From: James Keating <james.k.keating**At_Symbol_Here**GMAIL.COM>
Subject: Re: [DCHAS-L] PPE Excuses for Non-Compliance
Date: Thu, 30 Jul 2020 16:59:14 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: 00d501d666b4$48dd08c0$da971a40$**At_Symbol_Here**



Those of us who purchase and prescribe PPE should wear it before we buy it. We should request a variety of samples and wear them in the environment that we expect employees and students to wear it.


We should also stop forcing people to wear certain PPE if it is indeed unnecessary and not required by regulation. This will save money for the purchase of necessary PPE as well as instill confidence in the PPE policy and procedures of the institution and engender increased compliance - hopefully.


Many institutions implement over restrictive "best practices" based on a reaction to a past incident that may not be analogous or relevant to the tasks being performed. Make sure you are talking about apples and apples.


I don't see ill-fitting lab coats as a big deal. However, supplying ill-fitting PPE for tasks that involve climbing or crawling in and out of confined spaces is hazardous.



Safety Glasses:


Many of the excuses listed for not wearing certain PPE should be addressed by supplying more appropriate PPE or improving the work environment e.g. lowering humidity with air conditioning to prevent the fogging of safety glasses.


While I am on the subject of safety glasses, I have worn and required employees to wear at least 100 different brands and styles ranging from those designed to be worn over prescription glasses to foam backed glasses to ordinary and traditional employer supplied non-prescription glasses.


In a warm humid environment or when the employee is performing even moderate work almost all glasses fog up especially if the lenses are loose fitting where they meet the upper cheek of the face providing a pathway for warm, humid breath to fog the inside of the lenses. I have observed that the closer the bottom of the lenses fit to the top of the cheek the less the glasses fog because fogging is invariably on the inside. Preferably the bottom of the glasses should be inContact with face.


If I may, I would like to give an example of what I believe is a reactionary and inappropriate decision regarding the "upping the ante" if you will on eye protection requirements. This example is regarding a project where I was employed as a consultant serving as site/project safety manager for the General Contractor. The company was experiencing an unacceptable number of eye injury incidents nationwide. Their solution was to require the use of only company supplied foam backed safety glasses. The rational, as explained to me by the corporate safety manager, was that interviews with employees who reported foreign objects in the eye revealed that they were all wearing safety glasses when something ended up in their eye.


I asked the corporate safety manager if any of the interviewed employees volunteered that they were not wearing eye protection when the foreign object ended up in their eye and his response was no. My response was, "I thought so". Over the past 30 years serving as a safety manager and as a supervisory engineer on construction sites I have never had a worker tell me he got a foreign object in his eye and was not wearing eye protection.


The complaints of fogging from employees were continuous after these restrictive glasses were required. Moreover, if you review the ANSI test procedure for foam backed safety glasses it specifies stuffing cotton between the gaps in the safety glasses and the face of the test dummy head before starting the test. When ANSI received inquiries during the comments period there response was that the cotton was used to fill the gaps because people have different size heads. My guess is the ANSI committee assumed that workers would stuff these inevitable gaps with cotton balls just as they did with the dummy head during the test.


I personally saw no value in a universal requirement for foam backed safety glasses regardless of the task being performed. The hazards associated with visual restriction, resulting from fogging, far out weighed any additional protection provide by the foam backing, especially since these employees were performing construction work at heights that involved climbing.


The above scenario is just one of many reactionary and poor choices in selection and requirements of PPE, that I have witness in my career.


Jim Keating

EHS Consultant






From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Jeffrey Lewin
Sent: Thursday, July 30, 2020 12:57 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] PPE Excuses for Non-Compliance


  • The activity I'm doing doesn't require eye protection (using a microscope in a biology lab)
  • The activity I'm doing isn't hazardous, nor are there any hazardous activities in the lab (using a computer with no "active" experiments running, i.e. no one else working in the lab, but there are unattended experiments running)
  • The activity I'm doing isn't hazardous and other hazardous activities are "far enough" away (putting tape on the floor to designate "office" activity areas - especially problematic where students regularly use, either by choice or assignment, office space in the lab as their primary working area)
  • "I'm wearing safety glasses" i.e. impact glasses when the hazard calls for splash goggles
  • "That noise isn't _that_ loud "
  • "I'm wearing my ear buds, doesn't that count as ear plugs?"
  • "I have a face shield on, why do I need safety glasses?
  • (In a shop) holding up your hand in front of your face instead of putting impact eye protection
  • "I have leather boots on, why do I need safety toes?"
  • We once had a student show up in lab who claimed he had a "right" not to wear shoes; needless to say he was denied entry to the lab...and he never came back...but honestly, we wanted to see how he was going to go barefoot when it was 10F outside with snow coming down...



On Thu, Jul 30, 2020 at 10:59 AM Debra M Decker <00001204b93f9a5e-dmarc-request**At_Symbol_Here**> wrote:

Hi Pauline:



I was hoping that you all could help me brainstorm additional excuses that you all have heard



My glasses fog up.

I have to wear prescription glasses and safety glasses don't fit over my prescription glasses.

They hurt my ears.

The lenses are scratched.

I can't get close enough to my work (microscope use).

I'm working in the biosafety cabinet,  fume hood, glove box and I have the sash/window in front of me.


Lab coat:

Too hot 

Too tight 

Too loose

Too long

Too short

The sleeves drag in my work.

Someone else wore it and it's not clean.

It might get caught in the equipment.

I don't care if my clothes get chemicals on them.

I'm allergic.


Fundamentally,  I think, it's ill-fitting PPE that people don't want to wear. If you go down this road, I hope the Institute is prepared to invest in a variety of sizes and shapes of PPE.


Itll be interesting to see what others come up with. 





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Jeff Lewin

Director of Chemical Laboratory Operations

Research Integrity Office

Laboratory Operations

205 Lakeshore Center 

Michigan Technological University


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