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The Journal for Employee Protection
The Journal for Employee Protection
by Tony Potter
The provision and use of Personal Protective Equipment (PPE) has been subject of much debate over the years both in the UK and beyond. Up until recent times, employers would simply state that you must have your own safety boots and overall before starting work.
This is no longer the case with changes in recent years to legislation ensuring that PPE is provided by the employer free of charge to the worker. This is obviously the case in the UK and most of Europe however the same may not go for all workers in areas of the world not so well regulated. For the purpose of this article we will focus on UK legislation as a guide to what is an acceptable level of provision of PPE and in particular safety Footwear. Before we discuss the various types of safety footwear available on the market it is important that we review the legislation that drives the provision of, training for and the maintenance of PPE in the workplace today.
The following text pertains to UK legislation and is quoted widely within my company (along with the pertinent UAE / Local Legislation) as one of the drivers for compliance with H&S requirements as set out in the OH&S MS.
The Management of Health and Safety at Work Regulations 1999 require employers to identify and assess risks to health and safety in order to determine appropriate means of reducing those risks to an acceptable level. The use of PPE should always be regarded as a last resort but, where other control measures are not appropriate or sufficient; PPE must be provided and used.
General requirements for the provision and use of PPE are contained in the Personal Protective Equipment at Work Regulations 1992.
The following paragraphs relate to the requirements of the Personal Protective Equipment at Work Regulations 1992 . However, the same principles will need to be applied to the provision and use of PPE required under other legislation.
Where a risk cannot adequately be controlled by other means, employers and the self employed have duties to provide “suitable” PPE. Assessments of the parts of the body endangered by the risk, and the level of that risk, must be carried out in order to determine the type of PPE which is needed and to estimate its required performance.
To be “suitable”, the PPE must:
• (a) Be assessed as appropriate both to the risk involved and to the working conditions
• (b) Be selected to take account of factors such as the length of time it needs to be worn and the need to see or hear
• (c) Be capable of fitting the wearer correctly
• (d) Be compatible with other PPE which may need to be worn (e.g. boilersuits, gaiters for protection from sparks)
• (e) Carry a “CE” mark if manufactured after 30 June 1995. It is interesting to note that prior to that date, PPE had to carry a “CE” mark, be approved by the HSE, or conform to a standard approved by the HSE. Approved PPE already in use before 30 June 1995 was allowed to continue in use provide the requirements in (a) to (d) above are met
Comfort and convenience to the wearer are also factors which should be considered: employees should be consulted on such matters and be given a degree of choice, where appropriate, before final selection is made. Once selection has been made, further advice may be necessary to ensure that the equipment can provide the protection needed for the particular application.
In industry it is common practice to offer the worker a choice of PPE as long as it has been passed as being appropriate for the task. Employee consultation is an important factor in the selection process and goes a long way in ensuring that the correct PPE is chosen, used and maintained properly.
PPE should be examined in accordance with manufacturers’ recommendations, by properly trained persons before being issued. The wearer should also inspect it before use to ensure that it is clean and not defective.
Maintenance must be carried out in accordance with manufacturers’ inspections and schedules which will include where appropriate, examination, testing and record keeping.
Where equipment is used by more than one person, there must be arrangements for cleaning and disinfecting.
Where employees are issued with protective clothing and items such as safety helmets and goggles, suitable arrangements must be made for their storage when not in use. Consideration should be given to providing individual lockers in drying rooms so that employees can look after such equipment properly.
Items such as Respiratory Protective Equipment (RPE) and safety harnesses should be kept in a site store in the charge of a competent person.
Adequate information, instruction and training must be given on the wearing and use of PPE
Training should include such topics as:
• (a) The nature of the hazard
• (b) The source of the hazard
• (c) The effects of exposure to the hazard
• (d) The way in which the PPE functions
• (e) The way in which the PPE must be worn
• (f) Any limitations of the PPE
• (g) The way in which the PPE must be inspected and stored
• (h) The person to whom any defects or loss should be reported
Employers have a duty to take all reasonable steps to ensure the proper use of PPE. Adequate information, instruction training and supervision must be provided in the correct use and maintenance of the equipment.
Employees and the self-employed have duties to make full and proper use of PPE, to report any defect or loss and, where appropriate, to return it to stores after use.
There was a time when PPE regardless of its suitability would be issued in totally inappropriate circumstances to personnel. These personnel would often have no instruction in their correct use nor training in the maintenance of any measure to protect the equipment from damage.
Every working day accidents occur on worksites which result in both serious and minor foot injuries. Many of these accidents can be avoided by the wearing of boots or shoes having built-in steel toe-caps and steel mid soles.
In hazardous environments, it is necessary to minimise the risk of accidents to personnel by slipping and also to prevent faults and downtime caused by the discharge of static electricity. Therefore, the correct footwear is necessary in addition to the installed plant, floor areas and clothing.
Footwear is worn for many hours each day, and must offer safety (for people and processes) as well as comfort.
A risk assessment on a worksite will often establish the need for protective footwear. When carried out by competent persons, the risk assessment will almost certainly define the required footwear and furthermore state the particular standard that the footwear must conform to. In order for the risk assessment to be ‘suitable and sufficient’ the competent persons carrying out the assessment may use the guidance set out in this article.
It should be noted however that there are differences in the footwear for safety, protection and industry, which are designed according to the following standards both European and American:
Safety Footwear should conform to:
• EN 344 General Requirements
• EN 345 Specification for safety footwear
• EN 346 Specification for protective footwear
• EN 347 Specification for occupational footwear
Depending on the manufacturers locations you will find European (EN) or American (ASTMF) standards (which are equivalent in terms of requirements) and test methods on safety and working shoes for professional use.
General Requirements This standard defines the general requirements and test methods on safety shoes, protective shoes and working shoes for professional use.
It can only be used together with EN 345, EN 346 and EN 347 standard, which specify the shoes requirements according to specific risks levels.
This standard defines the basic and additional (optional) requirements on safety shoes for professional use.
These shoes include devices to protect the user against injuries caused by accidents liable to occur in the industrial environment for which the shoe has been designed, fitted with safety toe-cap intended to deliver a protection against impacts with an energy level equal to 200 joules.
Class 1: All materials except natural or synthetic polymers
S1 Basic properties and closed back, anti-static properties, heel energy absorption
S2 Like S1 and Waterproofed
S3 Like S2 and anti-puncture sole, studded sole
Class 2: Natural and synthetic polymers
S4 Basic properties and anti-static properties, heel energy absorption S5 Like S4 and anti-puncture sole, studded sole
This standard defines the requirements for protection afforded by Safety Shoes for professional use. There is also protection of the metatarsus and are resistant to the cuts.
These shoes are different from safety shoes because they have no protective toe-cap against impact and crushing.
O1 Basic properties and closed back, sole resistance to hydrocarbons, antistatic properties, heel energy absorption
O2 Like O1 and Waterproofed
O3 Like O2 and anti-puncture sole, studded sole
ASTM F 2413-05 provides test methods and performance standards for “Personal Protective Footwear” sold in the United States. You may also come across this footwear in areas of the Middle East, North Africa and South East Asia.
In order for Protective footwear to be in compliance with ASTM the following requirements must be undertaken:
“I” and “C” Markings – Impact and Compression Resistance
This is a test of a shoe’s capacity to protect the toe area of the foot against falling objects or heavy rolling objects such as a forklift. The toe area is protected by using protective toe cap construction, commonly referred to as “Steel Toes,” although some Iron Age/Knapp safety shoes use a Non-Metallic protective cap that is equally effective.
There are 2 levels of protection available for Impact (I) and Compression (C) resistance – Class 50 and 75. Class 75 is the highest and it is recommended for most applications.
I/75 = 75 ft. lbf (101.7 Joules)
I/50 = 50 ft. lbf (67.8 Joules)
C/75 = 2500 lbs (1100 Kg)*
C/50 = 1750 lbs (790 Kg)
*when a 50-pound (22 Kg) weight is dropped from eighteen inches (45 cm) onto the protective cap
Test Clearances after test for impact and compression:
– 0.500 inch (12.7mm)
“M” Marking – Metatarsal
Established standards for the protection of the upper foot (metatarsal bones) and toe areas. Designed to prevent or reduce injuries when the toe and metatarsal areas of the foot are exposed to “drop” hazards.
There are 2 levels of protection available for – Class 50 and 75.
Class 75 is the highest and it is recommended for most applications.
The impact energies (75 and 50) are the same as for the toe impact.
Test Clearances after the metatarsal test impact are:
– 1 inch (25.4mm)
EH footwear is designed to reduce the hazards due to the accidental contact of the sole with electrically energised parts and to provide secondary electricalhazard protection on substantially electrically insulated surfaces, live electrical circuits, electrically energised conductors, parts, or apparatus under dry conditions. Electric shock resistant footwear must be capable of withstanding the application of 14,000 volts at 60 Hz for 1 minute with no current flow or leakage in excess of 3.0 mill amperes under dry conditions.
Comfort is important in any shoe, but particularly with safety footwear. As well as the fitting of the boot or shoe, the purpose for which it will be used must be considered. Again, the risk assessment will determine the most appropriate type of footwear.
Another consideration will be the type of surface on which the footwear will be used; will this be wet and slippery or oily.
Will there by a considerable amount of rough ground? In which case, boots providing ankle support would be preferable to shoes.
Is there a risk of electric shock? Then soles with high electrical resistivity would be a serious consideration here.
If there is the risk of injuries is from falling objects and penetration, footwear with steel midsoles and 200J toecaps should be specified.
For work carried out in wet or muddy conditions, rubber boots (wellingtons) will be required and these again can be provided with steel toecaps and steel midsoles.
The problem of keeping water out of footwear results in moisture from foot perspiration being kept in. Better comfort can be achieved by using thick woollen socks between foot and boot to ensure that the perspiration is absorbed.
The weight factor, particularly with boots having safety features such as steel toecaps and midsoles can be important with respect to foot comfort. However, if a boot has adequate toe spring (an upward curving of the sole from the horizontal surface) then comfortable walking is accomplished by the heel-toe rolling action.
Steel toecaps designed to protect the toes may bruise or chafe the toes across the foot joint after prolonged use. A poorly located toecap may produce a prominent ledge adjacent to the foot joint. It is important to choose the correct size of footwear, allowing for the type of socks to be worn.
In construction site / shipyard environments, the work can involve many hazardous operations that can cause serious injury in a number of ways. Injury from dropped or falling objects can be severe should the incident be realised and suitable foot protection is not being worn.
1. SAFETY FOOTWEAR BS-EN 345- 1993 or Equivalent – Normal safety shoes used by all trades.
2. FOUNDRY BOOTS BS 4676 or Equivalent – Used by hot work trades (platers, welders, etc.)
3. WELLINGTON BOOTS BS-EN 344, 345 & 346 or Equivalent – Used while working in wet surroundings (hydro blasting, hp washing, etc.)
Tony Potter CMIOSH, MIIRSM
Chartered Safety & Health Practitioner
Drydocks World Health & Safety Manager
+9714 404 4529
Tony is a Chartered member of the Institution of Occupational Safety and Health (IOSH) and past Vice Chairman of the Middle East Branch of IOSH. And a full member of the International Institute of Risk and Safety Management (MIIRSM).
Tony came to Drydocks World – Dubai (previously Dubai Drydocks) in 2001 from the Shipbuilding / Repair / Conversion company of Cammell Laird. Where he held the post of HSE Manager at Cammell Laird for 5 years prior to his arrival in Dubai.
In the UK, Tony was a member of the Health & Safety Executives (HSE) NIG group for the industry – the Shipbuilders and Shiprepairers Health & Safety Consultative Committee (SSHSCC).
The SSHSCC met several times a year with the HSE to discuss industry issues including recent industry developments, accidents, near misses and future plans etc. The SSHSCC are instrumental in developing health & safety guidance for the industry in the UK through various working parties formed as a direct result of the HSE / SSHSCC meetings.
Guidance developed by the working parties is reviewed by the HSE and once approved, published through the Shipbuilders & Shiprepairers Association (SSA) and issue to all members.
During his time at Dubai Drydocks, Tony has played a pivotal roll in the development of the company safe systems and procedures and has also written and developed training modules including Risk Assessment and Permits to Work to name but two.
Published: 10th Feb 2010 in Health and Safety Middle East
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