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Personal protective equipment: Managing safety or exercising control?

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Sir’, he said in a pale voice. ‘It was 59 degrees in the engine room that afternoon and I took my helmet off. Not for too long, sir, just a few minutes. I was standing under the blower to cool my head. And then this safety of­ficer comes to me and starts shouting. “Why are you not wearing your helmet? What if you get injured? Who will be responsible for your safety? Did I not tell you before? Why do you keep ignoring safety?” Even before I could explain myself I was told to treat this as a verbal warning. Sir, one more warning and I lose my job, I go home. I have a family to support.’ He ended with a sigh.

After a brief silence he looked into my eyes and went on, ‘You see here, I’m working in this workshop. Nothing will drop on my head here. Why do I need to wear a helmet? When I go in the purifier room it is so hot, my eyes are sweating, why do I need to wear safety glasses? I cannot see anything, is that safe? When I go to the steering ‑ at, there is no noise, why must I wear ear plugs? Why can’t they leave this for me to decide? I am not ignoring safety, I know my safety, sir’.

Personal protective equipment

Working in harsh, unpredictable and unforgiving conditions often means adequate protection is required for front end workers. A wide and ever-increasing range of products is available to minimise the risk of personal injury. According to research body Global Market Insights, the market for personal protective equipment (PPE) is forecast to hit $67.6 billion by 2023, growing at a rate of 7.3% per annum between 2016 to 2023. Many countries have made it mandatory for employers to provide their workers with PPE. All this makes PPE ‘serious business’.

On the other hand, regulatory agencies and industry bodies have consistently maintained that PPE is often the ‘last line of defence’ in managing operational risks. Safe Work Australia, the government body responsible for workers’ health and safety (WHS), states that ‘Using PPE is ranked as one of the least effective safety control measures; that is a level 3 control measure. Level 3 control measures do not control the hazard at the source. They rely on human behaviour and supervision and used on their own tend to be least effective in minimising risks. Workplaces must not rely on PPE to satisfy their hazard control requirements. PPE should only be used:

  • as a last resort;
  • as an interim measure;
  • as a back-up.’

The UK’s Health and Safety Executive takes the same view. Protection by design, maintenance scheduling and setting up operational limits are considered more reliable measures of safety and risk management.

The PPE paradox

Why is it that something regarded as the least effective of all measures in managing safety is considered so important both from the policy and industry perspective?

In many high-risk industries (maritime, oil and gas being no exception), the desire to eliminate the risks associated with new technologies is far from practicable. This is eloquently captured in a quote by Henry Petroski, an internationally acclaimed American academic, specialising in history and civil engineering. According to Petroski, ‘Many new technologies come with a promise to change the world, but the world refuses to cooperate’. Here, Petroski is referring to the designed-in protection offered by new technology that time and again proves insuf­ficient in the work environment, due to unpredictable operating conditions, resource constraints, or the conflicting goals of safety and efficiency in getting the work done. It is the gap between the protection offered by the design and the reality of operating conditions that necessitates the use of PPE.

Starting from this viewpoint, PPE is an essential compromise between eliminating the risks altogether and undertaking the activity while accepting a certain level of risk that is inherent in everyday work. For example, ideally, it would be best to ­fit the entire mooring deck with a non-skid plating, but anti-skid footwear offers a practical and cost-effective solution. Other examples may include PPE allowing:

Heat resistant gloves allowing work on hot surfaces without adequate thermal insulation;

High visibility vests allowing work as a signaller in the vicinity of suspended weight;

The handling of heavy and wet ropes under tension;

The use of portable lifesaving equipment for entry into enclosed spaces without adequate escape arrangements.

In such cases, PPE acts as a compensation for what designed-in protection cannot offer. It could be argued that the more unsuited the design is for the work that will take place in it, the greater the need for PPE; which is compensation for an incomplete design. One could even say that an increased emphasis on PPE is an indicator of poor technical design. By the same token, a reporting system that consistently shows that front line workers do not follow the company’s ‘PPE policy’ could well mean that the design intent is flawed, or at best, unfit for the intended purpose of the system. That is how human factors and ergonomics experts would approach this problem.

Myth making

But life is not that straightforward. The emphasis on the use of PPE can also extend beyond just ensuring the usability and safety of front line workers. This is a deeper problem than it appears on the surface, and where the proper role of PPE is not understood, it could easily become the antithesis of safety.

Many companies are convinced that one of the most effective ways of managing safety lies in managing the behaviour of their workers. A number of behaviour based safety programs are being initiated to address this issue. One of the most frequent examples of behavioural safety – or the lack of it – is workers not wearing proper PPE. In fact, it is a common assumption in many accident investigation reports that failure to use proper PPE was a contributing factor, and the number of times it comes up in accident investigations, on-site inspections and safety observation cards serves to reinforce this assumption. As we learn from Erik Hollnagel, before we realise it, an assumption turns into a myth and the myth can become an accepted belief. All this leads to a ‘zero tolerance’ message from top management about missing PPE – and for companies conscious of their brand reputation, a significant investment in the best available PPE. I have known of instances where the first question asked in the wake of an accident is not about the injured worker’s well being, but whether or not the worker was wearing ‘proper’ PPE at the time when the accident happened.

What lies behind this myth that PPE is the ultimate preventer of accidents? I have interviewed many safety officers to find out what a ‘safe working environment’ would mean to them. What do they look for during inspections and why? A common theme in their answers is the correct use of PPE by workers. When pressed to explain why, a common explanation is consistent reports of ‘PPE violation’ in the Safety Management System. This is a perfect example of the vicious circle whereby assumptions become myths and myths become deep-seated beliefs within the organisation.

Controlling the vulnerable

Many companies set up performance indicators for monitoring safety, but end up monitoring what is convenient rather than what is meaningful.

A safety officer who is less experienced in a specific activity runs the risk of not knowing enough about that activity when interacting with an experienced worker in that area. Faced with an uncomfortable situation that creates anxiety, it is not uncommon for the safety officer to fall back upon prior knowledge rather than engaging in a meaningful dialogue. Spotting someone not using the mandated PPE is a convenient option. It is easier to discipline a worker for not following the ‘PPE policy’ than to attempt to understand the design limitations of technology and the goal conflicts involved in everyday work.

Although the PPE policy applies to everyone irrespective of their position on a vessel, it is often the case that only ratings are targeted for violating it. There are not many instances where senior officers are reported for not using the right PPE (even making allowances for the fact that PPE is more likely to be needed by those in lower ranks). It makes me wonder if the issue is really one of risk and safety, or whether it is a question of power.

The impression that PPE is an instrument for controlling those in lower ranks is only reinforced when one talks to those working at this level. There have been instances where the crew is quite literally ‘reprimanded’ for not using the correct personal protective equipment. During a safety meeting the chief steward was given a warning by the third officer for entering the vegetable room without winter gear for just a few minutes. In another instance, a rating was served a warning for not wearing the right type of gloves for the job. Workers are known to be served with warning notices for taking off their safety glasses or helmet even for a short break to escape scorching heat in machinery spaces. But it may be that the risk of someone collapsing from a heat stroke or getting knocked down due to impaired visibility is much higher than that from flying debris or dropped objects.

Evolving standards in the PPE industry create enormous opportunities for designing improved protective gear (such as working gloves and high-visibility garments) but innovations can sometimes also set up unrealistic expectations. From the management’s perspective, more (PPE) should automatically lead to improved safety – and yet the evidence appears to be inconclusive. In many instances, avoiding certain PPE is a safer choice.

Protective gear, it appears, has become a means to instil fear and insecurity in front line workers. There are instances where crew members may even lose their jobs for not wearing proper PPE. But wearing PPE is not a binary choice between good and bad or between following and not following procedures. The choice to wear PPE or not is not the same as if a crew member had a choice between consuming alcohol or not prior to starting his watch. Much of what PPE qualifies as ‘proper’ is situational, and the final decision may be best left to the worker based on discussion with his supervisor before the start of work (commonly referred to as ‘tool-box talk’).

A sensible solution?

Technology is ‘unruly’; not in the colloquial sense that it is uncontrollable but in that it cannot always be regulated through a pre-determined set of regulations and procedures. This is partly due to the harsh and unpredictable work environment at the front line, where risks to the workers cannot always be foreseen and eliminated. In such instances, the use of PPE is aimed at managing the unexpected and protecting the workers.

Contrary to the popular belief that the problem always lies with the behaviour of workers, the use and abuse of PPE policy may provide some unique insights into human adaptability and resilience. Sometimes a sensible solution may be to install an affordable CCTV camera in the crane cabin to avoid someone standing near a suspended weight, rather than focusing excessively on winning ‘hearts and minds’ on deck. We have a choice. We could either reprimand our crew for not wearing enough PPE, or we could pay attention to their choices and compromises, helping us to improve both safety and performance.

 

The paper was originally published in the Seaways – The International Journal of The Nautical Institute (December 2017). 

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