Well, the naming rather gives it away. It is personal to the individual and it is provided to protect them. For the EU the original 1992 PPE Regulations required EU employers to avoid risks through collective measures (protecting everybody), rather than relying on individual measures.
Very few changes have been made to the UK Regulations until recently when the Personal Protective Equipment at Work (Amendment) Regulations 2022 (PPER 2022) were announced. Where, due to the changes in working practices, we have more home workers, and especially “zero hours” contract workers the employment rights of those whom UK government agencies differentiate as “workers” or “limb (b) workers”, as opposed to “employees” have now been included under the Regulations.
Note: The term “limb b” comes from Section 230 (3)(b) of the Employment Rights Act 1996, as opposed to Section 230 (3)(a) which refers to “limb a” or those with contracts of employment.
Although this does not materially change the original 1992 PPE Regulations. What it does do, however, is to extend the requirements to cover workers holding a more casual employment relationship.
The uptake and standards globally do, however, sadly vary. This is to be expected with 193 – 197 different countries in the World (the variation depends on where the information comes from) and also a variation of Governance and laws within the Countries themselves; America for example has fifty states that can create their own additional laws. So considering standards globally I would challenge any safety professional, (who have been on holidays or working abroad), to say they have not stopped to take photos as examples of ‘bad practice’ for varying PPE issues? But I could probably challenge them to ask if they have stopped as often (or at all) to take photos of ‘good practice’ where PPE is used effectively?
So although PPE has been around for a long time now, and has been used and approved in varying degrees across the world it really came to the Global forefront during Covid, where I am sure many of us had to debate and explain – was it PPE, was it a face covering, did it need face fit testing, how long could we wear it, etc.?
But that is really only one small part of PPE. Let’s consider all the areas, perhaps it is good to start from the top down:
Head protection: How do we know what to wear? When to wear? What the specific standard is? How to check and how to maintain?
And the same questions will go for all the below:
- Eye protection
- Ear protection
- Respiratory protection
- Full body protection
- Arm/hand protection
- Leg protection
- Foot protection
And never forget the combined protection, where multiple areas need protection.
How do we choose and provide protection?
Well to start, we need to know what we are looking at and question what is the hazard the protection is being provided for.
By looking at the hazards and risks, and what basically could cause harm, considering the types of harm we should, by a process of assessment, be able to evaluate what areas needs to be protected, and more importantly what they need to be protected against.
In some instances this is straight forward – you have a chemical and it may have physical or airborne contact. Then look at routes of entry; inhalation, ingestion, absorption, injection, then decide what needs to be protected.
“never forget combined protection, where multiple areas need protection”
Of course this is different for all situations, the chemical example may not fit for fire risks as might be experienced by the emergency services, or mechanical risks as experienced within industry. However, best to remember, those fire fighters who present to fight a fire involving chemicals will need that protection.
So it is important to look at the bigger picture and look at the ‘unusual events’. I will go back to the firefighter, who when presented with a road traffic accident (not a fire) may need to use hydraulic cutters and be protected against any hydraulic injection injury. I remember a presentation showing the effects of such an injury. It was made accessible from a major business, distributed to inform people to raise awareness and a good example of shared knowledge. This has always stuck in my mind – a graphic example of what could go wrong and the importance of recognition and treatment. But as you will realise from reading this, I am not a firefighter. I did, however, want to really highlight that when looking at PPE you must include the individuals doing the role – they can best explain the issues that they might have if the wrong PPE is provided.
Now when I say the wrong PPE, it might be the right PPE for one situation, but maybe not provided to consider the nature and diversity of the workforce, or not be compatible PPE to deal with multiple issues. I believe it is fair to say a lot of higher hazard job roles require multiple protection, and in these cases compatibility is crucial.
Firstly consider the individual – we are all different and dare I say the World might not be so interesting if this was not the case? These differences need to be recognised and taken into consideration when providing PPE.
Everyone is individual, even identical twins may have some unperceived differences in behaviour. So given these differences, it becomes apparent why the term is personal protective equipment – it is for the individual and so there needs to be a range of sizes as a minimum, and a range of designs where possible.
I always envy those people who can buy standard sizes for clothes and shoes online. For me, even shoe sizes appear to differ depending on who is supplying them. The same goes for PPE.
Bodies vary in many ways. Height, weight, hand and feet size, face features, body shapes to name a few. The main thing to remember is one size does not fit all. One style may be suitable, but may have a differing function. Dare I say, a trouser zip allows males to urinate freely, while the same zip allows females to lower the trousers to go to the toilet? People are different, needs are different.
Secondly consider the combinations, or different needs of individuals. For example those of us who wear prescription glasses – how are those taken into consideration when providing eye protection? Perhaps through a pair of prescription safety glasses, or a pair of goggles that go over the glasses to provide the protection. Then how does that fit with the hard hat and ear protection?
Unless you are in this situation then you might not experience the difficulty. It takes me back to the comment that yes, look at the product, but also ask the individuals – the ones who do the job – they will be best to consider any issues that may arise.
Thirdly I can only suggest that you do not buy solely on the cost. I was always taught the adage ‘buy cheap, buy twice’. Which generally means that if you buy something cheap, it’s likely to be poor quality and it’ll break, wear out or not be fit for purpose. As a result, you’ll need to buy a replacement, costing you more money in the long run. It is not the price that is the only consideration it is the longevity and practicality of use.
“the main thing to remember is one size does not fit all”
But also consider the adage ‘buyer beware’, as it is the buyer’s responsibility to be sure that they are not being cheated or overcharged. Buying cheap so people can wear and use it effectively may be better than buying dear and designer and it doesn’t work.
Equally, where there are designated markings on products like CE marking for instance, it might be possible to have counterfeit items on sale that look similar but are not the correct symbols or standards. But now the UK has left the EU, the requirements for placing work equipment and machinery on the UK and EU markets, including arrangements for conformity assessment, marking and labelling have changed.
CE marked workplace products will be accepted in Great Britain (GB) until 31st December 2022. This includes workplace goods which have been assessed by an EU-recognised notified body.
The UK Conformity Assessed (UKCA) mark is the new UK product mark for workplace products and other goods. From 1 January 2021 UKCA marking began to replace CE marking for goods being placed on the GB market.
I just want to emphasise that price should not be the first consideration. You need to make sure “it does exactly what it says on the tin”, which colloquially means that the name of something is an accurate description of its qualities.
What is the law for provisions?
Well the law as we all know is complicated, if we look back to the EU 1992 Regulations – these are not reflected globally, so a lot of research needs to be done for specific countries. Though it could be said if countries could adopt the EU regulations (or a global standard) then that would be good. A lot of global companies may do this, or they adopt the standards from their country of operation, so companies operating from the UK may adopt UK standards, but applying them to other countries may well present another challenge – depending on which legislation is being considered. Adopting computer and homeworking legislation may be easier then looking at fire legislation.
As mentioned, the difficulty may be in the standards for different hazards across different countries. It may be there is an awareness of a problem, such as people wearing scarves to stop dust, but that only stops the visible dust not the potential substances within the dust.
Who needs the protection?
This one is easy: The worker who may be affected by the hazard. However, who that worker might be is significantly harder. This is the concept that ‘one size does not fit all’! So it is really important when selecting PPE that account is taken of the workforce, the gender, race, ethnicity, additional needs etc. We all look different because we are different, that doesn’t mean we should not all be protected so a good selection and options should be available.
How many people buy clothes/shoes online? Because they know their size (but doesn’t this vary by country?) and how many of those who purchase items send them back as they don’t suit or don’t fit. Think if your first purchase was your only purchase. Would you make do and shut up, or research and get results?
“you could spend days just searching for different types of PPE”
How many types of protection are in use?
Well to be honest you could spend days just searching online for different types of PPE, take gloves for instance, there are so many types to protect against so many different hazards from so many different providers. So again, research, find a reputable supplier and discuss the needs and definitely, as mentioned before, include the users.
To add to the complexity, we have areas where multiple items of PPE are required and so these must be compatible. By that I mean the buyer must research to see that they work together. Imagine a firefighter whose protection didn’t fit together properly… what would happen then?
But similarly, head protection, ear protection and eye protection often may not be compatible, and as such reduces the protection provided.
How will they be maintained?
This is possibly the biggest challenge – to educate people and ensure that they take ‘personal’ care of their PPE. It may be the last line of defence (we will look at that after), but it is their defence. So between looking after, cleaning, and maintaining, changing into PPE has got to have some ownership. Those of us who wear glasses (protective or not) will know we look after them, as without them we cannot see. The same applies to all PPE – without them we may lose one or more of our senses.
Where do I find a source or provider?
This is not an article to promote providers, rather to reinforce that you need to research the products, make sure they provide the protection that you want, in sizes that you need and that they are compatible and work together.
The most important consideration is not how they look, but how they function and provide the protection that is needed.
“the best way to control the hazard is at source”
At the end of the day
The best way to control the hazard is at source, and remove the need for PPE.
But, going back to the firefighters, for many workers this simply can’t be done. So if people are still required to wear PPE, then ensure it is:
- Provided at no cost to the workers
- Suitable and available in sizes to fit the workers
- Compatible with other PPE that may be worn simultaneously
- Maintained in good condition
- Correctly stored
- Properly used
That way, the workers will get the best personal protective equipment for their jobs.