More and more, construction companies with strong safety programs are focusing on reducing the number of injuries on their sites to zero. That includes serious injuries like ladder falls and minor injuries like incidental scrapes and insect bites. At the LHSFNA, we believe this is a commendable goal. No Laborer should be injured on the job and we applaud companies who take such a serious view on safety.
But too often the first solution proposed to achieve this goal of zero injuries is to put all workers in personal protective equipment (PPE). For example, 100 percent fall protection programs often require all workers performing tasks at 6 feet or higher to wear fall protection harnesses. Likewise, many worksites have 100 percent eye protection policies or 100 percent hardhat rules. While we want all construction workers to be protected, there is a better way to reduce injuries than covering workers in PPE.
Personal protective equipment is at the bottom of the hierarchy of controls for a reason. It is the least reliable form of protection. It can be uncomfortable, may not offer complete protection and workers don’t like wearing it. It also shifts the burden of protection from the employer, who by law must provide a safe workplace, to the worker.
Shouldn’t it instead be our goal to protect workers in such a way that no one needs to wear PPE to be safe? It may sound far-fetched, but zero PPE is not an impossible dream.
Eliminating Hazards through Design and Engineering Controls
The best protection from hazards is to eliminate the hazard itself. If that isn’t possible, engineering controls should be used to reduce or eliminate the hazard. We have been requiring and using PPE for so long that it’s hard to conceive of a workplace or construction site where it would not be necessary. But removing hazards through smart design decisions and engineering controls happens all the time.
Ground-fault circuit interrupters (GFCIs) have saved thousands of lives by engineering out the electrical hazard. Guards on saws (or engineering controls like the SawStop, which works like a GFCI to stop the saw) have saved thousands of fingers and hands. There are other potential solutions if we are willing to pursue them.
Hearing Protection vs. Hearing Loss Prevention
For many employers, hearing protection involves handing out ear plugs and training workers on their use. But ear plugs must be individually fitted and inserted properly and can cause issues by blocking out communications from others or making it difficult to hear warning signals. What if we instead made hearing protection unnecessary by designing tools and equipment that operate at less than 80 dB? NIOSH has been encouraging contractors to “buy quiet” for years and created a power tools database that includes information on sound and vibration levels for common types of tools.
Fall Protection vs. Fall Prevention
Safety professionals distinguish between fall prevention and fall protection. Fall protection involves providing harnesses and lanyards so workers can tie off, which prevents them from contacting the ground if they do fall. Like other types of PPE, fall protection is effective, but can be complicated. Workers must wear the harness properly, have a lanyard that can hold the weight of the fall, be tied off to an anchor that can hold up to 5000 lbs. of force, place the anchor properly and be tied off at all times. If workers do fall, they must be rescued in a timely manner before the harness cuts off their circulation. In addition, some feel that fall protection restricts mobility and can cause a tripping hazard.
Given all these factors, fall prevention (i.e., guardrails to keep workers from falling) seems like a good investment and a better bet than PPE alone. NIOSH has undertaken a number of fall prevention research projects that aim to design fall hazards out of construction, including an easy-to-use guardrail for roofing operations and design solutions such as roof parapets.
Respirators vs. Substitution and Controls
Like other types of PPE, respirators come with their share of challenges. They filter toxic materials from the air, but are uncomfortable to wear and present problems for workers who are claustrophobic, have problems breathing or have facial hair that interferes with the seal. Taking the mask off even for a minute reduces worker protection significantly. Can we reduce or eliminate respirator use?
Many organizations are looking into replacing the chemicals they use with less toxic ones (e.g., replacing solvent-based paints with water-based ones). New websites like Pharos are helping employers choose less toxic building materials. In Massachusetts, the Toxic Use Reduction Institute has worked for years to find safer substitutes for chemicals.
Beyond substitution, an increasing number of tools feature built-in engineering controls like local exhaust or water spray systems. Using these controls, manufacturers, contractors and unions worked together to reduce silica exposures in asphalt milling operations below OSHA’s proposed permissible exposure limit so workers did not have to wear respirators.
By challenging ourselves to focus on zero PPE as a goal, we could make the industry safer as a whole and make safety easier for millions of construction workers. It may sound unrealistic, but it can happen if we unhook ourselves from our attachment to PPE. There’s no doubt that PPE helps keeps workers safe, but it may not be the best solution and certainly shouldn’t be the only solution.
[Scott Schneider is the LHSFNA’s Director of Occupational Safety and Health.]