Step 6: Use of Engineering Controls, Work Practices and PPE

Date First Published on SafetySmart Compliance: February 21st, 2012
Topics: Hazwoper & Emergency Response |

Hazwoper Compliance

The next phase of Hazwoper compliance is to take the appropriate measures to eliminate or control risks to employees exposed to hazardous substances during operations (Sec. 1910.120(g)). Such measures include a combination of engineering controls like ventilation systems, work practices like buddy systems and use of respiratory protective equipment and other PPE. Here’s an overview of what’s required.

Click here for Model PPE Policy to include in your HASP.

Click here for Model Hazwoper Safe Work Requirements to include in your HASP.

 

Engineering Controls, Work Practices & PPE

 

Different requirements apply depending on the kind of substance(s) to which employees are exposed.

Subpart Z Substances

 

Subpart Z Substances include:

  • Air contaminants
  • Asbestos
  • Coal tar pitch volatiles
  • 13 different carcinogens covered by 1910.1003
  • alpha-Naphthylamine
  • Methyl chloromethyl ether
  • Dichlorobenzidine (and its salts)
  • bis-Chloromethyl ether
  • beta-Naphthylamine
  • Benzidine
  • 4-Aminodiphenyl
  • Ethyleneimine
  • beta-Propiolactone
  • Acetylaminofluorine
  • 4-Dimethylamineoazobenzene
  • N-Nitrosodimethylamine
  • Vinyl chloride
  • Inorganic arsenic
  • Lead
  • Chromium (VI)
  • Cadmium
  • Benzene
  • Coke oven emissions
  • Bloodborne pathogens
  • Cotton dust
  • 1,2-dibromo-3-chloropropane
  • Acrylonitrile
  • Ethylene oxide
  • Formaldehyde
  • Methylenedianiline
  • Butadiene
  • Methylene chloride
  • Ionizing radiation

 

Employers must use engineering controls and work practices to keep employee exposure of substances regulated by Subpart Z of the General Industry Standard, i.e., Toxic and Hazardous Substance, at or below their PEL, unless those controls and practices “are not feasible.”

Feasible engineering controls may include the use of pressurized cabs or control booths on equipment, and/or use of remotely operated material handling equipment.

Feasible work practices may include removing all non-essential employees from potential exposure during opening of drums, wetting down dusty operations and/or locating employees upwind of hazards.

If engineering controls aren’t required or feasible, employers must use “any reasonable combination of engineering controls, work practices and PPE” to keep exposure to Subpart Z substances at or below their PELs.

You can’t use an employee rotation level as a means of complying with PEL.

requirements unless there’s no other feasible way to comply with the airborne or dermal dose limits for ionizing radiation.

Subpart G Substances

 

Employers must follow the requirements that pertain to regulation of hazardous substances under Subpart G of the General Industry Standard, i.e., Occupational Health and Environmental Control Standard, including requirements relating to Ventilation (1910.94) and Non-Ionizing Radiation (1910.97).

 

Where Subparts G and Z Don’t Apply

 

Employers must use an appropriate combination of engineering controls, work practices and PPE to reduce and maintain exposure to PELs of hazardous substances and health hazards not regulated by Subparts G and Z, using exposure limits and published literature to determine safe exposure levels.

 

Selection of PPE

 

You must select and use PPE appropriate to protect employees from the hazards and potential hazards they’re likely to encounter as identified during the site characterization and analysis process.

Positive pressure self-contained breathing apparatus, or positive pressure air-line respirators equipped with escape air must be used when chemical exposure levels:

  • Create a “substantial possibility of immediate death”;
  • Create a “substantial possibility of” immediate serious injury or illness; or
  • Impair the ability to escape.
  • Totally-encapsulating chemical protective suits equivalent to Level A protection as recommended in Appendix B must be used where skin absorption of a hazardous substance may result in “substantial possibility of immediate death,” or  immediate serious injury or illness, or impair the ability to escape.
  • Totally-encapsulating suits must be capable of maintaining positive air pressure. (See Appendix A for selection guidelines); and
  • Totally-encapsulating suits must be capable of preventing inward test gas leakage of more than 0.5%. (See Appendix A for testing method guidelines.)
  • Level of protection provided by PPE selection must increase where additional information or site conditions indicate it’s necessary to keep exposure below PELs and published exposure levels.
  • Level of protection provided by PPE selection may be reduced where additional information or site conditions indicate it won’t result in hazardous exposure.

 

PPE Program

 

Employers must also implement a PPE program as part of the required written safety and health program and the site-specific safety and health plan explained above (See Step 1) addressing:

 

  • PPE selection to deal with site hazards;
  • PPE use and equipment limitations;
  • Duration of work mission;
  • PPE maintenance;
  • PPE storage;
  • PPE decontamination and disposal;
  • PPE training;
  • Proper fitting;
  • Donning and doffing procedures;
  • PPE inspection procedures before, during and after use;
  • Evaluation of PPE program effectiveness; and
  • Limitations during temperature extremes, heat stress and other appropriate medical considerations.

OSHA Guidelines

 

PPE Test Methods (Appendix A)

Description & Discussion of Levels of Protection & Protective Gear (Appendix B)

Compliance Guidelines (Appendix C)

Other OSHA Standards Incorporated by Reference:

Subpart Z of the General Industry Standard, i.e., Toxic and Hazardous Substance

Subpart G of the General Industry Standard, i.e., Occupational Health and Environmental Control Standard,

Ventilation (1910.94)

Non-Ionizing Radiation (1910.97).