Employers are responsible for ensuring that personal protective equipment (PPE) is available. Employers are also responsible for ensuring that employees are using these devices. If employees provide their own safety equipment, the employer is responsible for ensuring that it is appropriate. Respirators must be provided by the employer.
As part of both 29CFR1910.132 compliance and its chemical hygiene plan, the employer needs to specify the circumstances under which an employee should use PPE. When should safety glass versus chemical splash goggles be worn? When should gloves be used? What about lab coats and portable shields? Is hearing protection an issue? Should hearing protection devices be used?
The employer has an additional responsibility. The employer needs to make sure that the PPE is used. Working safely should be a condition of employment. Employees who fail to use required PPE should receive appropriate warnings, disciplinary action, and then be dismissed.
Any policy that falls short of providing for the provision of dismissal is inviting violations that can not be addressed and prevented. It allows employees to jeopardize their own health and safety and that of others around them without the possibility of necessary disciplinary action. Normally, it will not be necessary to invoke this final action. However, the availability of the sanction improves the compliance efforts.
The OSHA Personal Protection Standard requires employers to do workplace hazard assessment to determine the protective equipment needed. The employer must then provide the equipment and train employees in its use.
Source: Kaufman, James A., Laboratory Safety Guidelines - Expanded Edition, The Laboratory Safety Institute, www.labsafetyinstitute.org
