A small pallet plant on the edge of the woods with a handful of laborers might be able to get by on the premise that callused hands constitute all the personal protection they need. The rest of us understand that a thoughtful safety plan will A) demonstrate concern for the welfare of our employees, B) avoid unpleasant OSHA inquisitions, and C) avoid ruinous losses by preventing injuries.

            We want to keep our people protected, but we want to do it wisely. The three main variables that complicate a safety program are: 

            • Identifying what protection is needed and what products to employ

            • Getting employees on board

            • Keeping costs under control

What’s a Responsible Level of Protection?

            The legal requirement specified in OSHA 29 CFR Part 1910.132 prescribes in detail what Personal Protective Equipment (PPE) is required to protect against every conceivable workplace hazard, but it relies in part on the discretion of plant management to determine how dangerous the work environment is. The typical pallet plant is undeniably a dangerous place that necessitates the use of safety glasses, ear protection, reinforced footwear and gloves by any interpretation of the standard. Whether the environmental hazards of your plant require hard hats, dust masks, face shields or safety vests under the law depends on the nature of your facility and, to some degree, your own assessment of the hazards present.

            While the Obama administration has promised to step up enforcement of workplace safety, an informal survey of safety industry distributors did not turn up one example of a production facility being raided by OSHA or subjected to onerous fines.

            It is not the intent of this article—explicit or implied—to provide legal advice on safety issues. It is rather to make the point that PPE is important regardless of what OSHA demands. For any plant manager that has experienced an employee injury, the focus becomes less on OSHA compliance and more on loss prevention. The cost of saving one injury can easily pay for a lot of safety equipment, and that tends to be a greater motivator than the specter of a visit from old man OSHA.

            As president of Hub Industrial Supply, a company that supplies safety products to the pallet industry, I have observed two critical factors that influence the degree of safety compliance in the pallet industry – the size of the business and whether they’ve had a significant loss time incident in the past.

            The real little guys may have never had an injury that’s substantial so they’re trying to keep their costs as low as possible. The bigger the business, the more liability they have because lawyers like to go after the people with the deepest pockets.

            There is also a diversity of enforcement among various plants. Generally, the smaller plants say, “we give our guys glasses; if they don’t wear them, it’s fine.” In a bigger plant, even if safety glasses or gloves get in the worker’s way, they’re going to have to wear them, period. I visit some plants that require any visitor or someone just walking through (a production area) to wear a safety vest because they don’t want a forklift to run over them – I mean, safety is a big deal!

            Some plant operators believe that PPE is merely trading old hazards for new ones. I have heard some people say, “I don’t want my guys to wear gloves because if a glove gets snagged, it can tear the guy’s hand into the machine.”

            In fact, a poorly administered PPE program could indeed backfire in the manner described, according to Robin Roberts, a 30-year veteran in the glove industry. If an employee were forced to wear an ill-fitting glove, it could introduce a snag hazard that would negate the benefit of wearing the glove. But don’t blame the glove; blame the misguided and inflexible safety program.

            Providing effective PPE is becoming easier all the time as the safety industry continues to improve its technology and offer more comfortable, user friendly and cost-effective products, Roberts observed. “The reality is that recent years have brought about a remarkable number of gloves that offer features and benefits that far exceed the status quo,” he said.

            New production methods using materials like PVC, nylon and nitrile in gloves have yielded a new generation of high-performance hand protection. Some of the black nitrile gloves offered by Hub Industrial provide enough dexterity that a person wearing them can actually type on a Blackberry while wearing these gloves.

            Another example of safety product innovation is a face screen called the Brush Defender. Designed for use with a hard hat, it is a mesh material that won’t fog up like a plastic shield but will deflect flying debris. It gives you very good maneuverability of the head, you can wear glasses underneath it, and it protects the face.

            Hub Industrial Supply developed this product in response to a pallet recycler’s concern over flying nails at his tables. His workers were getting injured when rebuilding pallets with a pneumatic stapler. The recycled wood sometimes conceals embedded nails. A nail shot on top of the hidden nail can be deflected with the same thrilling ricochet as a .45 slug in a Hollywood action movie. I’ve know of guys who have saved their entire cheekbone because it protects the guy’s face from flying nails.

            With the wide variety of emerging PPE products becoming available, it’s always a good idea to ask your safety product supplier to audit your program from time to time and suggest changes.

            Roberts said a good way to keep your safety initiative up to date is to request samples of new products from your supplier to evaluate their efficacy without investing in something that isn’t going to work for you. He also pointed out that the most cost-effective products aren’t always the least expensive ones. “In many cases there are gloves that can be a less costly product over time even though they cost more to purchase,” he said.

How Do I Give My Staff the Safety Bug?

            Some plant managers feel they’ve done their duty by providing the required PPE and feel it’s up to the workers to use them or not. This egalitarian philosophy seldom survives the first injury loss, when the plant management realizes what they will have to pay to uphold the freedom of choice of their employee.

            Other plants make PPE mandatory, and failure to comply is cause for termination. Regardless of plant policy, it is highly desirable to have workers as happy with their PPE as possible. Satisfaction with their equipment means employees are A) more likely to use it and use it properly; B) less likely to be injured by neglect or misuse of it; and C) happier overall to be working for a company that is responsive to their safety and well-being.

            So what strategies can management employ to increase PPE esprit? There are at least three things you can do to make safety a team effort:

            • Provide choices of styles

            • Make those choices as stylish as possible

            • Implement a training program that fosters safety awareness

Choice of Styles

            Who can forget the immortal statement: “If the gloves don’t fit, you must acquit!”

            It won’t rhyme quite as sweetly as Johnny Cochran’s words, but the chant for pallet plants needs to be modified to: “If the gloves don’t fit, they won’t protect!”

            Equipment you offer must take into account the size differences of your workers, and nowhere is this more critical than gloves. Roberts said, “Many glove styles are available in a variety of sizes and in cuts designed for both men and women. Many employers simply provide only one size to all employees regardless of gender or hand size in an effort to ‘make things simple.’” The consequences of poor fit are premature wear of equipment, hand fatigue, and (as mentioned above) unsafe susceptibility to snagging.

            Ear protection equipment also seems to “feel” differently to different users, and offering a choice of styles allows workers to select the one they find most comfortable.

            Factoring in worker physiology and personal preference differences can make a big improvement in employee attitudes. In addition to this, have you considered the following?

The Fashion Factor

             Let’s face it: none of us like to look like dorks. Even in the down and dirty work environment, people take a certain pride in their appearance and will balk at wearing equipment that makes them look like Jerry Lewis in The Nutty Professor. Granted, the stigma fades eventually if everybody’s wearing it, but the point is this: performance always should be the first consideration, but any PPE that has a stylish appearance will assist in its acceptance.

            Take glasses, for example. Curry said his best-selling model combines performance and fashion: “It wraps to the face, is stylish, gives very good protection and has the ANSI spec stamped on the temple.”

            One potential downside to furnishing high-fashion PPE: if it’s too successful, you may have to keep it under lock and key to avoid theft.

Making it a Group Effort

            All this money and effort expended to provide your staff with useful and stylish choices of PPE will be twice as effective if it is backed up with an ongoing effort to train workers in correct usage of PPE and encourage them to put safety as the highest priority. Developing a specific safety program that fits your plant culture is a topic that deserves an article of its own and will not be attempted here. I suggest consulting your safety products distributor as an excellent resource for ideas. They can often be willing to help with free training, lectures and demonstrations to your staff. Some suppliers will even administer turnkey safety programs at little or no cost.

How Do I Keep Costs Under Control?

            Cost management of safety equipment requires value purchasing as well as controlling shrink. As mentioned above, some of the safety products that cost more up front actually deliver better value by outlasting the less expensive choices. For example, Curry said there are washable earplugs that cost eight to ten times what disposables cost, but they pay for themselves after two weeks’ use.

            Another angle to consider is ergonomics. Would you be interested in a product that cost more money but led to a 1.5% improvement in overall productivity because workers had better freedom of movement? As mentioned above, it pays to avail yourself of product samples to allow an opportunity to evaluate every possible value factor.

            To counter shrink due to premature failure or irresponsible misuse of equipment, the first step is to determine whether the problem is with the product or the user. Gloves are often the item of greatest concern since they tend to be the most expensive consumable.

            One of the best ways to optimize life on a pair of gloves is to require the employee to turn one in before they get another one, and if they don’t turn one in, you take it out of their check. The deduction should not be applied if it brings the employee’s rate to below the minimum wage, he hastened to warn.

            Roberts pointed out that high shrink in gloves isn’t always the fault of careless use. “How long the employee uses the glove before replacing it may provide clues to determine if a better glove could reduce the customer’s overall costs,” he said.

New Developments for Fall Protection PPE

            OSHA is currently in the process of revising its requirements regarding worker protection from tripping, slipping and falling hazards on walking and working surfaces. This revision includes PPE requirements used as fall protection products. Specifically, the agency wants to expand requirements that currently apply only to PPE used for face, eye, head, foot and hand protection. This includes requiring employers to conduct hazard assessments; to select the proper PPE; to remove defective or damaged PPE from service; and to provide training in the proper use, care, and disposal of PPE.

            The current walking-working surfaces standards also do not allow OSHA to fine employers who let workers climb certain ladders without fall protection. Under the revised standards, this restriction would be lifted in virtually all industries, allowing OSHA inspectors to fine employers who allow their workers to climb these ladders without proper fall protection.

            More information on these provisions will be available as OSHA finalizes changes later this year.

Conclusion

            A PPE-based safety program is a necessary precaution that can preserve your company from a lot of unforeseen trouble that could even threaten your company’s survival. By taking a thoughtful approach and using your safety equipment supplier as a partner, it is possible to effectively reduce risk, comply with OSHA, and keep it affordable.

            Gabriel Curry is president of Hub Industrial. He can be reached by email at Gabriel@hubindustrialsupply.com or by phone at 800-743-9401, or visit http://www.hubindustrialsupply.com/