Personal Protective Equipment Program

The program describes the selection, maintenance and use of personal protective equipment (PPE) at CSUN.

I.  Purpose/Scope

The purpose of the Personal Protective Equipment (PPE) Program is to establish a comprehensive approach toward controlling potential accidental employee injuries on campus and to reduce/prevent exposure to specified physical hazards when/where needed.   The requirements of this document apply to all employees when working in conditions requiring personal protective equipment.  This program does not apply to workplace operations regulated by Cal/OSHA’s High Voltage Electrical Safety Orders or to their Construction Safety Orders.

Good safety practices should not rely on PPE alone to control all possible hazards.  To enhance injury prevention, the proper use of PPE will be required after guarding, engineering and administrative solutions are deemed inadequate or impractical as determined by the employee’s department management and EH&S. 

II.  Definitions

• Airborne contaminant:  a harmful, irritating, or nuisance material, in the form of gas, dust/particulate, mist, or fumes, that is foreign to the normal atmosphere.

• Clothing: refers to whatever may be worn by the employee as protection for any body part.

• Combination of hazards:  a workplace situation where more than one hazard is present concurrently, such as exposure to non-ionizing radiation, toxic gasses and flying hot particles when welding.

• Excessive heat/flame: working conditions that create the possibility that heat illness could occur, including air temperature, relative humidity, radiant heat from the sun and other sources, conductive heat sources such as the ground, air movement, workload severity and duration, protective clothing and personal protective equipment worn by employees.

• Excessive sound:  exposure to an 8-hour time weighted average (TWA) noise level of 85 dBA or greater as measured on the A scale of a sound level meter. Impulsive or impact noise should not exceed 140 dB peak sound pressure level.

• Flying chips: exposure to particulate material ejected by mechanical processes (e.g., wood sawing, metal grinding, paint spraying) or wind-blown dust.

• Harmful light: Any exposure to high energy laser light or other high intensity natural or artificial light that may cause damage to eye structures. Moderate and high-power lasers are potentially hazardous because they can burn the retina of the eye, or even the skin.

• Harmful radiation:  The level or dose of ionizing radiation or non-ionizing radiation that may cause biological damage if exposed.  The ionizing radiation category primarily includes alpha, beta, x-ray, and gamma radiation. Non-ionizing radiation includes, among others, ultraviolet (UV), infrared (IR), radio frequency (RF), and microwave radiation. The difference between the two is that ionizing radiation has enough energy to eject orbital electrons from the atoms of the material being irradiated.

• Hazardous materials:  Any material which poses a health and safety threat to employees and/or students or a threat to the environment as a result of improper handling, disposal methods or accidental discharge is considered hazardous.

• Hazardous motion:  machinery or processes where any movement of tools, machine elements or particles exists, or movement of personnel that could result in collision with stationary objects.

• Personal protective equipment:  Any device or system of clothing and devices that protects the wearer from the obvious harmful substances, activities, conditions or environment at the workplace.

• Respirator: a device designed to protect the wearer from the inhalation of harmful atmospheres.

• Sharp objects: Any object used or encountered that can be reasonably anticipated to penetrate the skin or any other part of the body, and to result in an exposure incident, including, but not limited to, needle devices, scalpels, lancets, broken glass, broken capillary tubes, exposed ends of dental wires, knives, drills and burrs. 

III.  General Guidelines

The requirement to use PPE is a function of the type of work (activities), the duration of the exposure (e.g., time weighted average for sound level) and the degree of physical contact (action level to implement controls) with the potential injury/illness source. However, each job at the University has varying degrees of exposure to injury ranging from minuscule to severe.  Over the course of many years of job analysis and safety investigations the University published a number of Environmental Health and Safety Programs to identify those injury sources and to mitigate employee accidental injuries. 

Because the purchase, training, use and enforcement of personal protective equipment is implemented across a cross-section of departments at CSUN, the most expedient way for a supervisor to assess the need for PPE is to examine the existing EH&S Safety and Health programs.

Several other programs where PPE, to some extent, is specified include:

• Asbestos Management
• Biological Safety Program
• Blood-borne Pathogens Program
• Chemical Hygiene Program
• Energized Electrical Work Program
• Energized Work Program
• Fall Protection Program
• Lead Management Program
• Respiratory Protection

Supervisors responsible for the on-the-job health and safety of the employee, should look first to the specific program that details the PPE required.  If the hazardous job is occasional or does not fit into a specific program, the EH&S Department stands ready to assist with PPE selection and training as required to protect the employee. 

• Ballistic Exposure:  exposures consist of flying or dropped materials that may strike and injure an employee on the job causing a blunt or penetrating trauma.
• Biological Exposure:  exposures consist of any biological agent that may cause personal injury.
• Blunt Trauma Exposure:  refers to a type of physical trauma caused to a body part by impact. Resulting injury may be concussions, abrasions, lacerations, and/or bone fracturing. Blunt trauma is contrasted with penetrating trauma, in which an object such as a hypodermic needle enters the body.
• Chemical Exposure:  exposures consist of any chemical agent that may cause personal injury.
• Confined Space Entry Exposure:  exposures consist of entry or work within a confined space (a space large enough for a worker to enter, with limited or restricted means for entry and exit that is not designed for continuous occupancy. E.g., tanks, vessels, silos, storage bins, hoppers, vaults, pits, manholes, tunnels, equipment housings, ductwork, pipelines, etc.).
• Extreme Temperatures: working in very high or very low temperatures either localized or in the general environment can cause injuries.
• Fall Exposure:  exposures consist of any work activity from elevated heights or ladders.
• Fire Exposure:  exposures working around open flames or from fighting a fire.
• Hazardous Materials:  exposure to any material which poses a health and safety threat to employees and/or as a result of improper handling or disposal methods or accidental discharge. PPE may consist of gloves, safety glasses, goggles, face shields, clothing and creams.
• Hot Work: exposures to heat and/or flame from activities involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations.
• Penetrating Trauma Exposure:  exposures to puncture wounds while in a work environment.
• Radiation Exposure:  exposures to harmful ionizing or non-ionizing radiation in which an employee may work.
• Respiratory Exposure:  exposures to harmful contaminants in the air in which an employee may work.
• Rolling Stock:  exposures to powered and non-powered rolling carts, dollies and pallet movers used to manually transport heavy materials and equipment. PPE may consist of gloves and hard toed shoes.
• Sharp Objects:  exposures to tools, equipment and materials with sharp points or edges.  PPE may consist of gloves, special clothing and safety glasses.

Personal Protection Devices:  Any clothing or equipment provided by the University that is designed and constructed to safeguard the wearer from being exposed to a specific physical hazard. Such as:

• Body Protection Equipment:  used by employees exposed to potential injury to the body, trunk, limbs or torso.  PPE may consist of special clothing.
• Eye/Face Protection Equipment:  used by employees exposed to potential injury from harmful light or airborne particles in the work environment.  PPE may consist of special safety glasses, goggles or face masks.
• Fall Protection Equipment:   used by employees exposed to potential fall hazards from working at above ground levels of 6 feet or more.  PPE may consist of Personal Fall Arresting Systems.  Components of a personal fall arresting system, detailed in the “Fall Protection Program,” include a body harness, lanyard, lifeline, connector, and an anchorage point capable of supporting at least 5000 pounds.
• Foot Protection Equipment:  used by employees exposed to potential injury to the feet.  PPE may consist of special shoes, boots or metatarsal guards.
• Hand Protection Equipment:  used by employees exposed to potential injury to hands.  PPE may consist of special gloves or hand creams.
• Head Protection Equipment:  used by employees exposed to potential injury to the head.  PPE may consist of special hats, helmets or bump caps.
• Hearing Protection Equipment:  used by employees exposed to excessive levels of sound as specified in the University’s “Hearing Conservation Program.”  PPE may consist of special earplugs or earmuffs.
• Radiation Protection Equipment:  used by employees exposed to potential injury as specified in the University’s “Radiation Safety Manual.”  PPE may consist of safety glasses, protective clothing and gloves.
• Respiratory Protection Equipment:  used by employees exposed to potential injury to the lungs and associated breathing functions as specified in the University’s “Respiratory Protection Program.”  PPE may consist of special dust masks, respirators of single or multiple use and air supplied types.

• Skin Protection Equipment:  used by employees exposed to potential injury (e.g., dermatitis) from chemicals or other hazardous materials they may need to handle in the course of their work assignments.  PPE may consist of gloves, special protective hand creams, sunscreen or clothing.

V.  Exemptions & Exclusions

Employees working with energized electrical equipment are covered specifically under the University’s “Energized Electrical Work Program” and are exempted from this program for those related exposures.

VI.  Responsibilities

All Employees:

• Each person working in a hazardous environment, having been trained, is responsible for remaining aware of the hazards associated with their activities and with the materials being handled and the appropriate personal protective equipment required.  Each person is responsible for knowing how to use PPE safely according to the types of hazards.  If one is unsure of a hazard or proper procedure, they should ask for assistance before using that particular PPE.
• Must follow all appropriate PPE requirements while performing assigned duties.
• Must inspect PPE prior to each use.
• Must report conditions to your supervisor which may lead to injury.

Environmental Health & Safety Department (EH&S):

• EH&S has responsibility for the oversight of the development, implementation, and maintenance of the Personal Protective Equipment Program (PPE).
• Advise and assist in the implementation of PPE policies and practices.
• Provide technical assistance to all departments in complying with PPE requirements.  Provide consultation, monitoring, and training support services to all departments on matters related to PPE.
• Assist departments in identifying hazardous operations or materials, establishing safe work practices, and selecting protective equipment and other exposure controls.
• Provide regular, formal workplace assessments to determine if hazards are present, or are likely to be present, which may necessitate the use of personal protective equipment PPE.
• Assist departments with PPE procurement, use, fitting and maintenance.
• Seek methods to improve the PPE program.

Departments:  Departments affected by this program include, but are not limited to:

• Physical Plant Management:  Maintenance activities throughout campus buildings and grounds.
• Information Technology: Telecommunications and network installation and maintenance throughout the University.
• Student Housing:  Maintenance activities throughout campus housing facilities and grounds.
• School of the Arts, Production Department:  Construction and striking of stage productions.
• Engineering, Physics, Biology, Chemistry and Research Labs:  Handling hazardous materials.
• Athletics:  Contact and other sports.

Dean of College or Chair/Manager of Department:

• Responsible for the PPE Program within college or department.
• Ensure that requirements related to PPE program, as contained in this document, are adequately supported at the college or departmental level.

College/Department Safety Coordinator:

• Serve as a liaison with the Environmental Health & Safety Office to implement the PPE Program.
• Assist area supervisors in all aspects of this program.
• Monitor the procurement, use, maintenance and replacement of PPE in the areas over which they have oversight responsibility.

Supervisor:

• With assistance of EH&S and the department Safety Coordinator, determine the required protective apparel and equipment.
• Ensure that personal protective equipment is available and working.
• Responsible for ensuring new and existing employees receive PPE training as applicable to their job duties.
• Maintain appropriate records.

Shop/Lab/Maintenance Personnel:

• Understand and act in accordance with the safety requirements established by the department.
• Participate in all required training programs.
• Understand the function and proper use of all provided personal protective equipment.
• Wear and properly maintain the personal protective equipment necessary to perform each task.
• Use engineering controls and safety equipment properly and according to department requirements.
• Report to supervisor all facts pertaining to accidents that result in injury and any action or condition that may result in an accident.  

VII.  Selection Process

Selection Overview

• While personal protective equipment is an effective loss control tool in accident and injury prevention, these devices still do not reduce or eliminate the hazards.  Thus, PPE is advised when it is not feasible to render the workplace environment adequately safe.  It is not the University’s intention to make PPE the sole protection but a supplement to effective environmental control coupled with safe work procedures and proper training.
• Supervisors must take care when considering the appropriate PPE for a specific or combination of hazards. Selecting the correct PPE may mean choosing from a variety of types, materials, functions and design to achieve the most cost effective protection without compromising safety.  Many PPE devices available require choices among several variables and priorities over and above cost.  These choices are best made in consultation with the safety personnel in the Environmental Health & Safety Department (EH&S, Ext. 2401).

• The Internal Workplace Hazard Assessment and PPE Evaluation Form is used by EH&S to document that the area identified had undergone a workplace hazard assessment and verify that the use of PPE is appropriate for the hazards found.  Departments will be responsible for conducting this assessment and maintaining records. EH&S will be responsible for providing assistance to groups that need it..  Any suggestions for safety enhancement will be communicated to the proper department personnel.  Department supervisors may download this form and conduct a self-evaluation whenever conditions in the department change.

TABLE 1 - PPE by Job Title

 
TABLE 2 - PPE by Activity

 
TABLE 3 - PPE by Body Part Affected

 
 
TABLE 4 - PPE by Hazard

IX.  PPE Rules

The California State Department of Industrial Relations, Division of Occupational Safety & Health, CCR Title 8 Regulations references the following recommendations regarding personal protective equipment:

Procurement
The department person responsible for purchasing PPE should be very specific when ordering PPE so that there is a balance of quality, work efficiency and safety with the cost of the item.  The purchaser should select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from the hazards.  When cost effective, an inventory of approved PPE should be maintained.

Maintenance and Care
It is critical that all reusable PPE be kept clean and properly maintained in order to provide the protection intended. Cleaning is particularly important for eye and face protection where dirty or fogged lenses could impair vision. For the purposes of compliance with Section 3380(a) and (d), PPE should be inspected, cleaned, and maintained at regular intervals.  It is also important to ensure that contaminated PPE which cannot be decontaminated is disposed of in a manner that protects employees from exposure to hazards.  Defective or damaged personal protective equipment shall not be used.

Training
The department should provide access to training for each employee required to use PPE and the training should include the following:

• When  & why PPE is necessary
• Which PPE is required
• Proper use of PPE

Fitting

For PPE devices with adjustable features, adjustments should be made on an individual basis for a comfortable fit that will maintain the protective device in the proper position. Particular care should be taken in fitting devices for eye protection against dust and chemical splash to ensure that the devices are sealed to the face. In addition, proper fitting of a helmet is important to ensure that it will not fall off during work operations. In some cases a chin strap may be necessary to keep the helmet on an employee's head. Careful consideration must be given to comfort and fit because continued wearing of the device is more likely if it fits the wearer.

Respiratory PPE needs to be qualitatively fit tested at least annually, and when any changes to fit occur such as facial changes or respirator design changes. EH&S can assist with these tests.

Storage and Distribution

• When feasible, PPE should be kept in a clean, dust free locker, cabinet or area so that it is easily accessible to whomever needs it.  Some PPE devices will have storage considerations specified by the manufacturer.
• The department should make all PPE readily available to employees requiring hazard protection.  When possible, reusable PPE devices may be assigned to individuals.