SOP 2.

4: Personal Protective
Equipment Program
Household
Hazardous
Waste

Contents
1. Introduction.....................................................................................1
2. Regulatory and contractual requirements...........................................1
3. Needs assessment............................................................................1
4. Training............................................................................................2
5. PPE Section......................................................................................3
6. Documentation and record retention..................................................4
Attachment A. Certification of PPE hazard assessment completion...............5
Attachment B. Personal Protective Equipment (PPE) Requirements..............6
Attachment C. PPE and Clothing Compliance Checklist.................................7

1. Introduction
This Program shall ensure staff is provided with the proper selection, procurement, and use of personal
protective equipment (PPE) and/or clothing. Engineering and administrative controls are the preferred
methods for controlling hazards. PPE shall be used to protect Facility staff from exposure or injuries.

2. Regulatory and contractual requirements

PPE requirements are established in the HHW program and state agency contract (Exhibit A, parts A and
B) and OSHA 29 CFR; 1910.120 (q) and 1910.132–138. 29 CFR 1910, Appendix B, Subpart I, ANSI
eyewear standard Z78.1–1989, ANSI head protection standard Z89.1–1986, and ANSI footwear standard
Z41.1–1991 and 1910.136.

3. Needs assessment
3.1 A designated PPE person shall conduct a needs assessment to determine and establish required PPE
needed during specific operations. For this Program, this designated PPE staff person is the Facility
Manager. PPE requirements shall be specific to this facility and shall be updated as job
requirements change.

A written certification verifies that a workplace assessment has been performed; see Attachment A
of this SOP. PPE Hazard Assessment identifies the:

2.4 Personal Protective Equipment Program 1

  title that identifies it as being the certification of hazard assessment
 workplace evaluation
 person certifying that the evaluation has been performed
 date(s) of the hazard assessment

3.2 All required PPE shall be provided by the Program at no cost to Facility staff and meet ANSI
standards. A chart shall be posted on facility safety bulletin board which lists specific tasks
identifying required PPE; see Attachment B of this SOP.

3.3 Unique environmental conditions and the judgment of experienced Facility staff shall determine the
PPE level required for each specific situation.

4. Training
4.1 The designated PPE person shall be responsible for administering, implementing, and enforcing
PPE policy.

4.2 If a hazardous waste or any other contractor is providing services to this Program, they shall comply
with the PPE requirements specified in this SOP. The designated PPE person shall request a copy of
the contractor’s AWAIR program.

4.3 This Program shall provide training to all staff required to use PPE. The designated PPE person
shall be responsible for coordinating training and providing written certification.

4.3.1 Each Facility staff shall be trained on how to properly use PPE, including:
 choosing the type to be used and when
 how to don, doff, adjust, and wear
 the limitations and useful life
 care, maintenance, and disposal

4.3.2 PPE training shall:

 be conducted initially, before Facility staff use the PPE
 be conducted when lack of compliance is observed
 be conducted when workplace conditions change, rendering previous training obsolete
 be designed to encourage staff to report and seek treatment for symptoms of health
problems caused or aggravated while on the job
 continue until staff can demonstrate an understanding of the training

5. PPE selection
PPE shall be provided, used, and maintained wherever hazards exist (e.g., processing, environmental,

2.4 Personal Protective Equipment Program 2

 chemical, mechanical) or are encountered in a manner capable of causing injury or impairment in the
function of any part of the body. Injury can occur though absorption, inhalation, or physical contact with
these hazards. The designated PPE person shall set a good example by donning PPE and following
Program policy. The following provides guidelines for hazard assessment and PPE selection.

5.1 Eye and face protection. Appropriate eye or face protection shall be worn if exposures to
potentially injurious hazards exist (e.g., flying particles, liquid chemicals, corrosives, chemical
gases, vapors, UV rays). All eyewear shall provide:

 eye and side protection (detachable or permanent)

 protective devices to be worn over prescription eyewear, if needed
 a proper and comfortable fit

5.2 Foot hazards

5.2.1 OSHA requires that staff wear protective footwear if the potential for foot injuries exist,
including exposure to:
 compression, squeezing, smashing, falling, or rolling objects
 electrical hazards
 slipping
 chemicals
 temperature extremes
 repeated wetness which may result in fungal infections
 puncturing from objects which may pierce the sole of footwear

5.2.2 Engineering and work-practice solutions shall be utilized, including wearing footwear
correctly (fully laced, etc.) to receive maximum protection. The Program shall prohibit the
use of sandals or open shoes.

5.3 Hand and body protection

5.3.1 Glove manufacturer specification charts provide guidance in selecting proper PPE.
Appropriate hand and body PPE shall be worn when potential hazards exist, including
exposure to:
 cuts and punctures—severe cuts and lacerations, abrasions or punctures from tools,
machines or from handling sharp objects
 thermal exposure—caused by extreme cold or heat or hot work
 bloodborne pathogens—caused by first-aid or clean-up of blood, body fluids, or other
infectious agents; see SOP 2.7 Blood Borne Pathogens
 chemical exposure—skin contact from working with chemicals
 repetitive motion disorders—caused by computer use or jobs requiring repetitive
motion may cause carpal tunnel syndrome

2.4 Personal Protective Equipment Program 3

  entanglement—caused from wearing gloves, clothing, or jewelry near moving
equipment

5.3.2 Potential engineering and work-practice solutions may include:

 machine guards—protects against cuts, punctures, abrasion, and chafing
 job rotation—protects against repetitive motion hazards
 good housekeeping and clean-up—protects against chemical and bloodborne hazards
 workstation design—protects against repetitive motions and provides accident
prevention
 evaluating waste prior to handling—aids staff in determining appropriate PPE and
process method
 splash guards—protects against chemical contact with skin or eyes

5.4 Head protection. Head protection (e.g., hard hat) shall be worn if potential for injury from
falling objects exist. All head protection shall:

 be used according to manufacturer’s instructions

 not be altered in any way
 include bump caps as an appropriate alternative (if exposure to scalp injuries
exist)

5.5 Hearing protection. Facility staff shall wear hearing protection when exposed to noise levels
in excess of 85 dB(A) for an eight-hour time-weighted average. See SOP 2.12 Hearing
Conservation.

5.6 Respiratory protection. Site specific ventilation or exhaust systems are effective engineering
control tools. For procedures on both mandatory and voluntary use of respirators, see SOP 2.5
Respirator Program.

6. Documentation and record retention

The designated PPE person shall complete and keep on file all training records. Update documentation as
Facility operations change. This training documentation includes:

 staff training records (e.g., attendance, individual staff name, date, instructor, session
agenda/outline)
 the PPE Equipment and Clothing Compliance Checklist; see Attachment C of this SOP.

2.4 Personal Protective Equipment Program 4

Attachment A
Certification of Personal Protective Equipment Hazard
Assessment Completion

_____________________________________________ certifies that a Personal Protective

(name of person certifying completion)

Equipment Hazard Assessment of the _________________________ has been completed.

(name of HHW facility)

Assessment completion date: __________________________.

The results of this assessment are documented on the chart located in Attachment B of this SOP.

2.4 Personal Protective Equipment Program 5

 Attachment B
Personal Protective Equipment Requirements
Personal Protective Equipment Requirements for: ________________________HHW Program.
___________________ is the Designated Person responsible for PPE Program Implementation.

Please complete and post

Bulking
Spill
PPE Receiving Sorting Flammables, Bulking Lab- Traffic ID of
Cleanup
Wastes Wastes Solvents, or Latex Paint Packing Control Unknowns
(incidental)
Aerosols
Chemical-resistant gloves R R R O R R O R

Inner protective gloves O O R O R R O R

Tyvek protective suit O O O O O O O O

Apron or coverall R R R R R R O R

Chemical-resistant
O O R O O R O O
protective suit

Safety glasses with side

R R R R R R O R
shields

Goggles O O R O O R O O

Face shields O O O O O O O O

Reinforced footwear or
R R R R R R R R
toe caps

Chemical-resistant foot
O O O O O O O O
covers

Non-chemical-resistant
O O O O O O O O
foot covers

Respiratory protection O O R O R R O R

Safety headgear O O O O O O O O

Hearing protection O O O O O O O O

Long pants R R R R R R R R

Long sleeves R R R R R R R R

Reflective traffic vest O O O O O O R O

These recommendations are intended to provide guidance. Adjust list as needed to make specific to this
Program PPE policy. An “R” indicates PPE usage is required. An “O” indicates PPE usage is optional.

2.4 Personal Protective Equipment Program 6

Attachment C
Personal Protective Equipment and Clothing
Compliance Checklist
Yes No N/A
N/A

1. Are protective goggles or face shields provided and worn where there is any danger of flying   
particles or corrosive materials?

2. Are approved safety glasses required to be worn at all times in areas where there is a risk of   
eye injuries exist?

3. Are Facility staff who need corrective lenses (glasses or contacts) and work in environments
with potential harmful exposures, being provided with approved safety glasses, protective   
goggles, or other medically approved precautionary devices?

4. Is proper PPE provided where Facility staff could be injured, or where there is reasonably
anticipated exposure to corrosive liquids, chemicals, blood, or other potentially infectious   
materials?

5. Is appropriate foot protection required where there is the risk of foot injuries?   

6. Is all PPE maintained in a sanitary condition and ready for use?   

7. Are eye wash stations and drench showers located within 10 seconds of where Facility staff   
are exposed to injurious corrosive materials?

8. Are food or beverages consumed in areas where there is no exposure to toxic or potentially   
infectious materials?

9. Is hearing protection provided when sound levels exceed those of the OSHA noise standard?   

10. Are adequate work procedures and PPE provided and used when cleaning up hazardous   
materials or spills?

11. Are there appropriate procedures in place for disposal of contaminated PPE?   

_______________________________________ ____________________________________________
Audited by (print) Date Staff signature Date

2.4 Personal Protective Equipment Program 7