This week, OSHA once again showed their intent to issue PPE citations during PSM NEP audits. They are very content to issue a citation against 1910.132(a) or (d) when the process contains a flammable liquid and somehow the employer’s PPE Hazard Assessment determined that Flame Retardant Clothing (FRC) is not necessary. But there is another VERY STRONG and DIRECT link between PSM and PPE… Operating Procedures.
Operating Procedures (often referred to as SOPs) are required to contain the following:
1910.119(f)(1)(iii)(B) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;
So with that said, ask yourself… how did we determine the PPE that is needed for each SOP? In the good ole days we could claim we used the MSDS (now called an SDS), but several years ago OSHA updated/revised their PPE standards. One of those revisions was to require the employer to conduct and certify a PPE Hazard Assessment.
1910.132(d)(2) The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.
So in essence, don’t be surprised if during your next PSM audit OSHA asks to see those certified PPE Hazards Assessments which determined the PPE needed for those PSM tasks listed in your operating procedures, as well as your maintenance procedures.
On another note, for those tasks that are done outside any certified procedure, I truly believe that a Safe Work Permit that is PROPERLY ISSUED and approved by a Supervisor (or higher) will suffice for this PPE Hazard Assessment. It is my opinion that this safe work permit process is actually MUCH MORE accurate than using some assessment/JSA that was done years ago and resides in some file cabinet. Of course, the safe work permit MUST include the PPE required for the scope of work on the permit. Being approved by a Supervisor (or higher member of management) will act as the “certification”. Just another reason to implement safe work permits for ALL WORK that is not covered by an annually certified operating or maintenance procedure. REMEMBER in a PSM-covered process (as well as ADJACENT to it), CONTROL of access and work is a critical path. A well-implemented safe work permit process is PRICELESS in helping achieve this control.