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Guidelines Part 8

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Guidelines Part 8 - General Requirements

G8.2(3) Responsibility to provide

Issued August 1999; Editorial Revision February 1, 2008

Regulatory excerpt
Section 8.2(3) of the OHS Regulation ("Regulation") states:

If the personal protective equipment provided by the employer causes allergenic or other adverse health effects, the employer must provide appropriate alternative equipment or safe measures.

Purpose of guideline
The purpose of this guideline is to provide an example of selecting alternative equipment if the personal protective equipment provided by the employer causes allergic or other adverse health effects.

Appropriate alternative equipment
An example of selecting appropriate alternative equipment would be a worker allergic to natural rubber latex gloves, but who has work duties resulting in exposure to blood or other body fluids (a potential exposure to biological agents designated as a hazardous substance in section 5.1.1). In such a circumstance, the worker could use gloves made of vinyl, nitrile, neoprene, copolymer, or polyethylene, which would be appropriate alternatives to latex gloves for this particular exposure. See also OHS Guideline G6.34-2 for more information.

If a worker has an allergenic or other adverse health effect due to the protective equipment supplied and the remedy chosen is the use of "other safe measures," such measures have to provide at least equivalent protection to the worker that the personal protective equipment normally used would provide.

G8.5 Program

Issued August 1, 1999; Revised November 17, 2003

Section 8.5 of the OHS Regulation states:

If personal protective equipment is required to protect against a chemical exposure or an oxygen-deficient atmosphere the employer must implement an effective protective equipment program at the workplace which includes

(a) a statement of purpose and responsibilities,

(b) written procedures for selection, use, inspection, cleaning, maintenance and storage of protective equipment, when required,

(c) instruction and training in the correct use and maintenance of the equipment,

(d) for respiratory equipment, medical assessment of respirator wearers, when required,

(e) documentation when required, and

(f) program review.

To determine if personal protective equipment is required in a workplace to protect against a chemical exposure or an oxygen-deficient atmosphere, the employer has to consider the requirements of section 5.55 of the OHS Regulation. Section 5.55(1) states "If there is a risk to a worker from exposure to a harmful substance by any route of exposure, the employer must eliminate the exposure, or otherwise control it below harmful levels and below the applicable exposure limit established under section 5.48...." Options available to the employer include substitution, engineering control, administrative control, or personal protective equipment. However, section 5.55(3) states: "The use of personal protective equipment as the primary means to control exposure is permitted only when

(a) substitution, or engineering or administrative controls are not practicable, or

(b) additional protection is required because engineering or administrative controls are insufficient to reduce exposure below the applicable exposure limits, or

For guidance in determining whether personal protective equipment is required, see OHS Guideline G5.55.

For guidance on determining if a medical assessment of a respirator wearer is required under paragraph 8.5(d), see OHS Guideline G8.42.

G8.5(b) Special program option for pulp and paper industry

Issued August 1, 1999

Paragraph 8.5(b) of the OHS Regulation states:

If personal equipment is required to protect against a chemical exposure or an oxygen deficient atmosphere the employer must implement an effective protective equipment program at the workplace which includes...(b) written procedures for selection, use, inspection, cleaning, maintenance and storage of protective equipment, when required.

This guideline addresses a maintenance requirement for escape respirators used in the pulp and paper industry, specifically the replacement schedule for chemical cartridges used for protection against reduced sulfur gases, such as hydrogen sulfide, methyl mercaptan, dimethyl mercaptan, dimethyl sulfide and dimethyl disulfide. Escape respirators, except for workers required to ride in the pulp mill elevators, may be half facepiece respirators and mouthpiece, or biteblock respirators, and are used by mill personnel to escape to a safe area when the mill experiences a gas leak.

The performance of escape cartridges in the pulp and paper environment was assessed in a study conducted by BC Research Incorporated, and the findings were published in June 1994, in a report entitled "Life Expectancy of Cartridges for Escape Respirators: Final Report"", BCRI Project No. 4-02-394. Based on the findings of this study, the following guidelines are recognized as acceptable practice by the Board. (This guide was initially published by the Prevention Division in a letter issued October 6, 1994, to the pulp and paper industry.)

The replacement schedule for chemical cartridges for use in escape respirators, in the pulp and paper industry only, may be extended to 12 months for unused, unexposed and undamaged cartridges with the following provisos:

A cartridge in an escape respirator is to be changed after use in an emergency involving exposure to mill gases,
Each cartridge is to be marked to show clearly its expiry date,
A metal type cartridge is to be inspected prior to installation for dents in the base or threads, and
Any damaged unit is to be replaced.

Each pulp and paper mill is expected to have a comprehensive respiratory protection program, functioning as required by section 8.5. This is achieved when all workers who are, or may be, required to use a respirator are trained to an acceptable level of competency and all the elements of the program are in place covering correct use, limitations, maintenance and storage requirements for the devices selected.

For respirator use in industries other than pulp and paper mills, the employer must follow the respirator manufacturer's recommendations for cartridge replacement schedules.

G8.10 Personal clothing and accessories

Issued August 1, 1999

Section 8.10(1) of the OHS Regulation states:

The personal clothing of a worker must be of a type and in a condition which will not expose the worker to any unnecessary or avoidable hazards.

Under this section, the "lack of clothing" is a concern if a worker is exposed to injury from the material being handled, contact with an abrasive surface or object, or contact with a surface at a temperature that could cause a burn injury. For example, a worker handling hot tar or other material that could cause a burn through contact, such as from a splash has to wear suitable clothing covering the body and arms. A worker exposed to the abrasive action of material, such as the carrying of lumber on the shoulder or against the body, should wear appropriate clothing.

A worker may have to change or add clothing as the worker's job duties or work conditions change.

An employer may have a dress code or policy for clothing requirements during warm weather. Board officers will not enforce an employer's policy of this type. Officers will only become involved in enforcement if the lack of appropriate clothing is exposing a worker to the possibility of injury.

Removal of clothing during outdoor work in warm weather exposes workers to UV from the sun. Ultraviolet radiation from the sun is a "natural element", and under paragraph 8.2(1)(a) of the OHS Regulation, a worker is responsible for providing any necessary clothing to protect against it. Workers and employers need to be aware of the hazard from solar radiation, and need to take measures to limit exposure, such as by use of appropriate attire and the use of sun block creams.

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Disclaimer: The Worker and Employer Services Division issues Guidelines to help with the application and interpretation of sections of the Occupational Health and Safety Regulation and with divisions of the Workers Compensation Act that relate to health and safety. Guidelines are not intended to provide exclusive interpretations but to assist with compliance. WorkSafeBC ("Workers' Compensation Board of B.C.") does not warrant the accuracy or the completeness of the online version of the Guidelines and neither WorkSafeBC nor its board of directors, employees or agents shall be liable to any persons for any loss or damage of any nature, whether arising out of negligence or otherwise, which may be occasioned as a result of the use of the online version of the Guidelines.