Personal Protective Equipment - the New Normal

It may be a mandate or a way for your employees to feel safe at work, but certainly Personal Protective Equipment (PPE) is becoming the new normal. Having a strong plan for supplying, managing, and educating on the proper use of PPE will be crucial to achieving the desired results of protecting your workforce. Below are some tips for implementing a new PPE plan.

1. Determine Supply Needed – Bring together a cross-functional team to determine the PPE that your business is requiring. All final decisions should be documented in a Standard Operating Procedure that can be used for policy creation and training. • Determine PPE requirements and if your company will recommend or require PPE. • If requiring PPE, check with your legal advisor. Regulations may require a business incur the cost of required PPE. • Once you have determined the type and amount of PPE that will be needed, it will be important to begin to procure these items ASAP. As demand increases for PPE, supply will be limited. Now is the time to network with companies that you have established relationships to reserve the supply you need now and ongoing. Another option is to tap into smaller local businesses that may be able to fill certain needs. 2. Managing PPE – now that you have secured the PPE, you will need a plan for keeping inventory, storing, distributing, and replenishing PPE. Keep in mind that delivery times will be longer than usual so you will need set replenishment standards more conservatively than usual. • For larger organizations assigning a point person to manage this process will be important. • Publish the process for obtaining, storing, and replenishing PPE so Managers and Employees understand their part in maintaining adequate levels of PPE. 3. Educating the Workforce – Not only is educating your workforce on the why, what, and how important for ensuring proper PPE use; but, OSHA also requires employers to train each worker on the use of personal protective equipment. • Some critical items to include in your training are: o When it is necessary o What kind is necessary o Importance of hand hygiene o How to properly put it on, adjust it, wear it, and take it off o Limitations of the equipment, what protection it does & does not offer o Proper care, maintenance, useful life, and disposal of the equipment • Other Training Considerations: If you are requiring non-medical masks, gloves, and social distancing, these may be helpful. o Ensure training is virtual or meets social distancing guidelines. o Use virtual “how to” demonstrations, training videos, posters, instructions where possible. o Consider interactive training when possible for a more engaging experience and to determine understanding of training content. o Include direction on how to store or dispose of PPE on breaks and at end of shift. o Train everyone in your organization. It will be important that management sets the example of following and reinforcing your PPE plan. 4. Expectation Setting – Be sure to set expectations for the utilization of PPE. • Reinforce your established guidelines. Establish a plan to observe employees on the floor and provide tips to ensure that PPE is worn properly, and social distancing is maintained. • Provide positive reinforcement to employees for wearing PPE properly and following social distancing. • Meet with employees that are struggling with compliance. Seek to understand why? Perhaps there is an accommodation that is needed (be sure to document it properly and partner with your Human Resources team). It could be an allergy to the materials, limitation on range of motion due to mask ties, etc. Communication will be important to resolve the issue. 5. PPE Sanitization/Disposal – Develop a plan for disposing and sanitizing PPE. • Be sure to establish criteria for cleaning, sanitizing, and storing reusable equipment. • Determine if PPE can be reused and/or sanitized. Follow the manufacturer’s guidelines or EPA guidelines for PPE sanitation. • Identify PPE that is considered for hazardous or solid disposal. Follow the proper disposal methods determined by the EPA. • For disposable equipment ensure that receptacles are plentiful and staged in convenient areas for employees. • These areas will require limited access that meets social distance guidelines. • If PPE is required to wear outside of your facility to ensure social distancing and protect exit touch points, provide guidance for discarding PPE upon exiting the facility. 6. Documentation - Be sure to document all processes, training, accommodations, and employee coaching measures. This will help you to respond to future government agency inquiries or employee inquiries. Following these steps can prepare your organization for a successful PPE Program and smooth implementation. In addition, below are great resources for additional information.

COVID Control and Prevention Source: Occupational Safety & Health Administration

OSHA Workplace Guidance Document Source: Occupational Safety & Health Administration

OSHA Guidance Workplace Preparation Source: Occupational Safety & Health Administration

Existing OSHA Standards that May Apply Source: Occupational Safety & Health Administration

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