NIOSH Testimony on Personal Protective Equipment for General Industry by R. A. Lemen, October 16, 1989.
This testimony concerns the comments of NIOSH regarding the proposed revision of the protective equipment standards by OSHA. Concerning performance versus design standards, NIOSH contends that the latest versions of the personal protective equipment (PPE) standards that OSHA proposes to adopt have fewer design restrictions and therefore represent a net benefit to workers because PPE manufacturers will have a greater opportunity to develop PPE designs that are safer and more acceptable to workers. Concerning third party certification, NIOSH suggests that many models of PPE failed to comply with OSHA standards as advertised by their manufacturer. NIOSH also recognizes that third party certification may be a necessary requirement to assure that PPEs meet minimum performance criteria. Concerning protection to front, back and sides of the head, NIOSH suggests that the OSHA rule include provisions to encourage the use of head protection devices that are more protective than those addressed in ANSI standard Z89.1-1986. NIOSH recommends that an effort be made to identify occupations that would benefit from more head protection. Other specifics addressed include women's safety footwear, more protective classes of foot protection, footwear hazards, eye protection and exposures, identification of eye protection, and PPE systems.