how far to go in supplying consumables

atrimble

Our Accident Prevention Team is pondering an issue regarding our provision of sunscreen to employees who work outside. The Purchasing Agent indicates we already spend an average of $300 per employee each year in providing tools and masks and gloves, etc., and now we have a request from an employee for sunscreen protection after having got a bad sunburn last summer. The claim has been made that bad sunburns that don't require medical treatment are non-compensable work-related injuries, but that if they did require medical treatment that it would obviously be a work-related injury. The APTeam is really trying to bring down the cost of our work comp coverage, so we've encouraged the Purchasing Agent to accommodate small requests like personal water bottles and bug spray, etc. But she is now wanting to know where to draw the line.

How far do your companies go to protect their employees?

-Abby

Don D

I would tell the purchasing agent to worry about the purchasing process. He/she has no role in deciding on what safety expenditures to approve. Yes, I would provide sunscreen, especially in light of the experience you already have with the prior sunburn. When we start letting people in other departments tell us which expenditures in our own department make sense, we are abdicating our responsibility. Besides, the aim of the purchasing agent is geared only toward expenditure. They don't give a hoot about safety.

atrimble

I apologize for not being more specific - the Purchasing Agent is the vice-chairperson of the Accident Prevention Team. She gets a say in what expenditures are necessary to maintain or improve employee safety specifically because she has daily contact with the employees most prone to injury, and supervises the storage and distribution of all materials and equipment. The Accident Prevention Team is made of seven appointees from most of our departments for equitable representation of EE and ER concerns.

Don D

That notwithstanding, OSHA requires that each worksite on an annual basis conduct a PPE Analysis for the specific purpose of identifying hazards. Those include the hazards of flying objects, noise levels and yes, even damage from sun or wind exposure. And OSHA further requires that the employer, having identified said hazards provide its employees with whatever protections are necessary to protect against those hazards. In the examples given, it would include such things as safety glasses with side shields, hearing protection and sunscreen or requiring clothing that covers exposed areas of the body.

This is simply not a purchasing or cost avoidance problem. It is a safety requirement of the federal government.

atrimble

That's the justification I was looking for -"because the federal government says so." I knew that there had to be a reason that we're required to provided personal protective equipment - I just couldn't find the proper phrasing to sway the APTeam to compliance.

Thanks so much!

ritamcguire

Is there an actual OSHA requirement to perform a documented annual PPE Evaluation? As a matter of common sense, we do routine evaluations all year long. We keep notes regarding the results of these evaluations with any actions noted, but we never have prepared an annual report. Do you have a section reference for an actual OSHA requirement to perform these evaluations on an annual basis?

Thanks.

safety

I don't know about an annual requirement but as a best practice it is a good idea. Try looking in CFR 1910.132

[url]http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9777[/url]

Don D

atrimble: I sent you the OSHA section verbatim requiring PPE evaluations and the providing of appropriate protection. I interpret it to apply to sunscreen as well.

pork1

ATRIMBLE: Does it not make common sense to provide either sunscreen protection or long sleeve clothing. Not withstanding the Fed General Duties clause tells you, we will provide a safe working environment, and for those required to work outside the sun is a component of the environment. It like smoke, and mold are hazardous to one's health. Issue the sunscreen to your supervisor and let him/her provide the screen.

PORK