Friday, October 15, 2010

IMPROVING THE PPE BUYING DECISION PROCESS CAN HELP REDUCE INJURIES AND INJURY COSTS

Each year industry spends almost $4 billion dollars on personal protective equipment yet it still experiences injuries at a cost of about $127 billion dollars. According to the Bureau of Labor Statistics more than 60% of those injured were wearing PPE which shows that simply wearing some type of PPE on the job is no guarantee a worker won't be injured.

What is wrong with this picture? Why are employers spending 4 billion dollars a year on PPE that turns out to be ineffective against the hazards of the work place or so uncomfortable workers refuse to wear it?  A noted safety consultant believes that accidents and injuries are caused by two things:

1. Human error.

2. Management system defect.

When an injury occurs, the behavior of the injured worker is investigated to see if an error was made. Frequently, safety management systems are examined for defects but the focus is usually on a defect in safety enforcement. Seldom, if ever, is the PPE buying decision examined to determine why ineffective or inappropriate PPE was purchased and supplied to the workforce.

When we talk about the buying decision we are not talking about a decision to place a purchase order. We are referring to the decision to provide specific products to protect against the hazards of a particular job. At the root of the PPE buying decision problem is the widely held belief that PPE is a commodity and a regulatory expense that should be minimized. With that mind set there is little incentive to spend any time, effort or money to try to make a better buying decision.

But the truth of the matter is there are significant performance differences based on PPE design, material, and workmanship. For any particular job environment and hazards there is a specific style, brand and model of protective device that is more effective and more appropriate than any other. Safety officials and PPE buying decision makers have a responsibility to determine what that is.

Unfortunately, when faced with the problems of a downsized staff, budget restrictions and a whole host of seemingly more pressing problems, safety officials often opt for a straight rebuy of whatever PPE is being used with little or no thought about seeing if there is something better available. Or, they look for something similar at a lower price in a misguided attempt to comply with cost reduction initiatives by trying to lower the purchase price of PPE instead of the costs of injuries, downtime, insurance premiums and OSHA violations. Both of these options increase the risk of injury to their workforce.

OSHA acknowledged that there was a buying decision problem when they revised the PPE regulation in 1994. The revised rule still requires an employer to provide PPE whenever necessary to mitigate the risk of an injury on the job. But for the first time, based on the BLS findings, it called for a structured buying decision process in the general requirements section of 2 9 CFR 1910.132  in a sub paragraph called "hazard assessment and selection". Appendix B of the revised regulation provides guidelines for the buying decision process. OSHA estimates that 90% of injuries can be eliminated if the PPE guidelines are followed. A link to the OSHA buying decision guidelines is below:

https://docs.google.com/fileview?id=0B-NtMFfeWweVZDgyZmQ1MGUtOWMzOS00NDkzLWFkNzAtNzA4Mjg4ZTZlZTYz&hl=en&authkey=CLfT8qEB


Appendix B clearly demonstrates that OSHA does not consider PPE a commodity that should be purchased on price. In fact it says "select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from the hazards" A small percentage of employer's use the PPE selection guidelines to upgrade their programs and the results are striking.  But the vast majority of employers are either not aware of the assessment and selection provisions of the standard or choose to ignore them. We suggest that is a "mangement system error" that is as responsible for injuries as anything an employee does and should be investigated with the same vigor.

Appendix B, of the OSHA PPE rule also asks safety officials to use "common sense and expertise" when selecting PPE. While most safety officials have plenty of common sense, there is an alarming lack of PPE expertise even at larger companies with well-staffed safety departments. Lacking the in depth knowledge to make a proper determination of exactly what PPE should be used and why, safety officials continue to buy and supply the wrong PPE for the wrong reasons. That is where distributor and PPE manufacturer Sales Professionals can help by raising their level of knowledge to the point where they can make the quality of buying decision OSHA envisions and their employees deserve. Instead of "pushing sales", help customers make a better buying decision and sales will follow.


An improved PPE buying decision can reduce injury frequency by increasing the likelihood that the most effective and appropriate PPE is selected for the job. It can also help reduce cost by mitigating injury severity. Top quality PPE, carefully selected and properly used can contribute to cost reduction on a scale with any other cost reduction program.