From: Bruce Van Scoy <bvanscoy**At_Symbol_Here**TWC.COM>
Subject: Re: [DCHAS-L] PPE Excuses for Non-Compliance
Date: Fri, 31 Jul 2020 18:44:10 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: 03d001d6678c$1b7fefe0$527fcfa0$**At_Symbol_Here**twc.com
In-Reply-To <7C171CB3-1935-4FD3-8708-28C49838A4C8**At_Symbol_Here**gmail.com>


John,

I appreciate your comments. Over >35 years of experience I have encountered situations where improperly fitted PPE, e.g., safety glasses, goggles, etc. actually allowed a near miss to turn into injury.

At another company, purchasing threw a fit because I had 28 different splash-proof goggles on hand to personally fit each new employee. I even had "student" goggles. They wanted 3 with no more than 5.

After the 3rd injury, they capitulated. More effort required? Yes. Effective? Yes. We reached more than 4 million hours worked without a lost-time injury and became credit rated by our Bureau of Worker's Compensation (from penalty rated).

All PPE should fit personally and then be mandated by policy based upon the risk assessment. Please show me one researcher who spends 8-hours sitting at their computer without jumping up to do an addition, measurement, etc., I could never find one.

If the researcher is working in an office - great, none required. But in a laboratory the risk assessment has to override individual excuses. Ensuring the PPE is appropriate and properly fitted eliminated almost all of them.

About 1% refused to follow the rules regardless if the PPE was properly fitted or not until they learned that the rules would be enforced.

Amazingly, it only took 2 instances of personnel actions until people realized that we did care about safety, provided proper PPE and would enforce the rules based upon the assessments.

Just my experience,

BruceV

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of John Callen
Sent: Thursday, July 30, 2020 12:36 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] PPE Excuses for Non-Compliance

 

Pauline and All,

 

Please remember when you talk about PPE, do not forget the first word "personal."

 

Some PPE wears may have a valid reason.

 

As in the case for the issuance of respirators, under OSHA 29 CFR 1910.134,

 

"1910.134(d)(1)(iv)

The employer shall select respirators from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user."

The rationale for this requirement is that the respirator which fits correctly and is the most comfortable is the one the worker, researcher, student, etc. will wear.

 

This can be applied to all other PPE, such as protective safety eyewear.  

 

Using protective safety eyewear as an example, you should be allowing the researchers to select from several models and sizes, including OTG's, Over The (prescription) Glasses and you may be able to do this through your safety equipment distributor of choice.

 

Many years ago I participated in a "safety fair" which was facilitated by Walt Disney World's Occupational Safety & Industrial Hygiene (OS&IH) Department together with their distributor of choice.  The staff in small groups came in to see the selection of the various types, models and sizes of eyewear and select the one which fit properly and was comfortable.  One of the OH&IH Department Staff would record the name of the person together with the eyewear he/she selected and then did a tally for ordering them.  

 

Since there are about 100 protective safety eyewear manufactures including some private labels, it would be logistically and economically impossible for your researchers to select from all of them.  You could pair down the list to approximately 2 - 3 manufacturers to start, just like Walt Disney World did.

 

What I state above is in an ideal, non-pandemic environment.  We have to take into account the world we live in today, not only the supply and demand as to what is available but also  if one staff member tries on a pair of safety glasses, it would have to be thoroughly cleaned and disinfected if the next person would want to try the same one on, etc.

 

Just some thoughts for you.

 

Be Safe, Sound, Vigilant & Well!

 

All My Best,

 

John B. Callen, Ph.D.

3M Personal Safety Division - Retired

ACS/DCHAS Founding Member

 

 

 

On Jul 30, 2020, at 10:31 AM, Y. X. <roselle.oneil**At_Symbol_Here**GMAIL.COM> wrote:

 

Pauline,

While it's been several years since I worked in a lab, I had serious depth-perception problems when wearing safety goggles over my prescription glasses.  I had to tap whatever was in my hand against the edge of the 'target' to determine if the item was in front of, behind, or (rarely) on target.  I couldn't place anything without testing for the correct location.  It was irritating and it slowed me down.

Perhaps you can make an argument about the relative merits of 'irritation' and 'safety' - I'm old enough to remember when people absolutely refused to wear seat belts because they were inconvenient.  Nowadays, most people accept the inconvenience as a fair exchange for safety.

My two cents,

Roselle O'Neil

 

 

On Thu, Jul 30, 2020 at 10:18 AM Pauline Serrano <paulineserrano**At_Symbol_Here**gmail.com> wrote:

Hi All

 

As a part of new COVID19 safety policies rolling out at the Broad Institute, we've also decided to actually enforce our PPE policy of wearing a lab coat and safety glasses when working in a lab. Part of the fall out are a lot of excuses that we're hearing from researchers on why they're not complying. 

 

I was hoping that you all could help me brainstorm additional excuses that you all have heard from students, researchers about why they aren't wearing the appropriate PPE. 

 

I want to be ready with responses to each of these excuses. So I thank you in advance for your time with this. 

 

Kind regards,

Pauline Serrano

The Broad Institute of MIT and Harvard

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