Author: Ekaterina Bespalova, Head of Labor Safety Service — SARRZ
As of September 1, 2022, Decree of the Government of the Russian Federation No. 2464 dated December 24, 2021, came into force, establishing a new procedure (rules) for training employees in the field of HSE. One fundamentally new type of training is now training on the use (application) of personal protective equipment (PPE). This raises many questions:
- how (on what basis) to develop such a training program and how many hours should it consist of?
- which specific PPE requires training on use (application)? and what principle should be used to determine PPE that requires practical skills?
- how to teach methods of wearing workwear and safety footwear?
- what does the PPE Training Program developed by Training Centers without a List of used PPE include? All possible PPE? And how to organize practical sessions for developing PPE application skills in this case?
In our organization, we proceeded as follows:
- developed and approved a List of personal protective equipment, the use of which requires practical skills from employees. This List included all PPE, as any personal protective equipment requires practical application skills or, at the very least, wearing methods (Clause 28 of the Training Rules);
- developed and approved a List of professions and positions subject to PPE training, which also included all employees, since the site is industrial and even office staff (including visitors) use PPE (at least a helmet and a high-visibility vest) when visiting production areas (Clause 80 of the Training Rules);
- identified the persons conducting the PPE training and members of the HSE knowledge testing commission regarding PPE use and sent them to a Training Center for instruction (Clause 40 of the Training Rules);
- developed a PPE Training Program for the organization's employees based on the List of PPE requiring practical skills, taking into account the requirements and recommendations of the specific PPE manufacturer reflected in the operational documentation (Clause 39 of the Training Rules);
- developed questions to check the knowledge of the requirements established by the Program;
- established a material and technical base in the form of samples of the PPE used, passports and instructions for the use of these PPE, technical regulations of the Customs Union, and GOST standards for PPE to practice practical skills of use and application and to demonstrate the knowledge acquired during training (Clauses 41-42 of the Training Rules)
And, essentially, we began the training.
Difficulties arose during the development of the PPE Training Program, as no standard program exists and it must be based not only on the List of PPE types for which training is required but also take into account specific PPE models from a specific manufacturer. This is the necessary and important information contained in manufacturer catalogs and operational documentation for PPE. For example, there is a vast variety of types and models of workwear for protection against general industrial pollution and mechanical impacts, differing in style, fabric composition and quality, fittings, etc., which determines both the methods of wearing, maintenance requirements, and methods for assessing serviceability.
In connection with the above, the thought arises regarding the expediency of the PPE manufacturer providing recommendations on the application, use, wearing methods, serviceability assessment, rejection, care, and storage of the PPE they supply, for inclusion of this information in the training program and practical skill development. It would not be superfluous at all to have the opportunity (or necessity) for a representative of the manufacturer or supplier to demonstrate the correct use of PPE during the initial delivery.
I believe that the process of training in the use and application of PPE without reference to a specific model is abstract and ineffective. I also believe that Training Centers should adapt their training programs in accordance with the PPE used at the enterprise. Perhaps this type of training should be performed by the PPE manufacturer?
I would like to know the opinion of colleagues on this issue; please share in the comments.
Comments 3
Ekaterina Bespalova,
Thank you!
Anna Tyutyunnik,
Good afternoon, Anna!
In our organization, the people conducting PPE usage training are the OHS specialists and the production manager. The OHS team was recently expanded by 1 specialist and the training responsibilities were proportionally distributed among the team members. For the production manager, essentially nothing changed, since the responsibilities for training production personnel on PPE use were already part of their duties, just within the scope of the OHS training program.
How did you resolve the issue of incentivizing the people who conduct PPE usage training? Extra pay, relief from some job duties? This is an additional workload for them after all.