EHS magazine had a great post on the overuse as abuse of PPE.
Diminished Returns, Diminished Awareness was written by John Olesky.
Apparently John is as tired as I am of seeing everyone wearing whatever they call that high-visibility neon-green regardless of their actual job, hazard, or risk.
Maybe it keeps these guys from getting hit when they are on the red carpet?
DJ PAULY D
I think that this high-visibility neon-green is actually a magical talisman summoned up by the high priests/ witch doctors of safety.
It’s no coincidence that the witch doctor is using magical neon safety green…
Witch Doctor
Here’s a brief excerpt from John’s blog dealing with those neon green vests:
Vest Concerns
Why is it when I look at some construction sites, I see EVERYONE on site wearing reflective safety vests? OSHA, in 29 CFR 1926.651(d), sets forth requirements for workers who are exposed to vehicular traffic. OSHA states that “employees exposed to public vehicular traffic shall be provided with, and shall wear, warning vests or other suitable garments marked with or made of reflectorized or high-visibility material.”
And according to DOT, 23 CFR 634.3, Use of High-Visibility Apparel When Working on Federal-Aid Highways: “All workers within the right-of-way of a Federal-aid highway who are exposed either to traffic (vehicles using the highway for purposes of travel) or to construction equipment within the work area shall wear high-visibility safety apparel.”
These vests specifically were designed for use when there is some kind of vehicular traffic on or near the work site, or if heavy equipment such as a dozer or crane is moving around the site AND the workers will be exposed to the dangers of being struck by that traffic.
So I have to ask project managers and project safety managers, “Is there a danger of being hit by a ‘vehicle’ when employees are working on the 15th floor of a 30-story high rise building?” If not, then why are they required to wear reflective vests?
Amen John. And by the way, they are also wearing them in the store, the gas station, everywhere. I am seeing this neon -green assault to the eyes everywhere. It’s become ubiquitous.
The proper PPE is not magic. It is the result of proper analysis of hazards at that occupational location. The guy in the crane high above doesn’t need his visibility improved to protect him from vehicular traffic. The roofer doesn’t need a neon-green shirt, he needs fall protection. Guess which the roofer is actually wearing?
Dude- Where’s the tie off and fall protection?
ProRooferNW
As John Olesky said:
If we did a JHA correctly we would have to ask if the universal use of these vests on site truly makes the workers safe. We need to ask: Does this universal donning of safety vests even when they aren’t needed increase or diminishthe visual awareness for the heavy equipment operator or for the general public driving past the construction site?
It is my belief that the over use of these vests actually will diminish the safety factor that these vests originally intended for both the workers and for the general public.
Do the Hazard Analysis. Require appropriate PPE for the involved employees.
Avoid the if it’s good for one, it’s good for many approach.
After all safety ain’t magic.
Safety isn’t shamanism. It isn’t about magic. It’s about critical thought.
Critical thought- like requiring high visibility clothing- ONLY for those who would be protected by it.
What irks you about the perception of magical safety solutions?
Thanks to EHS Today for sharing John Olesky’s great post.
OSHA, Noise, And Your Precision Machining Shop
December 8, 2010Summary: A change in the interpretation of the word ‘FEASIBLE’ by OSHA could cause all shop owners whose shops noise level exceeds 85 dB to be REQUIRED by OSHA under this new definition to install expensive engineering or administrative controls to abate the noise to levels below the action level. PPE could no longer be acceptable as the sole means of addressing noise exposure in our shops.
Action You Need to Take:
1) Determine the noise level in your shop to see if it exceeds 85dB TWA.
2) Determine cost to install noise guarding on machines necessary to abate noise levels to below 85dB (engineering control)
3) Determine how many machines must be taken out of service at a time to prevent the noise level from exceeding the 85dB level ( administrative control )
4) Perform a business case analysis to see if your company can remain in business if this change to the definition becomes law, requiring you to purchase sound dampening or reduce production.
5) Document the cost to comply, loss of jobs, and any reduction in competitiveness, capacity or other issue that is a result.
6) Send to Miles Free mfree@pmpa.org so that I can include in PMPA’s formal comments.
7) Send a letter to the Docket for comments on this proposed change in interpretation as well as one to your congressman and please copy PMPA.
Submit comments at http://www.regulations.gov. Individuals who mail or deliver comments must submit three copies to the OSHA Docket Office, Docket No. OSHA-2010-0032, U.S. Department of Labor, Room N-2625, 200 Constitution Ave., N.W., Washington, D.C. 20210. Submissions not longer than 10 pages may be faxed to 202-693-1648
Don’t delay.
PMPA and other metalworking associations requested, and received an extension on the Comments deadline so that we could obtain facts needed to properly assess the consequences of this new interpretation. Comments are now due by March 21, 2011. We need your facts to make our case!
We need your data now to effectively represent you on this potentially shop closing issue.
All data that we have seen from Member shops so far has shown that these shops will need to add sound dampening equipment.
Links: Extension letter:
Notice of Proposed Reinterpretation:
PMPA Extension Request Letter:
The shop (and machininst jobs) you save may be your own.
4 Comments | Engineering, Front Office | Tagged: 85dB, Administrative Controls, Engineering controls, Feasible Reinterpretation, Noise, OSHA Comment, OSHA Noise Reinterpretaion, Personal Protective Equipment, PMPA, PPE | Permalink
Posted by speakingofprecision