i guess it's easy to enforce, and an easy finding.

Of course PPE is the 'last resort' for very valid reasons. The problem is that it is all too often seen as the easy answer to managing exposure to a hazardous situation. When it comes to prevention of exposure to chemicals it is anything but an easy answer. I have lost count of the number of times that I have visited a new client's workplace for the first time to find that they are relying primarily on gloves and that none of these are fit for purpose. Selection and use of PPE, and in particular gloves, against chemical hazards is something that is much more complex than many are aware of. Just as an example of this, in a recent edition of the Annals of Occupational Hygiene an article by some dermatologists examined the uptake of carbon disulphide with and without gloves and came to the conclusion that they were getting greater skin uptake when the gloves were worn compared with ungloved skin. What they had not recognised is that the gloves being worn (nitrile and natural rubber) were inappropriate for this chemical, having a permeation breakthrough time of less than 10 minutes. In fact, the only glove material that works with this chemical is Viton and a pair of Viton gloves costs around £80! Furthermore, studies have shown that a chemical inside a glove will penetrate the skin more easily due to the effect on the skin of the occlusion. Deciding which glove to provide and for how long it will protect is far from easy. Chris

I would like to see some examples where PPE is not necessary. There are many different interventions in health and safety, each has a place in the bigger picture. Understanding their effects and limitations is key to proper safety management. An over reliance on any type of control is likely to prove ineffective in the long-term. Likewise, omitting certain types of controls could also prove disastrous.

I often agree that mandatory PPE (whether the hazard is present or not) is ineffective, and unhelpful in improving people's safety awareness. But it's not always "lazy safety management": If I have to walk from the site office to the other end of a busy construction job, there's plenty of places (especially on a decent site with demarcated walkways) where I'd be constantly taking my hat on and off, putting on my hi-viz to use a crossing point, etc. Sometimes blanket rules are good.

I meant that a blanket rule avoids me doing all that putting-on and taking-off. It's all about the frequency of risk - hard hats and high vis are needed (ie justified by the presence of an actual hazard of sufficient likelihood) in a lot of areas on site, so making people wear them all the time is justified, and also makes it easier for people to comply. The discomfort of occaisionally wearing PPE where it's not needed is minimal compared to the benefit. On the other hand, mandatory eye and hand (or worse - hearing) protection, often a requirement on some sites, can end up with some people wearing PPE which is never, or rarely, justified. This is what my "sometimes blanket rules are good." comment was about - it's not always an indicator of lazy management.

I understand hierarchy of control differently. Some people see it as a set of steps, where one step, if successful, eliminates the need for the rest of the steps. I see the process of risk control as jigsaw puzzles - I need all pieces to appreciate the full picture. So I implement all necessary steps wherever possible. If I can't eliminate a hazard (which obviously is the only exception to my rule) but I manage to substitute it (e.g. milder chemical), I still check it's MSDS and choose appropriate PPE. If there are engineering controls in place, it doesn't mean that wearing PPE is not necessary - it depends on the environment. What about other operations on site? PPE might not be required for the guy who's super safe at the bottom doing his job, but someone might drop something at him from the top... accidents happen and PPE help to prevent them every now and then, regardless of how safe the site is (of course depends on the industry).

Hearing protection for those areas identified from survey as being noisy - agree. Dependent upon the facility the limitations to scope you describe may or may not include the total process from raw materials in to finished paper out in normal shift operation (shut down maintenance activity excluded): Stock preparation area tasks - depends upon degree of automation cut resistant gloves for handling baling wire/ragger rope, impact resistant face/eye protection if wires cut manually, Hi-Vis in mixed areas with transport / FLT movements. Wet end tasks - chemical goggles & gloves during felt & wire cleaning or working on additive systems, wet gear for under machine adjustments Dry end tasks - chemical goggles & gloves during dryer fabric cleaning Reeler tasks - cut resistant gloves for blade change /manual cut adjustment when not automated Warehouse - Hi-Vis due to mix with transport Safety footwear is a common theme in all operational areas of paper mills (seen in the US, UK, Sweden, Finland, France, Germany, Greece, Portugal, Holland) due to the floor surface / possible contaminants and large or heavy items used that may drop on to operatives feet. Dependent upon grade produced (tissue, Printing & writing, newsprint, fluting & liner, multiply board) there would be other issues where dedicated PPE may be required either task based or for the duration of the shift.

have you done a risk assessment on wet work? Wet work, i.e. exposure to water, even when not contaminated by chemicals) is a frequent cause of occupational irritant contact dermatitis. However, wearing occlusive gloves is equivalent to wet work, but there are steps that can be taken to avoid this. Chris

Wet work in a paper mill involves a warm / hot chemical soup - not just water. There are substances that dissolve from the primary raw materials. Typically there will be biocides, surfactants, drainage / retention aids and pH adjusters added to aid the manufacturing process. Dependent upon the finished product there will be bleaching / brightening agents, dye stuffs, fillers, de-inking chemicals, size, wet or dry strength resins, bulking agents. Then with most paper mills pursuing minimal effluent discharge the whole lot gets recycled back in to the process so flocculants from fibre recovery and the acidic / caustic machine cleaners are all added to the recipe.