Personal Protective Equipment - Procedure

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1.0 Purpose and Scope

This procedure outlines requirements for the provision and use of Personal Protective Equipment (PPE) at The University of Queensland (UQ) and applies to all UQ workers whose workplace activities require the use of PPE to mitigate risk of injury or illness. The use of PPE should not be relied upon as the sole source of risk control, and should be used with other control methods such as hazard elimination or substitution (higher order controls).

For the purposes of this procedure, the definition of UQ workers is broad – including staff, students, visitors, volunteers and contractors – and is intended to ensure UQ meets its responsibilities under the Work Health and Safety Act 2011 (WHS Act). The definition of UQ workers is provided in the appendix.  

1.1 Context

UQ is legally obliged under the Work Health and Safety Regulation 2011 (WHS Regulation) to implement appropriate control measures in the workplace (e.g. mandatory use of PPE) if it is not reasonably practicable to eliminate a health and safety risk.

The How to manage work health and safety risks Code of Practice 2011 provides practical guidance to achieving the standards of health, safety and welfare required under the WHS Regulation.

2.0 Process and Key Controls

(1) Organisational Units must undertake risk assessments of the hazards that are present in the workplace, proportionate and relevant to the activities being undertaken, and taking into account the duties and work of the group as a whole.

(2) Under the hierarchy of risk control, the use of PPE should always be considered in combination with more effective, higher order controls (see How to manage work health and safety risks Code of Practice 2011).

(3) Where PPE is determined to be an appropriate control measure, either in combination with other controls or as a stand-alone measure, through the risk assessment process or where stated in regulations:

(a) UQ must provide relevant UQ workers with the correct PPE and information, training and instructions in its proper use and maintenance;
(b) UQ workers must use the PPE in accordance with this procedure and any information, training or reasonable instruction from the Organisational Unit; and
(c) the PPE must comply with the relevant Australian Standard.

3.0 Key Requirements

3.1 Workplace risk assessments

Organisational Units that conduct hazardous activities must conduct risk assessments in accordance with the Occupational Health and Safety Risk Management Procedure to determine the use of PPE for specific tasks. Risk assessments should be proportionate and relevant to the activities being regularly undertaken in their workplace.

Further information and guidance in conducting workplace risk assessments is available from Workplace Health and Safety Queensland (the Regulator) and the UQ Health, Safety and Wellness (HSW) Division.

3.1.1 Certified Spaces – Biosafety and Biosecurity

Facilities certified by the Office of the Gene Technology Regulator or the Department of Agriculture may have specific PPE requirements, which must be adhered to by UQ workers. These requirements are detailed in the regulator’s guidelines and/or facility certification documentation (refer to UQ’s Biosafety Policy and procedures).

It may be possible to remove the need for certain PPE under specific conditions. In such cases, the UQ worker must submit a request to the Biosafety Advisors in the UQ HSW Division outlining the proposal and include a documented approved risk assessment. Work must not be undertaken with the modified PPE requirements before approval from the Biosafety Advisors is provided.

3.2 PPE standards in the workplace

Organisational Units must establish PPE standards in the workplace to protect UQ workers against the risk of injury. UQ workers must comply with these standards and supervisors must enforce compliance.

A UQ worker’s failure to use PPE where it is stipulated as a risk management control, or follow associated usage and maintenance instructions provided by the Organisational Unit, may breach the WHS Regulation. Such actions may be considered misconduct and managed as follows:

• for staff – in accordance with the Enterprise Agreement;
• for students, including higher degree by research students – under the Student Integrity and Misconduct Policy; and
• for other UQ workers (e.g. contractors and visiting academics) – exclusion from the work area until complying with the PPE requirements of the work area.

3.3 Provision of PPE

Organisational Units are responsible for ensuring that all necessary PPE required for a task is available to UQ workers, which will remain the property of UQ (except in certain circumstances – e.g. prescription safety eyewear which may be provided or subsidised by the Organisational Unit).

Undergraduate students are expected to provide their own laboratory coats and safety glasses that must comply with the relevant Australian Standard for their on campus laboratory practicals.

Where the PPE is not supplied by UQ, work must not commence until the appropriate PPE is made available. Privately purchased PPE must be fit for purpose, compliant with the relevant Australian Standards and comply with section 3.4 of this procedure. UQ workers who are UQ staff may be eligible to make a claim for reimbursement of actual costs in accordance with the Schedule 11 – Professional Staff Allowances (Uniforms and Safety Equipment and Protective Clothing) in the Enterprise Agreement [1].  Any queries for the provision of PPE in your area are to be discussed with your supervisor and with reference to the relevant risk assessment(s).

[1] In specific circumstances outlined in Schedule 11 – Professional Staff Allowances (Wet Weather) of the Enterprise Agreement, certain staff may become eligible for an hourly loading. 

3.4 Use of PPE

If PPE is required, it should be stated in the workplace specific Safe Work Method Statement, Standard Operating Procedure or other specific protocols.

Where PPE is to be used or worn in the workplace, it must be:

• selected to minimise risk to health and safety;
• suitable for the nature of the work and any hazard associated with the work;
• a suitable size and fit for the person wearing it;
• maintained, repaired or replaced as required so it continues to minimise risk; and
• used or worn by the UQ worker, so far as is reasonably practicable.

4.0 Roles, Responsibilities and Accountabilities

4.1 Executive Deans and Institute Directors

Executive Deans and Institute Directors are responsible for ensuring that strategic planning and budgeting provides for a safe working environment that minimises or eliminates risk to a point where lower order controls (such as PPE) are not solely relied upon in the workplace. Specifically, budget allocation should be provided to ensure that infrastructure is upgraded and maintained as required to ensure a safe and healthy work environment, and engineering controls are in place for equipment that pose a HSW risk of harm.

4.2 Heads of Organisational Units

Heads of Organisational Units must ensure:

• they visibly and actively promote the effective enforcement of PPE standards;
• supervisors in the workplace have adequate time to induct, train and supervise UQ workers in the correct use of PPE;
• UQ workers have access to the required PPE and are provided adequate information, training and reasonable instructions in the use and storage of PPE;
• risk assessments are completed for the activities and tasks within the workplace and the use of PPE is considered in combination with higher order controls; and
• UQ workers are completing PPE training and risk assessment requirements.

4.3 Supervisors

Supervisors (including academic supervisors of higher degree by research students) are responsible for:

• completing risk assessments in consultation with relevant UQ workers (considering the requirement for PPE in combination with higher order controls) –

o risk assessments for undergraduate activities are to be completed by the person responsible for supervising the undergraduate activity, who must explain the requirements to the students and provide access to the risk assessment;

• providing clearly written information and procedural guidance that is circulated to all relevant UQ workers on the correct use and maintenance of PPE in their work area;

• ensuring UQ workers are provided adequate information, training and reasonable instructions in the use of PPE;

• enforcing the appropriate and required use of PPE; and where PPE is not being used, or not being used correctly, the UQ worker is directed to cease the activity until the correct PPE is used; and

• ensuring that PPE in their work area is sufficient, appropriate, in good condition and stored away from sources of contamination and damage.

Supervisors of undergraduate students are responsible for overseeing the health and safety of students in teaching and learning activities. Refer to the Occupational Health and Safety in the Laboratory Guideline.

4.4 Health, Safety and Wellness (HSW) Managers and Workplace Health and Safety Coordinators (WHSC)

Workplace Health and Safety Coordinators and HSW Managers are responsible for:

• providing UQ workers with education, advice and support regarding the safe and correct use of PPE in the workplace;
• assisting UQ workers to perform risk assessments as required;
• assessing whether Organisational Units and UQ workers are able to demonstrate compliance with this procedure and that any compliance issues that are identified are rectified in a timely manner; and
• seeking specialist advice from the Health, Safety and Wellness Division on PPE that may be required (such as hearing protection, respiratory protection masks and breathing apparatus).

4.5 UQ workers

UQ workers are responsible for:

• complying with this procedure, any PPE requirements identified by a risk assessment and any workplace safe operating procedures regarding the correct use and maintenance of PPE in the Organisational Unit;
• completing risk assessments for the tasks and activities undertaken including any requirements for PPE in combination with higher order controls prior to commencing tasks; and
• checking the condition and cleanliness of PPE prior to commencing a task and reporting any defective, inadequate or damaged PPE to the supervisor immediately.

5.0 Monitoring, Review and Assurance

Heads of Organisational Units and supervisors should regularly review the effectiveness of PPE (as per section 3.4) particularly following incidents and near misses and after changes to processes, procedures, personnel, storage systems and physical changes in PPE products.

HSW Division will review this procedure as required to ensure its accuracy and relevance, and will conduct periodic audits of Organisational Units’ compliance with this procedure, which may include:

• existence and adequacy of workplace risk assessments;
• UQ workers’ compliance with PPE requirements in the workplace; and
• UQ workers’ awareness of compliance obligations associated with this procedure.

HSW Managers and WHSC will conduct regular inspections (at least annually) to review appropriate risk controls, including the appropriate use of PPE.

6.0 Recording and Reporting

Supervisors and/or Health, Safety and Wellness Managers and Coordinators will report, in UQSafe Incident, non compliance with PPE requirements or improper use of PPE in the workplace.

7.0 Appendix

7.1 Definitions

Enterprise AgreementThe University of Queensland Enterprise Agreement or as amended or replaced.

Personal Protective Equipment (PPE) – clothing or equipment designed to be worn by someone to protect them from the risk of injury or illness.

Organisational Unit – a formal grouping of staff established to conduct a discrete set of activities within a functional area of UQ.

UQ workers – for the purposes of this procedure includes:

• staff - continuing, fixed-term, research (contingent funded) and casual staff;
• contractors, subcontractors and consultants;
• visiting academics and researchers;
• affiliates - academic title holders, visiting academics, emeritus professors, adjunct and honorary title holders, industry fellows and conjoint appointments;
• higher degree by research students; and
• volunteers and students undertaking work experience.

Director, Health, Safety and Wellness Mr Jim Carmichael
Director, Health, Safety and Wellness Mr Jim Carmichael