Building a Robust PPE Program

Establishing a PPE program will provide guidance to the organization, visitors and the OSH professional.

OSHA’s requirements under the general duty clause state that “each employer shall furnish to each of its employees employment free from recognized hazards that are causing or are likely to cause death or serious physical harm.” It is the employers’ responsibility to understand the hazards associated with the type of work within their organization and to mitigate hazards to an acceptable level.

According to the Bureau of Labor and Statistics (BLS), employers reported 2.7 million injury and illness cases in the private industry in 2020. Occupational safety and health (OSH) professionals have the responsibility to assess and address workplace hazards and to provide a means to mitigate the hazards that are known or identified through an assessment in their organization. To mitigate hazards, OSH professionals must have a vast knowledge of codes and industry safety standards to assess and address workplace hazards and implement corrective actions.

Once the hazards have been recognized, and all other controls have been exhausted, personal protective Equipment (PPE) shall be selected as the last line of defense. The OSH professional shall select the appropriate PPE and establish a program. The purpose of a PPE program is to ensure processes and procedures are met and to ensure consistency. To have a successful PPE program, the OSH professional must establish a process that identifies management’s commitment, worker participation, hazard evaluation, hazard mitigation, training and education, program evaluation and continuous communication for the PPE program to be successful.

Hierarchy of Controls

Once the OSH professional understands the hazards with the job or task within their organization, the OSH professional shall determine a means to address the hazard before directly utilizing PPE. One methodology is to use the National Institute of Occupational Safety and Health’s (NIOSH) Hierarchy of Controls. The Hierarchy of Controls consists of five methods to help evaluate and mitigate the hazard, listed below from most effective to least effective:





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