Dr Steve Hankin, Director of Analytical Division at the
Institute of Occupational Medicine in Edinburgh, UK, explores PPE’s place in the protection of workers from health and safety risks.
Personal Protective Equipment (PPE) is equipment that is intended to protect the user against health or safety risks at work where such risks cannot be adequately controlled in other ways. PPE has its rightful place in the Hierarchy of Control and it is widely understood that PPE should only be used as a last resort. PPE encompasses a variety of items such as gloves, eye protection, protective suits, high-visibility clothing, safety footwear, safety harnesses amongst numerous other items.
To help users of PPE have confidence in its effectiveness there are fundamental common sense principles that manufacturers and the independent testing and certification process give thorough consideration to in the development and certification of PPE. The item needs to protect the wearer from the risks and take account of the environmental conditions where the task is taking place. Using PPE must not increase the overall level of risk or add new risks, for example by making communication more difficult. It needs to fit or be able to be adjusted to fit the wearer correctly, and be suitable for the needs of the job and the demands the work places on the wearer. The length of time the PPE needs to be worn, the physical effort required to do the job and the requirements for visibility and communication are all important factors and these are key aspects considered in various Standards-based testing of the performance of PPE.
When testing of PPE is done in compliance with a Standard, the testing requirements are often highly specified and range from the design of testing equipment, the number of items to be tested, the test conditions, through to the format of test results. National and International Standards provide specifications for different types of PPE and their testing requirements, such as chemical resistance (including chemical penetration and permeation), biological resistance testing (including penetration, antimicrobial and antibacterial efficacy), and impact protection, to name but a few.
When certified, CE marking symbolises the conformity of the product imposed on the manufacturer. When affixed to a product, the symbol indicates that the product conforms to all applicable provisions and appropriate conformity assessment procedures. As part of gaining the CE certification, an EC declaration of conformity and technical documentation are prepared and are made available by those placing the product on the market.
In the UK, PPE is currently governed by the Personal Protective Equipment Regulations 2002 (SI 2002 No 1144) which implement into UK law the provisions of European Council Directive 89/686/EEC. The Directive states that before selecting any PPE a basic assessment must be made to identify and evaluate the risk. Where possible, the risk must be reduced or eliminated by a modification of workplace practice. This option is always to be preferred to the use of PPE.
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The employer must inform their workers of the risks in the workplace, supply appropriate and correctly fitting PPE which complies with EU standards, and give adequate instruction in its use. They should further ensure that the PPE is used only for the purpose intended by the manufacturer, and in accordance with the manufacturer’s instructions. The employer is required to:
1. Audit workplace hazards and assess the level of risk to employees.
2. Define the properties necessary in the PPE to protect the employees.
3. Ensure that all PPE used in the workplace conform to the PPE Directive.
4. Compare the merits of the various types of protection available.
5. Keep full records of assessments and reasons for selecting a particular type of PPE.
If the risk should alter in any way, for instance by the introduction of a new chemical or industrial process, the assessment must be repeated. Member States are required to introduce written rules for workplace situations in which the use of PPE shall be considered compulsory.
The most recent development in the world of PPE is that the aforementioned European Directive has been reviewed and revised in order to reflect current technologies and processes for developing and bringing PPE to the market. PPE across Europe is now governed by the PPE Regulation (EU) 2016/425, adopted on the 12th February 2016, which starts a two-year transition period for Member States and Notified Bodies to prepare for the introduction of the new Regulation, which by legal definition, will not have to be transposed into each Member State’s national law (similar to REACH for chemicals management across Europe). Acknowledging changes in the Regulation is important for the PPE industry (manufacturers, distributors, test- laboratories and Notified Bodies) to ensure they continue to meet their regulatory compliance requirements.
In summary, PPE has its place in the protection of workers from health and safety risks, and an established structure of regulation and governance through Standards-based testing is designed to give users of PPE assurance that best practice and certification underpins its reliability and effectiveness. However, PPE will never be effective in protecting against health and safety risks unless PPE is
• properly assessed before use to make sure it is fit for purpose;
• maintained and stored properly; • provided with instructions on how to use it safely; • used correctly.
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