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The Journal for Employee Protection
The Journal for Employee Protection
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For those involved with providing workwear, it may not always be clear what the hazards are so it is important that manufacturers identify – as far as they can – what their workwear is intended to do or protect workers from. Accurate information is a key to making sure the correct workwear is selected. Without this, it may be difficult for users to decide which product offers the best protection.
To help ensure that manufacturing standards of workwear are consistent, the International Standards Organisation (ISO) and other standards bodies have been established. Under such standards, manufacturers and users can agree the standards that will apply to specified equipment or clothing. While most standards committees will have representatives from manufacturers, rarely will they include workers’ representatives.
In this article the huge area of workwear which offers personal protection from workplace hazards will be reviewed from the worker’s perspective. While many manufacturers of workwear will have involved people in their development of such equipment, the real test of its effectiveness comes at the workplace. So, what do the workers – the real users – think?
Most people will want to go to work and return home in roughly the same state that they left. In recognising that they may need to wear PPE they want it to be comfortable, not interfere with their ability to do their work, fit them, protect them against the respective hazards they face and be easily maintained. This is hardly rocket science!
In most studies looking at personal protective equipment and workwear, the key point is obvious – comfort. It needs to be comfortable to wear and protect them from the hazards it was provided for, not restrict them from doing their job and not introduce further hazards to the wearer. Therefore when considering the workwear needed, it is useful to consult with the workforce about the products to be used. Not only does this help in selecting workwear that people are comfortable with, it helps ensure they will wear it in the future. People support what they help create. If they are involved in the selection process, they are more likely to comply with requirements to wear it.
For organisations that employ many people, smaller groups can be established to do the initial selection work. Trade union representatives or other health and safety representatives can assist in this process. Having settled on the product as a result of specific trials, an order can be placed to cover the whole workforce.
If products are purchased without workers being involved, they may view products as being thrust upon them. If the cheapest product is bought which may be uncomfortable or is not perceived to provide adequate protection, workers may reject it. Although introducing an initial selection trial may delay the purchase of equipment, in the long run it usually pays in ensuring acceptance by the workforce.
At a European level, a new legislative approach was adopted by the European Commission in the late 1980s early 1990s. One of the issues it addressed was the ‘interface’ between PPE users and the manufacturers of PPE.
During the development of legislation to form the Single European Market, the process for adopting health and safety Directives was amended. This was introduced through the Single European Act brought into effect on the 1st July 1987. Instead of being subject to unanimous voting to agree a text, it was then subject to qualified majority voting. This quickened the pace at which Directives were agreed.
The Commission adopted a series of Directives under Article 118a (now part of Article 137(1) EC), which laid down minimum requirements concerning health and safety at work. Probably the most important of these was the Framework Directive (89/391/EEC) which introduced measures to encourage improvements in the safety and health of workers at work. In addition, the Framework Directive was supplemented by additional Directives on specific areas, which included the Council Directive 89/656/EEC on ‘the minimum safety and health requirements for the use by workers of personal protective equipment at the workplace’.
Within the Framework Directive, a set of principles was established which employers were required to address. The two in relation to this article are the requirements to access risks facing workers and the general principles of prevention that employers need to apply from the risk assessment. The general prevention principles set out in Article 6(2) are:
(a) avoiding risks;
(b) evaluating the risks which cannot be avoided;
(c) combating the risks at source;
(d) adapting the work to the individual, especially as regards the design of workplaces, the choice of work equipment and the choice of working and production methods, with a view, in particular, to alleviating monotonous work and work at a predetermined work-rate and to reducing their effect on health;
(e) adapting to technical progress;
(f) replacing the dangerous with the non-dangerous or the less dangerous;
(g) developing a coherent overall prevention policy which covers technology, organisation of work, working conditions, social relationships and the influence of factors relating to the working environment;
(h) giving collective protective measures priority over individual protective measures
(i) giving appropriate instructions to employees.
So the employer is required to assess the risks to the workforce and then apply control measures on the basis of the general principles of prevention to protect them. It can be seen that PPE is low down on the list. The Health and Safety Executive (HSE) in the UK refer to PPE as being ‘the last resort’. That is considered when all other control measures are not able to reduce the risk sufficiently. Only then can PPE be considered to reduce the residual risk that other measures cannot prevent.
Directive 89/656/EEC identifies measures that the employer has to implement in relation to PPE. These include ensuring the PPE is appropriate for the risk its use is intended, comply with European design and manufacturing standards, take account of ergonomic requirements, fit the wear correctly, after any adjustments etc. Hence it identifies how appropriately designed and manufactured PPE is to be used.
At the same time, under Article 100a of the Act (now Article 95 EC), a mechanism was put in place to ‘harmonise’ national legislation. This was to try and remove barriers to trade between Member States. In relation to personal protective equipment, the key aims were to ensure that it was fit for purpose and that different standards did not apply in different Member States. In December 1989 the Directive ‘on the approximation of the laws of the Member States relating to personal protective equipment’ was adopted (89/686/EEC). It:
‘lays down the conditions governing its placing on the market and free movement within the Community and the basic safety requirements which PPE must satisfy in order to ensure the health protection and safety of users.’
Not only does this Directive identify the mechanisms by which PPE can be placed onto the European Market (the route to conformity) it also sets out the basic health and safety requirements. These are extensive and not all are reproduced here. Included in these requirements are the design principles, such as ergonomic requirements, comfort of user, specific requirements types of PPE for specific situations such as those to be used in explosive atmospheres or protection against mechanical impact for the face, eyes or respiratory tract for instance.
So in Europe there is a legal mechanism which has requirements on employers to avoid workers being exposed to risk. Where this cannot be achieved, other control measures need to be applied, of which the use of PPE is the ‘last resort’. When PPE is used as part of the preventative measures, it must conform to the relevant design and manufacturing standards. The employer must then ensure the PPE is available, freely supplied to workers and maintained.
A key requirement is that the manufacturer provides sufficient information to enable employers, in the selection of appropriate PPE to consider the correct equipment. While for many items of equipment this will be clear, for others there may be some difficulties.
To indicate what needs to be done in selecting workwear, consider protective clothing for operating a chainsaw for instance. There have been sufficient deaths associated with industrial chainsaw use for manufacturers of such equipment to include safety features. However these are not sufficient to cover all risks because the chainsaw mechanism will cut flesh.
In this article, it is the leg and groin protection that is of most interest. In operating a chain saw, a number of incidents have occurred where the saw ‘kicks back’ and can make contact with the body. Hence the legs and groin need particular protection.
BS EN 381 Protective clothing for users of hand-held chainsaws covers the protective trousers needed when using a chain saw. There are two types of protection:
Type A chainsaw trousers protect only the front of the legs; and
Type C chainsaw trousers give protection all round the legs and are worn as ordinary trousers.
However Type C chainsaw trousers are made with a heavier material that gives all round protection for the legs and groin. In certain conditions this may cause heat stress. Just how complicated the situation can get may be seen by considering what else the operator may have to wear.
In the Health and Safety Executive (HSE) Guidance drawn up with the Arboriculture and Forestry Advisory Group on Top handed chainsaw use, they identify a range of issues about using such equipment. This includes personal protective equipment, maintaining the saw, preparing the saw for work, use of the saw, training etc. For personal protective equipment, the HSE recommend the following PPE:
? A safety helmet (HSE strongly recommends a mountaineering style helmet complying with BS EN 12492).
? Eye protection (complying with either BS EN 1731 or BS EN 166).
? Hearing protection (complying with BS EN 352).
? Suitable gloves appropriate to the task and subject to the Operator’s risk assessment.
? Leg protection and groin protection (complying with BS EN 381-5). HSE strongly recommends Type C leg protection for aerial work, because of the high all-round chainsaw cut protection. However, where wearing Type C is impractical (eg because of the higher risk of heat stress associated with it), it may be appropriate to use Type A, where justified by risk assessment.
? Protective boots with good grip and protective guarding at front vamp and instep (complying with BS EN ISO 20345).
? Non-snag outer clothing. The use of high-visibility clothing may also be appropriate.
So what can start out as a straightforward issue, can become complicated quite quickly! If a chainsaw operator works during the summer, heat stress may become an issue. The comfort of the operation may be affected by the different PPE required to work with the saw. In cold or rainy conditions, the dexterity of the operator may be affected. Trousers with good thermal properties may be needed in the cold. Manufacturers may need to consider that operators may wear thermal underwear with long legs in cold conditions.
It is critical then that the employer has a good understanding of the risks that apply to chain saw work, before the workwear suppliers are approached. While the supplier may have a good knowledge of the general risks, working reality may differ from one organisation to another. Unless the employer actually discusses all the risks, the supplier may not be aware of a situation that limits the effectiveness of the product.
Employers are required to avoid risks as far as possible. To do this, they need to know the risks that are faced by the workforce. This is done through a risk assessment. Such an assessment should identify all the significant risks associated with the work under review.
Having identified the risks, the employer needs to put control measures in place. The general principles are identified above. Where risks cannot be reduced to an adequate level, and PPE will need to be used, another process needs to be done to identify the appropriate PPE.
There are many situations that create hostile environments and require workers to be protected. Often workwear needs to take into account several factors. So protecting people from radiant heat in a steel works seems obvious. However workers may also need protection from hot metal splashes. Intense heat can be created during welding but workers can also be exposed to sparks. Hence the clothing material must protect the wearer from sparks and not catch fire!
The standards system at the European level is designed to help marry the manufacture of workwear to effectively address the hazards workers may face when risks cannot be totally eliminated. The situation with chainsaws is described above. Consider some others.
While a number of glove manufacturers can offer materials that are puncture resistant, many are limited when stopping the penetration of hypodermic needles. The strength of the needle and its fine point mean that most materials will be punctured by direct contact. However some manufacturers using materials such aramid fibres have been able to increase the resistance in the material. In this instance the gloves are used in situations where workers may be involved in situations where needles may be deliberately left in places where the police, for example, may search.
So for many situations, the workwear may not give total protection and the employer may need to use a combination of control measures to adequately reduce the risk. In some environments, it may be more straightforward. In a steel works, the clothing may need to protect workers from radiant heat and splashing of molten metal. Indeed in most operations that involve molten metal such protection may be needed. The different processes may require different products.
In the construction sector the need to protect the soles of safety boots from nail puncture is known. However with the increasing use of nail guns, demolishing buildings where nails may protrude from wood etc mean that the feet are not the only area of the body at risk. Depending on the building being worked on hands may need additional protection.
Involving the workers and their representatives will help provide solutions that offer the best protection.
The range of hazards that PPE addresses are wide and the production of PPE can be complex. However there needs to be a greater feedback from workers using PPE about the issues they have in relation to wearing the PPE. This also applies, of course, to general workwear.
At the 9th European Seminar on Personal Protective Equipment (January 2008, Finnish Institute of Occupational Health), Roland Gauthy of the European Trade Union Institute Health and Safety Dept in Brussels presented a paper on Personal Protective Equipment. He outlined a potential mechanism to obtain feedback from workers, using incidents involving fork lift trucks as a model. This involved identifying equipment being used in target organisations, obtaining feedback from the companies, feeding this into a coordinating management group to provide information that can be fed into the related European standards organisation – CEN – Working Groups.
Within the paper Mr Gauthy stated:
‘Seen in the bigger picture, PPE needs to be looked at as part of a systematic approach in which at least three subsystems interact: human factors, risk factors in the working situation and PPE related factors. At the centre of these interactions lie wellbeing at work and the safety of workers.’
‘The flexibility and suitability needed in a globalized and changing world where small and medium sized firms have to battle on international markets mean that efficient and relevant mechanisms, especially in the choice and allocation of protective equipment, are needed to integrate the invaluable practical knowledge developed by operators and workers.’
At a European level, the ETUC is able to have worker representatives on the Working Groups developing Standards. However not all are covered. Nevertheless, the design of PPE needs to reflect the working reality in which the equipment will be used. Some companies already do this and have it as part of their product development at the design stage. However it needs to be more universally developed.
Over time, the Standards process should provide a feedback loop. This should identify how effective the PPE has been in use and what improvements may be made in the future. Many of the obstacles to people wearing PPE have been identified and are well known.
But what can be done in the absence of a truly effective mechanism through CEN? At a national level there are often trade associations that cover specific sectors. Often they have European Counterparts. They can be approached to see if research could be done on specific PPE that may be of concern in the sector. In the case of the HSE in the UK, looking at slip resistance in soles for the catering and food manufacturing sectors, for example.
Sector based Government insurance organisations, such as in Germany, may be a source of collaboration. Here the trade unions are involved in Standards development at a national level as well.
The trades unions themselves may provide assistance. The ETUC has a Technical Centre that is involved with standards development. The Director is Laurent Vogel and the contact website is given. Initial contact with them may lead to a closer involvement of workers using PPE. They are in contact with national trade unions so may be able to assist making contacts in specific Member States.
Manufacturers may argue that how PPE is used is down to the employer and worker. However, if they are going to provide PPE that offers the best protection, feedback from workers who use the equipment is invaluable. It is true that in many organisations it is the procurement department or managers who purchase PPE. They may not be putting a great consideration on how the workers feel about the PPE. It is more effective to try and establish a more direct feedback mechanism.
Given that workers are the ones suffering death, injuries and ill-health, surely they are owed some consideration from the designers and manufacturers of PPE to explore how more direct feedback can be achieved? With all the advances in communications in this modern age, presumably there has not been a better time to consider a more direct route to receiving workers’ feedback. Worker involvement to an extent exists within the CEN standards development framework: it exists in several national standards organisations. What we need is something more effective in practice.
Published: 01st Apr 2010 in Health and Safety International
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