FEATURE PPE
or irreversible health problems. Each must meet the requirements of conformity assessment modules before being made available for purchase. There have been some key changes with
regard to where items fall within the categories. Protection against harmful noise and drowning, for example, have been transferred from Category 2 to Category 3, meaning equipment needs to undergo the most stringent conformity assessment process, combining EU type examinations with continued surveillance. On this matter, EU type examination certificates for Categories 2 and 3 will show the date of expiry – a maximum of five years or the last renewal. All PPE must also now come with a
PPE REGULATION 2016/425 what does it mean for you?
Sangeeta Aeri, technical manager at Supertouch, looks at the implications of the new Regulation for specifiers and purchasers of personal protective equipment (PPE) in the UK
arch of this year saw the European Parliament approve the new European PPE Regulation 2016/425, superseding the previous PPE Directive 89/686/EEC and all amended directives. Following consultation with the market, the new regulations have been introduced for a number of reasons. Firstly, there had been concerns over the consistency and adequacy of the coverage and conformity of assessments in some product areas. Secondly, the issue of market surveillance needed to be addressed – not least in light of evidence around the entry of substandard products into the UK PPE market. The goal of the new Regulation is
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therefore accountability throughout the supply chain, alongside enhanced innovation and, the removal of inferior products from the marketplace. The change from a Directive to a
Regulation is key. While the Directive set out goals for countries to achieve, the Regulation represents a legally binding Act which has to be implemented completely in all EU member countries. In the UK, this means that the PPE Regulations 2002 – the vehicle through which the PPE Directive was implemented – have been superseded. However, the Personal Protective Equipment (PPE) at Work Regulations 1992, covering the suitability, provision,
14 AUTUMN 2016 | INDUSTRIAL COMPLIANCE
maintenance, instruction and use of PPE, remain in place. The only change being that PPE must now be selected in line with the new EU Regulation.
KEY CHANGES
The first big difference is that the new Regulation covers the entire supply chain, not just manufacturers. All ‘economic operators’ – effectively anyone involved in PPE production, supply or distribution – have to ensure products meet the requirements. This includes areas such as product approval, conformity, and the maintenance of technical files and records. The definition of PPE has also been
altered. It is now defined as: ‘equipment designed and manufactured to be worn or held by a person for protection against one or more risks to that person’s health or safety’. This means it now also covers PPE designed for domestic use to counter heat, such as oven gloves. As with the Directive, the Regulation breaks down equipment into various categories – Category 1: Simple PPE, which protects people from minimal risks; Category 2: Intermediate PPE, covering anything not dealt with by Categories 1 or 3; and Category 3: Complex PPE, aimed at safeguarding wearers against risks which may cause very serious consequences, such as death
Declaration of Conformity, which can be issued by the manufacturer, or the individual selling the product in the EU if the manufacturer is based elsewhere. In this instance, the importer or distributor effectively becomes liable for the manufacturer’s full obligations. A proviso to this is that a simplified
Declaration of Conformity can be supplied in the form of a single sentence with a web link to the address where the full Declaration can be found.
WHAT SHOULD SPECIFIERS DO? The key for specifiers is to take steps to ensure that providers comply with the new Regulation. The best advice is always to purchase from a trusted source, ideally a member of the British Safety Industry Federation (BSIF) Registered Safety Supplier Scheme. Suppliers should be able to provide a
Declaration of Conformity demonstrating original certification for a purchase. Suppliers should also be asked to define their process for sample testing, to guarantee their products continue to meet the specified standards. Finally, specifiers should request that providers define their factory quality assurance process to ensure that equipment is being produced in line with its original certification. Certificates featuring an expiry date will
remain valid until that date. Where no expiry date is given, the certificate will expire seven years after the Regulation comes into force. If new products and certificates are issued, their validity must not exceed five years. The heart of the new Regulation
revolves around protecting workers. Specifiers and purchasers need to maintain vigilance in order to ensure products meet the required standards and that compliance is achieved.
Supertouch
www.supertouch.com T: 0121 565 5066
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