For PPE, There Is No Such Thing as One Size Fits All
By Susen Trail | 07/28/2022
The first day of my Ergonomics course at the University of Michigan Professor Strong explained how chairs, mostly not adjustable in those days were built for a 6' tall male. Which explained a LOT. He went on to point out that 6' males were not the majority at the time so this practice was "one size fits" few. As a result, office workers and people who spent a great deal of time seated were experiencing back and other ergonomic problems.
The Occupational Safety and Health Administration’s (OSHA's) Permissible Exposure Limits (PELs) were adopted wholesale from the 1968 American Conference of Governmental Industrial Hygienist (ACGIH) Threshold Limit Values (TLVs). The data for the limits at the time often came from studies conducted by the military. As a result, the limits are relevant to young, healthy, fit men. As time went on ACGIH added new, or adjusted some, TLVs from research that includes both male and female volunteers made up of graduate students or students of the professors doing the research. Some research is conducted on worksites, even so, the studies almost always use(d) younger, fit volunteers.
To access the TLVs you usually have to be a member, or purchase the exposure limits. However, in 2018 OSHA created a webpage with a Table that compared multiple exposure limits including a link to each chemical's TLV. Often your Safety Data Sheet (SDS) will include OSHA exposure limits, ACGIH TLVs, and some include the National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limits, or Occupational Exposure Limits (OELs) from other standards setting organizations or governments. This is another reason you want the most recent version of the SDS.
Most exposure limits, including TLVs and PELs have a 10X safety factor. This means they take the concentration at which the Lowest Observable Effects Level (LOEL) occur and divide it by 10 to set the limit. However, even a 10X safe level, may not be protective when your employees are over 50 years old, and/or is diabetic, pregnant, asthmatic, and so on.
There are other variables an individual may have that thwart your efforts to protect them. An employee with exposure to a chemical that reacts with the sun to give the employee skin cancer turns out to bike marathons in his spare time. Or an employee with non-intact skin, creating a breach in a normally protective barrier allows chemicals into the body by an additional route. In this case the air monitoring data is no longer representative and you have no idea what the body burden (amount of the chemical that is in the body) is at the end of the work shift.
Then there are the variables introduced by the employer. Very few of OSHA's exposure limits are correctable for extended shifts. For example, 1910.95 has a formula to reduce the exposure limits based on the duration of exposure to noise due to the shortened recovery time for the nerves in the ear before the next shift begins. Speaking of noise, there are also chemicals that work with other chemicals, or hazards such as noise, called Ototoxic chemicals that create adverse health effects below the noise standard’s exposure limits.
Where the production process creates a vapor, mist or aerosol it greatly increases skin exposure. (Always check the SDS for this hazard as well as the sensitizer hazard.) Another consideration are processes where multiple chemicals have the same target organ, common with solvents, and the exposure needs to be calculated using fractions and the limits, it's a whole thing but important.
Many Safety Managers select gloves for chemicals with skin exposure hazards but forget to consider that airborne chemicals can land on far from the source. Everyone in the area needs protection for the skin on their faces, ankles, forearms, anything not covered, if the chemical has a physical hazard, such as corrosive, or can be absorbed through the skin. Also, it's time to realize that Nitrile gloves are not resistant to all chemicals. In fact, a chemical mixture might have one chemical that cannot cross Nitrile gloves while another chemical in the mix slips right through, or minimally degrades the glove. Not only is glove material selection tricky but it may result in gloving with more than one type of glove material.
Paraphrasing our blog title, one size of Personal Protective Equipment (PPE), especially gloves, do not fit all and fit is extremely important. Large hands need to be accommodated because the glove material’s resistance to a chemical is based on the thickness of the glove at the location of exposure. When the knuckles or fingers of the glove are stretched then the resistance to the chemical is reduced, possibly eliminated. Gloves that are too big are difficult to use by any employee expected to manipulate small parts. It is important to include this information in the training so that employees report fit problems. When poor fit is manageable a good employee wanting to do their part is tempted to take their gloves off, resulting in exposure to a chemical that may, someday, be found to have adverse reproductive effects. And, there’s the rub! Chemicals are being introduced with their SDS Section 11, Toxicology, peppered with NA, as in the data is Not Available, read "we do not know at this time." However, I've found that employee’s read "Safe"!
Gloves and other PPE MUST fit and must be selected for their protective properties. When in doubt do not ask the chemical manufacturer, ask the glove manufacturer. When I was in enforcement I often sent an SDS to the glove manufacturer to be sure the Safety Manager's choice was effective.
PPE is the most common choice when employees are exposed to hazardous chemicals. However, because employee fatalities from diseases show up years after their occupational exposure most employers don’t see the results of chemical exposures. There are approximately 162 occupational illness fatalities per day. Most likely that is a serious underestimation because it is very hard to connect an exposure 10 or more years in the past to the illness. Especially, if it was not known that the chemical could have that adverse effect at the time of exposure so it was not part of the employee’s Hazard Communication training. Since the Bureau of Labor Statistics does not count long term, or latency illness cases few are aware of the fact that the number of people dying at home, in hospice, or hospitals has not decreased with the same alacrity as fatalities that are visible, such as falls, or crushed between accidents.
This is why OSHA provides requirements such as paragraph (e) of the air contaminants standard:
1910.1000(e) To achieve compliance with paragraphs (a) through (d) of this section, administrative or engineering controls must first be determined and implemented whenever feasible. When such controls are not feasible to achieve full compliance, protective equipment or any other protective measures shall be used to keep the exposure of employees to air contaminants within the limits prescribed in this section. Any equipment and/or technical measures used for this purpose must be approved for each particular use by a competent industrial hygienist or other technically qualified person. Whenever respirators are used, their use shall comply with 1910.134. [71 FR 16673, April 3, 2006; 81 FR 16861, March 25, 2016]
Because there is no such thing as 'one size fits all' when it comes to employee protection the sight of PPE to an enforcement officer is like waving a red flag to a bull. What is the hazard, where is your documentation showing engineering controls for this exposure do not exist, or, if there is an engineering control, why has it not been implemented? Always look for an engineering, or administrative control (such as rotating employees to reduce exposure.) Document your search so you don’t repeat previous investigations. Reduce your next research into new methods and equipment for control. Never stop looking and don't forget to ask the engineers to substitute a chemical that is not as hazardous, or at least better researched than what you have now.
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