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Hong KongPPE and hazard communication
The employer assesses hazards, provides PPE and generally pays for it. PPE sits last in the hierarchy of controls, after elimination, substitution, engineering controls and administrative controls.
Two related requirements, and the ordering principle behind both is what gets tested.
The hierarchy of controls
Eliminate the hazard. Substitute something safer. Engineer a control. Change the work practice. Then, last, protective equipment.
PPE is last because it protects one person and only while worn correctly. A guardrail protects everybody passively; a harness protects one person if they clip on.
A scenario describing a hazard and offering four responses is usually asking which sits highest in the hierarchy. PPE is rarely the best available answer even when it is an acceptable one.
Who pays
The employer, for most required PPE. There are limited exceptions, including ordinary safety-toe footwear and prescription safety eyewear where the employer permits it off site.
The general rule is that required protective equipment is provided at no cost to the employee.
The hazard assessment
The employer assesses the workplace to determine what hazards are present and what PPE is required. That assessment drives the selection rather than habit or preference.
Hazard communication alongside it
A written program, labels with six required elements, safety data sheets in the standard sixteen-section format, and training.
The PPE requirements for a chemical are in section 8 of its safety data sheet, which is where the two topics meet.
Training is part of both
Employees are trained on which PPE is necessary, how to put it on and take it off, its limitations, and how to care for it. Training is documented.
Hazard communication training covers the labels, the safety data sheets and the specific hazards in the workplace. Both are recurring rather than one-off, since new hazards and new people arrive throughout a project.
Common questions
What is the hierarchy of controls?
Eliminate, substitute, engineer, change work practices, then PPE last.
Why is PPE last?
It protects one person and only while worn correctly, whereas engineering controls protect everybody passively.
Who pays for PPE?
The employer, for most required equipment, with limited exceptions such as ordinary safety-toe footwear.
What drives PPE selection?
A workplace hazard assessment carried out by the employer.
Where are PPE requirements for a chemical?
Section 8 of its safety data sheet, on exposure controls and personal protection.