With the long winter we have had, everyone will be eager to wear their flip flops and shorts this spring. Do you have a policy in place requiring closed-toed shoes and leg covering in your labs?
There are many reasons to have a Personal Protective Equipment (PPE) policy in place, including being compliant with OSHA requirements. 29 CFR 1910.132 establishes the general requirements for PPE, including employers’ responsibilities for evaluating and selecting appropriate PPE and implementing a compliant program. There are numerous other standards with specific requirements for eye and face protection, hand protection, head protection, etc. In addition, the Lab Standard (29 CFR 1910.1450), requires covered facilities to develop and implement a Chemical Hygiene Plan that establishes policies for Personal Protective Equipment and work practices to prevent occupational exposure to hazardous chemicals. And common sense says that employees need to be protected from occupational exposure to hazardous material in the workplace.
Employers are responsible for performing hazard assessments to evaluate the physical and health hazards associated with their workplace. Once appropriate PPE is selected, employers are responsible for providing the appropriate PPE to their employees and training employees on the proper use and care of the PPE. It is the employee’s responsibility to comply with the established PPE policy by wearing the available PPE and caring for it properly. PPE needs to be replaced when it shows signs of being damaged or worn, and employers should evaluate their PPE program on a regular basis.
Evaluating the need for closed-toed shoes and long pants or skirts that fully cover the legs should be included in the review of appropriate personal protection. Remember to consider factors such as the risk of dropping glassware, which would present a hazard to any employee wearing flip flops or sandals. Under 29 CFR 1910.132, the employer is not responsible for paying for everyday clothing, such as long pants and street shoes.
Now is a great time to review your PPE policy and remind all employees of their responsibility to comply with it!