State of Maine Department of Transportation Administrative Policy Memorandum 410 Supercedes APM dated effective April 4, 2001 Revised Date: January 23, 2002 TO: All employees SUBJECT: Protective Clothing, Equipment and Devices Purpose and Scope Employees of the Maine Department of Transportation permanently or temporarily assigned to work areas where there is possible danger of injury, such as from impact, falling or flying objects, shock or burns, contaminated air or loud noise shall be protected by standardized personal protective clothing, equipment and/or devices and will be trained if necessary in the proper use and care of same. For purposes of this policy OSHA term P.P.E., or personal protective equipment, is intended to include any clothing equipment or devices that may be required in worksites utilized by DOT employees. Failure to use or to correctly use such P.P.E. in work areas or activities outlined in this policy and its appendices and attachments may result in disciplinary action up to and including discharge. Managers and supervisory personnel may be subject to disciplinary action when they fail to require use of P.P.E. or fail to enforce compliance with this policy through the use of ordinary supervisory and leadership techniques or by using the disciplinary process themselves where necessary. Basis This policy, its appendices and attachments, and the practices described have been developed on the basis of State and Federal law, regulation, or policy, and are supported by collective bargaining agreement. The specific policies and/or procedures as set forth in this administrative policy memorandum are not meant to reduce or diminish more stringent directives or procedures for use of P.P.E. that may be developed by unique operational units within the department. Instead they are meant to serve as standardized minimum requirements. In fact, Bureau Directors, Division Heads, Division Engineers and on-site supervisory personnel are authorized
and encouraged to direct the use of P.P.E. in areas and activities not outlined in this policy when in their judgment there is reason to believe that such action is in the best interest of the safety of the employee(s). Responsibility Employees of the Maine Department of Transportation are responsible for carrying out the intent of this policy and its appendices and attachments. Employees are responsible for attending training as scheduled to meet the requirements of this policy. Employees who fail to attend appropriate training or testing programs required before using or wearing certain P.P.E. may be deemed unqualified to perform their jobs or certain duties of their jobs. Employees so disqualified may be suspended without pay either continuously or for time periods when the duties requiring the P.P.E. are being performed, until they have completed the required training or testing program. During day-to-day operations, immediate supervisors and working leaders of departmental employees are charged with ensuring compliance with this policy, its appendices and attachments For purposes of this policy the meaning of immediate supervisor includes any DOT employee who has direct and personal management or control of a work location or of another employee. This could include a formally designated lead-worker, the senior of two or more employees working by themselves or in some situations, an employee whose job typically requires working alone with infrequent observation by a supervisor. This definition is in keeping with the intent of the State of Maine Workplace Manslaughter Law in its attempt to identify accountability for the safety of a worksite. This does not relieve regularly assigned supervisors from their responsibility to provide essential P.P.E. to such remotely assigned workers or working leaders, but simply recognizes the fact that supervision cannot be all places at all times. Bureau Directors, Division Heads, Division Engineers and all intermediate managers and supervisors are charged with implementing, promoting, monitoring and enforcing the provisions of this policy in a manner which clearly demonstrates to first level supervisors and employees that they support the overall safety policy of the Department of Transportation. Procurement, issuance of and accounting for all P.P.E. will be the responsibility of the Division Head or his/her designee, such as a safety coordinator. P.P.E. necessary to bring about conformance with this policy will meet or exceed state and/or federally adopted safety standards. Division Heads and Division Engineers are also responsible for ensuring that their employees are properly scheduled and directed to attend training and testing programs designed to qualify or maintain employee qualifications to use and wear P.P.E. First level supervisors will ensure that initial and continuing on-the-job-training emphasizes the use of P.P.E. as an integral part of performing duties in accordance with performance standards.
Contractor Safety The Department of Transportation has a certain responsibility to see that its contractors and utility companies work within the State s rights-of way, work in a safe manner. The Department shall act through its appropriate supervisory/management personnel. Contractors employed by the Department shall comply with all applicable safety standards including OSHA and MUTCD. Contractors shall not be required to comply with APM (Administrative Policy Memorandum) 410. If a serious violation of safety standards is observed and there is an imminent danger, then the work shall be stopped until conditions are corrected. If there is not an imminent danger but a clear violation exists, the contractor shall be notified. This notification should be through the contractor s competent person or highest-ranking person on site. Utility companies and their agents working within a State s rights-of-way shall comply with safety standards. Notification to a utility company or its agent shall be in the same manner as notification to a contractor employed by the department. The Department shall communicate through its Resident Inspector, Resident Engineer, Project Manager, District Manager, Superintendent, Division Traffic Engineer, Assistant Division Engineer, Division Engineer, Program Manager, Assistant Program Managers, Bureau Director, or Chief Engineer. Other Department employees who observe an unsafe condition shall notify any of the above employees to take appropriate action. If a contractor or utility fails to take necessary action, the appropriate outside agencies shall be notified such as OSHA or State Police. The Director of MDOT Health and Safety Programs will be responsible for overseeing this program and: Providing technical support and guidance to supervisors and safety coordinators; and Developing policy in new and related safety subjects. Training Employees of the Maine Department of Transportation will receive initial and periodic training and instruction on P.P.E. Training may be provided by anyone possessing sufficient knowledge or prior experience in the areas to be covered. Training may be presented in the following forms: verbally, written or visually, or any media type as needed. Content of this training shall cover at least the following areas: -- Explanation of the hazard from which the P.P.E is meant to shield the employee.
-- Proper fit and/or use. -- Maintenance, inspection and care. -- Emergency procedures for equipment or device failure -- Disciplinary consequences of failure to wear and use required P.P.E. In addition to the training described above, employees will receive through on-the-job training for any task(s) which incorporates the use of P.P.E as the only acceptable means of accomplishing job duties. The Appendices and Attachments listed below are included in this Administrative Policy Memorandum. Additional appendices and attachments will be published as necessary. Appendix A - Hard Hats Attachment A-1- Hard Hat Exceptions Appendix B - Safety Vests Appendix C Eye and Face Protection Appendix D Leg Protection Appendix E Safety Footwear Appendix F Hand Protection Appendix G- Respiratory Protection Subject: Hard Hats APPENDIX A Hard hats will be worn by all departmental employees while performing work activities outlined below 1. Highway maintenance activities 2. Bridge maintenance activities 3. Maintenance of traffic control devices activities
4. Construction loading and unloading activities 5. Activities in and around overhead equipment or objects as designated by the Division Head or supervisor 6. Equipment maintenance areas as designated by the Division Head or supervisor 7. Building construction or maintenance as designated by the Division Head or supervisor 8. Private areas designated by owner or operator as "Hard Hat" areas. 9. Highway and bridge construction inspection activities. The only exceptions to the above policy will be those approved in writing concurrently by the Director, DOT Health and Safety and the respective Bureau Director. Each exception will be distributed as an attachment to APM 410 and will be consistent statewide for the Division or Divisions for which the exception is approved. Subject: Hard Hat Exceptions APPENDIX A-1 Employees may wear MDOT furnished high visibility caps in lieu of all hard hats in the following circumstances: A. While involved in pre-construction activities where equipment and/or machinery are not in use; B. While performing any field traffic data collection activity such as: turning movement counts, origin and destination surveys and speed monitoring surveys that are not in a work zone. C. While painting equipment or buildings where equipment and /or machinery is not in use. D. In the performance of litter pick-up E. Striping of roadways. Subject: Safety Vests APPENDIX B High visibility reflectorized safety vests will be worn by all departmental employees whenever they are exposed to vehicular traffic. Vests must be worn as the outermost garment and not be
obscured by other clothing. APPENDIX C Subject: Eye and Face Protection The purpose of this Appendix is to reduce the chance of eye and face injuries sustained by Department of Transportation employees, contractors, its visitors and guests while in areas under our authority. Sections Outlined: 1. Affected personnel and Areas defined. 2. Activities covered under this policy 3. Selection of equipment 4. Compliance 5. Summary Section 1. Affected Personnel and Areas defined. This Appendix covers any person(s) who may be working, visiting or transiting in any area operated and/or controlled by the Department and who are either involved in or in proximity to a process or work that has the potential for eye or face injury. To Include: Any working bay, lab, shop, storage or stock area, job or work zone, yard area, bridges, barges, boats, piers, platforms and any other work site where hazards to the eye and face are present. Areas Excluded: Lavatories (except for custodians while engaging in their duties), lunchrooms, office areas, parking areas used for public and employee parking, while operating equipment (in an totally enclosed compartment or cab) and inside of motor vehicles. Section 2. Activities Covered & Protection Necessary Any work activity or task that has an identified or potential hazard which could result in eye or
face injuries. These activities may include but are not limited to; a. Transiting working areas -- Safety Glasses b. Grinding, chipping and sanding -- Safety glasses and face shield c. Welding, brazing, cutting -- Safety glasses and appropriate welding hood or shaded face shield d. General shop maintenance -- Safety glasses (minimum) e. Machining, drilling -- Safety glasses and face shield f. Steam cleaning, pressure washing and culvert thawing -- Safety glasses and face shield g. Working with woodworking tools -- Safety glasses (minimum) h. Parts washing -- Safety glasses or goggles and face shield i. Overhead work -- Safety glasses or goggles (minimum) j. Operating equipment with open operator compartments and cabs -- Safety glasses (minimum) k. Using jackhammers -- Safety glasses (minimum) l. Operating chain saws -- Safety glasses and face shield m. Working with chemicals -- Goggles (splash proof) and face shield n. Custodial work (lavatories and rest areas) -- Safety glasses or goggles o. Yard work (mowing lawns) -- Safety glasses (minimum) Note: This list of tasks is to be used as a guide only. Supervisors and employees must review all tasks prior to commencing work and select appropriate levels of protection. Safety glasses can be regular, over the glasses type (OTG) or Prescription eye wear, with side shields (detachable or fixed), meeting the ANSI Z87.1 standard. Face shields when required are in-addition to safety glasses or goggles and are not to be used alone as safety eye wear. Section 3. Selection of equipment Selection of equipment is based on the hazards present; Section 2 lists equipment required for
selected tasks only. For additional help in deciding what PPE is needed for the task: a. Review job hazard assessments (JSA), maintenance manuals and product Material Safety Data Sheets (MSDS). b. Read the safety products information sheet to insure that it meets the requirements of the task or application. c. Contact supervisors or designated Safety Coordinators. Section 4. Compliance Any employee covered under this policy shall, while in working status, wear protective eye and face wear as described herein. Failure to wear prescribed protective eye and face wear may result in disciplinary action. Section 5. Summary This appendix was established to eliminate or reduce eye injuries, for this program to succeed we must: Continue to identify and engineer out potential hazards, make remaining hazards known to all employees, select and wear the appropriate protective eye wear and train employees on use and care of protective eye wear. Subject: Leg Protection APPENDIX D Leg protection, such as long pants, shall be worn by all Departmental personnel when engaged in work activities that may result in exposure to hazards such as: 1. Sun Burn 2. Abrasion 3. Insect bites (Lyme Disease) 4. Poison Ivy
5. Hazardous materials and chemicals APPENDIX E Subject: Safety Footwear Safety Footwear meeting ANZI Standard Z41.1-1991 and Maine Department of Transportation APM 413 shall be worn by departmental employees while performing all work activities listed below. 1. Highway maintenance activities. 2. Bridge maintenance activities. 3. Maintenance of traffic control devices. 4. Construction loading and unloading activities. 5. Highway, Bridge and Multimodal construction activities. 6. Equipment maintenance activities. 7. Building construction and maintenance activities. 8. Highway and Bridge construction inspection activities. 9. Labs in which materials being handled pose a danger of foot injury. 10. Any other working area where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole. Subject: Hand Protection APPENDIX F Hand Protection will be worn by all employees when their hands are exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes.
APPENDIX G Subject: Respiratory Protection It is the primary intention of Maine Department of Transportation, to make available to its employees a place of work that is free from hazards due to air contamination caused by dusts, fogs, fumes, mists, gases, smokes, sprays or vapors. This may be accomplished by several methods. The first being the elimination or substitution of toxic materials and in their place, select and use non-toxic or less toxic materials in place of these materials; the second method is to control these hazards with engineering measures such as wetting down surfaces to keep the dust levels down,general and local ventilation; the third being enclosure or confinement of the work operation to prevent employee exposure; and the fourth being the use of respiratory protection as the means of protecting the employee from the harmful effects of toxic materials. It should be noted that respiratory protection is an alternative means for protecting the employee; all efforts should be initially made to eliminate the hazard. If this cannot be accomplished, minimize the hazard and utilize a respiratory protection program as outlined in the OSHA standards. Respiratory protection shall be used in the following situations only: During the installation or implementation of feasible engineering or work practice controls Maintenance and/or repair operations where controls are not sufficient to reduce the exposure Emergencies After exhausting all other feasible methods. The operator of a hand held power broom. RESPONSIBILITIES The division engineers, and all their supervisors in conjunction with the safety coordinators, shall implement this program. REQUIREMENTS If employees are going to wear respirators they have to meet certain requirements found in Me1910.134 (State of Maine Respiratory Protection Standard). The basic requirements are as follows: 1. Be cleared medically - up to 35 years old every 5 years from 36 to 40 every 2 years over 40 every year 2. Be fit tested for the respirator they are going to wear (annually) 3. Be trained annually
A standard half face respirator is more than adequate to ensure that exposure levels are not exceeded. There are two types available. One is the tight-fitting facepiece with cartridges, such as the(north) and the other is the filtering facepiece, (dust mask). The filtering facepiece is less conspicuous and would probably be more acceptable to the work force, however it will not provide the protection of the tight-fitting facepiece with cartridges.