Personal protective equipment (PPE), important as it is, should be viewed as your last choice to protect employees from hazards. When possible, engineering controls should be considered first. Engineering controls (i.e., guarding, shielding) require no human action to provide protection. Administrative or process controls are the next best thing (i.e., limiting the amount of time a worker is exposed to loud noises).

However, PPE may be your only choice in some situations. If neither engineering nor administrative controls are possible, then PPE is the preferred means of minimizing or protecting employees from physical and health hazards.


Understanding PPE
PPE is equipment that protects against physical or health hazards to eyes, ears, face, head, and other body parts. Such equipment may be required to protect against threats such as chemicals, impacts, heat, cold, dust, light, electricity, falling objects, sharp objects, and biological materials.

To determine if you will need PPE, a job hazard analysis (JHA) or assessment of job tasks should be conducted. When your assessment indicates that PPE is the only alternative for protection, then you can decide what types to employ. The JHA requires you to examine the job tasks, evaluate the hazards, and determine hazard mitigation measures. During the JHA, the hazards can be identified, and then the proper PPE selected. The JHA must be documented and include the workplace, date, assessor’s name, and document identification of hazard assessment.

The National Ski Areas Association has created generic job hazard analysis forms for some common tasks at resorts. Those JHAs should be modified to reflect your resort’s needs and procedures.

Doing a JHA in conjunction with the affected employees will assist in determining the needed PPE, because they are the ones who will know all the steps and processes for the job. This has an additional benefit of getting employees on board with PPE use, since they had a say on the requirements.


Ski Resort PPE
PPE relevant to a ski resort may include:

• Eye protection in the equipment maintenance area, rental shops, and housekeeping

• Welding shields in maintenance and fabrication shop and/or lift repairs

• Eye and hearing protection for snowmaking crews

• Hard hats for employees working under other employees working on lift or snowmaking towers

• Life jackets and safety rings for employees and volunteer patrollers working next to a snowmaking (or any) body of water

• Fall protection harness/equipment for lift mechanics, building maintenance, and possibly patrollers

• High visibility vests for night snowmaking and parking lot attendants

• Specialty gloves in rental, housekeeping, and food operations

All employees should wear the required PPE if they are in an area that has been determined to need it. For example, if a supervisor or manager is visiting the rental shop and equipment is being sharpened, the visitor should wear the proper PPE. Leadership must set the example when it comes to employee safety and act suitably at all times.


Equipment Requirements
PPE may include, but is not limited to, the following types of equipment:
• Safety glasses
• Ear muffs/plugs
• Hard hats
• Steel-toed shoes
• Special coveralls or clothes
• High visibility outerwear
• Fall harnesses
• Respirators or dust masks
• Rubber boots
• Job-specific gloves
• Life vests

Some of these types of PPE may have specific applications, such as electrical resistance or puncture resistance. The PPE you select depends on your job assessment. Many shoe, glove, and safety equipment vendors can help you make the specialized choices.

PPE selection may need to meet specific ANSI standards like ski lifts, or ASTM standards such as snowsport helmets. It is the employer’s responsibility to make sure the equipment meets the requirements. (See box for more details.)

In choosing PPE, employers must consider equipment fit, comfort, size, and compatibility with other equipment. Poor fitting or uncomfortable PPE is likely to go unused, which in turn increases the employer risk. Work with the employees when choosing their PPE, use their input to get buy-in. PPE must also be kept sanitary.

The employer’s responsibilities:

• Hazard assessment

• Select and purchase PPE

• Verify all PPE used meets requirements

• Communicate PPE selection and use to employee

• Training

• Retraining

The employee’s responsibilities:

• Demonstrate proper use of PPE

• Maintain control of PPE

• Notify employer when PPE is damaged or not functioning properly.

Employers are responsible for the purchase of PPE, except equipment that may be used regularly off work premises, such as steel-toed boots or prescription safety glasses. Specialty equipment such as shoes or boots that are required to stay at the employer work site, such as nonconductive safety steel-toed shoes that protect against electrical hazards, must be paid for by the employer.

The employer must also replace broken, worn, or non-functioning PPE, unless it was lost or intentionally damaged by the employee.

While best practice is for the employer to supply PPE and have control of job related equipment, if employees use their own PPE, the employer must inspect it to make sure it meets the job requirements and is not broken or worn out. The exception to this is the usual clothing used to protect from weather, such as winter coats, gloves, parkas, hats, and ordinary sunglasses. These are the employee’s responsibility.


Training
Employers must train the employees how to properly use their PPE. This training must include when the PPE is necessary, what PPE is necessary, how to properly use, adjust, and wear the PPE, limitations, and the proper care, maintenance, useful life and disposal of the PPE. The employer should make sure old PPE is disposed of properly so it does not get taken home for later use and never gets used on the job again.

Retraining is required when changes in the workplace make the previous training obsolete or change the type of PPE required. Retraining might also be required when an employee’s knowledge of PPE use appears inadequate, or if the employee lacks the skill to understand proper PPE use.

Employees should demonstrate that they understand the PPE functions, care, and limitations. All training must be documented, and include equipment trained on, when training occurred, and employee signature. At a ski resort, early in the season (both summer and winter) is a good time for a review of PPE for all employees.