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Executive Report: Practicalities of PPE Nigel Strickland provides an overview of legislation concerning personal protective equipment (PPE) and suggests that it brings both opportunities and obligations for hirers. EHN has recently published several articles considering the possible impact on the hire industry of the Control of Noise at Work Regulations 2005, and of the respirable crystalline silica (RCS) exposure levels within the Control of Substances Hazardous to Health Regulations 2002 (CoSHH). Their requirements are being publicised by on-going Health & Safety Executive (HSE) campaigns, and the hire industry has a strategic role to play in developing practicable solutions, providing education and supplying customer training. Appropriate new products are being added to many hire fleets, including equipment offering lower noise levels, dust management and suppression systems, and innovative educational campaigns are engaging companies in changing established working practices and removing risk. In addition, both sets of legislation contain concise specifications and guidance on the supply, training and use of personal protective equipment (PPE). This market (including protective clothing and workwear) in the UK is hugely significant, with total sales in 2006 estimated to be £825m. Even when the value of workwear and protective clothing, such as corporate uniforms, is removed from this figure, the market for head, face, eye and hearing protection, industrial gloves, industrial footwear, respiratory protection and breathing apparatus within construction is sizeable. The HSE estimates 2.2m people work in construction, making it the UK’s biggest industry, and it is probably the largest potential market for PPE. For example, it has been suggested that as many as 1.1m more workers could now require hearing protection as a result of the new noise legislation. Opportunities for the hire industry In terms of opportunities for the hire industry, the use of PPE has become much more widespread owing to increasing awareness of health and safety risks. Manufacturers have played their part by developing products that reflect the demands of an increasingly fashion-conscious workforce. Gone are the days when virtually all safety footwear followed Henry Ford’s dictum and came in black only. Similarly, the range of eye-protection available is much bigger, more comfortable and, therefore, more likely to be used. To take full commercial advantage of the wider use of PPE, hirers need to consider the range they offer, and how they market it. It is important to recognise the obligation of hire staff to have greater product knowledge concerning various ranges of PPE, their respective applications and the legislation governing their use – predominantly the Personal Protective Equipment at Work Regulations 1992. These define PPE as “all equipment (including clothing affording protection against the weather) which is intended to be worn or held by the person at work and which protects him against one or more risks to his health and safety”. This includes safety helmets, gloves, eye protection, high visibility clothing, safety footwear and safety harnesses. The use of hearing protection and respiratory protective equipment (RPE) is covered by the relevant legislation mentioned above. The Regulations stipulate that PPE is to be supplied and used at work whenever there are risks to health and safety that cannot be adequately controlled in other ways. It must be considered as a last resort for the control of risks and only used after all other practicable measures have been taken. It must be remembered that PPE protects the wearer and no-one else in the workplace, and that it gives maximum protection only if correctly chosen, fitted and used. This last statement cannot be overexaggerated, as current research into RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations) reports mentioning PPE clearly proves. Almost 63% of reported incidents reveal claims of misuse, incorrect selection, lack of maintenance and/or lack of training as major contributory factors. Interestingly, not one report mentioned failure of PPE as a contributory factor. Lack of knowledge The British Safety Industry Federation (BSIF) (www.bsif.co.uk) calculates that this lack of knowledge regarding PPE and CE markings causes 22,995 injuries and incidents a year. A recent industry-wide BSIF survey showed that very few safety officers, trade unions or PPE users know or comprehend the correct methods for selection. It is also evident that many are confused regarding what the markings on products mean, and how best to relate the ‘user information’ supplied with the equipment to specific tasks. Importantly, the legislation states that the decision to use PPE must be determined through a proper risk assessment, carried out by a suitably qualified person. Once this has been made, the choice of PPE should only be taken by a competent person. Clearly, this has potential implications for any hire company and its employees when supplying PPE to customers, as the law is explicit that, if the supplier is prepared to engage in the final selection of PPE, they then take on (or accept some liability for) the employer’s responsibility, namely in selecting appropriate equipment. The implications for hire personnel advising customers on the specific selection of PPE, without, as is most likely, having taken part in the customer’s risk assessment procedure, are obvious. They should be aware of adopting a legal responsibility over which they have no control, along with the possible outcomes. Recent legal cases have stated that there may be occasions where an employer has relied on the advice of others and, subsequently, these advisors could be found liable. However, this does not absolve the employer of his responsibilities to protect his employees, to ensure that the advice accepted comes from a “competent source” and to provide “suitable” equipment. As these are criminal and not civil offences, the courts can impose fines, with the defendants acquiring criminal records. In a recent case, both the employer and the provider of the advice were each fined £20,000. In the absence of every hire depot having staff who are fully trained and competent concerning the wide range of PPE available, the quality of the relationship a hirer has with its PPE supplier is paramount. Any good, specialist supplier will be able to provide detailed information and assist in selecting suitable products. They will also know which standards the PPE has been tested to, indicating performance characteristics, and will provide details of the specific “user information”. Understand product selection However, no matter how good the support and backup is, it makes sense to take a little trouble to understand how to select suitable PPE once the need for it has been assessed. There are various European Harmonised Standards (ENs) for PPE. For example, protective eyewear is covered by 20 EN (EN166) references, and hard hats by 12 EN references (EN397). Within the standards there may also be various subdivisions to denote the standard of protection or type (such as ear muffs/defenders EN352-1, ear plugs EN352-2, helmet mounted muffs/defender EN352-3). All PPE sold must comply with the PPE Regulations (EC Directive) 2002 - a title confusingly similar to the PPE at Work Regulations 1992! The latter relate to the actual sale and supply of PPE, rather than its use and issue. The former require that the PPE must be tested by an independent body to the European PPE Directives, and be marked with the standard to which they have been tested, also possibly stating a ‘class’ or ‘type’ reference. The CE mark does not, by itself, identify that the PPE is right for the proposed use, rather that it has satisfied the basic safety performance standards. A combination of legislation, campaigns to change working practices and an increasingly fashion conscious workforce is creating a vibrant and growing market, with the hire industry well placed to benefit. However, with these opportunities come increased responsibilities and a need to educate the workforce within the industry itself. What better way for a hire company to start than by undertaking risk assessments, establishing PPE requirements and supplying PPE training for its own staff? Not only will they be complying with the law, but they will also create an overall awareness that could have a positive impact on the bottom line. • Executive Hire News › Archives › June 2007 › Executive Report › Practicalities of PPE
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