As a Health and Safety Professional I have often found that although personal protective equipment (PPE) is provided by management for employee use, the choice is not always cost effective or appropriate, e.g. it does not necessarily provide the correct type of protection, and it can be over prescribed.
To assist companies in the introduction of PPE risk management and control measures, I have assisted in the development and introduction of a PPE training course, which will enable supervisors and employees to carry out PPE risk assessments and introduce simple management techniques to ensure that they comply with legislative requirements and continually improve health and safety performance – at the same time provide the most cost effective PPE solutions.
The legal duties and obligations around PPE are The Personal Protective Equipment at Work Regulations 1992, which seek to ensure that where risks cannot be controlled by other means, Personal Protective Equipment is correctly selected and used.
PPE used in heavy industry
In shipbuilding, ship-repairing and engineering activities there are many hazardous processes where PPE is used as the first choice of protection against workplace hazards, as opposed to considering its use as the last resort.
To comply with legislation and reduce health risks, PPE must always be regarded as a ‘last resort’ to protect workers against risks to safety and health. Engineering controls and safe systems of work should always be considered first. For example, it may be possible to carry out a workplace task using methods that will not require the use of PPE.
If this is not possible, more effective safeguards should be explored and if appropriate, put in place. For example, when welding and grinding activities are being carried out, fixed screens could be provided as well as individual eye protection, to prevent injuries to other employees working in the vicinity.
There are a number of reasons why PPE must be considered as a ‘last resort’:
• PPE only protects the person wearing it, whereas measures controlling the risk at source protect everyone in the workplace
• The correct levels of personal protection can be difficult to achieve and the actual level of protection is difficult to assess. Effective protection can only be achieved by selecting suitable PPE, ensuring that it is correctly fitted, maintained and used appropriately for the required task
• PPE can restrict the wearer to some extent by limiting mobility or visibility when carrying out certain tasks, thus creating possible additional hazards
Hazardous work activities
Some of the hazards encountered in shipbuilding and vehicle manufacturing processes include painting/spraying, shot-blasting, steel cutting using gasses, welding, drilling, grinding, caulking and burning, steel fabrication, lifting, slinging, forging, sheet-metal working, transferring large objects, plumbing, out-fitting, working in confined spaces and at height, lifting and handling, working with hazardous substances, noise and vibration, fumes from welding and hot processes, painting, galvanising, vapours and hazardous fumes from various processes.
Health hazards from processes
The hazards from the various manufacturing processes include induced hearing loss, crushing of feet, legs and upper body parts, entanglement, projectiles/impact, chemical burns, radiation, arc welding eye flash burns, hot metal and chemical splashes, cuts from sharps, biological and chemical hazards, respiratory hazards from dust and extreme hot and cold working temperatures.
Various types of PPE are used in the above manufacturing processes to protect employees from respiratory, face, eyes, head and neck, hearing, upper body, arms, hands, legs, knees, feet and leg hazards. Typical PPE equipment to protect individuals from these hazardous processes also includes clothing to provide protection against inclement weather. PPE is intended to be used by a person at work, to provide protection against one or more of the above risks to their health and safety.
PPE includes equipment such as safety footwear, gaiters, leggings, spats, hard hats, bump caps, helmets, hoods, high visibility waistcoats, goggles, face shields, life jackets, respirators, full air-fed masks, half face filtered masks, safety harnesses, ear plugs, ear defenders and moulded acoustic filtered plugs.
Examples of protection include safety glasses and goggles for eyes, shields and hoods for face, helmets and bump caps for head, safety shoes for feet, gloves and gauntlets for hands and arms, vests and aprons for body and ear plugs and muffs for hearing protection.
Waterproof, weatherproof, or insulated clothing is subject to the regulations only if its use is necessary to protect employees against adverse climatic conditions that could otherwise affect their health and safety.
The sheer diversity of the above demonstrates the obvious need for the introduction of PPE training and techniques in these and many other industry processes. Introducing PPE training will ensure that good working practices are cost effective, reducing health and safety risks and possible subsequent employee claims.
Appropriate PPE training techniques
Where PPE is provided by employers, they must arrange for suitable health and safety training which must include appropriate information and instruction in its safe use and maintenance.
The extent of information, instruction and training will vary with the complexity and performance of the equipment. For example, a full Breathing Apparatus kit (BA) will require more detailed training in its use than a disposable face mask.
Information and instruction should cover:
• The risk(s) present and why the PPE is needed
• The operation (including demonstration), performance and limitations of the equipment
• Use and storage (including how to put it on, how to adjust and remove it)
• Any testing requirements before using the PPE equipment
• Appropriate user maintenance that can be carried out (e.g. hygiene and cleaning procedures plus records)
• Factors that can affect the performance of the equipment (e.g. working conditions, personal factors, defects, damage and contamination)
• How to identify defects in PPE, and the reporting procedures
• The procedure to obtain replacement PPE
In addition to the initial training, supervisor checks will help to determine whether refresher training is required.
PPE Policy and Guidance
To ensure that appropriate PPE methodologies, techniques and best practices are introduced and maintained, a strategic policy needs to be produced to include PPE risk assessment, advice and guidance for supervisors and employees.
The policy should include:
1. The legal duties
2. Policy statement and aim
3. Scope of documen
4. Organising for PPE Health and Safety
5. Promoting a positive PPE culture
6. Managers’ Responsibilities
Managers are responsible for ensuring that they have a comprehensive understanding of PPE requirements and must ensure that their staff understand and comply with the policy. This includes whatever PPE requirements are considered appropriate when risks are assessed.
Suitable PPE is provided as appropriate to all their employees, is properly stored, maintained, cleaned, repaired and replaced when necessary.
Adequate information and training is provided to those who require PPE and any injuries, ill-health or incidents relating to the use of PPE are reported and addressed. PPE provided is used properly and PPE is monitored and reviewed. Special arrangements are implemented, where necessary, for individuals with health conditions that could affect the use of PPE.
7. Employee Responsibilities
Employees have a responsibility to ensure that they use all PPE provided in accordance with the manufacturers’ instructions and the information, and instruction and training they have received. Check the condition of their PPE, store, clean and maintain their PPE. Report losses, defects or other problems with PPE to their manager and report any personal conditions that may affect their ability to use PPE.
8. What is PPE?
PPE is equipment that is intended to be worn by a person to protect them from risks to health and safety while at work. The correct selection of PPE will depend on the risk and any subsequent hazards from the workplace task, which should be assessed by a competent person as part of the risk management process.
9. Selection of suitable PPE
Following a PPE risk assessment, the potential hazards will be identified and there may be several types of PPE that would be suitable. For example, when assessing the need for eye protection, employers need to identify the types of hazard present, such as liquid splashes, excessive heat or projectiles, and then assess the degree of risk, such as the composition of the liquid, operating temperatures or likely size and velocity of projectiles. The employer can then select the most appropriate type of PPE to provide the necessary protection.
10. When to use PPE
PPE is not always necessary or appropriate where the likelihood of an employee being injured by a hazard which has been risk assessed is considered to be very low, or insignificant. For example, in most workplaces there will be some risk of employees dropping objects onto their feet, but it is only when there is manual handling of items which are heavy enough to injure the feet that the risk will be high enough to require the provision of safety footwear.
When providing PPE for employees, the employer needs to ensure that sufficient equipment is readily available, and that employees have clear instructions on where they can obtain it. Most PPE is provided on a personal basis, but sometimes it may be shared by employees, for example where it is only required for limited periods. When equipment is shared, employers need to ensure such equipment is properly cleaned and, if necessary, it should be decontaminated to ensure there are no health risks to the next employee using it.
11. Risk Assessment of PPE
Before choosing any personal protective equipment, employers are required to ensure that an assessment is carried out to determine whether the personal protective equipment they intend to provide will be suitable in providing protection against workplace hazards.
A competent workplace assessor must take into consideration any risk or risks to health or safety which cannot be avoided, or protected against by other means. If PPE has to be used in order to protect the employee against identified risks, then the selected PPE must also be assessed to determine if it is compatible with any other personal protective equipment which may also have to be used simultaneously. For example, if a person is wearing a safety helmet and he needs to also wear hearing protection at the same time, then it may be necessary to provide ear muffs that can be attached to the helmet to provide the dual protection required for head and ear protection.
Employers also have to ensure that their assessment is reviewed if there is any reason to suspect that it is no longer valid, or there has been a significant change in the working practice or process to which it relates. The purpose of the assessment is to ensure that the employer who needs to provide PPE chooses PPE which is correct for the particular risks involved, and for the circumstances in its use. In the simplest of workplace tasks which can easily be repeated and explained at any time, the assessment to identify suitable PPE need not be recorded; however, in more complex assessments it is advisable to record the assessment and keep it readily accessible for employee information, or in respect of an employee insurance claim, Health and Safety Executive (HSE) improvement, or prohibition notice against the organisation.
12. Suitability of PPE / Fit Test
There is a wide range of CE marked PPE equipment available which has been specifically designed to provide various levels of protection for employees who need to wear it in certain working conditions. PPE manufacturers and suppliers have legal duties to provide product information to help employers make the correct choice of PPE for different working applications. This information is usually in the form of a performance specification which conforms to European (EN) or International (ISO) standards. Key PPE design requirements include tests on product performance, labelling to identify the level of protection and what instructions should be supplied with the PPE.
When it comes to personal protective equipment, different manufacturers will attempt to make their products as effective and attractive as possible. However, few will give sufficient thought as to how their PPE will work in practice, with a whole selection of PPE which is designed for other purposes. This can often result in the equipment being incompatible with another piece of equipment, resulting in it interfering with the protection provided by other equipment. Employers are responsible for ensuring that each piece of PPE works in conjunction with other protective items. In simplest terms, compatibility means the PPE must fit together comfortably and provide integral protection for the worker against workplace hazards.
At the end of this process, a range of potentially suitable PPE should be identified to match the end user’s requirements with regard to fit, comfort, wearability and appropriate levels of personal protection. PPE must be comfortable to wear for long periods and not affect the health of the wearer. If employees experience discomfort when using PPE, they will soon stop wearing it, which could result in serious health risks and possibly loss of life.
The effects on the wearer of non-compatible or unsuitable PPE can range from minor discomfort to more serious health problems, or possibly a very dangerous level of distraction from the task in hand.
The best way to avoid this type of problem is to involve employees in PPE trials and decisions about equipment they are required to wear. This type of end user involvement should result in higher levels of equipment usage and in minimising or eliminating near misses and workplace accidents.
As a suggestion, PPE users could be asked to complete a simple PPE questionnaire asking their opinions about each piece of equipment they try. For example:
• Was the product comfortable?
• Did it provide suitable and satisfactory protection?
• Was sizing a problem – did it fit correctly?
• If a replacement product, how did it compare with what was used before?
13. Accommodation and Maintenance of PPE
To prevent PPE damage and possible contamination, employers must ensure that suitable arrangements are in place to enable employees to safely store their PPE when not in use to prevent against damage from chemicals, sunlight, high humidity, heat and accidental damage.
The storage arrangements can be quite simple. For example, a clothing hook fitted in a clean indoor room would suffice to hang weatherproof clothing, and a safety helmet, and other items could be kept in suitable containers.
PPE needs to be maintained in accordance with the manufacturer’s instructions and replaced as appropriate. It is good practice and a legislative requirement to have an effective PPE maintenance system in place which includes examining each item for faults, damage, wear and tear and contamination. A simple testing procedure is required for certain types of PPE and more detailed tests are necessary in accordance with the manufacturer’s operating instructions. PPE repair and replacement is also necessary and examination of equipment should be carried out by appropriately trained staff. In general, PPE should be examined to ensure that it is in good working order before being issued to the user.
14. PPE Information, Instruction and Training
The PPE regulations require employers to provide suitable information, instruction and training for their employees, to enable them to make effective use of the PPE that they provide, and to enable them to make effective use of the PPE to protect them against workplace hazards.
A systematic approach to training is required for everyone who is involved in the use of PPE. The extent of the instruction and training will vary with the complexity and performance of the equipment.
The extent of training that is required will depend on the type of PPE equipment, how frequently it is used and the needs of the people being trained.
Employees will require theoretical training in PPE techniques and an explanation of the risks to understand and be made aware of why it is needed, when it is to be used, repaired or replaced – and its limitations. It is important to ensure that anyone using PPE receives practical training and instruction on how to fit and use PPE properly by carrying out classroom demonstrations in its correct use.
When carrying out training employees should receive copies of manufacturer’s advice sheets to enable easier understanding of the safety requirements for PPE use. This is necessary as PPE is the last resort after other methods of protection have been considered.
It is important that users understand and wear PPE all of the time they are exposed to the risks, and fully understand that they should never allow themselves exemptions for those tasks which might only take a few minutes.
Once an organisation has undertaken PPE risk assessment and specified the appropriate equipment and level of training required for staff, the correct use and maintenance of the various types of equipment will become the key issues. Regular equipment inspections should be carried out and recorded to ensure health and safety compliance, and also to encourage 100% usage among PPE wearers.
The storage and use of equipment, the ongoing training of employees in using PPE, the keeping of up-to-date records and the reporting of loss or damage to equipment must also be monitored by employers, and also end users, on a daily basis when being used.
The HSE recommends that companies incorporate a PPE compatibility strategy into their formal management systems. Introducing such a strategy will provide the necessary and vital framework to achieve continuous improvement in health and safety performance through standard setting, monitoring and reviewing the performance of PPE.
Bill Knowles Director of Course Development Vision Safety Associates LTD
E: e-mail [email protected] W: http://www.visionsafety.co.uk T: +44 (0)7802 350673
My health and safety experience spans in excess of 35 years and includes working as a Shipbuilding Group Health and Safety Manager, Sub Contractor Health and Safety Controller and as a Chartered Safety Professional in a number of medium to high risk organisations which include shipbuilding, ship-repair, manufacturing, engineering, policing and the voluntary sector. I am a member of the following professional bodies:
• Chartered Member of IOSH
• Member of the International Institute of Risk and Safety Management
• Fellow of The Royal Society of Environmental Health
A brief summary of my Health and Safety Qualifications :
• NEBOSH Health and Safety Management Diploma
• Royal Society of Health Construction Diploma (distinction)
• IOSH National Health and Safety Certificate
• National Examination Board of Supervisory Management Certificate
• Institute of Noise and Vibration Certificate
• O U Degree Course Qualification in Health and Social Welfare
Points of interest :
• Regional health and safety award for developing innovative supervisory safety training course
• British Safety Council Awards achieved for two separate companies
• HSE award for safety poster design
• Chief Constable’s Commendation for Health and Safety
• Provided health and safety training for Children’s Camp Volunteers
Published: 01st Aug 2010 in Health and Safety Middle East