When PPE Isn’t Enough: Rethinking Chemical Safety Through the Hierarchy of Controls
A hands-on assessment of hazardous chemical handling reveals how overreliance on PPE can introduce new risks—and why engineering controls and worker engagement are critical to safer outcomes.
I’ve been working with a client recently on safety and industrial hygiene assessments and improvements for a process that involves handling some pretty hazardous chemicals. It’s an older process that involves manual handling of drums, as well as weighing and adding chemicals to process tanks using buckets. While some engineering controls are in place, there is a heavy reliance on personal protective equipment for chemical handling.
This experience reinforced the value of the hierarchy of controls. In this situation, the chemical protective PPE created heat stress concerns in the summer. Worker acceptance and compliance is a challenge with bulky and uncomfortable PPE that makes their job harder. This is particularly noticeable with experienced workers who may become complacent around chemicals that should normally instill a little fear and/or respect.
Selecting the right level of PPE for these tasks can be challenging. While worker protection is always a priority, every layer of PPE for chemical protection can create other risks. Respirators affect visibility and communication. Gloves can affect dexterity and grip. Chemical protective suits become uncomfortably sweaty quickly and eliminate evaporative cooling, increasing the risk of heat stress.
Health and safety management systems such as ISO 45001 and OSHA VPP emphasize the importance of employee involvement. Getting input from workers on this process has helped with adjustments to the level of PPE, balancing the chemical and other risks with the demands of the job. Involvement has also improved understanding of the risks and the need for PPE among both new and experienced workers, and compliance with both.
PPE will be an ongoing challenge and will create unwanted risks in this chemical-handling task. This takes time and effort for workers, supervisors, and health and safety staff.
One of the key lessons from behavioral safety is that people learn and make decisions based on repeated outcomes, drawing conclusions from both their own experiences and the behavior of others around them. For example, if most of the time I don’t get splashed with a chemical, but every time I wear PPE it is hot, uncomfortable, and makes my job harder, then there is a lot of negative reinforcement in wearing it, and positive reinforcement for short-cutting PPE. Over time, the absence of incidents can create a misperception that the hazard is less than it really is. If hazards are perceived as low risk, PPE is less likely to be valued or used consistently. It makes sense that PPE would not be as reliable as engineering and other controls.
This article originally appeared in the issue of Occupational Health & Safety.