Assessing Your Personal Protective Equipment Program
Paula Penning Certified Prof. Environ. Auditor
Having appropriate Personal Protective Equipment (PPE) Programs are vital for helping protect employees and complying with the provisions of such safety standards as ANSI, NIOSH and OSHA. This article offers readers useable information and ideas on how to perform a cursory review of their programs. While it discusses basic information on reviews, it does not replace the need for an assessment conducted by a professional auditor, nor does it imply that the reader will be in compliance with government regulations if they follow the information. Only Government Agency Inspectors can perform a compliance audit and only an Agency Inspector can tell you if you are in compliance with their standards.
Creating a Review Checklist
The goal of a PPE Review is to determine gaps between PPE programs and the standards against which they are measured.
The first part of any effective review is to determine what should be measured. Some examples of PPE Programs that may be part of a review include: eye protection, head/face protection and respiratory protection.
After a list of programs has been compiled, one needs to determine what controls the programs. Examples of documented controls include:
¥ Government regulations
¥ Company safety and health policies
¥ Company standard operating procedures
¥ Company claims
¥ Training programs
¥ Industry guidelines
¥ Government guidelines
¥ Customer expectations
The next phase in the review process is to create a checklist of all the requirements the program must meet. This can be accomplished by reviewing each standard, and thinking of each requirement in the form of a question. For example, if one is reviewing eye protection and the company health and safety policy requires everyone to wear safety glasses in manufacturing areas, one would ask "is everyone wearing eye protection in manufacturing areas?"
Next, consider how to determine the answer to the question. In this case, how can one determine whether everyone is wearing safety glasses? A reasonable method would be to monitor persons entering or working in the manufacturing area at several different times during the day.
Often it is impossible to observe every person in the facility at all times during the day. In those cases samples may be used and conclusions may be drawn based on a sample size, rather than an entire population.
Following are some techniques that can be used to determine a representative sample.
Select a monitoring time during a busy period when there will be a number of employees to view. Observe personnel after lunch or break to see if employees remember to put their safety glasses back on. Sample times can also be chosen completely at random, by using a random number generating program.
When choosing a sample it is important to keep in mind that personal knowledge of the facility or an operation may cause unintentional skewing of a sample. This may be countered by randomizing the sample selection process. Randomizing selection can be as simple as pulling operations to review out of a hat.
An additional issue that may come up is determining the appropriate number of operations to review. An important point to keep in mind is that a small sample size (one or two) will not normally provide enough data on which to make a confident conclusion. Some possible resources for guidance on sample size determination include quality control engineers, an internal auditing department or a professional auditor.
The next step in the process is to review the task. It is important to keep the tasks objective wherever possible. Objectivity means that one is working in a way that is not influenced by emotional or personal bias. A good example is setting time and location guidelines and actually observing people at work, rather than asking people if they wear their safety glasses. Asking someone to answer a question will typically get a subjective response. It is best to avoid writing steps that tell the reviewer to ask someone a question.
Observing can also be subjective. It is important that the person assigned to the PPE Program Review understands the importance of being objective. A good way to do this is by setting review criteria such as location or time. This is illustrated by the following format:
1. Verify that employees entering manufacturing area A
are wearing safety glasses by monitoring the entrance
from 8:00 to 8:30am. Company XYZ Standard Operating
Procedure Part 2.6
2. Verify that employees working in manufacturing area
B are wearing safety glasses by monitoring the work area
at 1:30pm and again at 4:00pm. Company XYZ Standard
Operating Procedure Part 2.6
A "notes" section after each step is part of the review document. This allows the reviewer to document what they found. In the example above, the best way to document observations would be to note the total number of employees who were not wearing eye protection versus the total number of employees. A "note" may be worded as: "2 of 18 employees were not wearing eye protection."
The above format also references the standard on which the step was based. Adding this enables quick reference between the task and the standard; and it is also helpful for follow up and perhaps employee training after the review is completed.
The checklist is the quality control for the review, therefore it is imperative it is thorough and easy to follow. Persons performing the review should be required to sign off on each step when it is completed.
Some PPE programs require medical surveillance or medical approval. It is important to note that only health care professionals are able to review medical records. A facility health care professional can assist with reviews of medical information.
The following examples illustrate the importance of having a health care professional part of the review:
First, the review is written based on the PPE standards that include medical information. The health care professional would then be given a copy of the review checklist and asked to complete it.
Second, the health care professional can confirm information while the review steps are read. For example, one can ask the health care professional to confirm if anyone experienced a hearing threshold shift last year. If yes, one could ask them to confirm whether whoever had the shift received a second audiogram.
If medical services are outsourced, request a copy of the provider's quality control program to verify that medical services are consistently being performed according to standards.
Depending on the number of PPE Programs that must be reviewed, it may be helpful to ask others to assist. It is important for the person assisting to understand the importance of closely following the Review Checklist. Mentoring or a short training session on proper technique can be a useful tool. The best training method may be to simply allow someone to observe an experienced reviewer. This training can then be followed up by observing the new reviewer's work and providing feedback.
Important skills a reviewer should learn include good observation skills, writing clear and concise notes and signing off on each step on the review checklist when completed.
Reviewing a program takes discipline. Even experienced health and safety professionals may simply browse through a written program and state that it looks "OK," rather than verifying it contains all elements required by a government agency. If followed, the written checklist will help guide the reviewer by specifying what they are to do. It will also help assure that anyone assisting you is performing the review in a similar manner.
What to Look For In A Consultant
When determining which consultant to use one should look for:
¥ Health and safety auditors with experience in internal or
financial auditing.
¥ Health and safety auditors who have knowledge and
understanding of audit methods and techniques.
¥ Health and safety auditors who have received training by the
Institute of Internal Auditors.
¥ A firm or individual who has a quality control program.
This will help assure a consistent review every time the firm or individual is used.
The audit program the firm or individual is using is based on objective sampling and data gathering, rather than subjective observations.
Development of PPE reviews is an important part of an overall company PPE Program. When written and implemented properly a review can be a helpful tool in determining such things as whether employees are using their equipment, whether records are being kept properly and if training has been completed. A review, however, is only as good as the information and test methods put into the checklist. Beginning with the subject to be reviewed, the standards that control it, and the importance of objectivity, a checklist can be developed that can assist a PPE Administrator in determining whether they have an effective program.
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