protective clothing for brewery workers...• protective equipment, including personal protective...
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Presented By
David Currier & Reva GoldenBrewers Association Safety Subcommittee
PROTECTIVE CLOTHING
FOR BREWERY WORKERS
Best Management Practice
for the Selection of
Protective Clothing for Brewery Workers
Brewers Association2
Agenda
• Hierarchy of Control
• OSHA and Regulatory Compliance
• Protection Head to Toe
• PPE Assessment
• FAQ – The Real Life of Protection
• Summary
OSHA General Duty Clause
“…Shall furnish to each of his employees
employment and a place of employment
which are free from recognized hazards
that are causing or are likely to cause
death or serious physical harm to his
employees…”
Brewers Association7
Brewers Association8
OSHA PPE Standards29 CFR 1910 Subpart I - Personal
Protective Equipment
1910.132 - General requirements.
1910.133 - Eye and face protection.
1910.134 - Respiratory Protection.
1910.135 - Head protection.
1910.136 - Foot protection.
1910.138 - Hand Protection
1910.95 – Hearing Conservation
1910 Subpart I App B - Non-mandatory
Compliance Guidelines for Hazard
Assessment and Personal Protective
Equipment Selection.
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1910.132 – General
Requirements
• Protective equipment, including personal protective equipment
for eyes, face, head, and extremities, protective clothing,
respiratory devices, and protective shields and barriers, shall be
provided, used, and maintained in a sanitary and reliable
condition wherever it is necessary by reason of hazards of
processes or environment, chemical hazards, radiological
hazards, or mechanical irritants encountered in a manner
capable of causing injury or impairment in the function of any
part of the body through absorption, inhalation or physical
contact
• The employer shall assess the workplace.
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1910.132 – General
Requirements -
Payment
• …. personal protective equipment (PPE), used to comply with
this part, shall be provided by the employer at no cost to
employees. The employer must pay for replacement PPE, except
when the employee has lost or intentionally damaged the PPE.
• The employer is not required to pay for employee-owned
equipment. Where employees provide their own protective
equipment, the employer shall be responsible to assure its
adequacy, including proper maintenance, and sanitation of such
equipment.
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• The employer is not required to pay for:
– Everyday ordinary clothing, such as long-sleeve shirts, long
pants, street shoes, and normal work boots;
– Items, used solely for protection from weather, such as winter
coats, jackets, gloves, parkas, rubber boots, hats, raincoats;
– Ordinary sunglasses, and sunscreen;
– non-specialty safety-toe protective footwear (including steel-
toe shoes or steel-toe boots), non-specialty prescription
safety eyewear, provided that the employer permits such
items to be worn off the job-site.
1910.132 – General
Requirements -
Payment
1910.95 – Hearing Protection
• Protection against the effects of noise exposure shall be
provided when the sound levels exceed . . .
• feasible administrative or engineering controls shall be utilized.
• If such controls fail to reduce sound levels personal protective
equipment shall be provided and used to reduce sound levels
• Action level – 85 dBA
– Raised voice conversation at arm’s length
• PEL – 90 dBA
• Noise Reduction Rating (NRR)
• Do not over protect
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1910.133 – Eye and
Face Protection
The employer shall ensure that each
affected employee uses appropriate eye
or face protection when exposed to eye
or face hazards from flying particles,
molten metal, liquid chemicals, acids or
caustic liquids, chemical gases or vapors,
or potentially injurious light radiation.
• ANSI – Z87.1
• Look for “Z87+” or “Z87-2+”
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1910.134 – Respiratory
Protection
• In the control of those occupational diseases
caused by breathing air contaminated with harmful
agents (i.e. dusts, gases, or vapors…)
• The primary objective shall be to use feasible
engineering controls (enclosure, general and local
ventilation, and substitution of less toxic materials).
• When effective engineering controls are not
feasible, or while they are being instituted,
appropriate respirators shall be used pursuant to
this section.
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1910.134 – Respiratory
Protection
• Medical surveillance and fit testing
• Training
• Atmospheric testing
• Storage and inspection
• Dust masks
– Mandatory
– Voluntary
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1910.134 – Respiratory Protection
Appendix D – Voluntary Use
“Dust masks”
– Workers may wear respirators to avoid exposures to hazards, even if the
hazard does not exceed the permissible limits.
– If your employer provides respirators for your voluntary use, or if you provide
your own respirator, you need to take certain precautions to be sure that the
respirator itself does not present a hazard.
Precautions:
– Read and heed all instructions provided by the manufacturer
– Choose respirators certified for use to protect against the contaminant of
concern.
– Do not wear your respirator into atmospheres containing contaminants for
which your respirator is not designed to protect against. For example, a
respirator designed to filter dust particles will not protect you against gases,
vapors, or very small solid particles of fumes or smoke.
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1910.134 – Respiratory
Protection
When effective engineering controls are
not feasible…
• Dumping grain
• Sweeping out trailers
• Clean the mill room
• Dry hopping
Most these tasks will fall under the
voluntary use rules
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1910.136 – Foot Protection
The employer shall ensure that each affected employee uses protective
footwear when working in areas where there is a danger of foot injuries
due to falling or rolling objects, or objects piercing the sole, or when the
use of protective footwear will protect the affected employee from an
electrical hazard, such as a static-discharge or electric-shock hazard,
that remains after the employer takes other necessary protective
measures.
Protective footwear must comply with :
– ASTM F-2413-2005, "Standard Specification for Performance Requirements for
Protective Footwear,"
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1910.138 – Hand Protection
Employers shall select and require employees to use appropriate hand
protection when employees' hands are exposed to hazards such as
those from skin absorption of harmful substances; severe cuts or
lacerations; severe abrasions; punctures; chemical burns; thermal
burns; and harmful temperature extremes.
• Chemicals
• Moving supplies/pallets
• Hot surfaces
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1910.138 – Hand Protection
• Chemicals – use glove manufactures compatibility charts
• Physical Hazards – use cut resistance rating
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Hierarchy Revisited
Burden of protection on worker
• Will they use it properly?
• Will they use it at all?
For PPE to be successful it
must be:
• Selected properly (compatible
to the hazard)
• Used properly
• Stored properly
• Renewed regularly
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Hazard Assessment
Selecting the right PPE for the right job
Initial Survey/Brewery Walk-thru
• For each specific area
o Mill Vs. Cellar. Vs Bottling Line
• Or each specific process
o Multi-use space
Identify/Categorize Hazard Sources
• Impact, penetration, compression, chemical, heat, harmful dust ,
light/radiation, loud noises
Where’s it gonna hurt?
• Head, Eyes/Face/Ears, Hands, Feet, Skin, Lungs
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Hazard SourcesMotion
• Motor-driven equipment, tools, machine elements
• Vehicles, forklifts, garage doors
– Is there movement of personnel that could result in collision with
stationary objects?
High Temperatures
• Steam lines, burners, ignition sources, kettle
– Skin burns, eye injury, or heat stress
Process Chemicals
• What chemicals are you using?
• Can they splash? Are they creating vapors?
Generation of Dust
• Grain handling, filtration, sweeping, drilling/sanding
Light/Radiation
• Welding, brazing, cutting, furnaces, heat treating, high intensity lights
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Hazard Sources (cont’d)
Falling Objects
• Working from heights, elevated platforms, warehousing/stacking
Sharp Objects
• What may pierce through feet or cut hands
Rolling/Pinching
• Usually on conveyor lines
• Keg/compressed cylinder handling
Electrical
• Arcing and shock response
Noise
• Are there any areas where you have to raise your voice?
Workplace Layout
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Organize and Analyze the Data
Look at the hazards and determine what
PPE is needed for each area or task
• General area PPE requirements
• Task specific PPE requirements
May require additional analysis
• Just how serious is the hazard and
what’s the risk?
– It’s dusty, but do I need a respirator?
– It’s loud, but do I need earplugs?
– We need safety glasses but which
ones?
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Selection Guidelines
Is the PPE really going to work?
• Gloves, Glasses, Respirator, Boots
Fit Considerations
• Sizing options
• Adjustability
Will it last forever?
• Storing
• Degradation
• Introducing new hazards
Training• Now that you’ve:
– Identified the hazards and selected the proper
PPE for each area/task
• You must train your employees!
– How to use, store, inspect, clean, maintain
– Equipment limitations
• Application incompatibilities
• Frequency of change out
– Signs of failure
• Breakthrough, symptoms of exposure
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Real Life Examples
Employer provides ear plugs
– Employees don’t wear
– Doesn’t consider sizes, comfort, or instruct on how to store/wear
Employer provides dust mask for grain room
– One-size-fits all and poor change out schedule
Kitchen has laminate gloves for cooking
– Brewers borrow and find out not good for PAA
Wearing nitrile gloves when cleaning up after bottling
– Finding a piece of stray glass on the floor
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Real Life Examples
Employer buys female employee a pair of pink boots
– Generic rain galoshes don’t protect against dropped keg
Safety boot with tucked in pants or shorts
– Chemicals drip down and permeate socks
Shoe staging areas
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In Summary - PPE
Personal Protective Equipment
PPE can be a great tool for improving brewer safety
– Not the only tool
– Never the best solution
The right PPE must be selected for the job
– Hazards must be assessed
– May require systematic and scientific analysis
– Limitations must be considered
PPE must be used correctly
– Employees must be trained on use, storage, and maintenance
35
Brewery Safety Training
On-Line Brewery Safety Training
https://brewersassociation.litmos.com/self-signup/
Code: 1327
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Questions & Answers
https://www.brewersassociation.org/wp-content/uploads/2015/04/Best-Management-Practice-for-the-Selection-of-Protective-Clothing-for-Brewery-Workers.pdf
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