FEATURE PPE
Highlighting CE mark weaknesses
Neil Hewitt, divisional director Quality and Technical Standards at Arco discusses the issues of non-compliant, CE marked PPE, and the steps industry can take to minimise the risk of these products entering the European market
D
espite Personal Protective Equipment (PPE) having the required EC type
approval and CE mark, recent tests have indicated that some of the products that you would assume to be safe, may not be fit for purpose. This has resulted in the British Safety Industry Federation (BSIF) calling on all those in the industry to ensure their supply chain routes are fully aligned to provide safe, legal and fit for purpose PPE. In February of this year, the new PPE
regulation was adopted by the European Parliament, reclassifying some products, introducing a five year limit on CE certificates and clearly identifying the obligations of all economic operators in the supply chain – including manufacturers, distributors and importers. It also clearly defines that an importer or distributor who markets a product in Europe under their own name, brand or trademark becomes liable for the full manufacturer’s obligations. Although this will be a good step forward for the industry, it could take unitl 2018 for these changes to be implemented, and we need to act now. The importance of robust legislation to protect workers is paramount. The document that currently underpins the legislation is the PPE Directive 89/686/EEC. Its role is to ensure that suppliers of PPE follow the correct approval procedures before placing the product on the market. Category two and three items of PPE must follow an EC type approval and carry the ‘CE mark’ to prove certification. Whereas category one, or minimal risk PPE, are self certified and CE marked by the manufacturer after they assess the product against the essential health and safety requirements of the PPE directive. However, worrying data has emerged that with the growth of the industry, comes the
16 AUTUMN 2016 | INDUSTRIAL COMPLIANCE
increased risk of CE marked products that do not conform, which could result in an individual not being adequately protected during an accident.
INADEQUATE PPE Procedural weaknesses within the EC type approval and CE marking process allows less reputable manufacturers or importers to gain CE certification for products they wish to market and then subsequently make changes to the product. These changes could impact on the product’s safety performance as further testing may not be conducted because the CE certificate is already available. Although, manufacturers of category three PPE are required to have a third party monitoring process in place for the actual product or a quality management system, there is no third party production monitoring process for category one or two PPE. It is up to the manufacturer to ensure the product continues to conform to the standards. An example of these failures came to
light when Arco performed a number of tests on safety footwear toecaps. Traditionally, toe caps were made from steel to ensure toes were not crushed in the event of an accident, but non-metallic materials have entered the marketplace, offering lightweight design and the ability to minimise disruption in security areas. Arco carried out product assurance
compression testing, in its UKAS and SATRA independently accredited laboratory. It became apparent that the safety footwear using some injection moulded plastic toe caps in their construction performed significantly worse than the fibreglass composite toe caps during compression testing. However, the use of thermoplastic toe caps in safety footwear
Compression testing of toe caps
construction is not immediately evident, with purchasers relying on the CE mark being accurate. Arco does not allow the use of sub- standard thermoplastic toe caps in the construction of its own brand products. It has also highlighted the issue to all proprietary footwear brands in the Arco catalogue and has requested confirmation of the type of toe cap used within footwear. Arco is a member of the BSIF Registered Safety Suppliers Scheme (RSSS). Companies displaying the scheme's logo have signed a binding declaration that the safety equipment they offer meets the appropriate standards, fully complies with the PPE regulations and is appropriately CE marked. Identifying true product compliance is difficult for the user so the responsibility falls to the manufacturer, who may not have the resources in place to ensure regular testing. Anyone who has concerns over the safety of the equipment they are being supplied should follow these steps: • Ask your suppliers for a declaration of conformity that shows original certification for the PPE you are purchasing. • Ask your suppliers to define their process for sample testing to ensure safety products continue to meet the required standards.
• Ensure your suppliers are members of the BSIF Registered Safety Supplier Scheme. • Ask your suppliers to define their process of quality assurance at the manufacturing facility to ensure the products are being manufactured as they were originally certified. • Always buy from a trusted source. Arco continues to lead the charge,
working with the BSIF, to raise the standards of compliance in the UK. As an industry, it is important to work together to ensure that measures are in place to ensure that the products supplied are capable of doing the job they are intended for, while purchasers need to remain vigilant to safeguard their workforce.
Arco
www.arco.co.uk T: 01482 222 522
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