PPE compliance is a common safety issue, and it may ebb and flow over the life of a program. I don’t say this to excuse or minimize it. Instead, I want encourage everyone to remain vigilant, even if your program’s compliance is currently on target.
When safety culture begins to shift away from thorough PPE compliance, it can snowball quickly and create a prolonged, frustrating rift between safety professionals and employees. The good news is that there are proactive steps you can take to keep your program on track.
The Underlying Causes of PPE Non-Compliance
The most common excuses for PPE non-compliance cite comfort, accessibility, and necessity. In some cases, these concerns may be well-founded (and should prompt a closer policy review), but more often they are indicators of larger safety culture issues.
These issues include training deficiencies, poor oversight, and inconsistent communication. PPE compliance is a critical component of health and safety, and it’s important to establish it as a high priority throughout the organization. It only takes one or two bad apples to promote a non-compliant culture.
Always Lead By Example
The importance of PPE compliance needs to be stressed to all members of the organization, including upper management. Few things are as damaging to the safety message as when employees see the safety team members or management out of compliance. One instance of quickly popping in to “grab something, or speak to someone, or drop something off”, can set a precedent that is very difficult to correct.
With these concepts in mind, what steps can you take to improve PPE compliance?
Start Early: Involve Employees in the PPE Selection Process
Comfort is always one of the top complaints when it comes to PPE compliance, so the more you can do to proactively address this issue, the better compliance will be. Too many organizations select and order PPE without any input from the employees who will wear it. This often results in the selection of low quality, “cost-effective” PPE, rather than comfortable products that improve compliance. Cost should not be the determining factor in PPE selection. Protection and comfort should always take precedence.
One of the best strategies for improving compliance allow employees to sample PPE options. A PPE demo day is an efficient way to introduce employees to multiple offerings, improve buy-in, and create momentum toward a more compliant program. These demos can be held for safety glasses, lab coats, hearing protection, gloves, aprons, helmets, faceshields, shoes, or any other required PPE your program requires.
Make It Easy: PPE Should Be Readily Accessible
Another common complaint is accessibility. With that in mind, employees shouldn’t need to go out of their way to find the appropriate PPE. This is especially true for “quick” tasks that require employees to pop in and out of the work area. All required PPE should be conveniently located at each entrance and any PPE required for specialized tasks should be provided at the point of use. If employees need to spend significant time hunting down the appropriate PPE, you open the door for corner-cutting and compliance issues.
Don’t Overdo It: Use PPE Evaluations and Risk Assessments to Justify Requirements
Internal PPE policies should always be reasonable and easily justifiable. While your policies may be heavily guided by regulations, programs often have some flexibility when making decisions. As such, all PPE policies should be based on task-specific risk assessments. Additionally, you should be just as concerned about requiring too much PPE as you are about requiring too little.
Not only will unnecessary PPE lead to internal compliance issues, in many cases extraneous PPE can increase risk. Examples of this include heat stress, vision obstruction, and snag hazards. Keep this in mind when developing PPE policies, especially in multi-use facilities.
Reinforce the “Why”: Build Personal Connections and Help Employees Understand the Risks
Once you’ve developed a reasonable PPE policy, the final step is to effectively communicate it to promote buy-in and compliance. While this should certainly start with your training program, training alone isn’t enough.
Be visible throughout the facility and build relationships with your employees. Be forthright and honest about the policies and explain the factors that went into their development. You should also constantly encourage comments, suggestions, and feedback about changes or improvements, especially as workplace processes evolve. A “this is the policy, deal with it” attitude will not help your case.
Whenever possible, it’s also important to stress the personal protection aspect of the policy. It’s easy for this to become lost in the regulatory shuffle, but highlighting personal protection is often much more effective than “hiding behind regulatory compliance”. Be honest when regulations guide policies, but also help employees appreciate the impact on their health and safety. If employees believe that a policy is only regulatory in nature, it tends to promote a “don’t get caught” attitude rather than a commitment to protecting themselves, co-workers, and the facility.
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