PPE Equipment & Working Safely

Personal protective equipment has been an essential aspect for all tradesmen. PPE refers to special clothing, apparatus, or equipment that protects a user from potential health hazards or risks resulting from workplace exposures. They can include safety helmets, eye protection, safety footwear, safety harnesses, gloves, and high-visibility clothes. Respiratory protective gear which now include surgical masks and hand sanitiser.

PPE is useful in various aspects, although the construction and engineering industry have the most inherent risks of personal injury. The sectors have been the areas where safety measures have mostly been followed.

The Occupational Health and Safety Administration covers widely the safety and life-saving measures employers should follow, although they mainly focus on construction and high-risk workplaces.

However, following the coronavirus outbreak that began in late 2019, there has been a surge in demand for PPE. In the wake of the pandemic and coronavirus, PPEs are now considered essential health safety tools for every occupation.

Organisations need to adopt comprehensive PPE programs to cater to their employees.

Most businesses were asked to close down, while those providing essential services must work under strict compliance with health safety procedures. The procedures include measures to ensure hygiene and protection from the highly contagious virus.

Health and safety is an essential aspect of every business, including in the normal business setting. Employers and self-employed people are responsible for their welfare and that of their employees and clients.

Organisational health and safety programs should incorporate personal protective equipment programs which should include:

Face protection and especially the eyes. Employees should have face shields, safety glasses, safety goggles, laser welding shields, and safety side shields, among others.
Foot protection gear such as boots with puncture-resistant soles.
Fall protection mechanisms such as a personal fall arrest system, lanyards, and harnesses, knee guards, among others.
Head protection gear, including hard hats and helmets.
Hand protective gear such as barrier creams, sanitisers and gloves.
Ear protection, such as earmuffs and earplugs.
Respiratory protection, including dust masks and face supplied-air respirators.
Body protection, including welding leathers, life jackets, skin protection and chemical suits, coverall, and high-visibility vests, among others.

Even though employers have the task of providing the necessary PPE, employees can also bring in their gear. However, the employer has the responsibility of ensuring the equipment meets the required standards. Such employers can be liable when employees perform their duties with protective gear that does not meet the required safety standards.

PPE Last Line of Defence

In the construction and general engineering, PPE should come as the last line of defence. Employers should first ensure the workplace administrative, and engineering controls ensure minimum exposure levels.

Administrative controls should ensure the organisation provides employees with less or zero toxic materials where possible. So, employees do not have to wear protective gear. In the case of poisonous substances or emissions, employee rotation should be at maximum to minimise the period of exposure for the workers. Engineering controls should ensure appropriate ventilation for respiratory purposes, and necessary tools for machinery and equipment tight-fixing.

Covid-19 Impact on PPE and Protective Gear

Although most initiatives are legitimate and geared towards fighting the global pandemic, employers and businesses should be careful while purchasing the equipment. Fraudulent suppliers trade some of them, and others are not clinically tested and proven to be effective, and could thus expose users to more risks of contracting the virus. Institutions are advised to be more stringent with their procurement practices.

The Health and Safety Executive in the United Kingdom has issued an alert concerning the KN95 masks. Face masks are among the basic requirements for workers and even the public as a measure to curb the virus’ spread.

The KN95 masks have been labelled as not having the capacity to provide adequate protection. Therefore, traders must ensure they have compliance documents to show for their products, including Notified Body supporting information.

PPE Regulations

The UK government adopts the EU Regulation of 2016 that applies to PPEs introduced to the market from April 21, 2018. It was implemented by PPE Regulations 2018, although additional recommendations were made in 2020 and published by the EU on March 13.

The suggestions are not a piece of binding regulation but have been adopted by the government for use over a limited time. The adoption follows interests to address the demand for PPEs following the coronavirus outbreak.

The regulations apply to any PPE that is:

Designed and manufactured for a person’s wearing to protect the user from one or more risks related to health and safety.
Equipment connection systems that are not worn or held by a person, and are designed for connecting the equipment to some external devices temporarily.
Interchangeable components of equipment which are useful in protection.

However, the regulations do not apply for PPE:

Designed for military use or in the maintenance of law and order.
Designed for self-defence other than in sporting activities.
For private use protection, for instance, in atmospheric conditions which do not pose extreme threats.
For the face, head, or eye protection of drivers and passengers of motorcycles.
For use on sea vessels or aircraft that are subject to international treaties.

Despite the exemptions, some equipment that appears to be protective equipment may be subject to regulation as medical equipment if they mean to protect the person, such as a surgical mask. A medical gown is a medical device, but when used to protect the patient from the doctor or vice versa, it becomes subject to regulation as a PPE.

All PPEs are required to undergo an assessment procedure based on the relevant risk category as proof of compliance with the essential requirements. According to the 2020 Recommendations, PPEs used for the coronavirus pandemic should continue to meet the safety requirements. Such PPEs are allowed to proceed to the market without the CE mark affixed. Procedures for assessing conformity must be initiated through a Notified Body.

A Notified Body is a group that has the approval of the member states’ authority and notified the EC as to have the competence to perform PPE conformity assessment procedures as per the EU personal protective equipment regulation.

Also, PPEs bought by the government for health workers do not need to undergo conformity tests, provided they were manufactured in line with European standards.

Use of PPE for Protection against Covid-19

All the regulations on PPE include medical equipment that qualifies or is put to use as PPEs. However, due to the increasing demand for the protective gear following the coronavirus outbreak, all merchants, including manufacturers, importers, and distributors, can present the products to the market before they have the CE markings. However, the conformity assessment procedures must have been initiated, and by a notified body.

Workplaces are not encouraged to adopt extra PPEs as a precautionary measure against the coronavirus. However, they can adopt the PPEs in clinical settings or respond to a confirmed coronavirus case.

However, employers or workplaces where there are high risks of contracting the virus, or where the risk assessment report indicates that PPEs are necessary, the equipment can be used. Employers must ensure in such cases that they provide workers with fitting PPEs free of charge.

Further measures instituted as a result of the pandemic include requiring people to stay at home unless for unavoidable circumstances, closure of businesses, but those providing essential services, and stopping public gatherings. Also, individuals should observe social distancing measures where one should be two metres away from colleagues, or a one-metre distance where there are mitigation measures in place and where the two-metre distance may not be achievable.

Face masks can continue to be used in such instances where social distancing is not possible.

They are mandatory in areas such as public transport and other indoor settings. Such PPEs can still be used in the industrial context where employees need protection against workplace risks, including smoke and dust. However, they should not be an alternative to other health and safety measures, such as minimising contact hours.

The measures will help contain the virus spread and save lives. Crucial parts of the regulation have been incorporated into law, setting out what individuals and entities need to do, and what they must not do. The government keeps measures under close monitoring and can relax if the trends show some possibility.

Requirements for PPE Manufacturers

Any person or entity that manufactures or has PPEs manufactured and markets them under their name qualifies as a manufacturer. The manufacturers must ensure that:

Before placing products on the market, ensure that they are manufactured as per the essential health and safety requirements.
Ensure that a relevant conformity procedure has been carried out and provide technical documentation to it.
The manufacturer must then write a declaration of conformity and make sure the product comes with the declaration and a CE mark on the product.
The declaration of conformity and the technical document must be available over the next ten years after introducing the PPE to the market.
The manufacturer should make sure that the necessary procedures remain in place to ensure production continues in conformity with the standards. Any changes in the characteristic, the design, or the harmonised standards concerning the product’s compliance shall be taken into account adequately.
Every product must have a type, batch, or serial number, or any other aspect that will allow for its identification. The manufacturing entity also needs to affix its registered trade name, the trademark, and a postal address. If the product cannot allow such affixing, such details may be included in its packaging or an accompanying document.
The PPE must be accompanied by a set of instructions of use and safety information. The details should be in a clear, legible and easy to understand language.
Manufacturers must protect the health and safety of users by testing the PPEs before presenting them to the market, carrying out investigations on complaints, maintaining a record, and making recalls where necessary, if the products show any signs of non-conformity.

Requirements for Importation of PPE

The UK sets out importers as individuals or entities that present PPEs to the market, after acquiring them from a foreign country outside the EEA.

Such persons or entities must ensure that:

Before introducing the PPEs to the market, the importing entity must ensure that the manufacturers’ appropriate conformity procedures have been carried out. They must ratify that the manufacturer drew up the technical documentation and that the products have the CE marking. The PPEs should also be accompanied by required documents such as the declaration of conformity, and identification markings.
The importers must label their names on the product, the registered trademark and trade name, and postal address. The details can alternatively be {put on the packaging}.
The importer should retain a copy of the declaration of conformity for the next ten years from the date of introduction of the PPEs to the market, and ensure the technical documentation can be presented on demand.
Where appropriate, the importer must conduct sample tests, investigate, and keep a record of complaints or recall in case of non-conformity complaints. The importer should also keep distributors posted on such details.
The PPEs are in safe custody and transported in a manner that does not compromise their conformity with health and safety standards.
Safety information and instructions for use accompany the PPEs. The instruction and safety information should be presented clearly, and legibly and understandably.
The importers must ensure that upon a reasonable request by the UK authorities, they provide all the documentation and information to prove the conformity of their products, or withdraw the PPEs as appropriate. Also, the importer shall notify the UK authorities if the PPEs show any non-conformity and give the details, and any corrective action taken.
Any importer who believes the PPEs presented in the market have non-conformity issues must take corrective action immediately to ensure conformity, or recall the products as appropriate.

Requirements for PPE Distributors

Any person who makes personal protective equipment available on the market, other than the manufacturer and importer, qualifies to be a distributor.

Distributors in the UK market must ensure that:

Every distributor must ensure the PPE has the CE mark and has the information and instructions for use. The information should be relayed in clear and understandable English. The distributor should also ensure that the importer and manufacturer have complied with marking requirements.
The distributor must act with due care to ensure the PPEs conform to the EU PPE Regulation or the health and safety standards.
Distributors who have a reason to believe that the protective equipment they supplied to the market does not conform to the EU PPE Regulation must take corrective action immediately to either bring the products to conformity or withdraw. Where the equipment poses risks to users, the distributors will undertake to notify the authorities in the United Kingdom with details of the risk involved and the action taken.
The distributors must ensure that the equipment under their custody is safe and transported in a manner that does not undermine their state of conformity with the health and safety requirements.
In the case of a reasoned request by the UK authorities, distributors shall provide documentation and information in paper or electronic form to prove conformity in a clear and easy-to-understand language. All distributors shall cooperate with the authorities on actions deemed to eliminate risks posed by the protective equipment, upon request by the authorities.

Conclusion

The information on the novel coronavirus is getting updated every day. The fact that traders at various levels lack a reliable source of the regulation is of concern. The article aims to provide individuals and entities with the details regarding the PPE Regulations to ensure conformity to the pre-existing rules and the 2020 recommendations.

The UK Enforcement Regulation gives enforcement authorities the powers to take the necessary action against individuals and entities that do not conform to the EU PPE Regulations. The UK Market surveillance authorities can also take appropriate measures to ensure the UK market’s withdrawal or restriction of any products that place the health and safety of the UK citizens, the environment, and property at risk.

The authorities should explain the non-compliant item, the necessary actions or advice issued, and the reasons for such action. They can provide an opportunity for dialogue unless a fast response is essential.

Employers and individuals looking for PPEs should also ensure they choose the appropriate PPEs if the equipment is deemed necessary despite the engineering and administrative controls.

Involving employees can be useful, including the workers wearing the equipment to ensure they have fitting equipment, foremen, or safety professionals. After getting the PPEs, they should ensure to educate workers concerning appropriate wearing and use of the products.

Ensure the workers or any users are aware of:

The right wearing, adjustment, fitting, and removal
When and why it is necessary to have the PPE
The appropriate care and maintenance
The indicators of the end of service, especially for protective equipment of single-use

View HM Government PDF:

HM Government: Working Safely During COVID-19 in Other People’s Homes