Since last March, a major focus on correct PPE wear has been on masks – you can even buy masks that include a reminder that the mask is supposed to cover the nose. However, I have seen too many incidences of improper usage of PPE or lack of checking whether an employee is even wearing their provided PPE over the years. Today’s workplace safety tip from OSHA is a reminder to make sure that your employee’s are properly wearing their PPE.
Most employers will say that they offer their employees any possible PPE that you can think of to keep their employees safe. While writing job descriptions, I have even seen storerooms that are stocked better than any supply store with steel toed boots, all manner of gloves, safety vests, etc., but many employers don’t always check to see that it is properly used.
Next time you drive through a road maintenance project, take a good look at the road crew. Are they wearing eye protection as they are prepping the road surface or is their eye protection flipped up and sitting on top of their head? Are they using any type of ear protection as they are using the blower or operating heavy equipment to patch the surface of the road? Last fall while out with a road crew, I asked one of the crew members why they weren’t wearing any ear protection when they were shoveling out the road surface while the grinding attachment was running. The answer was “Well, they were in my truck and it is hot and sweaty out today which makes the ear plugs fall out. Besides, I played in punk and metal bands for 25 years so my hearing isn’t going to get any worse.” These are not great answers…..and the rest of the crew wasn’t much better. When one was asked about eye protection after blowing out a pothole, “It’s tough. I know I should wear something but that road is half in the shade, half in the sun and my glasses are either too light or too dark.”
In another case, an employee was sent to us for a Fit For Duty test. As the employee was filling out paperwork, they shifted in their chair. The foot that had been tucked under the chair came into view and I noticed that the employee was wearing a camwalker (walking boot). The Fit For Duty hadn’t been for any issue related to a foot or ankle injury. When I asked about the boot, I was informed that they were not cleared for shoes yet due to a partial amputation of the foot. The employee then told me that they had been working like this since the amputation. The employer has a rule requiring the use of safety boots while on-site. Nobody had realized that the employee was limping (due to the amputation and the rocker bottom of the camwalker) and didn’t notice because the camwalker was black like the employer issued safety boots.
One of the safety directors at a client site used our visits as a chance to provide gentle reminders to site personnel about wearing their appropriate PPE whether it was boots, gloves, vests, or hardhats. If he saw an employee that was missing PPE, he’d ask me to ask for some information about their job – which is why I was there in the first place – and then as we were leaving, give a subtle “If you need an extra vest/boots/gloves/etc., stop by the office and we’ll get you another set.”
Be proactive in making sure that employees are wearing the appropriate PPE at all times so that they remember to wear it without needing to be reminded.
Some of the OSHA daily tips seem like they shouldn’t need to be said – much like today’s tip. But, we’ve all gone into a bathroom in a workplace – either as an employee or as a customer – that didn’t have hand soap or paper towels. During the pandemic, I can think of many different places that had hand sanitizer set up in key locations only to be left without having been refilled.
While hygiene supplies – whether it is soap, paper towels, or hand sanitizer – have a cost, that cost is significantly less than the cost of having one or more employees call out sick.
Even though we have been watching graphs of positive COVID cases go up and down over the last year, physicians have seen illnesses such as the flu and the common cold decrease over the same time. Public health officials attribute this to people washing their hands regularly, watching their distance, and covering their sneezes and coughs.
Training only works if the people that you are training understand what you are trying to share with them. When it comes to health and safety procedures, you need to make sure that the message gets to your employees.
OSHA offers a great e-mail feature that provides a workplace safety tip in your e-mail on a daily basis. Today’s tip was a solid reminder that while masks can help prevent spread of COVID, they are not a substitute for physical distancing and barriers.
Personal protective equipment (PPE), whether masks for COVID or hearing protection in noisy areas, is considered the last line of defense in protection of employees. Employers should attempt to use engineering controls or administrative controls to reduce or mitigate risks before relying on PPE to protect an employee.
Engineering controls involve changes to the physical workspace that change how a task is performed. When possible, engineering controls are the preferred over administrative controls because they help to mitigate risks at the source.
Engineering controls for COVID include physical barriers between workstations, changes to air filtration, inclusion of decontamination stations, installing drive through windows, installing contactless payment kiosks, etc.
Engineering controls for non-COVID related issues may include reducing the weight of objects, the use of assistive devices to handle materials, or machine guards.
Administrative controls involve changes in policies, procedures, and practices to reduce risks. Administrative controls rely on changing workers behaviors in a task and are not as effective as engineering controls.
Administrative controls for COVID include encouraging sick employees to stay home, use of Zoom meetings over face to face meetings, and establishing alternating workday cohort schedules.
Administrative controls for non-COVID related issues may include job rotation schedules, written operating procedures for a task, warning signs and alarms, etc.
With non-COVID related issues, the first steps are to identify the hazards and risks so that a decision can be made as to what engineering controls or administrative controls can be put into place. One of the job description projects that we had performed helped to expedite the purchase of an engineering control solution for a client.
County Weights and Measures personnel are responsible for testing the accuracy of pumps at gas stations and typically have performed this task using calibrated 5 gallon tanks that are filled at the pump and then poured back into the fuel storage tanks after measurement. This can be a dangerous task as it relies on drivers noticing the cones that may be placed to show that a pump is not available for service or notice the safety vest worn by the Weights and Measures employee.
After documenting this task for the custom job description, a suggestion was noted that the specialized pickup mounted collection and measurement device would reduce this risk. The device allows Weights and Measures officials to pump directly from the gas pumps into a truck mounted collection device that can be moved from pump to pump, rather than making multiple trips carrying 5 gallon containers across busy parking lots. This engineering control allows for significant reduction in risk of injury to the employee.
As I walked out of the foodstore after grabbing lunch, I was reminded of why it is so important to have solid job descriptions for heavy equipment operators. I watched the operator of this piece of equipment hop out to shovel snow into the scoop because the plows had piled the snow in a location that was inaccessible to the heavier equipment.
I can’t even count the times that I have listened to a heavy equipment operator say during an FCE that they don’t need to be there for physical testing because all they do is sit and operate a piece of equipment. Many times, this was a tricky situation because the employer did not have a job description that had more than a couple of bullet points, typically noting requirements to be certified to operate certain types of equipment. This can sometimes take the return to work decision from the physicians and rehab professionals and place it in the hands of the lawyers to argue over what tasks are actually performed by the employee.
The Dictionary of Occupational Titles entries don’t often offer much help for equipment operator positions as they include information about tasks the equipment might be used to complete but they don’t provide a clear picture of the entirety of the position. Over the years, I have been out in the field with equipment operators who operated all manner of heavy equipment and were also responsible for other tasks during the course of their shift. These tasks included manual digging with shovels (or even shoveling snow into the loader), carrying equipment, lifting and carrying debris to a loader bucket for removal, adding or removing different attachments to the heavy equipment and more.
In addition to the physical tasks, I have been in locations that have required heavy equipment operators to walk across wet and/or uneven terrain just to get to their equipment. As I write this post, people are still digging out from Winter Storm Orlena which dumped anywhere between 15 and 30 inches of snow across the northeast. Many equipment operators have had to walk across slippery parking lots, covered in ice and snow, to get to their assigned loaders. On large construction sites, while the site is still being graded and excavated in preparation for construction, operators often walk across muddy, uneven areas. This mud can cake up in the steps on the side of the equipment making that 20 inch first step into a 23 inch first step as well as making things a little more slippery for climbing on/off of equipment.
While I have been on job sites in which the heavy equipment operators are solely operators – typically on sites where multiple unions are working together – the majority of sites have had heavy equipment operators that fill multiple roles or maybe assigned tasks other than operating equipment.
Take a minute to check your job descriptions.
Do they include information on getting to and from equipment? (Where might they be walking?)
Do they include step up height for the different pieces of equipment that are operated?
Do they include the additional roles and responsibilities of the operator? Do they help with manual digging with a shovel? Do they have to pick up materials for loading that may not be able to be accessed by the equipment?
If you are wondering whether your job descriptions provide enough information about the essential minimum postural and physical demands as well as describe the essential tasks in a way that explains them to the treating physician or therapist, give us a call at 732-796-7370 or e-mail me at email@example.com.