Plant & Works Engineering
New PPE Regulation - a welcome health check
Published:  07 March, 2017

The key European rules regulating the equipment used to protect workers have been left unchanged for more than 20 years. However, a new Personal Protective Equipment (PPE) Regulation (2106/425) will introduce key changes to the way PPE is manufactured, sold and imported within the European Union. Irrespective of Brexit, the legislation offers UK manufacturers of PPE, employers and safety managers a unique opportunity to reassess occupational health and safety. Olivier Touchais, global manager for general safety at Honeywell Industrial Safety, reports.

Due to replace the existing Directive 89/686/EEC on 21 April 2018, Regulation (EU) 2016/425 sets common quality standards for PPE in all Member States to enhance the European workforce’s health and safety. Unlike the Directive, it will apply to the entire supply chain: manufacturers, distributors and importers of PPE [1]. Following a one-year transition from the PPE Regulation’s implementation, all these ‘economic operators’ will have to ensure that any new products they place on the EU market are recertified to retain the CE classification that makes these eligible for sale.

Whereas the UK is now set to leave the EU, it will most likely still be a Member State when the PPE Regulation comes into force and the legislation will be legally binding. The British Safety Industry Federation (BSIF) believes that, even after Brexit, the British health and safety sector will still want to comply with the legislation, which will be the standard mandate throughout international supply chains [2]. In other words, if the UK sets its own rules and standards, it will be extremely difficult for its businesses to trade in PPE, not only with EU countries, but also with a significant number of affiliated markets where the PPE Regulation will apply [3].

Perhaps more importantly, the UK has long been at the forefront of occupational health and safety both in terms of legislation and best practice. With this in mind, it is likely that, even after Brexit, the country will want to continue abiding by such an important international set of rules, one that is designed to enhance worker protection. The BSIF has stressed the importance of continuing to ensure that safety and health is acknowledged as an important sphere in government policy. That, and helping to supply the market with quality PPE through a capable supply chain [3] is good business practice.

The UK has one of the best safety records in the world, which has been achieved through the efforts to reduce the number of fatalities and injuries following the introduction of the Health and Safety at Work Act 1974 [4]. More recently, the country’s health and safety sector has been among the main international influencers in the fight against occupational diseases, highlighted in campaigns like the Institution of Occupational Safety and Health’s No Time to Lose [5] and the Health and Safety Executive’s new Helping Great Britain Work Well strategy [6]. In other words, there has been a shift from a predominantly physical injury-focused approach to one that looks at long-term conditions, such as respiratory illnesses, musculoskeletal disorders (MSD) and noise induced hearing loss (NIHL).

The new PPE Regulation goes in the same direction. While it maintains the PPE Directive’s three categories, it associates PPE with risks rather than pieces of equipment. So, for example, instead of hearing protection, it refers to ‘harmful noise’, which is now classified as Category III: the highest risk category (risks likely to lead to severe health problems or death). This is just one indication of how the Regulation assigns previously neglected occupational illnesses the importance they deserve, with the effects of hearing loss now seen as severely damaging to a person’s quality of life.

This vision is at the heart of the more rigorous approach to the way PPE is tested and certified, one that promotes higher levels of worker protection. The PPE Regulation introduces a five-year validity period on EU Type Examination Certificates: when a manufacturer renews certificates for their products, they will need to make sure these meet the latest industry standard – typically from the EN or ISO series. For PPE moving from Category II to III, manufacturers will also need to either provide random samples of their products at regular intervals – typically once a year – to EU notified bodies (such as testing companies and national standards organisations) or subject themselves to factory audits. These new rules will give employers, safety managers – and ultimately workers – more assurance that the PPE they’re using meet the latest quality standards and is entirely fit for their specific purposes in their facilities.

Having periodic reassessments is key to ensuring that workers are protected and use the right type of PPE. This is because standards are regularly updated – often in line with PPE technology innovations - to offer the highest levels of accuracy in measuring PPE performance. Take cut-resistant gloves. Over the last decade, manufacturers of PPE have continued to develop glove technology to enhance the quality of products, using a range of innovative materials such high performance polyethylene (HPPE), glass and steel fibres. Being unable to measure the real performance of these new materials, the standard for cut-resistant gloves - EN 388 (which relied on the coupe test) - was recently updated. The introduction of a new test method (ISO 13997 TDM) and user-friendly markings will make it easier for safety managers and workers to select the right level of cut protection. The PPE Regulation will ensure that all new gloves will comply with these latest standards.

It is important that employers and safety managers familiarise themselves with the changes that the PPE Regulation will introduce. Careful management of the one-year transition period will be crucial. During this time, products that meet both the current EU Directive and the forthcoming Regulation will exist on the market. Safety managers that receive the same product but with different packaging and certification may not understand, for instance, why identical products do not have the same notice of usage nor different certification references. If employers want to ensure their workforce is provided with PPE that meets the highlights and most up-to-date quality standards, it is vital that they source PPE from a trusted partner, one that can help them understand the transition process and fully grasp any changes in regulatory requirements.

Regulatory compliance is paramount, but often it is not enough to ensure that workers are kept safe and healthy. The importance of the PPE Regulation, and its renewed focus on risk, lies in its potential to offer both manufacturers of PPE and businesses an opportunity to go beyond a purely ‘compliance-driven’ approach.

On the manufacturing side, there is the opportunity to look at the entry point of standards and use specialty materials to create products that build in a level of redundancy to not only meet quality requirements, but go beyond them. Equally, manufacturers of PPE will continue to work with users to make sure products are fit for purpose, as there is no such a thing as ‘one size fits all’.

Additionally, the growth in IoT (Internet of Things) means ‘connected’ PPE will enable safety managers to access vast streams of data that can be used to ensure workers receive the right training in the use of their protective equipment and that this is up to date, well-maintained and fit for purpose. By embedding sensors in PPE and integrating this with cutting-edge software, the latest technology enables businesses to develop an overall safety ecosystem to monitor, track and control exposures. The intelligent, real-time data this approach offers can be used to not only help prevent occupational illnesses like NIHL, but also enables businesses to make informed decisions quickly and so reduce costs and downtime whilst increasing worker productivity. It also means workers can concentrate on the job at hand rather than worry about whether their equipment is working properly.

Employers and safety managers will also have a key role to play, by adopting a safety strategy that includes offering regular training, encouraging feedback from workers and disseminating best practices. Demonstrating that you care about the health, safety and wellbeing of workers can go a long way towards instilling positive safety behaviour and increasing staff retention, especially in competitive industries – such as oil and gas and the utilities – where specialist skills are in demand.

Ultimately, PPE is the last line of defence against injury. Workers want to have absolute confidence that they are being sufficiently protected, and employers want to have confidence that they are investing in a product that will protect their greatest asset: their people. The fact that EU legislation is addressing these key issues is welcome. Especially in a country like the UK, where health and safety organisations have traditionally striven to enhance worker protection ‘beyond compliance’, the PPE Regulation can offer an ideal framework to take occupational health and safety to the next level. It should, therefore, remain at centre stage however the UK’s exit from the EU eventually pans out.

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7. The PPE Regulation will also be applicable in the four members of the European Free Trade Association (Switzerland, Norway, Iceland and Liechtenstein), the two candidates to the European Union (Turkey and the former Yugoslav Republic of Macedonia) and 16 affiliated countries (Albania, Armenia, Azerbaijan, Belarus, Bosnia and Herzegovina, Egypt, Georgia, Israel, Jordan, Lebanon, Republic of Moldova, Montenegro, Morocco, Serbia, Tunisia, and Ukraine).