How to develop PPE policy and management

Pieter Lotz consults employers in Limpopo province on health and safety management.
Pieter Lotz consults employers in Limpopo province on health and safety management.

Effective selection, issue, use, and management of personal protective equipment, requires a detailed PPE policy.

The PPE policy should be integrated in the health and safety risk management system, and thus part of the general management system, and the corporate culture, writes Pieter Lotz, Principal Consultant of Cygma SHEQ in Polokwane.

Effective selection and use of personal protective equipment (PPE) go a long way to ensuring that workers wear their equipment when and where the management system requires them to do so.

PPE is the last resort in safety management, but it has saved many lives, eyes, burns, cuts, inhalations, and other injuries, allowing us an opportunity to improve the main elements of health and safety management.

The law is quite clear on the risk management process to be followed before PPE is considered as a last resort of protection of workers.

General Safety Regulation 2 requires an evaluation of the risk attached to any condition or situation which may arise from the activities in a business, and appropriate steps to be taken to make the situation safe.

The law recognises that not all situations or conditions can be made safe, and then requires the reduction of the risk and the provision of personal protective equipment (PPE).

Reduction of the residual or remaining risk, and the free issue of PPE, go hand in hand as a last resort of health and safety management.

The last layer of management or mitigation, should not be seen as a separate step in risk management. The law confirms that PPE is not the first, and never the only risk management measure.

For many employers it seems to be a quick and visible ‘safety’ solution, instead of the proper process. However the long-term disadvantages of an inadequate approach to PPE management, can be a costly business overhead.

Items  of PPE get lost, damaged, or supposedly ‘stolen’, because workers like shortcuts, or comfort, or just to appear tough.

PPE of the one size fit all kind, could be uncomfortable, sweaty, unhygienic, uncool, and unfashionable, even by the styles of sailors of the Renaissance.

In contrast, some workers wear PPE even after work, as a fashion statement. But PPE is not a fringe benefit. Like all measures to prevent injury or exposure to the vectors of infection and illness, it has to be managed well.

PPE items, and specifications, must meet or exceed the probable residual risk.
PPE items, and specifications, must meet or exceed the probable residual risk.

PPE law

In addition to the legal requirement of direct relevance to the residual risk of individual workers, there are a number of prescriptive legal requirements that PPE must adhere to in South Africa.

One such legal requirement applies to respirators, in VC 8072 of 2003, amended in 2011 by the Department of Trade and Industry, in Government Gazette 34272.

The selection and procurement of PPE must follow a definitive process. It is a rather complex and rigorously scientific process, which ideally should involve the company’s appointed occupational hygienist. Let us examine different types of PPE separately.

Foot protection, safety boots and shoes

The common purpose of foot protection is to protect the toes and upper part of the foot from falling or rolling objects, and the sole from sharps and slips. The common term is ‘steel toe cap (STC)’.

The selection of footwear to be issued to employees must be based directly on the risks they could be exposed to on site.

I have met a safety consultant who insisted that steel toe cap safety shoes must be issued to climbers working on lattice towers and cat ladders. The qualified climbers, with years of experience, disagreed, as falling objects and pinch points are not their risks.

Their risk is in losing your footing and falling from the structure. Most climbers use takkie-like shoes with non-slip soles and soft uppers to allow ascending walls and ladders with maximum feeling and flexibility in the feet.

The Institute for Work at Height confirmed that the final choice of footwear lies with each professional climber.

Hearing protection selection

One of the key issues around the selection of hearing protection is the noise reduction rating (NRR) of the device.

Ranging from ear muffs to disposable plugs, hearing protectors offer various degrees of protection, depending on its NRR. In cases of extreme noise levels, no single solution is available, and a combination has to be used.

With the maximum permissable noise exposure level of 85dB(A), any hearing protector with a NRR of 5 or less will be ineffective at noise levels above 90dB (A).

Most hearing protectors have a NRR, or reduction, of between 12 and 15dB, and can only be used in noise levels below 98 to 100dB. Above this level, a combination of two items, usually muffs and plugs, must be used.

Another disadvantage of these noise reduction devices is the feeling of isolation, and reduced speech recognition, which introduces a different set of hazards.

A number of devices are available that will allow normal speech to be heard, while still reducing excessive noise.

The selection of hearing protectors should ideally focus on the highest frequencies, and the ability of these devices to filter out the higher noise levels.

It is therefore not a ‘one size fits all’ solution, but will differ among noise zones. It is advisable to check the device specifications against frequency measurement reports provided by an approved inspection authority.

Eye protection selection

Eye protection offers two options: safety goggles, or a full face shield; and against two different hazards; flying objects, or electromagnetic radiation, such as welding rays or laser beams.

Eye protection has two major set-backs; effectiveness where the worker also wears glasses; and lens fogging.

More expensive goggles have a special coating to prevent fogging, but these require special cleaning methods, as dust and solvents can reduce the effectiveness of the coating.

According to Michael Eldridge, a US Marine veteran and founder of Safety Glasses USA, the key factors contributing to fogging include:

  • Ambient heat; temperature of the surrounding environment
  • Tight fit; overly snug, with lack of airflow. This problem is commonly associated with goggles and wraparound lenses.
  • High humidity; moisture in the air
  • Exertion; sweat adding heat and humidity from the skin.
Emergency plans may require additional and different kinds of PPE, from 'standard issue' for the site.
Emergency plans may require additional and different kinds of PPE, from ‘standard issue’ for the site.

A dust mask is not respiratory protection

Respirators are under- evaluated, and often replaced with a useless dust mask. A number of factors influence the efficacy of respiratory protection.

The shape and design of a typical half-mask respirator (covering nose and mouth) is limited by the facial characters and movement of the worker. Some air always by-passes the filtration medium.

Another key issue is exhalation causing hot air to blow back into the wearer’s eyes or safety goggles, if used in combination.

One solution to prevent this uncomfortable experience is to use half-mask respirators with an expiration valve to allow free flow of exhaled air.

Some disposable respirators allow much better inhalation and exhalation than others, particularly water-resistant types. The filter medium itself is the main consideration in the selection of effective respirators.

Most respirators use an activated charcoal or carbon layer inside the fabric, to trap most hydrocarbons. However not all chemical mists and vapours react with the activated charcoal, and still penetrates the mask.

Note that respirators are not to be used in atmospheres with an oxygen level of less than 20 %. In these cases a self-contained breathing apparatus, or air-line with full face masks must be used.

Consult the manufacturer’s selection guide to choose the correct type of mask and filter medium to protect workers from the chemicals that may be present during the course of work, or in the event of a spillage of material.

Respiratory protection should also be subjected to regular comparison with clinical data from medical surveillance reports. Any increase in the uptake of hazardous chemicals in the body is a clear indication of inadequate respiratory protection.

Employers’ duties in the selection and use of PPE

Careful assessment of the physical (such as dust, particles, sharps, and impacts) and chemical substances (in any form, including vapour, fume, mist, or spray) to which employees may be exposed, must be done in writing, preferably with sketch plans, before developing a purchasing specification.

The next step would be to select and test the proper and most effective PPE items based on the hazards and the level of exposure.

It is also a legal requirement that the proper use, cleaning and maintenance, as well as the limitations of the relative protection offered by individual devices, are explained to employees during induction, toolbox talks, and training.

Some employers are not aware that PPE may not leave the premises, and lockers must be provided for the safekeeping of PPE when not in use.

Some management requirements that the law does not provide for, include issues such as personal use and hygiene. Shoes, ear plugs and other items for personal use should not be shared among employees.

Ear plugs in particular can cause ear infection if not properly cared for and may even spread from one ear to the other through frequent interchanging between left and right ears.

In the food industry, the selection of ear plugs for instance can prove challenging, as these items are small and can easily end up in food containers such as bottles and cans.

How to select overalls

The typical blue cotton or poly-cotton overalls seen in factories around the country is in itself not regarded as effective PPE, as it offers very little protection from injury, save perhaps for accidental contact with a mildly hot surface.

Overalls may require special fabric to prevent static electricity, or protection against alkaline or acidic substances, or fine dust, or grit, or moisture.

The number and frequency of items that should be issued to a person may be regulated by the Basic Conditions of Employment Act, or a Sectoral Determination, or a specific Industry Bargaining Council.

It is advisable to develop a PPE policy that includes issue and replacement of PPE during a normal year. The longevity of an item depends on its frequency of use, and level of care.

The standard safety shoe lasts about 12 months if worn daily, and cared for. More expensive shoes may last up to three years, but when frequently used in wet environments, this life cycle is greatly reduced.

A proper record of return and issue will assist in establishing the turnover of a particular item in a specific environment or section of the workplace. This information can then be used to improve the selection process. The disposal of used PPE is also important, as “discarded items” may re-enter the employee pool more than once.

It also important to note that PPE used for protection against asbestos and lead are regulated by separate regulations and must be treated as contaminated waste and disposed of in the prescribed manner.

Workforce consultation on PPE

It is vitally important to consult the Health and Safety Committee,  or workplace forums or shop stewards, on the PPE policy.

There should be parity based on exposures; not on seniority or any other basis. However PPE is contagious. We had once issued windbreakers to staff working in low temperatures of 5 degrees Celsius and less, but within a few months, the items became “standard issue” to all staff.

The selection and issue of PPE must be done on scientific grounds and with the necessary  discipline from all managers to ensure its effectiveness; consistent use; personal care; and integration into the organisation’s health and safety culture.

  • Pieter Lotz (Nebosh International Construction Certificate, and Samtrac) is the Principal Consultant for Cygma SHEQ in Limpopo province, based in Polokwane. Contact him via email here.
  • Cygma SHEQ has developed several PPE policies for employers, including Bidvest Port Operations (formerly SAS), Oceana Foods, and Servest.
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4 thoughts on “How to develop PPE policy and management

  1. Hello Koos. By the looks of reports on sexual abuse and harassment in the Platinum Belt, it should be. It is any case already issued for free to just about everyone with a slapstick. It will soon also be classified as hazardous waste as public parking lots are littered with the stuff. With enough sun, who knows what will come next (pardon the pun).

  2. Please do not loose sight of the fact that PPE is a last resort.
    The hierarchy of hazard control is Elimination; Substitution; Engineering; Administration; Personal protective equipment.

    Regarding anyone needing a condom at work, I would say they are in the wrong profession. Unless they are mariners and or divers and want to keep their cigarettes and matches dry.

    The best option of course would be to eliminate the need for such PPE to be supplied at work. Perhaps provide those who feel they need to have condoms at work with a personal blow-up doll, or fake rubber vagina, and a bottle of vaseline!

    I fail to see how condoms are relevant to workplaces, unless some staff are “(F) ing up” in\at work?! Or sex workers of course. Which currently in this country are not professional of recognized, and are illegal.

    If sex workers are active at work, then replace them with other who have better morals, and/or administrative measures. And ensure training?

    Sexual abuse and sexual harassment is illegal, and actively prosecuted.
    Do condoms count as workplace PPE in South Africa? I would say NO.

    However some safety practitioners are uniformed, uneducated and inexperienced, and are considered pricks, and thus may need them!

  3. Brian, I think the condom issue was a bit tongue in cheek. I like your idea of replacing sex workers with ones with better morals. I am sure the “look, but don’t touch” idea will go down well in the current economic climate. Likewise, some safety measures tend to slow down the economic machine.

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