The Importance of Personal Protective Equipment (PPE) for Dealers

The Importance of Personal Protective Equipment (PPE) for Dealers

Janet Wimmer

Regulatory Advisor

KPA

Moderator

Becky RossMarketing Manager

(303) 228-8753

[email protected]

Janet WimmerRegulatory Analyst

(901) 277-0301

[email protected]

Presenter

If you have questions during the presentation, please

submit them using the “Questions” feature

Questions will be answered at the end of the webinar

QUESTIONS

Personal Protective Equipment

is commonly called

PPE.

The Importance of Personal Protective Equipment for Dealers

Dealers Responsible?

• “They have their own safety glasses.”

• “They can buy gloves. I provide them in the Parts Department.”

• “If I pay for it, they will abuse it.”


Liability

• Employee Injury

• Non-Compliance with Occupational Safety and Health Administration (OSHA)


Employee Injury

• Example: Recent eye injury

• Increase in insurance premium

• Cost of employee recovery


Occupational Safety and Health Administration (OSHA)

• Clear unambiguous regulation• Statistical data regarding employee injuries• Additional inspectors• Fines per occurrence


Occupational Safety and Health Administration (OSHA)

Personal Protective Equipment Regulations29CFR1910.132 General Requirements

29CFR1910.133 Eye and Face Protection

29CFR1910.134 Respiratory Protection

29CFR1910.135 Head Protection

29CFR1910.136 Foot Protection

29CFR1910.138 Hand Protection

29CFR1910.95 Noise Exposure


Personal Protective Equipment Regulations

1910.132(a)Application. Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition



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:


The Hazard Assessment

13– KPA CONFIDENTIAL –

• Define a Hazardous Activity such as: Grinding

• Work-related exposure will be: Particles

• Can the hazard be eliminated without PPE: No

• What is the required PPE: Safety Glasses


1910.132(d)(1)(i) 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;



1910.132(d)(1)(ii) Communicate selection decisions to

each affected employee; and,

1910.132(d)(1)(iii) Select PPE that properly fits each

affected employee.

1910.132(e) Defective and damaged equipment.

Defective or damaged personal protective equipment

shall not be used.



1910.132(f) Training.

• When and What PPE is required• How to put it on and take it off• Equipment limitations• How to maintain the equipment

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.



1910.132(h)(1) Except as provided by paragraphs (h)(2)

through (h)(6) of this section, the protective equipment,

including personal protective equipment (PPE), used to

comply with this part, shall be provided by the employer

at no cost to employees.

You are not required to provide steel toed shoes or prescription safety glasses.


HOWEVER

1910.133(a)(3) The employer shall ensure that each affected employee who wears prescription lenses while engaged in operations that involve eye hazards wears eye protection that incorporates the prescription in its design, or wears eye protection that can be worn over the prescription lenses without disturbing the proper position of the prescription lenses or the protective lenses



1910.132(h)(5) The employer must pay for replacement

PPE, except when the employee has lost or intentionally

damaged the PPE.


At a Minimum

Safety Glasses with Side Shield and Browguard Organic Vapor Respirator

Supplied Air and Protective Suit Nitrile Gloves


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Eye and Face Protection

1910.133(a)(1) The employer shall ensure that each

affected employee uses appropriate eye or face protection

when exposed to eye or face hazards from flying particles,

molten metal, liquid chemicals, acids or caustic liquids,

chemical gases or vapors, or potentially injurious light

radiation.




1910.133(a)(4) Eye and face PPE shall be distinctly

marked to facilitate identification of the manufacturer.

1910.133(b)(1) Protective eye and face protection

devices must comply with any of the following consensus

standards:

ANSI Z87



1910.133(a)(5) The employer shall ensure that each

affected employee uses equipment with filter lenses that

have a shade number appropriate for the work being

performed for protection from injurious light radiation.


Eye and Face Protection Fines

From October 2010 through September 2011

Citations on 8 dealerships totaling $16,015.00

Average cost per dealership $2,002.00


WHAT TO DO?

• As found in on the internet, eye injuries are the most common injury in this business. To deal with this some of our dealerships

• Require safety glasses to be worn by all persons entering the shop sections of the dealership.

• Midas International requires their employees to wear safety goggles in their shops.


DO NOT FOOL YOURSELF!

If you provide the cheapest safety glasses,

• They probably do not give the employee clear vision.• They probably are not adjustable for a comfortable fit.• They probably do not fit all employee’s heads.• They probably will not be worn.


Respiratory Protection

Supplied Air Respirator Organic Vapor Respirator

1910.134(a)(2) A respirator shall be provided to each employee when such

equipment is necessary to protect the health of such employee. The employer

shall provide the respirators which are applicable and suitable for the

purpose intended. The employer shall be responsible for the establishment and

maintenance of a respiratory protection program...


Respiratory Protection1910.134(c)(1) …the employer shall establish and implement

a written respiratory protection program with worksite-specific

procedures. Including the following:

• Procedures for selecting respirators • Medical evaluations • Fit testing • Procedures for proper use • Procedures maintaining respirators;• Ensure adequate air quality, quantity, and flow• Training of employees



1910.134(c)(2)(i) If the employer determines that any voluntary

respirator use is permissible, the employer shall provide the

respirator users with the information contained in Appendix D and

1910.134(c)(2)(i) In addition, the employer must ensure that any

employee using a respirator voluntarily is medically able to use that

respirator, and that the respirator is cleaned, stored, and maintained

so that its use does not present a health hazard to the user.

Exception: voluntary use of filtering facepieces (dust masks).

1910.134(c)(4) The employer shall provide respirators, training, and

medical evaluations at no cost to the employee.



Supplied air and complete coverage is

required for the spraying of clear- coats

and hardeners containing isocyanates

Organic vapor respirators are required for

the spraying of paints and thinners

containing organic chemicals.

The bodyman mask should be used by

bodymen and welders.


Respiratory Protection Notes

• Written program• Medical surveillance • Fit test • Workplace analysis • Change-out schedule.• Isocyanates • Equipment Inspection


Respiratory Protection Fines



Average cost per dealership $1,129.00


Head Protection

1910.135(a)(1) The employer shall ensure that each affected employee wears a protective helmet when working in areas where there is a potential for injury to the head from falling objects.

THIS DOES NOT APPLY TO DEALERSHIP OPERATIONS.


Foot Protection

1910.136(a)General requirements. The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, and where such employee's feet are exposed to electrical hazards.

THIS DOES NOT APPLY TO DEALERSHIP OPERATIONS.


Hand Protection

Nitrile Gloves Electrical Hybrid Gloves Welding Gloves

1910.138(a) General requirements. Employers shall select

and require employees to use appropriate hand protection

when employees' 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.



Hand Protection

Nitrile Gloves Electrical Hybrid Gloves Welding Gloves

Nitrile Gloves Used Petroleum/Solvents

Hybrid Gloves Electrical Shock

Latex Gloves Detail cleaning products

Leather Gloves/mechanic Gloves Abrasion/Heat

Welding Gloves Hot metal and sparks



Hand Protection Fines



Average cost per dealership $600.00


Noise Exposure

Earmuffs Disposable Ear Plugs Disposable Ear Plugs Earmuffs

1910.95(b)(1) When employees are subjected to sound

exceeding those listed in Table G-16, feasible administrative or

engineering controls shall be utilized. If such controls fail to

reduce sound levels within the levels of Table G-16, personal

protective equipment shall be provided and used to reduce

sound levels within the levels of the table 1.G-16.


Noise Exposure


1910.95(c)"Hearing conservation program.“

1910.95(c)(2) For purposes of paragraphs (c) through (n) of this section,

an 8-hour time-weighted average of 85 decibels or a dose of fifty percent

shall also be referred to as the action level.


Noise Exposure Note


Sound analysis in shops generally do not indicate that

noise is over 85 decibels for eight hours. It is prudent to

have disposable earplugs for your employees comfort.


PPE Requirements Perform a Hazard Assessment of the Workplace. Select required PPE and have employees use it. Provide the PPE at no cost to the employee. Train the employee in the proper use and

maintenance. Removed damaged equipment from the work area. Replace damaged equipment at no cost to employee. Review work practice to make sure employees are

wearing PPE when required.


PolicyWhat do you provide?

The Hazard Assessment states what PPE you must provide

Who distributes it at your store?

Designate a manager to be in charge

When is it distributed?

At the time of hire and when damaged or worn out.

How is the distribution documented?

Except for disposable gloves, all distributed equipment should be tracked.


Policy

When do you expect the equipment to be used?

Consider safety glasses:

Whenever one is in the shop.

When one is grinding.

When one is working on an engine that is running.

When one is under a vehicle.


Policy Enforcement Reward System:

• Random inspection--Five dollars when found wearing proper PPE• Contest between two sides of the shop—lunch for the least infractions

Punishment System:

• Write up each time employee not wearing PPE when required.• Three write-ups require disciplinary action.

NOTE: If there is no enforcement, there is no real Policy


Opportunity

#1 Protecting your employees from injury.

#2 Protecting your dealership from lawsuit and/or increased insurance costs.

#3 Protecting your dealership from OSHA fines.

#4 Creating a positive employee attitude, by showing them you care about their safety. You have spent time creating a Personal Protective Equipment policy and money supplying proper PPE and effort to enforce the policy.


Business

The Importance of Personal Protective Equipment (PPE) for Dealers