User:Sleo99/sandbox/ppe-kamaj

Katarzyna Majchrzycka CIOP-PIB

Personal Protective Equipment (PPE)

This article provides useful information for employers in relation to the safe application of personal protective equipment (PPE) in the workplace. Particular emphasis will be placed on issues concerning the proper selection of PPE for particular workplace conditions, including technical aspects, ergonomics and end-users’ acceptance. The issue of providing proper information to employees and how the PPE should be marked will be discussed on the basis of the information supplied by the manufacturer (manufacturer’s instructions) with the final product. The importance and range of practical training at workplaces, and the adjustment of PPE by individuals will also be considered.

Basic definitions
Personal protective equipment (PPE) means all equipment (including clothing affording protection against the weather) which is intended to be worn or held by people at work and which protects them against one or more risks to their health and safety, and any addition or accessory designed to meet that objective

This definition does not apply in respect to PPE which is:


 * ordinary working clothes and uniforms which does not specifically protect the health and safety of the wearer,


 * equipment used by emergency and rescue services,


 * PPE worn or used by the military, the police and other public order agencies,


 * PPE for means of road transport,


 * sports equipment,


 * self-defence or deterrent equipment,


 * portable devices for detecting and signalling risks and nuisances.

Directives concerning PPE
The basic Directive concerning PPE is Directive 89/656/EEC, which specifies the minimum health and safety requirements for the use by workers of PPE at the workplace.

The Directive states that: PPE shall be used when the risks cannot be avoided or sufficiently limited by technical means of collective protection or by measures,

methods or procedures of work organisation.

At the same time, there is another EU legislation concerning PPE, Directive 89/686/EEC [2] which covers the rules for conformity assessment and placing of PPE on the EU market.

This has been developed as the preferred means of demonstrating equipment conformity with the basic health and safety requirements (BHSRs) specified in Directive (89/686/EEC).

Only equipment which meets these BHSRs is entitled to carry the CE mark and to be sold for use in the EC.

General rule
In accordance with general occupational safety and health (OSH) provisions, the employer shall ensure employees’ safety and health with respect to every aspect of work [ERO-10-06-a-1 OSH management system]. For any risk in the workplace, the general prevention hierarchy should be used i.e. elimination or substitution of the risk at source should be given priority followed by or combined with technical measures, organisational measures, and PPE as a last resort.

The role of PPE is solely to reduce the possibility of exposure to a hazard (e.g. high-visibility clothing is designed increase the employee’s visibility), it does not eliminate the hazard [RO-11-03-4 Hierarchy of controls ERO-10-06c-1 RMTools].

Before taking a decision whether PPE should be used by employees at work, the employer should consider the following options:

- elimination,

- substitution - material or change in process,

- engineering controls,

- revised work practices,

- equipment change,

- administrative controls.

Following from the above, because PPE is the last resort after other methods of protection have been considered, it is important that users wear it all the time they are exposed to the risk. The level of employee’s safety falls drastically when PPE is used for shorter periods of time than required given the time of exposure to hazard.

Employers have an obligation under the Directive to ensure that suitable PPE is provided to all his employees who may be exposed to a risk to their health or safety while at work except where and to the extent that such risk has been adequately controlled by other means which are equally or more effective.

The employer shall:

-	ensure that employees receive PPE free of charge,

-	choose appropriate PPE depending on the risks,

-	specify the conditions of PPE use,

-	organize training sessions,

-	ensure suitable storage, cleaning, disinfection, maintenance and necessary repairs of PPE used by employees.

Worker and/or their representative shall be informed of all measures to be taken with regard to the health and safety when PPE  is used by workers at work. Involving employees in the risk assessment process is a highly effective way of identifying hazards and developing solutions that work [ERO-10-06 a-2 OHS Management Systems and Worker Participation]. They will be able to bring their knowledge, experience and understanding of the activity. Consultation and participation of workers and/or of their representatives shall take place in accordance with Article 11 of Directive 89/391/EEC.

It is important, whenever possible, that employees are given a chance to choose a specific model of PPE, however only if it ensures appropriate protection against existing risks.

Provision of PPE
In order to ensure appropriate protection, PPE should:

-	comply with the relevant Community provisions on design and manufacture with respect to safety and health,

-	be appropriate for the risk involved, without itself leading to any increased risk,

-	be suitable for the conditions in a given workplace,

-	meet ergonomics-related requirements and take into account the employee’s health condition,

-	be tailored to the user i.e. fit the wearer correctly, after necessary adjustments.

CE marking
It should be emphasized that only PPE bearing the CE mark may be regarded as complying with the basic health and safety requirements, therefore employers should always choose PPE for their employees from amongst these. For this purpose, it is necessary for employers to have a basic knowledge and understanding of the rules for placing PPE on the EU market.

.

Directive 89/686/EEC divides PPE into three groups based on the type of risks they sufficiently address and lays down different certification procedures for individual groups of equipment. These are named in the Directive as "Simple design", "Complex design" and neither of these, the last being a third Category. Whilst the Directive does not explicitly define these three groups as Categories, it is common practice to use the terms category I, III and II respectively.

Category I ("simple design") covers PPE designed to protect against minimal risks. These products are of simple design where the designer assumes the users can themselves assess the level of protection provided against the minimal risks concerned, the effects of which, when they are gradual, can be safely identified by the user in good time.

Category III (so-called "complex design") covers PPE intended to protect against mortal danger or against dangers that may seriously and irreversibly harm the health, the immediate effects of which the designer assumes the user cannot identify in sufficient time

Category II covers PPE of medium complexity design (PPE not included in category I or III).

Directive 89/686/EEC clearly defines the groups of PPE included in category I and III. For example, category I include gardening gloves, thimbles, gloves affording protection against diluted detergent solutions, light anti-scalping helmets, sunglasses, light footwear while category III include respiratory protection devices (RPD), PPE providing only limited protection against chemical attack or against ionizing radiation (protective clothing), PPE  against falls from a height and PPE against electrical risks and dangerous voltages or that used as insulation in high-tension work.

The Directive provides different conformity assessment procedures depending on the category of PPE (Fig. 1). In the case of PPE category I, the manufacturer declares at their sole responsibility that the product complies with the Directive and will have to establish their technical documentation (technical file). For PPE in categories II and III, these must be examined by a notified body (NB), which determines and certifies that a given a PPE model complies with the respective BHSRs of the Directive. Additionally for PPE in Category III, the Directive requires the manufacturer to ensure the quality control of their products.. For these cases, the CE mark on the PPE will be accompanied by a four digit code number identifying the responsible NB appointed to ensure that the manufactured products continue to satisfy the BHSRs.

Fig. 1 CE marking of PPE Directive



Source: created by author

The declaration of conformity assessment and the information supplied by the manufacturer (manufacturer’s instructions) should include PPE type identification data, actual place of manufacture and identification data of the notified body. This provides additional information in case the employer has doubts as to the choice of appropriate PPE depending on the risks involved or needs to modify the construction of PPE in order to accommodate it to the employees’ individual needs. It should be emphasized that the employer is not allowed to modify the construction of PPE in any way without having consulted the manufacturer, who is responsible for the compliance of products placed on EU market.

There are occasions when PPE  could be given a CE marking under a number of different Directives, which may not take into consideration the BHSRs, e.g. medical devices Directive 2007/47/EC If an employer selects such PPE for providing protection against health and safety hazards, it is important that they seek confirmation from the supplier to ensure that the certified PPE satisfies the requirements of the PPE Directive.

Selection of suitable PPE
Prior to choosing PPE, the employer should identify all hazards (chemical, biological, physical, environmental) existing in the workplace and assess their occupational risk [ERO-10-06-a-1 OSH management system]

See table 1 for reference.

Table 1. Non exhaustive guide list of harmful and hazardous factors together with some examples of types of PPE

Source:

If necessary, the employer should also measure the concentration or intensity of hazardous and harmful factors, and then compare the results with exposure limits [ERO-10-06c-8 OEL], (Occupational Exposure Limits with respect to concentration, for example, of dusts, fumes, gases or intensity of noise, vibrations).

The need for PPE must be identified through risk assessment. A risk assessment is a careful examination of what could cause harm to people in the workplace. Doing a risk assessment will help employers identify the significant risks in their workplace, and avoid wasted effort by effectively targeting these risks. In addition to identifying the need for PPE, it is essential that the right type and grade of PPE is specified and provided.

A good and encouraged practice is to use material safety data sheets (MSDS) [ERO 10-06c-11.b "Labelling“] when performing risk assessment [ERO-10-06c -1 Risk Management tools for dangerous substances]. Their use is intended to provide workers and emergency personnel with procedure for handling or working with that substance in a safe manner, and includes information such as physical data, toxicity, health effects, first aid, reactivity, storage, disposal, PPE, and spill-handling procedures.

To allow the right type of PPE to be chosen, the employer must carefully consider the different hazards for each assignment, task or activity to be undertaken [ERO-10-06c-2 REACH]. This will enable them to assess which types of PPE are required and suitable to protect against such hazards.

PPE may be divided into the following groups based on the impact of hazardous and harmful factors on the human body:


 * protective clothing[RO-11-06-3 Protective clothing - against chemical and biological hazards, RO-11-06-4 Protective clothing – against physical hazards, RO-11-06-5 Protective clothing - Reflective clothing],
 * hand and arm protection,
 * foot protection,
 * eye and face protection,
 * hearing protection,
 * head protection,
 * respiratory protective devices (RPD),
 * personal fall protection[ERO-10-06b-9 personal fall protection].

Proper selection of protection class of PPE according to the risk, ought to be made following the norms harmonised (EN) with the Directive 89/686/EEC

Information contained within the European harmonized standards (EN), especially those concerning protection classes of different types of PPE are intended to provide necessary data aiding the selection of PPE for hazards identified during the risk assessment. The analysis and assessment of risks is fundamental for choosing the correct PPE and should take into account the following factors:


 * workplace organization,
 * climate conditions,
 * additional risks related to PPE use,
 * individual user characteristics,
 * working hours and other characteristic elements which might have adverse impact on the employee’s health or well-being.

It should be emphasized that if there is more than one type of risk, then as a consequence, it might be necessary to use more than one type of PPE. The construction of the equipment must allow to adjust it without compromising its protective capacity i.e. compatibility of different classes or types of PPE designed for simultaneous use.

For the graphical representation of the PPE Selection process refer to the Figure 2 (Paragraph 7 : Management)

Employer’s checklist
To make it easier for the employer to follow the regulations, it would be helpful to apply the practical checklist below. Having initially chosen the specific PPE, the following should be checked :


 * Is it suitable given the occupational risk involved and the workplace conditions?
 * For example, eye protection designed for providing protection against agricultural pesticides  will
 * not offer adequate and sufficient face protection for someone using an angle grinder to cut steel
 * or stone.


 * Will the use of the PPE not increase the general level of occupational risk?
 * For example, the use of a mask or protective glasses against splinters of solid objects may limit the employee’s vision and, as a consequence, lead to the collision with moving parts of the machinery.


 * Does PPE fit the user, after the necessary adjustments have been made?
 * It is necessary to check if clothes, gloves and footwear have been tailored to the user. It is  especially important when women use PPE, since frequently they are smaller in size than men, which may lead to ill-fitting of commonly manufactured oversized PPE . The aim should be to choose PPE which will give maximum protection while ensuring minimum discomfort to the wearer, as uncomfortable equipment is unlikely to be worn properly. Not fitting the wearer correctly may lead to a significant reduction of effectiveness of PPE which may result in leaving the employee unprotected.


 * Does it take account of ergonomics and the employee’s health condition?
 * The PPE selection procedure should also take account of employees’ health condition, especially any disorders which may hinder or prevent the use of the PPE. For instance, sight defects may be an impediment to wearing masks or eye protection, whereas claustrophobia may prevent a person    using RPD. Another important problem is that it is difficult to tailor PPE specifically to the needs of people with untypical body shape (e.g. body deformation or facial hair), as it may prevent  the proper adjustment of respiratory protective equipment.  With regards to RPD, fit tests should be carried out.


 * Are there any conditions for using the specified PPE, in particular instances and times when it should be worn?
 * For example, it is essential to establish breaks when wearing leak-tight clothing to protect against chemical agents when working in a warm environment. Another important example is the specification on the maximum working time of gas filters protecting against chemical substance vapours or the protection time / period for gloves protecting against organic solvents, oils and lubricants.


 * If there is more than one type of risk and it is necessary to use several types of PPE - is it possible to adjust the pieces of equipment to one another (without compromising their protective capacity)?
 * For example, wearing filtering half masks may prevent from adjusting protective goggles.

There are many guides and brochures aimed to help employers and safely use PPE safely (e.g. Respiratory protective equipment at work, Effective PPE Program , Selecting protective gloves.

Important information
In order to ensure easy and quick access to information concerning the scope / properties of any PPE used, identification symbols (e.g. class 1, type 1) and pictograms introduced by the manufacturer,  have been drawn up, which, along with information supplied by the manufacturer, help to select suitable PPE  for the risks in the workplace. Identification symbols relating to different PPE groups are covered to different extents. For example in the case of eye and face protection against solid objects, the following identification symbols relating to their mechanical resistance have been introduced: “S” – increased robustness, “F” – low energy impact, “B” – medium energy impact, “A” – high energy impact. Table 2 presents common identification pictograms used.

Table 2: Sample pictograms



Source:

Information supplied by the manufacturer be written in the official language of the country where the PPE is used.

The information supplied by the manufacturer (manufacturer’s instructions) must contain a description of the identification symbols on the product.

All types of PPE (and/or packages) should bear appropriate identification in accordance with respective EN.

The manufacturer’s instructions should contain:


 * the producer’s name and address,
 * instructions concerning storage, use, cleaning, maintenance, expiry date and disinfection,
 * additional equipment to be used with PPE and description of spare parts used with it,
 * protection class at different risk levels and the scope of use relating to them,
 * type of packing suitable for transport

Training
Both employees and persons supervising PPE usage should know:


 * what protective properties the PPE used has,
 * what the consequences of not using it are,
 * how to use PPE properly, in accordance to its function  as stated in the information supplied by the manufacturer (manufacturer’s instruction should be accessible and understandable for employees),
 * that PPE is the last resort protection for employees (after all other prevention methods have been exhausted) and therefore it is necessary to use it at all times while exposed to a given hazard,
 * how to clean PPE and when to change it e.g. when expired, damaged or no longer appropriate for the type of activity being undertaken.

The employer is legally obliged to organize training on how to wear and use PPE. If necessary, training sessions should include appropriate demonstrations. PPE-related training should be organized at the employer’s cost during working hours. It should also include new and changing risks and be repeated periodically [RO-11-06-6 training].

Maintenance and inspection
PPE should be handled with caution. After use it should be stored in appropriate conditions (e.g. in a dry, clean cupboard, and in the case of small objects like glasses, additionally in a box or case).

PPE should be kept clean and repaired as appropriate, in accordance with the information supplied by the manufacturer. The manufacturer’s instruction should include recommended replacement periods and duration of use.

Simple maintenance works may be conducted by trained employees. In turn, complex repairs should be carried out by specialists.

PPE is intended for personal use. Whenever a given piece of equipment is worn by more than one person, action should be taken to ensure that the use of equipment does not pose any threats to health and hygiene of different users. The employer’s obligation is to ensure that the washing, maintenance, repairs or disinfection of PPE is free of charge.

Management
The use of PPE should be supervised. Areas where the use of PPE is mandatory need to be identified and adequately signed so that all employees are aware of the requirements. Specifying smaller areas where it is actually necessary to wear PPE is more efficient than an obligation to wear PPE in the whole workshop or unit (92/58/EEC).

It should be noted that management are also obliged to use PPE in all areas where hazardous and harmful factors exist. In particular, management are obliged to draw up and implement procedures and instructions to be followed in the event of any of the following:


 * there have been changes in technological process being used in the workplace,
 * there has been a change in the materials being used in a process,
 * there has been a reduction in the hygiene standards,
 * there have been changes in staff, e.g. new employees or employees being transferred from other area of the workplace,
 * there are possibilities to obtain and use new, more effective and more comfortable PPE,
 * essential types of PPE cannot be obtained.

If employees and/or their representatives use PPE, they should be notified of all actions related to safety and health [ERO-10-06-f.7 Methods and effects of employee involvement regarding OSH issues].

While choosing protective equipment, the employer should attempt to find a balance between the need to ensure effective protection and the requirements of the production process.

Key elements of PPE management system was presented in Figure 2.

Fig. 2 Key elements of PPE management



Source: created by author

Links for further reading
UE –OSHA – European Agency for Safety and Health at Work, Report – Gender issues in safety and health at work, 2003. Retrieved on 22 June 2012, from:http://osha.europa.eu/en/publications/reports/209/view?searchterm=None

UE –OSHA – European Agency for Safety and Health at Work, Summary – New risks and trends in the safety and health of women at work, 2011. Retrieved on 22 June 2012, from: http://osha.europa.eu/en/publications/reports/new-risks-trends-osh-women/view

COSHH Risk assessment procedure. Retrieved on 22 June 2012, from: http://www.stfc.ac.uk/she/resources/pdf/sc37chemicalriskassessment.pdf

NIOSH – National Institute of Occupational Safety and Health. Retrieved on 22 June 2012, from: http://www.cdc.gov/niosh/topics/emres/ppe.html

UE –OSHA – European Agency for Safety and Health at Work, European legal requirements relating to work-related MSDs. Retrieved on 22 June 2012, from: http://osha.europa.eu/en/topics/msds/legislation_html

European Agency for Safety and Health at Work Safe maintenance in practice 24 November 2010. Retrieved on 22 June 2012, from: http://osha.europa.eu/en/publications/reports/safe-maintenance-TEWE10003ENC/view?searchterm=PPE%20regulations

OSHA Occupational Safety and Health Administration 2003. Retrieved on 22 June 2012, from:http://www.osha.gov/Publications/osha3151.pdf

EU-OSHA - European Agency for Safety and Health at Work (2009). Risk Assessment. Retrieved 30 September 2012, from: http://osha.europa.eu/en/topics/riskassessment