The Importance of Personal Protective Equipment (PPE) for Dealers

1. The Importance of Personal Protective
Equipment (PPE) for Dealers
Janet Wimmer
Regulatory Advisor
KPA

2. Moderator
Becky Ross
Marketing Manager
(303) 228-8753
bross@kpaonline.com

3. Janet Wimmer
Regulatory Analyst
(901) 277-0301
jwimmer@kpaonline.com
Presenter

4. If you have questions during
the presentation, please
submit them using the
“Questions” feature
Questions will be answered
at the end of the webinar
QUESTIONS

5. Personal Protective Equipment
is commonly called
PPE.
The Importance of Personal Protective Equipment
for Dealers

6. Dealers Responsible?
• “They have their own safety glasses.”
• “They can buy gloves. I provide them
in the Parts Department.”
• “If I pay for it, they will abuse it.”
The Importance of Personal Protective Equipment
for Dealers

7. Liability
• Employee Injury
• Non-Compliance with Occupational
Safety and Health Administration
(OSHA)
The Importance of Personal Protective Equipment
for Dealers

8. Employee Injury
• Example: Recent eye injury
• Increase in insurance premium
• Cost of employee recovery
The Importance of Personal Protective Equipment
for Dealers

9. Occupational Safety and Health
Administration (OSHA)
• Clear unambiguous regulation
• Statistical data regarding employee injuries
• Additional inspectors
• Fines per occurrence
The Importance of Personal Protective Equipment
for Dealers

10. Occupational Safety and Health
Administration (OSHA)
Personal Protective Equipment Regulations
29CFR1910.132 General Requirements
29CFR1910.133 Eye and Face Protection
29CFR1910.134 Respiratory Protection
29CFR1910.135 Head Protection
29CFR1910.136 Foot Protection
29CFR1910.138 Hand Protection
29CFR1910.95 Noise Exposure
The Importance of Personal Protective Equipment
for Dealers

11. Personal Protective Equipment
Regulations
1910.132(a)Application. Protective equipment, including
personal protective equipment for eyes, face, head, and
extremities, protective clothing, respiratory devices, and
protective shields and barriers, shall be provided, used,
and maintained in a sanitary and reliable condition
The Importance of Personal Protective Equipment
for Dealers

12. Personal Protective Equipment
Regulations
1910.132(d)(1) The employer shall assess the
workplace to determine if hazards are present, or are
likely to be present, which necessitate the use of personal
protective equipment (PPE). If such hazards are present,
or likely to be present, the employer shall:
The Importance of Personal Protective Equipment
for Dealers

13. The Hazard Assessment
13– KPA CONFIDENTIAL –
• Define a Hazardous Activity such as: Grinding
• Work-related exposure will be: Particles
• Can the hazard be eliminated without PPE: No
• What is the required PPE: Safety
Glasses

14. Personal Protective Equipment
Regulations
1910.132(d)(1)(i) Select, and have each affected
employee use, the types of PPE that will protect the
affected employee from the hazards identified in the
hazard assessment;
The Importance of Personal Protective Equipment
for Dealers

15. Personal Protective Equipment
Regulations
1910.132(d)(1)(ii) Communicate selection decisions to
each affected employee; and,
1910.132(d)(1)(iii) Select PPE that properly fits each
affected employee.
1910.132(e) Defective and damaged equipment.
Defective or damaged personal protective equipment
shall not be used.
The Importance of Personal Protective Equipment
for Dealers

16. Personal Protective Equipment
Regulations
1910.132(f) Training.
• When and What PPE is required
• How to put it on and take it off
• Equipment limitations
• How to maintain the equipment
1910.132(f)(2) Each affected employee shall demonstrate an
understanding of the training specified in paragraph (f)(1) of this
section, and the ability to use PPE properly, before being allowed to
perform work requiring the use of PPE.
The Importance of Personal Protective Equipment
for Dealers

17. Personal Protective Equipment
Regulations
1910.132(h)(1) Except as provided by paragraphs (h)(2)
through (h)(6) of this section, the protective equipment,
including personal protective equipment (PPE), used to
comply with this part, shall be provided by the employer
at no cost to employees.
You are not required to provide steel toed shoes
or prescription safety glasses.
The Importance of Personal Protective Equipment
for Dealers

18. HOWEVER
1910.133(a)(3) The employer shall ensure that each
affected employee who wears prescription lenses while
engaged in operations that involve eye hazards wears
eye protection that incorporates the prescription in its
design, or wears eye protection that can be worn over
the prescription lenses without disturbing the proper
position of the prescription lenses or the protective
lenses
The Importance of Personal Protective Equipment
for Dealers

19. Personal Protective Equipment
Regulations
1910.132(h)(5) The employer must pay for replacement
PPE, except when the employee has lost or intentionally
damaged the PPE.
The Importance of Personal Protective Equipment
for Dealers

20. At a Minimum
Safety Glasses with Side Shield and Browguard Organic Vapor Respirator
Supplied Air and Protective Suit Nitrile Gloves
The Importance of Personal Protective Equipment
for Dealers

21. Eye and Face Protection
1910.133(a)(1) The employer shall ensure that each
affected employee uses appropriate eye or face protection
when exposed to eye or face hazards from flying particles,
molten metal, liquid chemicals, acids or caustic liquids,
chemical gases or vapors, or potentially injurious light
radiation.
The Importance of Personal Protective Equipment
for Dealers

22. Eye and Face Protection
1910.133(a)(4) Eye and face PPE shall be distinctly
marked to facilitate identification of the manufacturer.
1910.133(b)(1) Protective eye and face protection
devices must comply with any of the following consensus
standards:
ANSI Z87
The Importance of Personal Protective Equipment
for Dealers

23. Eye and Face Protection
1910.133(a)(5) The employer shall ensure that each
affected employee uses equipment with filter lenses that
have a shade number appropriate for the work being
performed for protection from injurious light radiation.
The Importance of Personal Protective Equipment
for Dealers

24. Eye and Face Protection Fines
From October 2010 through September 2011
Citations on 8 dealerships totaling $16,015.00
Average cost per dealership $2,002.00
The Importance of Personal Protective Equipment
for Dealers

25. WHAT TO DO?
• As found in on the internet, eye injuries are the most
common injury in this business. To deal with this some
of our dealerships
• Require safety glasses to be worn by all persons
entering the shop sections of the dealership.
• Midas International requires their employees to wear
safety goggles in their shops.
The Importance of Personal Protective Equipment
for Dealers

26. DO NOT FOOL YOURSELF!
If you provide the cheapest safety glasses,
• They probably do not give the employee clear vision.
• They probably are not adjustable for a comfortable fit.
• They probably do not fit all employee’s heads.
• They probably will not be worn.
The Importance of Personal Protective Equipment
for Dealers

27. Respiratory Protection
Supplied Air Respirator Organic Vapor Respirator
1910.134(a)(2) A respirator shall be provided to each employee when such
equipment is necessary to protect the health of such employee. The employer
shall provide the respirators which are applicable and suitable for the
purpose intended. The employer shall be responsible for the establishment and
maintenance of a respiratory protection program...
The Importance of Personal Protective Equipment
for Dealers

28. Respiratory Protection
1910.134(c)(1) …the employer shall establish and implement
a written respiratory protection program with worksite-specific
procedures. Including the following:
• Procedures for selecting respirators
• Medical evaluations
• Fit testing
• Procedures for proper use
• Procedures maintaining respirators;
• Ensure adequate air quality, quantity, and flow
• Training of employees
The Importance of Personal Protective Equipment
for Dealers

29. Respiratory Protection
1910.134(c)(2)(i) If the employer determines that any voluntary
respirator use is permissible, the employer shall provide the
respirator users with the information contained in Appendix D and
1910.134(c)(2)(i) In addition, the employer must ensure that any
employee using a respirator voluntarily is medically able to use that
respirator, and that the respirator is cleaned, stored, and maintained
so that its use does not present a health hazard to the user.
Exception: voluntary use of filtering facepieces (dust masks).
1910.134(c)(4) The employer shall provide respirators, training, and
medical evaluations at no cost to the employee.
The Importance of Personal Protective Equipment
for Dealers

30. Respiratory Protection
Supplied air and complete coverage is
required for the spraying of clear- coats
and hardeners containing isocyanates
Organic vapor respirators are required for
the spraying of paints and thinners
containing organic chemicals.
The bodyman mask should be used by
bodymen and welders.
The Importance of Personal Protective Equipment
for Dealers

31. Respiratory Protection Notes
• Written program
• Medical surveillance
• Fit test
• Workplace analysis
• Change-out schedule.
• Isocyanates
• Equipment Inspection
The Importance of Personal Protective Equipment
for Dealers

32. Respiratory Protection Fines
From October 2010 through September 2011
Citations on 14 dealerships totaling $15,801.00
Average cost per dealership $1,129.00
The Importance of Personal Protective Equipment
for Dealers

33. Head Protection
1910.135(a)(1) The employer shall ensure that each
affected employee wears a protective helmet when
working in areas where there is a potential for injury to the
head from falling objects.
THIS DOES NOT APPLY TO DEALERSHIP OPERATIONS.
The Importance of Personal Protective Equipment
for Dealers

34. Foot Protection
1910.136(a)General requirements. The employer shall
ensure that each affected employee uses protective
footwear when working in areas where there is a danger
of foot injuries due to falling or rolling objects, or objects
piercing the sole, and where such employee's feet are
exposed to electrical hazards.
THIS DOES NOT APPLY TO DEALERSHIP OPERATIONS.
The Importance of Personal Protective Equipment
for Dealers

35. Hand Protection
Nitrile Gloves Electrical Hybrid Gloves Welding Gloves
1910.138(a) General requirements. Employers shall select
and require employees to use appropriate hand protection
when employees' hands are exposed to hazards such as those
from skin absorption of harmful substances; severe cuts or
lacerations; severe abrasions; punctures; chemical burns;
thermal burns; and harmful temperature extremes.
The Importance of Personal Protective Equipment
for Dealers

36. Hand Protection
Nitrile Gloves Electrical Hybrid Gloves Welding Gloves
Nitrile Gloves Used Petroleum/Solvents
Hybrid Gloves Electrical Shock
Latex Gloves Detail cleaning products
Leather Gloves/mechanic Gloves Abrasion/Heat
Welding Gloves Hot metal and sparks
The Importance of Personal Protective Equipment
for Dealers

37. Hand Protection Fines
From October 2010 through September 2011
Citations on 4 dealerships totaling $2,400.00
Average cost per dealership $600.00
The Importance of Personal Protective Equipment
for Dealers

38. Noise Exposure
Earmuffs Disposable Ear Plugs Disposable Ear Plugs Earmuffs
1910.95(b)(1) When employees are subjected to sound
exceeding those listed in Table G-16, feasible administrative or
engineering controls shall be utilized. If such controls fail to
reduce sound levels within the levels of Table G-16, personal
protective equipment shall be provided and used to reduce
sound levels within the levels of the table 1.G-16.
The Importance of Personal Protective Equipment
for Dealers

39. Noise Exposure
Earmuffs Disposable Ear Plugs Disposable Ear Plugs Earmuffs
1910.95(c)"Hearing conservation program.“
1910.95(c)(2) For purposes of paragraphs (c) through (n) of this section,
an 8-hour time-weighted average of 85 decibels or a dose of fifty percent
shall also be referred to as the action level.
The Importance of Personal Protective Equipment
for Dealers

40. Noise Exposure Note
Earmuffs Disposable Ear Plugs Disposable Ear Plugs Earmuffs
Sound analysis in shops generally do not indicate that
noise is over 85 decibels for eight hours. It is prudent to
have disposable earplugs for your employees comfort.
The Importance of Personal Protective Equipment
for Dealers

41. PPE Requirements
 Perform a Hazard Assessment of the Workplace.
 Select required PPE and have employees use it.
 Provide the PPE at no cost to the employee.
 Train the employee in the proper use and
maintenance.
 Removed damaged equipment from the work area.
 Replace damaged equipment at no cost to employee.
 Review work practice to make sure employees are
wearing PPE when required.
The Importance of Personal Protective Equipment
for Dealers

42. Policy
What do you provide?
The Hazard Assessment states what PPE you must provide
Who distributes it at your store?
Designate a manager to be in charge
When is it distributed?
At the time of hire and when damaged or worn out.
How is the distribution documented?
Except for disposable gloves, all distributed equipment should be
tracked.
The Importance of Personal Protective Equipment
for Dealers

43. Policy
When do you expect the equipment to be used?
Consider safety glasses:
Whenever one is in the shop.
When one is grinding.
When one is working on an engine that is running.
When one is under a vehicle.
The Importance of Personal Protective Equipment
for Dealers

44. Policy Enforcement
Reward System:
• Random inspection--Five dollars when found wearing proper PPE
• Contest between two sides of the shop—lunch for the least
infractions
Punishment System:
• Write up each time employee not wearing PPE when required.
• Three write-ups require disciplinary action.
NOTE: If there is no enforcement, there is no real Policy
The Importance of Personal Protective Equipment
for Dealers

45. Opportunity
#1 Protecting your employees from injury.
#2 Protecting your dealership from lawsuit and/or
increased insurance costs.
#3 Protecting your dealership from OSHA fines.
#4 Creating a positive employee attitude, by showing
them you care about their safety. You have spent
time creating a Personal Protective
Equipment policy and money supplying proper
PPE and effort to enforce the policy.
The Importance of Personal Protective Equipment
for Dealers