For the first time in 20 years, the laws regarding Personal Protective Equipment (PPE) clothing are changing. They’re being changed at a European level and despite the fact that we recently triggered Article 50 taking us out of the EU, the new regulations will become law in the UK in just over one year’s time, on 21st April 2018.
It’s a reasonably-sized change. Some examples of the new rules are that now, many CE certificates will now only last for 5 years. This in-built future obsolescence may build in extra costs for FM managers to consider, both for in-house teams and outside contractors. Additionally, there’ll be responsibility assigned for compliance at every level of supply and usage, including the purchaser of PPE.
A manufacturer found not to be adhering to the new rules faces the risk of a fine of up to £5,000 or 3 months in prison. They may be forced to recall from all customers a defective PPE product – potentially an astronomically expensive penalty. If there’s an accident before non-compliance is discovered, a manufacturer is likely to face civil and criminal proceedings.
For FM managers, safety experts Arco advice that, as a matter of course, you do the following when ordering PPE, particularly if something is causing you concerns:
• Ask your suppliers for a declaration of conformity that shows original certification for the PPE you are purchasing.
• Ask your suppliers to define their process for sample testing to ensure safety products continue to meet the required standards.
• Ensure your suppliers are members of the BSiF Registered Safety Supplier Scheme.
• Ask your suppliers to define their process of quality assurance at the manufacturing facility to ensure the products are being manufactured as they were originally certified.
• Always buy from a trusted source.”
The first risk category (Simple PPE) is there to protect people from dangers that a risk assessment might class as a minimal threat to the health and well-being of an employee.
Simple PPE includes risk from superficial mechanical injury, contact with “weak” cleaning materials, prolonged contact with water, contact with hot surfaces at less than 50°C, eye damage through exposure to sunlight and atmospheric conditions not of an extreme nature.
At the other end of the risk spectrum is Category 3 – Complex PPE. These cover risks that may kill or cause traumatic, irreversible damage to an employee’s health.
The listed threats here include risk from substances and mixtures known to be hazardous to health, atmospheres with low oxygen, ionising radiation, high temperatures (air temperature of 100°C or more), low temperatures (air temperatures of -50°C or less), failing from heights, electric shocks, and live working.
Previously at Category 4 under the current system, the following threats have been moved to Category 3 – exposure to harmful bacterial agents, risk of drowning, risk of cuts by hand-held chainsaws, high-pressure jets, bullet wounds, knife stabs, and harmful noise.
The last category is “Intermediate PPE”. This is a catch-all category covering eventualities and risk assessments not met by categories one and three.
Being aware of the rule change is the first important step.
Make sure you do as much reading up on the new way of doing things. Learn all you possibly can learn. The rules have not changed massively from the previous regime but they have changed, nonetheless.
Once you feel comfortable with the new regulations, revisit risk assessments that your in-house team or outside contractors are working on already so that you’re confident that the right PPE fits these jobs.
Try to implement a new set of guidelines (albeit with little change) that you can cascade down to other managers, leaders within your teams, and to your contractors. For the first few times, satisfy yourself that your instructions are being followed satisfactorily.
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