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You wouldn’t use a rubber mallet to try and drive a nail. Instead, you’d get a claw hammer which is designed for that purpose. In other words, you would get the right tool for the job. That same logic applies to personal protective equipment (PPE). You would never knowingly enter an oxygen deficient atmosphere wearing a disposable dust mask; or wear latex gloves to take a cake out of the oven.
Recently, while conducting a mock OSHA inspection, I ran across tags which were provided by a vendor and attached at the dispensers to serve as container labeling for hazardous materials in pipes. One, a sanitizer/deodorizer, stated, “Wear protective eyewear (goggles or faceshield)..”
The other was an acid and the PPE information stated, “Wear protective gloves, eye (or face) protection …”
Both of these are suggesting to the user that they have a choice: they can protect their face or choose, instead, to protect their eyes.
There is a very common misconception that a faceshield is adequate eye protection from hazards such as flying particles and corrosive chemicals. According to ANSI Z87.1-1989, which OSHA has incorporated by reference, a faceshield is considered to be a secondary protector which, “…shall be used only in conjunction with a primary protector.” In other words, a faceshield affords limited protection and should never be worn without some other protector such as safety glasses or the appropriate goggles; in this case, chemical splash goggles.
Note: The use of a faceshield alone would not be adequate eye protection.
When conducting your PPE hazard assessments, as required by 1910.132(d)(1), become familiar with the properties of various types of PPE. Read the appropriate consensus standards and manufacturer’s recommendations. The purpose of conducting PPE hazard assessments is to enable the employer to make informed decisions on proper selection. If the ones doing the selecting are unfamiliar with the pros and cons and the intended use of PPE, they are unable to make wise selections.
If you would like to schedule an mock OSHA inspection of your facility or have questions regarding PPE and OSHA regulations,. please do not hesitate to contact me at 919-593-2145 or firstname.lastname@example.org.