October 10, 2007

Clarification of Personal Protective Equipment Requirements

Laboratory management has distributed the text below to clarify personal protective equipment (PPE) use requirements. Long sleeve shirts are no longer required for just entry to the Experiment Floor, the set up laboratories, the tech areas, and the mechanical equipment rooms. Long pants or a long skirt/dress and closed shoes that cover the entire foot are still required for entry to these areas.

We are working to define the specific PPE requirements for tasks performed at the NSLS and will distribute that when complete. Until that document is available, the BNL Standard Based Management System (SBMS) Subject Areas are to be consulted for PPE requirements decisions. The NSLS ESH&Q staff will help to evaluate individual circumstances and determine those requirements.

BNL Management PPE Message:

Long Sleeve Shirt Clarification

If there are specific requirements in SBMS, work planning documents, job risk assessment, department procedures, or area postings to wear a long sleeve shirt or lab coat, then they must be worn. Examples of work activities where these requirements currently exist are:

• working with corrosive (pH <4 or >10) or other high hazard chemicals (carcinogens, etc.).
• working with cryogens and uninsulated pipes or vessels containing cryogenic liquids.
• welding, cutting, and brazing (non-melting, flame retardant long sleeve shirts)
• operating circuit breakers and disconnect switches (not wall light switches) that are rated 50 volts to less than 240 volts (non-melting, flame retardant long sleeve shirts).

Additional specific examples are listed in Section 1, Planning for and Preparing to use Personal Protective Equipment of the SBMS subject area on PPE https://sbms.bnl.gov/sbmsearch/subjarea/119/119_Pro1.cfm). It is permissible to wear low hazard protective clothing (short sleeve shirts) in labs, shops, or industrial areas if these hazards are not present [i.e. flying particles, molten metal, sparks, sharp objects, chemicals, harmful temperature extremes, and cryogens, or injurious light radiation (e.g., UV and IR)]. Additional examples are provided in the BNL Handbook on PPE Selection and Use (https://sbms.bnl.gov/sbmsearch/subjarea/119/2r01e011.pdf)

If there is a question regarding PPE requirements, then please contact your supervisor, ESH Coordinator, or Safety and Health Representative. If organizations have concerns that strict adherence to PPE SBMS requirements will have unanticipated effects that will reduce worker safety, or need assistance in evaluating PPE requirements for specific task hazards not addressed in the PPE subject area, please contact the Safety and Health Services Division subject matter expert where the issue will be reviewed and resolved.

Regarding tours and inspections:

Tours conducted with a qualified escort are not subject to the PPE minimum requirements stated in the PPE subject area, unless they are entering a hazardous area. For tours or inspections of laboratory, shop, and industrial work areas at BNL where known hazardous environments exist or where personnel are working on or near hazardous tasks, the host organization provides the appropriate PPE or other forms of hazard controls. This could include suspending work activities or cordoning off areas to designate safe zones.

Safety and Health Services Division will conduct a series of workshops on the PPE subject area in the next few weeks to explain the current requirements and solicit feedback for improvement. All supervisors are encouraged to attend one of these sessions.

Questions, concerns, or comments can be forwarded to Andrew Ackerman, ESH/Q Division Manager (Ext. 5431).