Personal Protective Equipment (PPE) is the last line of defense against occupational hazards. PPE should be considered only after more effective controls have been examined (elimination, substitution, engineering, and administrative).  In order for PPE to protect the user, it must be selected, stored, maintained, and worn properly.  

In addition to the roles and responsibilities described in UVM’s Policy for Workplace Health & Safety, the following apply specifically to the use of PPE:

  • Failure/refusal to wear required PPE is a basis for disciplinary action.
  • A student not wearing course required PPE in a laboratory or technical area may not participate in lab activities until such PPE is worn.
  • Workers may be liable for costs associated with injuries that would have been prevented by proper use of PPE when they have willfully not used that PPE.

Contact Risk Management and Safety (RMS) to assist with assessments and training.

Contact Labor and Employee Relations (LER) to assist with non-compliance.

 

Procedures

Supervisors and Managers

  1. Identify job classifications and tasks that require hazards assessment.
  2. Assess hazards in consultation with RMS/TCO. Document hazards assessments and maintain records.
  3. Ensure employees receive training in proper use, storage, limitations, and maintenance of PPE and maintain documentation of personnel trained.
  4. Ensure PPE is provided to employees as appropriate and that PPE is free from defect.
  5. Ensure required PPE is being properly used by affected employees and students when and where hazards exist in workplaces for which they are responsible.
  6. Review tasks as hazards change or at least every 3 years.

Individual Employees, Students, and other Affiliated Personnel (Workers)

  • Inform supervisors of hazards encountered on the job, or in the lab, shop, field, or other area.
  • Wear PPE when appropriate and/or at the direction of a supervisor. Inspect PPE prior to use and replace as necessary.
  • Clean, maintain, and appropriately store PPE according to manufacturer’s recommendations or best industry practice.
  • Do not re-use PPE that is designed for 1-time use (disposable).
  • Immediately notify supervisor of damaged or defective PPE, new hazards, physical changes, or other conditions where PPE does not offer adequate protection for the hazard.

Academic courses which include laboratory, shop, or field work are required to indicate hazards and controls, including required PPE. The sponsoring college or department may provide this PPE from operating funds or student fees, or require students to obtain the specified PPE. Common communal PPE such as thermal protection, welding aprons, face shields, etc., will be provided by the sponsoring department. The instructor of record for a course, or designee, is responsible for ensuring that students are familiar with and properly using required protective devices

Risk Management & Safety (RMS) and PPD Training &. Compliance Office (TCO)

  • RMS communicates the requirements and resources of this policy to departments and campus community.
  • TCO consults with departments/units to identify and assess risks associated with asbestos, lead, and silica as these relate to facilities.
  • RMS consults with departments/units regarding other risks.
  • RMS recommends PPE to supervisors in departments/units across campus. TCO recommends PPE to supervisors in the Physical Plant Department
  • Provide general training in use, maintenance, and limitations of PPE.

All individuals shall report unsafe conditions, accidents, and chemical spills or exposures to their supervisor, RMS, and/or the Ethics and Compliance Reporting and Help Line . The University prohibits retaliation for good faith reporting of safety issues. Procedures devised for handling hazardous situations and materials shall be followed conscientiously and any member of the campus community shall feel authorized to stop work if they believe that continuation of the work poses an imminent danger to their safety or health or that of people in the vicinity.

 

Risk Assessment Tools

A risk assessment of the workplace or work task should be conducted in order to select the PPE that is appropriate for the workplace hazard.  A risk assessment is used to identify all possible hazards of a job or work area and ways to minimize or eliminate exposure to the hazards. 

Below are risk assessment tools available to supervisors and managers: 

  • Write a Standard Operating Procedure (SOP) for the work task.  Include roles and responsibilities for every person involved in the work, specify clear and simple instructions for the task, and include things can go wrong (i.e. "what if" scenarios). An SOP is also a useful training tool for new personnel
  • If the work includes the use of a machine, instrument or other piece of equipment, consult the manufacturer's instructions for PPE recommendations.  
  • Conduct a Job Hazard Assessment, or JHA (PDF) of the task. A JHA is used to identify each step in a job task and all of the potential hazards. The results of the JHA can be used to determine the appropriate PPE for the task. 
  • Use the Chemical Use and Planning Form (PDF) for work involving chemicals

For more information on PPE selection, visit OSHA's publication on PPE (PDF).

Please contact RMS with any questions. 

 

PPE Limitations

All PPE has limitations. This is why PPE is referred to as the last line of defense and why administrative and engineering controls are utilized before determining PPE use. Specific hazards require specific PPE selection. Remember, no one material protects against every hazard.

PPE limitations

  • PPE may restrict movement, dexterity, field of vision, communication, and/or comfort.
  • Misunderstood or misused PPE may provide a false sense of security.
  • PPE that is too large, too small or otherwise poorly fitted may result in overexposure to a hazard.
  • Inproper donning and doffing procedures may expose the user to hazards.
  • PPE must be maintained properly to be effective
  • When contaminated, the user must stop their work and change PPE.

The value of keeping yourself protected greatly outweighs any PPE limitations.

 

Maintenance and Replacement of PPE

Each employee or student is responsible wearing all required PPE in the correct manner.  Employees and students are responsible for informing their supervisor when worn or damaged PPE needs to be replaced. PPE used for hazardous materials protection, including laboratory coats, shall not be laundered at private residences or public laundry facilities. Any protective clothing that becomes contaminated with hazardous materials must be decontaminated prior to being laundered or appropriately discarded. Colleges/Administrative units are responsible for providing suitable laundry services and/or facilities to maintain required PPE, including laboratory coats.

 

Training

Since PPE can fail, those who wear it must be trained to understand its limitations. Each supervisor will conduct training to ensure workers know how to properly wear, adjust, and maintain assigned PPE. Workers must demonstrate understanding of the proper use of assigned PPE. The training must be documented (record the date, time, name of trainer, and name of employee or student) and cover these elements:

  1. When PPE is necessary;
  2. What PPE is necessary;
  3. How to properly don, doff, adjust, and wear PPE;
  4. The limitations of the PPE, and;
  5. The proper care, maintenance, useful life, and disposal of the PPE.

 

Re-evaluating the Appropriateness of PPE

Each supervisor is responsible for periodically re-evaluating the selection and use of PPE in work areas under their control. The hazard assessment should be repeated when new hazards are identified or introduced into the workplace or at least every three (3) years.

 

PPE Regulations

OSHA requires that employers attept to control risks trough adminsitrative controls, engineering controls, and work practices before relying on Personal Protective Equipment. When PPE is required, OSHA regulations stipulate how it is selected, provided, maintained, and used.  The quick links on this page are to UVM information for specific types of PPE. OSHA's regulations for PPE can be found at 29 CFR Subpart I - Personal Protective Equipment

 

Contaminated PPE must not be worn in common areas.

Make sure to remove all hazmat-related PPE before traveling from an area of contamination (including laboratories) into hallways, breakrooms, elevators, or bathrooms.