PROTECTIVE CLOTHING FOR BREWERY WORKERS...• Protective equipment, including personal protective...

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

Personal Protective Equipment

(PPE)

is the last choice



OSHA

&

Regulatory Compliance


Federal vs. State Programs

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…”



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.


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.


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.


• 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


Protection Head to Toe

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



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+”


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.



Protection

• Medical surveillance and fit testing

• Training

• Atmospheric testing

• Storage and inspection

• Dust masks

– Mandatory

– Voluntary


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.



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


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,"


1910.136 – Foot Protection


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


1910.138 – Hand Protection

• Chemicals – use glove manufactures compatibility charts

• Physical Hazards – use cut resistance rating


PPE Assessment


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


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


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


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


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?


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


In Practice…

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



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


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


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

https://brewersassociation.litmos.com/self-signup/

36

Questions & Answers

https://www.brewersassociation.org/wp-content/uploads/2015/04/Best-Management-Practice-for-the-Selection-of-Protective-Clothing-for-Brewery-Workers.pdf

https://www.brewersassociation.org/wp-content/uploads/2015/04/Best-Management-Practice-for-the-Selection-of-Protective-Clothing-for-Brewery-Workers.pdf

PROTECTIVE CLOTHING FOR BREWERY WORKERS...• Protective equipment, including personal protective...

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