Personal Protective Equipment: It's the Law!
Roy, Ken, The Science Teacher
Observed by his science supervisor in a high school AP laboratory, a veteran chemistry teacher allowed students to use 12 M hydrochloric acid without any eye protection. With 34 years of experience and a sound track record, the teacher felt there was no need to require it. If a safety incident had occurred, this instructor would have broken the law: In most states, students and employees in science laboratories are required to use eye protection when working with hazardous chemicals. The teacher--and the supervisor who observed the unsafe behavior--would have had to deal with serious legal entanglements from lack of "duty of care" and liability issues, not to mention the possibility of blindness.
In addition to the Occupational Health and Safety Administration (OSHA) personal protective equipment (PPE) standard--OSHA Laboratory Standard 29CFR 1910.132 (see "On the web")--and other professional prudent practices, many states have protective eye device statutes. PPE is third in the hierarchy approach to dealing with safety. In this priority list, the employer must first evaluate the feasibility of engineering controls and administrative procedures (discussed in my last two columns) before considering the use of PPE.
OSHA's PPE standard relates to respiratory devices; protective equipment for eyes, face, head, and extremities; protective clothing; and protective shields and barriers. The standard requires employers to provide PPE wherever it is necessary due to hazardous processes or environment; chemical hazards; mechanical irritants; or radiological hazards encountered in a manner capable of effecting injury or impairment in the function of any part of the body through absorption, inhalation, or physical contact. The employer is also mandated to have the employee use PPE as appropriate and maintain PPE in sanitary and reliable condition.
To assess and determine the need for PPE, a survey must be conducted by the employer with help from science teachers. It should identify activities and equipment for which appropriate PPE can minimize hazards. Selection of PPE is based upon a level of protection greater than the minimum required to protect the exposed science teachers from potential or observed hazards. Students are covered under separate, non-OSHA state and local regulations and professional laboratory safety standards (see "On the web").
Once the employer performs a hazard survey of the workplace to determine those that are present or likely to be present, he or she must: Select, provide, and require the use of appropriate PPE for each affected employee; communicate PPE selection decisions to each affected employee; select and provide PPE that properly fits each affected employee; and conduct and document employee training.
The following components reflect the body of the PPE assessment that should be addressed by teachers, students, and supervisors in science laboratories or field experiences:
* Body: Aprons--of the appropriate length just below the knees to prevent trip-and-fall hazards--are needed to protect clothing and skin from such incidents as spills and splashes in the laboratory. …