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Personal protective equipment for snow

  • Douglas Freer, CSP
- Posted: October 14, 2013
Your company has specific responsibilities as it relates to your employees’ health, safety and well-being. Providing necessary personal protective equipment (PPE) is one such responsibility. 

The Occupational Safety and Health Administration (OSHA) has minimum PPE requirements that employers must provide to employees at no expense to them. Similar state agencies may also have requirements. While there is some ambiguity in OSHA regulations as they relate specifically to the snow & ice management industry, at a minimum, a company needs to ensure it does not place its employees knowingly into an unsafe working environment. Now is the time to review your policies and make any appropriate changes to your program.

Cost to the company
Managing uniforms and PPE is part of a company safety program, and the better managed the lower the indirect costs will be to the company.

Your company does not have to pay for or provide any PPE equipment that goes beyond OSHA’s minimum requirements. But consider whether certain items would improve employee safety and morale, and whether they are worth the investment regardless.

What is the cost of a workers’ compensation claim compared with the purchase of PPE that could have prevented the injury? Beyond an increase in premium costs, there are indirect costs related to employee injury, such as lost productivity and efficiency, increased labor costs, increased training costs for new/replacement employees, and increased supervisory time to manage incidents and the adjustments that have been made to the team.

Uniform items are not considered PPE but may serve a dual purpose of helping to prevent injuries and to keep your employees safe. A well-run safety program will, in part, focus on the management of uniform gear and PPE for its employees; but the cost of providing items either directly or through reimbursements, in addition to the administration of the program, are direct costs to the company and impact the bottom line.

What PPE is necessary?
From head to toe, consider the work environment, job description and function of each piece of PPE to determine what uniform or PPE could or should be used when performing the job. Pay particular attention to PPE related to tasks that involve chemical handling and prolonged exposure to the elements.

Required or optional?
When evaluating what gear or PPE is required in your company, remember that you cannot make an employee work in an unsafe condition. For example, if you require a hat and winter work gloves to perform their job and the employee shows up without them, you cannot force them to work without those items. Either you send them home or you provide them with replacements.

There is a difference, however, between minimum regulatory requirements and what you may require above and beyond for your employees to work. You may also make suggestions and choose to make certain items optional. While you do not have to provide items beyond the minimum, consider the hassle of not providing or making items available that you require.

PPE distribution
You don’t want to wait until the first storm of the season is bearing down on you to ensure your employees are outfitted and protected. Consider the following points as you build your PPE program:
  • What PPE will you inventory in an equipment supply closet or cabinet that is ready for distribution?
  • How will the inventory be managed and tracked, and who is responsible for those tasks?
  • If you are not distributing PPE prior to the season, how will you verify that employees have the necessary PPE before they begin work?
  • Do they need to bring it into work for someone to verify they have the necessary gear? What is the repercussion if they show up unprepared?

Company-provided PPE will result in readily available gear, increasing the convenience factor for employees, as well as ensuring consistency across the company. Providing the same type of safety vests or jackets with or without company identification/logos presents a unified appearance. What happens if you don’t provide them, for example, an employee brings a safety vest that does not meet your standards? It may take more time to manage the exceptions than it would to simply manage a PPE/uniform program that provides consistent results. 

Who pays? 
Employers must provide OSHA-required PPE at no cost to the employee, but what about additional company-required uniform or safety items that go beyond the minimum standard?

  • Will you bite the bullet and make the investment to pay for all items?
  • Will the employee be expected to return the items after each event or each season?
  • For borrowed gear, will employees pay a deposit in the event of loss or damage?
  • Can they pay for items via a payroll deduction?
  • What happens if they lose it or wear out an item and require a replacement?
  • Considering the expense to be properly equipped, will employees who must acquire the gear be financially capable of doing so prior to the season?
  • Do you provide a PPE or uniform type reimbursement for certain items like winter work boots?

PPE training
Employees should be trained on winter workplace safety and proper dress prior to the start of the season. You could hold a preseason meeting, post the information on a bulletin board, and include pertinent information in an employee or safety manual. Here are a few topics at minimum that should be covered:

  • What type of gear or PPE is required or optional?
  • What are the consequences of not wearing required uniform or PPE?
  • How do you identify, protect against and avoid issues like frostbite, hypothermia and fatigue?
  • What will the employee provide, and what will the company provide?
  • Review the training/safety manual.
  • Review best practices and let experienced workers share what has worked best for them.
  • Review the position description and job function with each team member, and answer their questions about gear they may need and how they can acquire it.

Proper safety gear communicates a message to current and prospective employees as well as your clients and the general public.

Traffic cones and warning lights for vehicles and equipment are part of a coordinated safety program and help to ensure that the public and your employees are safe. Take your safety program a step further by proactively addressing and managing uniform/PPE for the benefit of your employees and company.

Safety tips - health and wellness in the field

  • Drink plenty of fluids. Mild dehydration can drain energy and make you feel tired. Your sidewalk crews, particularly hand labor crews, are likely in need of more fluids than equipment operators, given their increased level of activity. Water is the best choice for hydration.
  • Watch the caffeine. Research has shown that large amounts of caffeine—more than 500 to 600 milligrams (equivalent to 5 to 7 cups of coffee)—per day can have a diuretic effect and can make you jittery, sleepless or anxious. If you want hot tea or coffee, consider decaf.
  • Stay warm. Working outdoors without proper protection from the cold, wind and precipitation can weaken immune systems that may already be under stress. Make sure you are properly dressed for the weather.
  • Be a germ buster. During a storm, contractors may not have access to facilities to wash their hands, leaving them prone to spreading or catching colds or other illnesses. Prior to and after a storm event, wipe down steering wheels, plow and equipment controls, door handles and all other items in the cab that crews may touch. Antibacterial wipes and lotion are inexpensive and can be made readily available to your crews to encourage their use when soap and water are not available.

Suggested uniform and PPE by position description

All Employees

  • Proper undergarments for layering
  • Water-resistant/proof jacket and outerwear
  • Multiple layers of gloves in case they become wet
  • Different types of gloves for different functions (general warmth, chemical handling, working on equipment, etc.
  • Multiple hats to change during the storm as they get wet
  • Waterproof and warm foot gear
  • Reflective outerwear either incorporated into waterproof jacket or safety vest

Plow and/or salt truck driver

PPE_Driver  PPE_Glovessmall   PPE_Goggles

  • Gloves for handling deicier equipment
  • Eye/face protection for handling liquid deicing chemicals

Sidewalk crew

PPE_ATV   PPE_Ear protectionsmall

  • Hearing protection for snowblowers, backpack blowers, etc.
  • Ski goggles for snowblowers or ATV operators
  • Helmet for ATV operations

Equipment Operator

  • Gloves or gear for working on equipment
  • Gloves for handling chains/binders
  • Hearing protection, depending on the equipment

Supervisory Staff

  • Personal selection of gear to handle all types of functions they may perform
  • Additional inventory of critical items to give to a crew member who is without during the storm
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