How to Conduct a PPE Risk Assessment

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Practical Considerations for Industrial Hygiene Exposures

BY PAUL E. ALLEN AND KEVIN MAHONEY

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Risk assessments are a vital part of industrial hygiene. They are intended to characterize occupational exposures to hazardous workplace conditions and drive controls to protect the workforce. In the United States, OSHA mandates that employers must assess the workplace for hazards that are or may be present, determine the proper personal protective equipment to protect employees, and communicate PPE decisions to employees. In this article, we review the risk assessment process for industrial hygiene exposures, the routes of exposure, how to characterize exposures, and how to make decisions to protect the workforce.

WORKPLACE SURVEY: GATHERING INFORMATION The first step of your PPE risk assessment is to gather information about the work environment. The information-gathering stage will help define the scope of the workplace survey by identifying the workforce or exposure groups to be assessed, the tasks those individuals perform, the PPE they use, and a list of the chemicals they handle. This stage also involves reviewing past risk assessments, if available.

A workplace survey is not complete without performing a walkthrough of the facility. A walkthrough allows the assessor to gather additional information about the work environment and to speak with the employees.

Note that many exposures are not consistent throughout a workday. Chemical exposures have peaks and valleys and are dependent upon the tasks performed, the chemicals handled, the area the person works in, and the controls in place. A walkthrough of the facility helps the assessor identify the tasks with the greatest exposure potential.

RISK RANKING When occupational and environmental health and safety (OEHS) professionals collect a large amount of data, they can experience “paralysis through analysis,” or uncertainty about knowing where or how to start. The best way to start is with a matrix like the one shown in Figure 1, which you can use to rank the exposure risks in your workplace according to their likelihood and severity.

Figure 1. A risk matrix ranks risks presented by job tasks according to their likelihood and consequence. Risks that fall in the red areas of the matrix are unacceptable and the highest priority for further evaluation.

Tap on the figure to open a larger version in your browser.

To begin this process, list all jobs and tasks with identified or suspected industrial hygiene exposure risks. This listing can be done in any order. Use your workplace observations, professional judgment, and quantified sampling results to evaluate these tasks. For both the likelihood and severity of exposure risks associated with a task, assign a score ranging from 1 (very unlikely/infrequent) to 5 (very likely/frequent). Multiplying the likelihood and severity scores yields a total score that will help you prioritize risks, with the highest score being the highest priority. For tasks deemed to present unacceptable risk, you may need to implement temporary controls until exposures can be evaluated further.

ASSESSING EXPOSURES Beginning with the task that has the highest risk ranking, initiate an evaluation to quantify exposures. The evaluation should consider the hazard as well as the route of exposure. Routes of exposure may include inhalation, physical exposure (noise, radiation, and temperature), dermal exposure, ingestion, and injection. Guidance for assessing exposures appears in appendix B of OSHA’s PPE standard, which suggests the following hazard categories for review: • impact • penetration • compression (from a vehicle roll-over) • chemical • heat • harmful dust • light (optical) radiation

This article focuses on risk assessments of health hazards: chemical, heat, dust, and light radiation exposures.

Evaluating inhalation exposures for chemicals and dusts includes taking breathing zone samples over a full or partial shift or during specific tasks and comparing them to occupational exposure limits to determine acceptability. The AIHA IHMOD exposure modeling tool can be used to estimate exposures for leaks, spills, and other scenarios that cannot be easily accessed for sampling.

Dermal hazards can be absorbed through the skin and cause damage to the skin itself. Dermal contact can occur while handling chemicals, through chemical splashing or spraying, touching contaminated surfaces, and several other ways. Although surface sampling can determine the level of contaminants deposited on a surface, you will need to rely on your professional judgment and workplace observations to determine whether a potential exposure exists and what impact it would have on the individual. The AIHA IHSkinPerm tool can help with estimating dermal absorption through the skin, and the Exposure Science and Sustainability Institute (ESSI) Dermal Risk Assessment Model (DRAM) tool provides a systematic evaluation of risks due to dermal exposure.

Physical hazards such as noise, light (optical) radiation, and heat can be monitored through personal sampling as well as through the use of direct-reading instruments. These instruments can also be used to develop sound-level maps and to document measurements from heat stress surveys.

DATA ANALYSIS Based on findings from the workplace survey, risk prioritization, and quantification of exposure, you can begin to analyze PPE needs. The risk matrix prioritizes the risks and helps point to areas of initial focus. The first risks to examine are those that appear in the red and orange areas of the risk matrix.

Review the tasks related to these risks for any quantifiable sampling results that can help identify the level of PPE that is required. The results of your risk assessment allow for an adjusted risk matrix score. This secondary score will be used to incorporate the quantifiable results. If the workplace monitoring results are above or below the OEL, the score can be adjusted on the risk matrix. All exposures above the OEL will require recommendations for controls and a follow-up evaluation.

In some cases, you will need to assign a score for tasks that haven’t been quantitatively assessed. For example, you may be assessing a new task or one where sampling isn’t possible due to resource constraints. In these cases, professional judgment is required.

RECOMMENDATIONS FOR PPE AND OTHER CONTROLS PPE is the last line of defense to protect against a contaminant of concern. As is familiar to us from the hierarchy of controls, elimination, substitution, engineering controls, and administrative controls are more effective than PPE and should be considered first (see Figure 2). Sometimes, however, your assessment will show that PPE is necessary. These are the situations addressed in this article.

Figure 2. The hierarchy of controls. Source: NIOSH.

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Although PPE is the least effective control, it can be used in conjunction with additional controls or until additional controls are implemented. PPE may also be the most feasible control available. As additional controls such as ventilation and worker rotation are implemented, another evaluation can be performed and PPE requirements adjusted.

If inhalation hazards exceed the OELs, respiratory protection should be recommended until controls are put in place to reduce exposure to an acceptable level. The respirator selected should have a cartridge that will protect against the contaminant of concern and a protection factor that lowers concentrations below the OEL. Note that, when dealing with a small number of samples, it is possible for exposures to exceed the measured results in the assessment. The AIHA IHSTAT tool, which applies statistical analysis to identify the likely exposure distribution, can help you make decisions about PPE even with limited data. This is especially helpful when sample results approach but do not exceed the OEL.

Dermal protection can range from full-body encapsulating suits, which are sometimes called “level A suits,” to chemical protective gloves. Making decisions for dermal protection should involve evaluating what areas of the body may be exposed, the severity of the exposure, and what chemicals the PPE needs to protect against.

Not all chemical protective clothing is created equal. Chemical gloves, for example, will have manufacturers’ data for what chemicals the gloves will protect against, what chemicals the gloves will not protect against, and how long the chemicals take to degrade the material. Ease of use should be considered when developing a list of PPE for employees to wear. For example, wearing goggles and a half-face respirator may be uncomfortable, and the respirator may affect the goggles’ seal. Upgrading to a full-face respirator will not only be more comfortable, but it will also provide both respiratory and eye protection. Wiley’s Quick Selection Guide to Chemical Protective Clothing, 7th edition, can help with chemical protective clothing selection.

Reducing noise exposure can include utilizing ear plugs, earmuffs, or a combination of the two. Noise protection should reduce the sound to an acceptable level but still allow employees to communicate with each other. Selecting earplugs with a noise reduction rating well above what is needed may create unintended consequences such as preventing employees from communicating with each other. When noise is contained in specific areas, noise maps can be used to communicate areas where hearing protection is required.

Light (optical) radiation, such as radiation emitted from welding and brazing operations, may require UV protection including welding shields, welding masks, or sunglasses. OSHA’s standard for eye and face protection specifies minimum protective shade numbers that can be used for these tasks. These guidelines protect the worker as well as nearby workers who may be affected.

Recommendations to protect against heat stress are often difficult to implement because measurements may change not only from season to season, but from day to day. The heat index or ambient temperature can be used to trigger field measurements. PPE may include cooling vests and cooling towels, but administrative controls such as work/rest routines or worker rotation are often implemented in addition to PPE when engineering controls are not available.

COMMUNICATION Once the evaluation and assessment are complete, the results need to be shared with your workforce. Using the risk matrix, the staff can quickly see where tasks have fallen in terms of their assessment score. The items in the orange and red areas will require discussion of the PPE needed for those tasks.

Review the job hazard analysis (JHA) for these tasks to determine the proper application of PPE. The training, fit, care, and maintenance of the PPE will need to be handled for each specific type of equipment. Your company policies should provide guidance for use of respirators and other required PPE.

Adding the risk assessments to the JHA can make them more effective. The color-coding of the risk assessment can help employees easily identify the higher-risk tasks and prompt them to check for the required PPE for that task.

RE-EVALUATIONS The PPE risk assessment process is ongoing. As with standard approaches based on the hierarchy of controls, it is hoped that PPE is a temporary solution. As additional controls are implemented, the risk assessments will need to be updated and PPE requirements adjusted or dropped when possible. OEHS professionals should plan to perform new assessments periodically to confirm their relevance and correctness, and should conduct a new assessment whenever changes to a job task or process are implemented.

PAUL E. ALLEN, CIH, CSP, ARM, CRIS, AOEE, is the product consulting director, industrial hygiene, commercial risk control with CNA Insurance in Chicago, Illinois.

KEVIN MAHONEY, CIH, CSP, CHMM, is an industrial hygienist at PBF Energy’s Paulsboro Refinery.

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RESOURCES

NIOSH: “About Hierarchy of Controls.”

OSHA: Occupational Safety and Health Standards, Personal Protective Equipment, Nonmandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection.

OSHA: Occupational Safety and Health Standards for Shipyard Employment, Personal Protective Equipment, Eye and Face Protection.

Wiley: Quick Selection Guide to Chemical Protective Clothing, 7th edition (March 2020).