Procuring Personal Protective Equipment (PPE) can be a complex, challenging process – particularly given the number of substandard products that have been flooding the market. Alan Murray, CEO of the British Safety Industry Federation (BSIF), explains how you can ensure that you get above-the-neck PPE that is safe and effective.
For those operating in hazardous work environments, effective Personal Protective Equipment (PPE) is essential. Today, products that protect people from head to toe are widely available, with further innovations to improve safety and comfort being developed at pace. However, selecting appropriate products for your workforce presents significant challenges. You need to know whether the PPE you buy meets required standards and will perform as it claims. You must also be confident that your suppliers are able to comply with the regulations in place in your country of residence.
Here, we look in more detail at the pitfalls of PPE procurement – focusing primarily on above-the-neck protection – and what you can do to gain more control over this process.
Standards and Compliance
Why are there substandard and non-compliant products on the market?
Not all PPE is created equal. For example, in the UK and the EU, the law states that PPE must be correctly tested and certified to comply with the Personal Protective Equipment Regulations 2018. Unfortunately, not every PPE supplier follows the rules. There is a general lack of official market surveillance and enforcement across the UK and Europe that means it can be difficult to distinguish responsible suppliers from less responsible ones. This has led to an increase in the number of non-approved and substandard products being sold.
The unprecedented demand for PPE during the COVID pandemic has also led to an increase in suppliers, resulting in a greater number of products that – due to technical defects – might put users’ health and safety at risk.
Indeed, reports suggesting hundreds of millions of pounds were wasted on poor quality and unusable PPE during the pandemic highlighted just how easily substandard products can find their way onto the market.
Employers must ensure that they only provide fully compliant PPE for their workforce. The failure to do so means contravening safety legislation. In the UK, where BSIF operates, items are available that claim UKCA and/or CE approvals but, in reality, they have not all been appropriately certified. In our experience, these products often do not perform as they should, putting lives at risk and, in doing so, exposing businesses and individuals to prosecution for failing to protect staff.
“millions of pounds were wasted on poor quality and unusable PPE during the pandemic”
What are the problems around above-the-neck PPE?
Above-the-neck PPE encompasses products to protect the ears, eyes, neck and head. Eye protection includes safety spectacles, goggles, face screens, face shields and visors to safeguard against chemical or metal splash, dust, projectiles, gas and vapour or radiation.
Hazards to the head and neck can range from chemical drips or splash to climate or extreme temperatures, as well as falling or flying objects, the risk of banging the head, and hair getting tangled in machinery. PPE and safety equipment solutions include safety helmets, bump caps, hairnets and neck covers. Specially designed eye or hearing protection can also be integrated into some safety helmets.
Hazards to hearing from noise, meanwhile, come from a combination of sound level and duration of exposure. Earplugs, earmuffs or semi-insert/canal caps that reduce noise to an acceptable level, while allowing for safety and communication, can help to mitigate these risks.
However, recent research provides an insight into the scale of the problem regarding substandard and non-compliant above-the-neck PPE. The pandemic and resultant PPE shortage has only served to exacerbate this situation.
According to the European Commission, finding safe protective materials has been one of the biggest challenges during the pandemic. It therefore launched a coordinated activity on the safety of products (CASP Corona2020) to assess the risk these products pose towards users’ health and safety. There has been a particular focus on PPE face masks, hand sanitisers and PPE single-use gloves. In total, 31 authorities from 22 EU/EEA countries participated in this joint project.
The test specifications for face masks were prepared taking reference from the relevant European PPE standards. They focused on measuring the total inward leakage and filter penetration as well as on verifying the labelling as per Regulation (EU) 2016/425.
Of the 74 PPE face masks tested during the project, 85 per cent did not meet the EU health and safety requirements established in the project testing plan. The main issues among the samples tested were total inward leakage requirements and labelling. Most of the face masks failed to provide the necessary fit, which directly led to inadequate protection from outside air coming into contact with the user’s respiratory system. Also, many face masks had inadequate labelling, which prevents consumers from being certain that they are selecting an appropriately approved personal protection device. The absence of proper information such as the CE mark and/or the corresponding Notified Body number was the most prevalent issue, according to the report, suggesting that the products had not been correctly conformity assessed.
Since the start of the pandemic and the PPE shortage crisis, the Health and Safety Executive – the UK’s regulatory body – has also seen FFP masks with ear loops being placed on the UK market, despite the use of such products being outlawed in the NHS from as far back as September 2020.
Earlier this year, it issued a safety notice on the use of masks and respirators that rely on ear loops after new research had revealed that such products do not protect people adequately when used as tight-fitting respiratory protective equipment (RPE). This includes those provided with clips, ‘snuggers’ or other means of tightening the fit of the mask to hold the respirator/mask in place. The safety notice covers ear-looped masks and respirators that are CE or UKCA marked and applies in all work-related situations in the UK. This is because a tight seal to the wearers’ face is unachievable in the majority of cases.
Therefore, HSE recommends that ear-looped masks and respirators should not be sold or used in workplace settings where tight-fitting RPE is required. To provide adequate protection for individual wearers, all tight-fitting RPE should be fit-tested by a competent assessor as part of the selection process.
Earlier this year, the BSIF conducted its own testing and analysis of above-the-neck PPE that had been manufactured by non-Registered BSIF Suppliers. From 51 tests of PPE used or worn above the neck, 41 failed. They included RPE/RPD, head protection, eye protection and ear protection. Only ten items met all the claims of protection made by the manufacturer while also carrying the correct markings and documentation.
The UK has one of the best combined health and safety records in the world, with the access to high-quality PPE and safety equipment playing an important role in supporting this record. As such, these results are surprising and shocking to many.
So how can you avoid falling foul of such products? To start with, it may be helpful to examine two examples of non-compliant products more closely, so you know what to look for in practice.
Sand blasting hood with safety helmet
This item was purchased online from an SME in the UK. While they did not manufacture the helmet themselves, they did produce the outer cotton and leather hood with a visor.
The hood is attached to the helmet using two rivets that have been fixed to the brim and centre-top of the safety helmet. This act in itself would have made the product non-compliant, as any combination of PPE has to be tested and approved as an ensemble.
The helmet was tested for impact protection according to BS EN 397:2001, which involves a weighted ball being dropped from a height onto the helmet. The amount of force transferred from the outside of the helmet to the inside – where the user’s head is – should not be above five Newtons. In the case of this helmet, the conducted force was 16.53 Newtons – over three times the maximum allowable.
In addition to the above, the hood itself was not marked with any of the required information. There was no CE or UKCA mark to indicate it had been assessed before the item was placed on the market, no details of who the manufacturer was, no details of what protection the hood offered, and no identifying information such as a product name or code.
The product was also supplied without the required user instructions – the PPE Regulation obligates all manufacturers to provide detailed instructions on how to care, store, use and maintain PPE. There was no Declaration of Conformity either. This is the manufacturer’s assurance to the market that the product has been suitably assessed and (where relevant) certified. Both are known as ‘Accompanying Documentation’, although it is permissible to have the Declaration available to download via a link printed on the user instructions.
Full face respirator
This product was also purchased online following information from a BSIF member who had seen it in use on a construction site.
The product is a copy of one created by a well-known global brand in respiratory equipment. However, it was clear that it had not undergone the same exhaustive testing and certification process. The mask does not carry any of the required markings – CE/UKCA, BS EN Standard – that apply or the manufacturer’s details.
The filters provided for use with the mask do not carry the correct CE/UKCA information. Nor do they feature the number of the notified or approved body that is responsible for the ongoing assessment of the product on an annual basis. The filters carry the numbers of three EN Standards, which is incorrect as it should only be approved to one of the three.
The product was provided without any enquiry to the buyer as to what it would be used for and whether the hazards faced would be particulate- or gas-based, yet the filters provided are specifically designed for protection against organic gases. If this was used by someone in an environment such as a building site to help protect against the effects of silica dust in the atmosphere, it would not provide any protection to the user’s respiratory system.
User instructions were provided with the mask, but the language used both in format and grammar indicate that it has been badly translated into English. The Declaration of Conformity was not provided and there was no link provided on the user instructions.
Both case studies provide an insight into what to look for in a product and what can go wrong should substandard and non-compliant above-the-neck PPE be procured and used in hazardous work conditions.
“the European Commission has published recommendations for procuring PPE face masks”
What can you do about it?
Following the testing and analysis of its coordinated activity on the safety of products (CASP Corona2020), the European Commission has published recommendations and tips to end consumers for procuring PPE face masks. These recommendations have been created in agreement with participating market surveillance authorities (MSAs) from the European Union (EU) and European Economic Area (EEA). They are as follows:
“CE marking followed by a 4-digit number is essential. Consumers must check the CE marking on the package and on the mask itself upon purchasing. A 4-digit number specifies the Notified Body indicating that the quality and safety of the chosen mask meet European requirements). Fitting is essential. Consumers must be sure that the mask fully covers their nose, mouth and chin without leaving gaps. A nose wire is crucial in preventing air from leaking in/out through the top of the mask. The fabric is of the utmost importance. Masks that are made of unbreathable fabric should be avoided.”
The Registered Safety Supplier scheme
As a buyer or specifier of PPE, you are responsible for ensuring that the product is properly certified and approved. You could undertake your own checks but few end users have the time, resources and knowledge to verify the claims of suppliers. The BSIF offers the Registered Safety Supplier (RSS) verification scheme to help.
Companies displaying the scheme’s shield have signed a binding declaration that the PPE and safety equipment they offer meets the correct standards, fully complies
with the regulations, and is UKCA- and/or CE-marked. This means that, by using a Registered Safety Supplier, you can be confident you will receive genuine products that are fit for purpose as well as genuine information and guidance.
Benefits of specifying a Registered Safety Supplier
Verifying that your supplier is a Registered Safety Supplier gives you reassurance that the necessary checks have been performed and ensures that your supplier is committed to high standards. Members of the RSS scheme must fulfil the following criteria in order to gain admittance and carry the shield: sell only certified PPE; meet all responsibilities of the PPE Regulations; submit their products for random independent performance testing; train public-facing staff in the BSIF’s Safe Supply Course (a publicly recognised qualification to educate those selling PPE and safety products); maintain a quality policy; hold necessary authorisation for service provision; have the capability to carry out any necessary product recalls; and trade honestly and ethically. All Registered Safety Suppliers are audited to confirm compliance with the scheme’s requirements. A full list of registered suppliers is available to view at: https://www.bsif.co.uk/rsss/
CHECK – SELECT – PROTECT
We at the British Safety Industry Federation are urging PPE buyers and end users to follow this simple three-step process when buying PPE. Doing so will ensure that the products you buy are fit for purpose:
1. CHECK your supplier is BSIF Registered. BSIF audited suppliers are compliant, competent and trustworthy.
2. SELECT appropriate, certified and approved products. Registered Safety Suppliers can support the product selection process through their competence, capability and knowledge.
3. PROTECT your people, your most precious asset, and help your business to thrive.
Specify the RSS scheme today
The importance of conformity assessment is critical for maintaining users’ safety – along with the effective vigilance of consumers to recognise products that conform to European CE marking and conformity assessment requirements.
The RSS scheme provides the reassurances you need on safety as well as a host of other benefits. You don’t need to worry about the consequences of product recall in terms of time, money and damage to your company’s reputation, for example.
Anyone can sell safety, but you shouldn’t buy safety from just anyone –always specify the shield.
To find out more about the benefits of specifying a BSIF-registered supplier in your supply chain, contact the BSIF today at [email protected] or by calling (0)1442 248744. For a full list of Registered Safety Suppliers, visit: www.registeredsafetysupplierscheme.co.uk