"Changes in the types of PPE to be used render previous training
obsolete; or"
OSHA 1910.132 (f)(3)(iii)
"Inadequacies in an affected employee's knowledge or use of
assigned PPE indicate that the employee has not retained the requisite
understanding or skill."
Then, in OSHA 1910.132
(f)(4), written documentation requirements are stated: "The
employer 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."
In summary, according to
OSHA, the employer must
1. Assess the workplace
2. Select the appropriate Personal Protective Equipment
3. Train employees
4. Verify effectiveness of the training
5. Observe for factors that may require retraining
6. Provide documentation
Personal Protective
Equipment (PPE) may include eye and face protection, respiratory
protection, head protection, foot protection, electrical protective
devices, hand protection, etc.
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