Tinus Boshoff
By law, employers must as far as reasonably practicable, protect persons at work. Workers and other persons like visitors, contractors and suppliers have the right to be protected from harm caused by failure to take reasonable and practicable control measures. The employer or user of machinery is obligated by law to take the necessary steps in order to provide a safe and health work environment.
In order to provide a safe and health work environment the employer or user of machinery should evaluate the risk attached to any condition or situation which may arise from their work activities.
Section 8(2) (d) of the Occupational Health and Safety Act (OHS Act) stipulates that the employer must establish, as far as is reasonably practicable, what hazards to the health or safety of persons are attached to any work which is performed. The section also stipulates that employers must establish what precautionary measures should be taken in order to protect the health and safety of persons and provide the necessary means to apply such precautionary measures.
It is evident that work related hazards and risks needs to be identified in order to establish the necessary precautionary measures. A risk assessment could prove to be a valuable tool in this regard. It could basically be described as a careful examination of what, related to the work activities of an organisation, could course harm to people or damage to property.
During the risk assessment process we identify the hazards associated with an activity (physical task, or process at hand), to assess the seriousness of these hazards and to formulate systems of work, training or other methods (controls) to eliminate or reduce the associated risk to a minimum or at least to an acceptable level.
General Safety Regulations 2 of the OHS Act provides minim standard legislation in this regard. It elaborates on the matter by stipulating that the employer must provide the necessary equipment and facilities to ensure that any person exposed to hazards and risks at a workplace or on the premises or in the course of employment where machinery is used, is safe.
The regulation also stipulates that where it is not practicable to safeguard the condition or situation, the employer or user of machinery, shall take steps to reduce the risk as much as is practicable.
Please note that the main aim should be to firstly remove or secondly mitigating the risk associated with the exposure to a particular hazard. If the hazard or risk cannot be removed, the next potion would be to apply appropriate steps or measures to mitigate it.
PPE should be used when it has been determined that its use will lessen the likelihood of occupational injury and/or illness and when other protection methods are not available.
PPE is used to reduce or minimize the exposure or contact to injurious physical, chemical, ergonomic, or biological agents. PPE basically creates a barrier against workplace hazards.
A hazard cannot be eliminated by PPE, but the risk of injury can be reduced. For example, wearing hearing protection reduces the likelihood of hearing damage when the ear plugs or muffs are appropriate for the kind of noise exposure and they are used properly. However, hearing protection does not eliminate the noise.
Engineering controls, administrative controls, and good work practices are always preferred instead of personal protective equipment (PPE) as methods to protect workers against workplace hazards. PPE must always be regarded as a ‘‘last resort’’ to protect against risks to safety and health.
There are a number of reasons why PPE must be considered as a ‘‘last resort’’:
- PPE only protects the person wearing it, whereas measures controlling the risk at source protect everyone in the workplace
- theoretical maximum levels of protection are difficult to achieve and the actual level of protection is difficult to assess. Effective protection is only achieved by selecting suitable PPE and if it is correctly fitted, maintained and used
- PPE may restrict the wearer to some extent by limiting mobility or visibility, or by requiring additional weight to be carried, thus creating additional risk.
In addition to identifying the need for PPE, it is essential that the right or proper type and grade of PPE is specified and provided.
Two types of criteria need to be determined:
- the degree of protection required, and
- the appropriateness of the equipment to the situation (including the practicality of the equipment being used and kept in good repair).
The degree of protection and the design of PPE must be integrated because both affect its overall efficiency, wearability, and acceptance.
GSR 2 also stipulates that the employer or user should effectively manage and controlling risk by making use of the following safety equipment and facilities:
- safety equipment or facility of a type that will effectively prevent bodily injury
- safety equipment of a type that will effectively protect the wearer thereof against harm
- equipment that will effectively protect persons against falls
- facilities that will effectively prevent slipping, unsafe entry or unsafe conditions
- safety equipment or a facility of a type that will effectively protect against harm
- suitable insulating material underfoot where persons work on a floor made of metal, stone, concrete or other similar material, and
- generally, such safety equipment or facilities as may be necessary to render the persons concerned safe
In addition, a number of other OHS Act regulations have specific requirements relating to the provision, maintenance and use of PPE. The stipulations of these regulations are more specific than the requirements stipulated by GSR 2. A particular regulation that prescribes specific safety equipment or facilities shall take predominance over the above mentioned regulation.
PPE could also be used in conjunction with other controls to ensure the safety and health of workers.
It is essential to train employees in the proper use, maintenance and limitations of PPE and facilities. The extent of information, instruction and/or training will vary with the complexity and performance of the task.
Information and training could for example include:
- the level of risk(s) involved
- the reason why the PPE is needed (the potential risks to health and safety caused by exposure)
- precautions to be taken by the employees to protect themselves against the health risks associated with the exposure, including the wearing and use
- potential sources of exposure
- the content and scope of applicable regulations
- the operation (including demonstration), performance and limitations of the equipment
- correct use (how to fit and wear PPE, how to adjust it for maximum protection and storage)
- correct storage
- any testing or medical surveillance requirements before use
- any user maintenance that can be carried out (e.g. hygiene/cleaning procedures)
- factors that can affect the performance of the equipment (e.g. how to care for it, working conditions, personal factors, defects and damage)
- how to recognise defects in PPE, and arrangements for reporting them
- where to obtain new PPE if it needs to be replaced
In addition to initial training, refresher training may be required from time to time. Education programs should continue on a regular basis. One of the most common reasons for failure of a PPE program is the inability to overcome objections to wearing it.
PPE must be properly maintained, it is important to make sure the equipment continues to provide the degree of protection for which it is designed. Maintenance should include inspection, care, cleaning, repair, and proper storage. Manufacturer’s instructions (including recommended replacement periods and shelf life) could prove to be valuable in this regard.
An important part of maintenance is the need for continuous inspection of the PPE. Continuous inspections help to identify damaged or malfunctioning of PPE before it is used. The use of poorly maintained or malfunctioning PPE could sometimes be more dangerous than not wearing any form of protection at all. The workers gain a false sense of security and think they are protected when, in reality, they are not.
PPE may not be removed from a workplace or from premises where machinery is used, except for purposes of cleaning, repair, maintenance, modification, mending or replacement. Adequate storage facilities for PPE should thus be provided for situations when it is not in use. Where PPE may become contaminated during use, storage should be separate from any storage provided for ordinary clothing.
If items of PPE are required they must be provided free of charge by the employer. PPE stays the property of the employer. In order to prevent the unecessary loss or misuse of PPE, the implementation and use of a PPE policy could prove to be very valuable.
An employer may not require or permit any employee to work unless such an employee uses the required safety equipment or facilities. The worker is also obligated to co-operate with the employer to ensure that this duty or requirement are performed and complied with.
By law employees must carry out any lawful orders given to them and obey the health and safety rules and procedures laid down the employer in the interest of health or safety.
It is an offence to interfere with, damage or misuse safety equipment or personal protective equipment.
I trust that the above mentioned information would be useful.
For more information contact Tinus Boshoff
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