Table of Contents
- Purpose & Scope
- Legal Requirements
- Head Protection
- Eye & Face Protection
- Foot Protection
- High-Visibility Apparel
- Hearing Protection
- Respiratory Protection
- Hand Protection
- Selection Criteria & Fit Testing
- Inspection, Maintenance & Replacement
- HCMI Minimum PPE Requirements
- Daily PPE Checklist
1. Purpose & Scope
Personal Protective Equipment (PPE) is the last line of defence in the hierarchy of controls. When engineering controls, administrative controls, and safe work practices cannot fully eliminate a hazard, properly selected and worn PPE protects HCMI workers from injury or illness on every construction project we manage.
This guide applies to all HCMI employees, subcontractors, and site visitors on any HCMI-managed church construction project in Ontario. Every person entering an active construction area must comply with these requirements.
2. Legal Requirements
PPE requirements for Ontario construction projects are established under multiple regulations:
- O. Reg. 213/91 (Construction Projects), sections 21 through 29 — prescribe minimum PPE for construction workers including head protection (s.22), foot protection (s.23), eye protection (s.24), and protective clothing requirements.
- Occupational Health and Safety Act (OHSA), s.25(1)(a) — employers must provide information, instruction, and supervision to protect worker health and safety, which includes PPE training.
- OHSA s.25(2)(h) — employers must take every precaution reasonable in the circumstances for the protection of a worker.
- OHSA s.27(1)(a) — workers must use or wear the equipment, protective devices, or clothing required by the employer.
Regulatory Note: Under O. Reg. 213/91 s.22(1), every worker on a construction project shall wear protective headwear at all times. Section 23(1) requires Grade 1 protective footwear with sole protection. Failure to comply can result in Ministry of Labour orders and fines up to $100,000 for individuals under OHSA s.66.
3. Head Protection
All hard hats must meet CSA Z94.1 (Industrial Protective Headwear). HCMI requires Class E (electrical) rated hard hats on all sites due to the potential for contact with electrical conductors during church construction and renovation work.
- Type 1 — protects from blows to the top of the head (minimum standard).
- Type 2 — protects from blows to the top and sides (required for steel erection and overhead work).
- Class E — tested to withstand 20,000 volts (phase to ground).
- Class G — tested to withstand 2,200 volts (general use).
Hard hats must be replaced immediately after any impact, if cracked or dented, if the suspension system is damaged, or at a maximum interval of five years from the date of manufacture (check the date stamp inside the shell). UV-degraded shells that are chalky, faded, or brittle must be replaced regardless of age.
4. Eye & Face Protection
Eye and face protection must conform to CSA Z94.3 (Eye and Face Protectors). The type of protection depends on the hazard:
- Safety glasses with side shields — minimum for general construction tasks, flying particles, dust.
- Safety goggles (sealed) — chemical splash, heavy dust, concrete cutting.
- Face shields — grinding, chipping, use of pneumatic tools. Must be worn over safety glasses, not as a standalone protector.
- Welding helmets/goggles — appropriate shade number per CSA W117.2 for the welding process being performed.
Prescription eyewear does not substitute for safety glasses unless it meets CSA Z94.3 and is marked accordingly. HCMI will subsidize prescription safety eyewear purchases through our benefits program.
5. Foot Protection
All footwear must meet CSA Z195 (Protective Footwear). O. Reg. 213/91 s.23 mandates Grade 1 footwear with sole protection on construction projects:
- Grade 1 (green triangle symbol) — puncture-resistant sole, Class 1 toe protection capable of withstanding 125 joules of impact.
- Sole protection — a puncture-resistant plate rated to withstand 1.2 kN of penetration force.
- Electrical hazard (omega symbol) — recommended for all HCMI sites where electrical work is occurring.
Boots must be 6-inch minimum height, lace-up style, and in good repair. Worn-out soles, separated uppers, or missing lace hooks require immediate replacement. HCMI provides an annual boot allowance for eligible employees.
6. High-Visibility Apparel
High-visibility garments must conform to CSA Z96 (High-Visibility Safety Apparel). O. Reg. 213/91 s.69.1 requires high-visibility clothing when workers are exposed to vehicular traffic or mobile equipment:
- Class 2 — minimum for most HCMI construction activities (vest or T-shirt with reflective striping).
- Class 3 — required when working near active roadways, in low-light conditions, or during flagging/signaling operations.
- Fluorescent background — orange, yellow-green, or red. Garments that are faded, torn, or have damaged reflective tape must be replaced.
HCMI Policy: All workers must wear CSA Z96 Class 2 or higher high-visibility vests at all times on HCMI sites, even when vehicular traffic is not present. This exceeds the regulatory minimum and reflects our commitment to maximum visibility on busy church construction sites.
7. Hearing Protection
Hearing protection must meet CSA Z94.2 (Hearing Protection Devices). Under O. Reg. 381/15, hearing protection is mandatory when noise levels exceed 85 dBA (8-hour time-weighted average):
- Foam earplugs — NRR 29-33 dB, suitable for most construction noise. Must be properly rolled and inserted.
- Pre-molded earplugs — reusable, NRR 22-27 dB. Must be cleaned regularly and checked for deterioration.
- Earmuffs — NRR 23-31 dB, ideal for intermittent noise exposure. Cushion seals must not be cracked or hardened.
- Dual protection (plugs + muffs) — required when noise exceeds 105 dBA, such as during concrete breaking or pile driving.
HCMI provides hearing protection at no cost on every site. Workers must not modify hearing protection devices or use personal audio earbuds as a substitute.
8. Respiratory Protection
Respiratory protection must conform to CSA Z94.4 (Selection, Use, and Care of Respirators). The type of respirator depends on the contaminant and its concentration:
- N95 filtering facepiece — nuisance dust, non-toxic particulate. Not suitable for silica dust at or above the OEL.
- Half-face elastomeric with P100 filters — silica dust, concrete cutting, grinding operations.
- Full-face elastomeric with combination cartridges — mixed exposures, paint spraying, solvent vapours.
- Supplied-air respirator (SAR) — oxygen-deficient atmospheres, confined spaces, highly toxic substances.
All workers who wear tight-fitting respirators must be fit tested annually using a quantitative or qualitative method per CSA Z94.4. Workers with facial hair that interferes with the seal cannot wear tight-fitting respirators and must use a loose-fitting powered air-purifying respirator (PAPR) or SAR instead.
Fit Testing Requirement: HCMI arranges annual respirator fit testing for all workers who may be exposed to airborne contaminants. Records are maintained in the HCMI safety office. No worker shall perform tasks requiring respiratory protection without a current fit test on file.
9. Hand Protection
There is no single CSA standard covering all construction gloves, but selection must be hazard-appropriate. Common glove types for church construction work include:
- Leather work gloves — general material handling, rough surfaces, abrasion hazards.
- Cut-resistant gloves (ANSI/ISEA 105 Level A4+) — sheet metal work, glass handling, sharp materials.
- Chemical-resistant gloves (nitrile, neoprene) — concrete, solvents, adhesives, coatings.
- Impact-resistant gloves — sledgehammer work, demolition, heavy steel handling.
- Insulated gloves (CSA Z462 rated) — electrical work, only for qualified electrical workers.
Gloves must fit properly. Loose gloves can catch on rotating equipment, and tight gloves reduce dexterity and increase fatigue. Inspect gloves before each use for tears, punctures, or chemical breakthrough.
10. Selection Criteria & Fit Testing
Proper PPE selection follows a systematic process:
- Hazard assessment — identify all hazards at the task level through the Job Hazard Analysis (JHA) process.
- Match PPE to hazard — select equipment rated for the specific hazard type and exposure level.
- Verify CSA certification — all PPE must bear the appropriate CSA certification mark. Imported equipment meeting only ANSI standards is not acceptable unless it also carries CSA certification.
- Size and fit — PPE must be individually fitted to each worker. Hard hat suspensions must be adjusted, safety glasses must not gap at the sides, and boots must be the correct size.
- Compatibility — ensure that multiple PPE items worn simultaneously do not interfere with each other (e.g., safety glasses must seal properly under a face shield, earmuffs must seal over hard hat brims).
- Worker acceptance — involve workers in PPE selection when possible. Workers who find PPE comfortable are more likely to wear it consistently.
11. Inspection, Maintenance & Replacement
Every piece of PPE must be inspected before each use. Follow these replacement schedules:
- Hard hats — replace every 5 years (date-stamped), or immediately after impact, cracking, or UV degradation.
- Hard hat suspensions — replace annually or when stretched, cracked, or frayed.
- Safety glasses — replace when scratched (scratches reduce impact resistance), cracked, or bent.
- Safety boots — replace when sole tread is worn smooth, uppers separate, or toe cap is exposed.
- High-visibility garments — replace when fluorescent colour is faded or reflective tape is peeling, torn, or less than 50% intact.
- Hearing protection — disposable plugs are single-use. Earmuff cushions should be replaced every 6-12 months.
- Respirator cartridges/filters — replace per manufacturer schedule, when breathing becomes difficult, or when breakthrough is detected.
- Gloves — replace at first sign of cuts, abrasion wear-through, or chemical penetration.
12. HCMI Minimum PPE Requirements
The following PPE is mandatory for every person on an HCMI-managed construction site, regardless of trade or task:
- CSA Z94.1 Class E hard hat (Type 2 for steel and overhead work)
- CSA Z94.3 safety glasses with side shields
- CSA Z195 Grade 1 safety boots with puncture-resistant sole
- CSA Z96 Class 2 (minimum) high-visibility vest
- Work gloves appropriate to the task
Additional PPE is required based on the specific task and hazard assessment. Supervisors must verify PPE compliance during daily site inspections and toolbox talks. Workers without proper PPE will be removed from the work area until compliant.
HCMI Zero-Tolerance Policy: Refusal to wear required PPE is grounds for immediate removal from the site. Repeat violations will result in progressive discipline up to and including termination. PPE is non-negotiable on every HCMI project.
13. Daily PPE Checklist
Complete this mental checklist before starting work each day:
- Hard hat: no cracks, dents, or UV damage? Suspension intact and adjusted?
- Safety glasses: no scratches, cracks, or loose lenses? Side shields in place?
- Boots: soles have tread? Uppers intact? Laces secure? Green triangle CSA tag visible?
- High-vis vest: fluorescent colour bright? Reflective tape intact? No tears?
- Gloves: correct type for today's task? No tears, holes, or wear-through?
- Task-specific PPE: hearing protection, respirator (fit test current?), face shield, fall protection as required?
- All PPE fits properly and does not interfere with other protective equipment?
Report any damaged or defective PPE to your supervisor immediately. HCMI will replace damaged PPE at no cost to the worker. Never use damaged PPE or modify PPE in any way not approved by the manufacturer.
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