Personal Protective Equipment Policy

It is the policy of the University of Pennsylvania in coordination with the Office of the Environmental Health and Radiation Safety (EHRS) to provide employees with a safe and healthful working environment. This objective is accomplished by utilizing facilities and equipment that have all feasible safeguards incorporated into their design. When effective engineering controls are not feasible, or when they are being initiated, administrative controls will be used, followed by the use of personal protective equipment (PPE). 

The University of Pennsylvania PPE Policy applies to all staff working outside of laboratory settings. This general PPE program addresses eye, face, head, hand, foot and body protection. Other policies detail specific PPE for laboratory chemical protection, biological protection, radiation protection, respiratory protection, laser radiation protection and hearing protection.

• For PPE guidelines for working with chemicals in laboratory refer to the University of Pennsylvania Chemical Hygiene Plan.

• For PPE guidelines for working with biohazards, infectious or potentially infectious materials, refer to the University of Pennsylvania Biological Safety Manual.

• For PPE guidelines and safe work practices for handling of radioactive materials or radiation emission sources, refer to the University of Pennsylvania Radiation Safety User Guides.

• For proper donning, doffing, use, maintenance, cleaning and care of respirators, refer to the University of Pennsylvania Respiratory Protection Program.

• For Laser Safety recommendations and requirements, refer to the University of Pennsylvania Laser Safety Manual.

• For PPE guidelines for workers enrolled in Penn's Hearing Conservation Program, refer to the University of Pennsylvania Hearing Conservation Program.

The Office of Environmental Health and Radiation Safety (EHRS)

EHRS will:

• Update the written Penn Personal Protective Equipment Policy.
• Provide guidance to Departments and Supervisors regarding the selection of PPE.
• Assist Supervisors with hazard assessments.
• Provide training to Supervisors and Employees for non-routine or specialized PPE.

Departments

Departments will:

• Purchase and make readily available all PPE required by Supervisors for Employees.

Supervisors

Supervisors will:

• Select PPE based on a written hazard assessment for job titles, job duties or job tasks.  Individual hazards may include impact, penetration, compression, laceration (sharp), chemical, heat, cold dust, light/radiation, and biological-type hazards.  The Supervisor must identify the hazards of each work task and will select and have employees use the appropriate PPE.
• Certify hazard assessments and review and update hazard assessments a) whenever procedures change or b) at least annually.
• Provide training to Employees regarding the proper use and limitations, maintenance, storage and disposal of PPE.
• Re-train employees when there are changes in PPE or when an employee does not follow proper PPE use.
• Prohibit the use of improper, damaged or defective PPE.

Supervisors must verify that the employee understands the provided training, maintain training records, and ensure that employees properly use PPE.

Employees

Employees will:

• Be responsible for wearing and maintaining their PPE.
• Report to their Supervisor when PPE is improper for the work task, defective or damaged.
• Inspect, clean and maintain PPE.
• Not share PPE unless it has been properly cleaned and sanitized in accordance with the manufacturer's specifications.  PPE will be distributed for individual use whenever possible.
• Attend training in how to choose, don, doff, wear, clean, maintain, store and dispose of PPE.
• Understand the limitations of PPE for specific job duties.

Eye and Face Protection

Each affected employee shall use appropriate eye or face protection when exposed to eye or face hazards from dust, flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.

Each affected employee shall use eye protection that provides side protection when there is a hazard from flying objects. All eye and face PPE must be selected in compliance with the OSHA 29 CFR 1910.133 and the ANSI/ISEA Z87.1-2020 standards. Detachable side protectors are NOT acceptable and shall not be utilized by Penn Employees.

University Departments are required to provide Employees with the protective eyewear necessary to perform job tasks safely. Employees shall Contact EHRS with questions regarding the selection of protective eyewear.

Eye and face PPE shall be distinctly marked to facilitate identification of the manufacturer.

Each affected employee shall use equipment with filter lenses that have a shade number appropriate for the work being performed for protection from injurious light radiation. A listing of appropriate shade numbers for various operations follows.

• In an effort to improve eye PPE compliance at Penn, EHRS has partnered with Fisher Safety to produce the UVEX Genesis safety glasses with the Penn logo. The UVEX Genesis provides excellent clarity and improved fit, style and comfort for most users.

• Employees who wear prescription lenses while engaged in operations that involve eye hazards shall wear eye protection that incorporates the prescription in its design, or shall wear eye protection that can be worn over the prescription lenses. Uvex Astro OTG 3001 safety glasses provide good protection over eyeglasses.

Contact lenses may be worn in chemical work environments under appropriate safety eyewear.  Contact lenses do not protect eyes from chemical contact and can increase the severity of chemical splashes to the eyes.  If contact lenses become contaminated, rinse the eye(s) using an eyewash and remove the lens as quickly as possible.  Contact lenses that have been contaminated should be discarded.

Head Protection

Employees shall wear a protective helmet (hard hat) when working in areas where there is the potential for injury from falling objects or exposed energized electrical conductors that could contact the head.  If there is a possibility of hitting protruding objects or pipes, a bump hat may be worn.  

All head PPE must be selected in compliance with the OSHA 29 CFR 1910.135 and the ANSI/ISEA Z89.1-2009 standards.

Hand Protection

Hand protection must be worn to protect against hazards of skin absorption of harmful substances, biological agents, radioactive materials, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns, or harmful temperature extremes. 

Glove selection for chemical protection shall be based on performance characteristics such as breakthrough time and permeation rate, conditions of use, and duration of use.  One type of glove will not protect from all chemical hazards.  Gloves will wear out and must be inspected before use and disposed of when degraded or defective.  Latex gloves are not permitted for any activity at Penn.  When gloves are removed, hands should be washed thoroughly.

Glove selection for physical protection shall be based on performance characteristics necessary to protect the hand against cuts, lacerations, abrasions, punctures or temperature extremes as appropriate for reasonably anticipated contacts and upset conditions during individual job tasks. Individual job tasks should be assessed for the work conditions present, duration of use, and the hazards and potential hazards identified by Supervisors and Employees.

All hand PPE must be selected in compliance with the OSHA 29 CFR 1910.138 standard.

Foot Protection

Protective footwear must be worn in areas where there is the potential for foot injuries from falling or rolling objects, from objects piercing the sole, or from exposed energized electrical conductors that could contact the feet.

Protective footwear must be sized and shaped appropriately for individual employees.

All foot PPE must be selected in compliance with the OSHA 29 CFR 1910.136 and ASTM F-2412-18a standards.

Body Protection

If chemical or toxic dust contamination exists, protective clothing that resists physical and chemical hazards shall be worn over street clothes.  Laboratory coats are used to protect against chemical and biological spills, sprays, fine powders and other releases.  Fire resistant lab coats should be used when working with flammable materials or open flames.  Plastic or rubber aprons can be used to protect from corrosive or irritating chemicals. 

Work coveralls offer full protection of clothing from most physical hazards and some chemical hazards. High density polyethylene coveralls (such as Tyvek suits) protect the clothing against toxic dust contamination.

Selecting PPE

1. A hazard assessment will be performed for each work area to determine if hazards are present.  The assessment will identify the proper controls, including PPE, for mitigation the identified hazards.
2. Supervisors may use information from the manufacturer safety data sheet (SDS) for chemicals or manufacturer manuals for physical hazards to determine the correct PPE for chemical and physical hazard use.
3. PPE must be certified and meet regulatory guidelines, including, but not limited to, American National Standards Institute (ANSI), Occupational Safety and Health Administration (OSHA), and the National Institutes of Occupational Safety and Health (NIOSH).
4. EHRS will provide guidance for selection of PPE as needed.

Fitting PPE

Careful consideration must be given to comfort and fit. PPE that fits poorly will not afford the necessary protection to Employees. Continued wear or use of PPE is more likely if it fits the wearer comfortably. Protective devices are generally available in a variety of sizes and shapes. Care must be taken to ensure that the right size and shape is selected for each Employee.

Devices with Adjustable Features

Adjustments should be made on an individual basis for a comfortable fit that will maintain the protective device in the proper position. Particular care should be taken in fitting devices for eye protection against dust and chemical splash to ensure that the devices are sealed to the face. In addition, proper fitting of hard hats is important to ensure that it will not fall off during work operations. In some cases, a chinstrap may be necessary to keep the helmet on an employee's head. (Chinstraps should break at a reasonably low force, however, so as to prevent a strangulation hazard.) Where manufacturer's instructions are available, they should be followed carefully.

Revised: 12/9/2021