OSHA's PPE Updates Based on National Consensus Standards

September 14, 2009 // Published as a news service by IHS

The rule addressed requirements for eye- and face-protective devices, as well as head and foot protection.

Amendments to the PPE standards include a requirement that safety shoes comply with an American National Standards Institute (ANSI) standard.

There also is a requirement that filter lenses and plates in eye-protective equipment meet a test for transmission of radiant energy specified by another ANSI standard.

According to the Sept. 9 Federal Register posting, Updating OSHA Standards Based on National Consensus Standards; Personal Protective Equipment, the incorporated ANSI standards are more than a decade, and in some instances, two decades old.

Over this period, ANSI updated all of the standards, and, in the instance of ANSI Z41 - Standard for protective footwear, ANSI withdrew its standard when ASTM International adopted a standard for protective footwear.

In response, manufacturers began manufacturing PPE that conforms to the updated ANSI and ASTM standards. As a result, employers and employees had difficulty obtaining PPE manufactured in accordance with the national consensus standards incorporated earlier in OSHA standards.

OSHA estimates that these types of PPE last about two to four years.

In the past, OSHA updated its PPE standards by revising them to incorporate recent versions of the national consensus standards while leaving the earlier versions of these national consensus standards in the regulatory text, according to the Federal Register posting.

This action temporarily alleviated the problem of trying to obtain PPE manufactured in accordance with an earlier version of a national consensus standard, but it ensured that the problem would arise again as the later versions of the standards superseded the newly incorporated versions.

To alleviate this problem, OSHA proposed to replace the references to specific national consensus standards with a performance-oriented "good-design" requirement.

The proposed rule provided guidance on how employers could meet the good-design requirement. It also included nonmandatory appendices listing those national consensus standards that OSHA determined were good-design standards that would meet the good-design requirement.

Commenters agreed with OSHA's proposal to update the references to national consensus standards.

However, employee representatives, PPE manufacturers and safety professionals opposed the proposed replacement of specific references to national consensus standards in the regulatory text with a performance-oriented, good-design requirement and a nonmandatory appendix.

To address these and other comments, OSHA revised the text of the final rules to allow employers to meet the design requirements of its PPE standards by using PPE constructed in accordance with any of three national consensus standards - the two most recent national consensus standards and the national consensus standard incorporated in the current OSHA standards.

Additionally, the final rules maintain the option employers currently have to use PPE that is not manufactured in accordance with one of the listed consensus standards if the employer can demonstrate that the PPE it selects is as protective as PPE constructed in accordance with one of the incorporated consensus standards.

The final rule becomes effective Oct. 9, 2009.

For more information, review the Sept. 9 Federal Register posting.

Source: U.S. Department of Labor Occupational Safety and Health Administration (OSHA).