Does your safety program have any safe work practices or does your Process Safety Management system have procedures with this requirement? It seems to be the fairly commonplace to require personnel to “have PPE available” for some critical tasks that can turn into an IDLH environment rather quickly. For those not familiar with this “practice”, it basically means that the worker doing the tasks does NOT have to have the PPE donned, just merely have it with them. We see some companies require the PPE to be within arms reach; however, most make no attempt to define “have it available”. Do we actually believe this to be a solid safety procedure when this is allowed?
Imagine having a procedure that requires the worker to have their respirator with them, but not actually on their face. The concept behind this practice is that should there be an incident where the employee’s exposure increases to a point he/she would need the respirator that they would have it with them and could don it immediately. Does anyone see an issue with this concept? Let’s say the employee is changing out a chlorine cylinder or draining oil from an ammonia refrigeration process. Do we actually believe that with these two HHC/EHS’s that in the event of an uncontrolled release that the employees will reach for their respirator, don it while standing in the hazardous atmosphere and then evacuate the hazard zone? Does anyone else see the problem with donning a respirator in a contaminated area? We have seen this practice applied to many different HHC/EHS’s, as well as to many different forms of PPE; from chemical boots and goggles to air purifying respirators and for some reason it seems to be used with those chemicals that have very HIGH vapor pressures and very LOW level of concerns (LOCs) such as Chlorine and Ammonia.
We have to reach a point in our acceptable level of risks where we find this “practice” as UNACCEPTABLE. We will never be able to eliminate all our risks; however, even though PPE is our last level of hazard control in our hierarchy of controls we must apply this level of control properly. PPE ONLY works when it is used properly within its limitations and to use it properly it MUST be DONNED BEFORE the exposure event occurs and since we are not yet able to predict accidents this means we need to be PREPARED for the unexpected. A respirator in a tool box or hanging from a valve handle does NO GOOD to the worker when it is needed! Do we really believe that by requiring our personnel to DON the PPE BEFORE it is actually needed will somehow be viewed as “extreme” or just “good measure”? If we view this as extreme, we have a ways to go in our true perception of safety and I believe our workers deserve better.