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By: Geoffrey S. Pope Published: July 2021

PPE, the Hierarchy of Controls, and Covid Recovery Safety Planning.

As the sun seems to be peeking out from behind the clouds of the Covid-19 pandemic, a semblance of normalcy has returned to some construction activities at least.  Still, we are by no means “out of the woods,” infections and deaths continue to occur and to spike around the country, and various experts are cautioning that variants of the original virus, or the need to vaccinate and keep vaccinating everyone, leaves us open to successive waves of infections and deaths.  So, I’m sure that nearly all construction employers are continuing to take special precautions, and striving to calculate how the unknowable course of Covid over the next year or two might impact the industry, generally, and day-to-day construction tasks in general.

PPE, as most readers know, is “personal protective equipment” worn on construction sites to reduce exposure to hazards that cause serious injuries and illnesses. Generally, it must be provided at employer expense.  It must be designed and constructed per ANSI or other industry standards, be regularly inspected, cleaned, and maintained, taken out of use when damaged or worn out, and fitted properly.  Users must be trained to know when and what kind of PPE is necessary; how to put it on, adjust, wear and remove it; its limitations, proper care, maintenance, useful life, and disposal of each item.

Some items (the hard hat, safety glasses, study work shoes or boots, high-visibility shirts with sleeves, long work pants) must be worn by all while onsite.  Other items, such as high visibility safety vests with reflective striping, must be worn in proximity to vehicular traffic.  Protective gloves are usual, but the material will vary, according to what is being handled by the wearer.  Full-face shields are necessary when cutting, grinding or chipping; splash goggles are needed to protect against harmful chemicals.  Respiratory protection is needed to work to avoid the inhalation of harmful substances.  Welders must wear welding leathers, and electricians must wear rubber gloves, with leather protectors, shock and slip-resistant boots, flame-resistant clothing and face shields, and insulated sleeves, in addition to the hard hat.  Anyone working on a surface elevated by 6 feet or more must (in the absence of other fall-protection measures) wear fall protection — usually, a harness to be fastened to a safety line.  The foregoing are common examples, not a comprehensive list.

NIOSH prescribes what it calls its “hierarchy of controls,” whereby it ranks the effectiveness of five means of controlling hazards.  The best way of reducing a hazard (if available) is to eliminate the hazard, by physical removal. Next-best is substitution, or replacing the hazard.  Number three is engineering controls, to isolate people, to the extent it be possible to do so, from the hazardous condition.  Number four is administrative controls, or changing the way people work.  Fifth (and last) is sole reliance on PPE.  While face coverings and gloves are high on the list of anti-Covid precautions, you want to steer away from over-reliance on these items.

Of course, in fighting Covid contagion, as in many other contexts, approaches in combination will often prove to be beneficial.  One illustration is that a major risk factor for contracting Covid-19 is close exposure to infected individuals, their exhalations, and their droplets (especially in poorly-ventilated, indoor spaces).  Infected surfaces are also thought to be a risk factor (although a less important one than was thought early in the pandemic).  Naturally, PPE (gloves and face coverings) have a role to play, but the masks in particular are far from sure protection.  So you will want to add administrative controls, such as limiting the sharing of items such as respirator masks and hand tools, and requiring that they be diligently cleaned and sanitized between uses.  “Social distancing,” and planning the scheduling of tasks to be performed in indoor spaces so as to permit distancing and, more generally, reduce the number of people present in indoor work areas simultaneously, are further administrative controls that should be helpful in curbing transmission.

Yet another administrative measure you might consider where, for example, you learn that symptomatic individuals have recently been present in an area, especially a closed, indoor space, where work is needed is to postpone that particular work, and deploy those forces elsewhere.

Of course, while limiting proximity (and crowding) as among employees is part of this equation, so, too, do you want to reduce potential worker exposure to occupants of building areas not under construction, customers, inspectors, visitors, or other outside individuals, as may enter or be present in the work area.  As you probably can’t prevent entirely the entry onto your site, or even into an enclosed area, of all who might possibly be infected (e.g., by testing all comers for the virus) this is a further administrative measure to implement.  Specifics to consider are placing plexiglass or other barriers to ensure that outside individuals cannot come closer than 6 feet to your workers; restricting access, or the numbers of individuals who can be present in proximity to your employees at any given time, or requiring that entrants be masked.

So, while basic PPE is a routine daily requirement, and special-purpose PPE is useful or indispensable for certain tasks, masks and gloves (even coupled with general exhortations to socially distance and wash one’s hands a lot, which may be difficult, or impossible to carry out) are by no means a sufficient ongoing response to Covid.  From today forward, a more attentive, analytical, well-organized and coordinated approach to integrating health and safety concerns is going to be required.  Consulting services from an industrial hygienist are also something you might consider.  Distancing, job hygiene (particularly with respect to PPE and tools that may be shared) and other Covid-specific measures now or hereafter recommended are likely to be leading priorities, but other perennial or job-specific hazards will also benefit from more attention, and better planning, the necessity for which needs to be seen as a fact of life going forward.  Consideration of the “hierarchy of controls” offers construction employers .an important analytical tool.

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