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Body & Limb Protection PPE Compliance Game Plan

Injuries to the arms, legs and torso are a risk at just about all worksites. Common types of limb and body injury include:

In addition to preventing most injuries, requiring workers to use appropriate body and limb protection and PPE is key to ensuring compliance with OHS regulations. Here’s a look at OHS body and limb PPE requirements and a 6-step game plan for complying with them.

Step 1. Perform Body/Limb Injury Hazard Assessment

The first step in the compliance process is to have a qualified person identify and assess potential body and limb injury hazards at your site. In BC and Yukon, the hazard assessment must be done in consultation with the workplace JHSC or health and safety representative. Pay particular attention to high-risk operations such as:

Step 2: Try to Engineer Away Body & Limb Hazards

Canadian OHS laws follow the so-called hierarchy of controls approach to managing hazards, at the top of which is total hazard elimination via substitution, engineering and/or work design solutions. Example: You want to control amputation hazards to workers who work on cutting machines:

  • Substitution: Eliminate the task or machine that poses the hazard’if that’s not reasonably practicable:
  • Engineering Controls: Implement solutions that engineer away the hazard by ensuring the cutting machine is equipped with appropriate guarding devices or shutoff mechanisms that prevent the blade from activating when a worker’s body part is in the cutting zone and place a physical barrier around the machine to keep unauthorized personnel away.

Step 3: Use Administrative or Work Controls to Manage Body & Limb Hazards

If engineering controls aren’t reasonably practicable or as a supplement to those controls, minimize the hazard by controlling the way the work is performed. In the cutting machine example, work controls would include:

  • Ensuring workers who operate the machine are properly trained, instructed and supervised to use it safely;
  • Banning untrained workers from using or working near the machine;
  • Implementing safe work procedures for carrying out machine operations involving risk of injury;
  • Regularly inspecting and maintaining the cutting machine and its safety devices to ensure they’re in safe working order;
  • Prohibiting workers from disabling the machine’s safety devices; and
  • Appropriately discipline who violate that or any of the other cutting machine safety rules.

Step 4: Ensure Workers Have and Use the Required Arm & Limb Protection

PPE is the protection of last resort that should be used only when engineering controls are impracticable or as a supplement to those controls. To start, all workers should purchase and use a set of general purpose gloves and boots or safety footwear. However, employers are generally responsible for providing or at least ensuring that workers have and use special kinds of PPE such as:

  • Protective gloves to protect workers exposed to prolonged or severe hand-arm vibration;
  • Gauntlet gloves, aprons, arm protection, safety pants and chaps made of leather or other suitable fire-retardant material for welding and other hot work operations;
  • Rubber insulating footwear, gloves and mittens for workers who work on or near energized equipment (where lockout is impracticable) or power lines;
  • Puncture-proof safety boots, mitts or gloves and limb protection for handling sharps and other materials involving risk of puncture, cuts, abrasion, perforation and laceration;
  • Acid-resistant gloves, footwear or arm and leg protection for handling batteries;
  • PPE for handling infectious or corrosive biological materials or chemicals, particularly in healthcare settings.

Step 5. Ensure Proper Use & Maintenance of Body & Limb Protection

As employer, you’re responsible for ensuring that workers properly use and maintain the body and limb protection they’re required to wear. So, establish clear safety rules and policies requiring that workers, among other things, to:

  • Ensure that their protection and PPE is comfortable and fits properly;
  • Ensure that the protection doesn’t create any safety hazards’for example, wearing gloves while using machinery could pose entanglement dangers;
  • Inspect their PPE before each use for cracks, holes, separation of materials, etc.;
  • Follow manufacturer’s recommendations for cleaning and maintenance; and
  • Replace any PPE that’s defective or so worn out as to render the protection provided ineffective.

Step 6: Train Workers in Body & Limb Protection Rules

Every worker required to use body and limb protection must, before first use, receive training and instruction from a supervisor or other qualified person covering, at a minimum:

  • How the protection works;
  • Why the worker has to wear it;
  • Any limitations in the protection the equipment provides;
  • How to properly use, maintain, inspect and store the equipment; and
  • How to carry out the applicable safe work procedures for operations requiring use of the equipment.

Be sure to verify that workers understand and are capable of applying their training and keep written records documenting the training provided, who furnished it and the date and time of training.