Published: 30th May 2014
Introduction to Personal Protective Equipment
As the Chairman of British Standards Institute Committee PH/3 Protective Clothing, including hand protection/gloves, I am appointed to lead for the UK on all protective clothing in Europe on CEN Technical Committee 162, where Working Group 8 deals with gloves, and internationally on International Standards Organization (ISO) where WG8 addresses gloves.
Standards and standardisation – protocols and procedures
The building of trust with EU and ISO delegates is important, and can and does lead to progress when writing new or revising existing standards.
It might not be clearly understood, but no EU Member State can have a conflicting PPE standard where there is in place an EN standard.
Where there is no EU (EN) standard, then Member States are permitted to have their own – but when and if an EN is developed, balloted and agreed, they have (by EU Law) to withdraw that national standard.
Standardisation issues are fraught with complications, not least when you have a room full of manufacturers, often competing in the same market place. They are hardly likely to agree to any new draft standard or test method that directly impacts their market share adversely.
Still with me? Then let’s continue.
The whole arena of PPE, its selection, use, maintenance and replacement can be quite a complex area for employers who have little time to study and absorb such matters. Unfortunately for them, probably fortunate for the end users, ignorance of the law is not a sound defence.
In this article, I will touch briefly on the UK PPE at Work Regulations 1992 (as amended), particularly the procurement of PPE – in this case protective gloves, the important Regulations therein and a guide for employers to make decision making somewhat easier.
These Regulations stem from European Union Directives 89/EEC/686 PPE Products Directive, but mainly 89/EEC/656 PPE Use Directive.
These Directives complete a suite of EU Directives addressing health and safety, with an onus on a tripartite system between the employers, end users/employees, EU Member State Nominated Test Houses (laboratories), independent consultants (e.g. myself) and national government organisations.
Health and safety – PPE directives/national regulations
We read much in the popular press with regard to health and safety, often portrayed in a very negative way.
If people would only take a little time to understand legislation and regulations, they would find they are based in the main on a past history of problems, including fatalities and injuries.
It is also the case that those who do not understand the legal position add unnecessary and totally unwarranted requirements, purporting this is under health and safety legislation.
I believe strongly that those health and safety consultants/advisors who have no work/life experience do not have the confidence to address health and safety in a common sense manner.
The attitude should be CAN DO but safely, not CANNOT do.
If I give an example, I am presently providing top down health and safety advice to the Bloodhound Project. This is a UK attempt at the world land speed record, anticipated speed 1,000 mph. The Health and Safety Executive (HSE) themselves are using this as a case study to demonstrate how ‘supposed’ hazardous activities can be managed safely.
It is a requirement of legislation/regulations to consult with users, usually via their trade union, or if there is no trade union the employer will appoint health and safety coordinators.
It should be borne in mind that consultation with the users would provide valuable feedback and a level of confidence in the PPE (gloves) subsequently procured.
It is not sensible management to ignore the views of the users, as they are the ones who will need to wear the gloves.
Obviously we recognise the hazards and the risks emanating from them – it is the project’s clear intention to succeed, and with no incidents or injuries.
Those working on the project – from the entrepreneur Richard Noble to the engineers – are all committed and experts, but can at times need a little reminder that safety is paramount, which in the end it always is.
Ignorance is no defence in the eyes of the law, so it is better to be wise before rather than after an incident.
The recent introduction of the Corporate Killing Legislation now clearly identifies those at the very top of the company as being responsible for health and safety. This would include the provision of the correct PPE for their employees.
Do my employees require protective gloves?
Not a difficult question, is it?
Clearly for employers or their representatives who have received no instruction, information or training pertaining to the topic, then the PPE Regulations – and any regulations – can appear complex and complicated.
The Health and Safety etc Act 1974 is somewhat legalistic in its writing – note the inclusion of ‘etc’. Few people realise this is contained within the title and can capture a whole raft of issues e.g. stress, that the lay person would never believe were addressed.
What type of glove, or maybe more than one, do the identified hazards below require protection from?
Chemicals Abrasion Electricity Electric arc Heat and flame Biological Radiation
Regulation 6 – Assessment of personal protective equipment
1. Before choosing any personal protective equipment, which by virtue of Regulation 4 he/she is required to ensure is provided, an employer or self employed person shall ensure that an assessment is made to determine whether the personal protective equipment will be suitable.
2. The assessment required by paragraph (1) shall include:
a. An assessment of any risk or risks to health or safety, which have not been avoided by other means
b. The definition of the characteristics which personal protective equipment must have in order to be effective against the risks referred to in subparagraph (a) of this paragraph, taking into account any risks which the equipment itself may create
c. Comparison of the characteristics of the personal protective equipment available with the characteristics referred to in subparagraph (b) of this paragraph
d. An assessment as to whether the personal protective equipment is compatible with other personal protective equipment which is in use, and which an employee would be required to wear simultaneously (a)
PPE application in real life
The UK PPE at Work Regulations 1992 is written in a clear, concise and simple way and are therefore relatively easy to understand.
We start by asking ourselves as the employer, what are the hazards, if any, associated with my employees’ working environment? Once identified, what are the risks emanating from the hazards?
If the hazard is a tiger, then the risk is somewhat controlled if the tiger is kept in a secure cage, isn’t it? It is unless you have to enter the cage to feed or clean it out, or take it for walkies!
So we then introduce control measures to limit the risks from the hazard.
The PPE at Work Regulations are quite explicit, in that PPE is a last resort and solutions such as engineering solutions need to be considered before the decision is taken to provide PPE.
Any PPE provided to employees has to be provided free of charge.
Most people do not relish wearing gloves – they can make the hands sweat, certainly limit dexterity.
If these facts are not understood, considered and explained to employees who are required to work with equipment and/or tools, then the problem, including acceptance that workers have to wear PPE is exacerbated.
The balance between protection and comfort is one that we in the UK (BSI), Europe (CEN) and Internationally (ISO) standardisation field continually grapple with.
We are now working with Sweating Torso test facilities in an attempt to write a test method, which it is hoped will be able to rank PPE – gloves’ – performance, glove versus glove.
It should always be remembered, that it is not comfortable to wear PPE, and I am attempting to get ergonomists, for example, to understand this and move away from the term ‘comfort’.
Compatibility of PPE is crucial. No point issuing a glove if it cannot be worn with the jacket/tunic, as this would defeat the intention of providing the glove.
Gloves are renowned for allowing substances, chemicals, or burning embers into the hand via the cuff, so it is essential that when PPE is being considered, we refer to the PPE at Work Regulations.
Regulation 5 – Compatibility of personal protective equipment
1. Every employer shall ensure that where the presence of more than one risk to health or safety makes it necessary for his/her employee to wear or use simultaneously more than one item of personal protective equipment, such equipment is compatible and continues to be effective against the risk or risks in question.
2. Every self employed person shall ensure that where the presence of more than one risk to health or safety makes it necessary for him/her to wear or use simultaneously more than one item of personal protective equipment, such equipment is compatible and continues to be effective against the risk or risks in question.
Any final decision must take into account the range of PPE – including gloves – that an end user will be required to wear.
Role of manufacturer
It can be seen clearly from the PPE Regulations that the employer is required to conduct the PPE Assessment. Often the manufacturer associated with the company can and does provide information – this can be both useful and informative. What the glove manufacturer cannot do is conduct the PPE Assessment for the employer.
After all, no manufacturer is going to advise you to purchase from a competitor, so employers need to be savvy as to what information they require, and weigh this up against that which is supplied by any manufacturer.
It has to be stated that those PPE manufacturers who sit on BSI, CEN and/or ISO committees are demonstrating a level of commitment which needs to be recognised. After all, there are costs associated with travel and hotels when attending CEN and ISO meetings. If, for example, the matter under discussion has been voted to become an EN and ISO standard, these meetings can and will be in Brazil, New Zealand, USA, Australia and many also in the EU Member States.
Those manufacturers who are aware of this are equally astute to recognise the benefits of hosting such meetings, where up to 70 representatives from around the world can be attending.
If the company ‘bean counter’ needs persuading, then ask him/her how much it would cost to send a representative to all those countries attending, with travel, hotels and subsistence – not a difficult decision to make, is it?
I can assure you many ‘bean counters’ don’t get this, nor, I might add, do they get the business.
It is always intended that PPE committees are balanced, with users, manufacturers, test houses and independent consultants. Sadly representation from the users, either through their trade union or otherwise, is very poor – while the representation from manufacturers can be high.
In high risk industries, where the hazards and risks can be of significant importance, it is difficult to understand why the users are not better represented.
The answer probably lies in the costs of attending such meetings – after all, the manufacturers will pass on their costs, whereas trade unions, for instance, do not have this option.
I have argued with the EU Commission representatives that this matter needs to be addressed.
These are a good source of information for the employer and, indeed, a route to be nominated onto a BSI PPE committee.
It is a requirement that BSI representatives to CEN and/or ISO committees have to be a member of the BSI Mirror Committee, who indeed themselves nominate the delegates to these committees.
They often have mini Mirror Committees on such things as test methods, and influence, mostly in a positive way, the drafting of new, or revision of existing standards.
Where to now?
At the present time, we have a Joint Working Group (JWG) of CEN and ISO delegates considering the ‘permeation’ aspects of PPE. This committee is looking specifically into gloves and footwear.
Consideration of such matters is the subject of intense debate, with some arguing that ‘breakthrough time’ is itself a problem, as the end user would then be contaminated at that point, possibly even injured, as opposed to permeation figures which would allow an assessment of the hazards and risks over a lengthy period.
There are ongoing discussions on this aspect of PPE.
Let me finish this section by giving an example as to how employers’ priorities change – including in the public sector.
Immediately following 9-11, there was a mad dash to introduce or amend numerous standards, be these respiratory, glove or clothing related, and introduce an element of Chemical, Biological, Radiological and Nuclear (CBRN) protection.
This has now somewhat diminished in importance as small communities and the respective manufacturers now consider it unlikely that there could be any ‘terrorist attack’.
Might it not be better to revise the perceived risk to one of ‘Whole hazard approach’?
After all, CBRN does not mean ‘terrorist attack’. It covers a far wider number of hazards and risks, such as pollution of rivers and water courses, SARS epidemics, chemical releases, fires where chemicals are involved, causing toxic plumes… nuclear incidents.
We are advised to expect only one nuclear power station incident every 10,000 years – I calculate we have had up to a dozen in the last 30 years, so no more for the life of the planet earth?
What gloves, how and why?
1. Every employer should conduct a PPE Assessment.
The hazards and risks will generally have been identified when carrying out sensible health and safety generic risk assessments (GRA).
2. Discuss with users and consider wherever possible utilising their input – this leads to confidence in the PPE.
3. Keep an audit trail of actions.
In the event of the HSE calling unannounced, or after an injury, surely they will ask “Why did you buy those gloves?”
If an employer has not identified the hazards and risks as required under the PPE at Work Regulations, how on earth can they know what type of glove is required?
My final thoughts are that here we are 40 years after the Health, Safety and Welfare etc Act 1974 was introduced; 25 years after the EU PPE Directive 89/EEC/656; and 22 years since the UK transposition into the PPE at Work Regulations 1992 – and I am writing about how these Regulations work.
I fear I have to inform you that the EU PPE Directive 686 (Products Directive) has been under revision by the Commission for the last seven to eight years.
We have a new draft in 2014, but due to the EU Parliamentary Elections this year there will be little progress until after the elections and a 12 month transition period. So I predict 2016/17 for the new Directive.
I am available to offer advice, conduct training on all things CEN/ISO standardisation, with a view to making it easier to understand and more importantly, to protect your company from litigation.
Published: 30th May 2014 in Health and Safety International