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Personal protective equipment (PPE)
Throughout our website we mention personal protective equipment (PPE), it is a factor in the majority of our courses so we thought it might be useful to write an article regarding PPE and what the law actually states and the items covered by this heading.
As an employer, you may need to protect your employees and their representatives from the risk of injury in the workplace. Employers have duties concerning the provision and use of personal protective equipment (PPE) at work and you need to meet the requirements of the Personal Protective Equipment at Work Regulations 1992 detailed below.
Firstly, what is PPE?
PPE is equipment that will protect the user against health or safety risks at work. It can include items such as safety helmets and hard hats, gloves, eye protection, high-visibility clothing, safety footwear and safety harnesses.
Hearing protection and respiratory protective equipment provided for most work situations are not covered by these Regulations because there are other more specific regulations that apply to them. However, these items need to be compatible with any other PPE provided.
What do the Regulations require?
Wherever there are risks to health and safety that cannot be adequately controlled in other ways, the Personal Protective Equipment at Work Regulations 1992 require PPE to be supplied, following suitable and sufficient Risk Assessment.
The Regulations also require that PPE is:
● properly assessed before use to make sure it is fit for purpose;
● maintained and stored properly;
● provided with instructions on how to use it safely;
● used correctly by employees.
Assessing suitable PPE
To make sure the right type of PPE is chosen, consider the different hazards in the workplace and identify the PPE that will provide adequate protection against them; this may be different for each job.
Ask your supplier for advice on the types of PPE available and their suitability for different tasks. In some cases, you may need to get advice from specialists or from the PPE manufacturer.
Another useful source of information is the British Safety Industry Federation (www.bsif.co.uk).
Consider the following when assessing suitability:
● Does the PPE protect the wearer from the risks and take account of the environmental conditions where the task is taking place? For example eye protection designed to protect against agricultural pesticides may not offer adequate protection when using an angle grinder to cut steel or stone.
● Does using PPE increase the overall level of risk or add new risks, eg by making communication more difficult?
● Can it be adjusted to fit the wearer correctly?
● What are the needs of the job and the demands it places on the wearer? For example, the length of time the PPE needs to be worn, the physical effort required to do the job or the requirements for visibility and communication.
● If someone wears more than one item of PPE, are they compatible? For example does using a respirator make it difficult to fit eye protection properly?
Selection and use
When selecting PPE:
● choose good quality products which are CE marked in accordance with the Personal Protective Equipment Regulations 2002 – suppliers can advise you;
● choose equipment that suits the wearer – consider the size, fit and weight; you may need to consider the health of the wearer, eg if equipment is very heavy, or wearers have pre-existing health issues, standard PPE may not be suitable;
● let users help choose it, they will be more likely to use it.
Using and distributing PPE to your employers:
● instruct and train people how to use it;
● tell them why it is needed, when to use it and what its limitations are;
● never allow exemptions for those jobs that ‘only take a few minutes’;
● if something changes on the job, check the PPE is still appropriate – speak with your supplier, explaining the job to them;
● if in doubt, seek further advice from a specialist adviser.
The hazards and types of PPE
Hazards: Chemical or metal splash, dust, projectiles, gas and vapour, radiation.
Options: Safety spectacles – light eye protection (EN166F OR EN166FT), goggles (EN166B), face-shields, visors.
Note: Make sure the eye protection has the right combination of impact/dust/splash/molten metal eye protection for the task and fits the user properly. For example when cutting, grinding, welding or where flying particles occur.
Hazards: Impact from falling or flying objects, risk of head bumping, hair entanglement.
Options: A range of helmets, hard hats and bump caps.
Note: Some safety helmets incorporate or can be fitted with specially-designed eye or hearing protection. Don’t forget neck protection, eg scarves for use during welding. Do not use head protection if it is damaged – replace it.
Does the law require personal head protection on construction sites?
For the vast majority of cases yes – on almost all construction sites the risks of head injury are such that the law requires head protection to be worn.
Construction work should be organised to minimise this risk, for example: preventing objects falling by using scaffolds with toe boards and, if necessary, brick guards. But if after organising work to minimise the risk of head injury, the risks still remain, you should:
Ensure all workers are provided with, and wear, suitable head protection. This is necessary to comply with the Personal Protective Equipment Regulations 1992 which, from 6 April applies to the provision and wearing of head protection on construction sites following the revocation of the Construction (Head Protection) Regulations 1989.
Want to avoid being dealt a knockout blow? Use your head and wear your hard hat. These are the essential health and safety tips you should follow, even if you don’t directly employ the people working on your site.
It is important that you:
Provide hard hats for your workers (and any visitors to your site).
Hard hats should:
● be in good condition. If it’s damaged,throw it away;
● fit the person wearing it and be worn properly;
● not stop you wearing hearing protectors as well (when needed);
● only be obtained from a reputable supplier – there are fake hard hats on the market.
Make sure that hard hats are worn:
● by making it a site rule;
● always wearing your hard hat to set an example;
● checking others are wearing theirs.
Are their any exemptions to the wearing head protection for specific religious groups?
Yes. Section 11(1) of the Employment Act 1989 link to external website as amended by Section 6 of the Deregulation Act 2015 link to external website exempts turban-wearing Sikhs from any legal requirement to wear a safety helmet in a workplace, including a construction site. The exemption applies only to head protection and turban-wearing Sikhs should wear other required personal protective equipment. This exemption applies to any turban-wearing Sikh eg visitors, employees; there is no such exemption for Sikhs who choose not to wear a turban or for other religious groups.
Are safety helmets compulsory?
If there is no risk of injury to the head, then hard hats are not required by law. However, on almost all construction sites, despite controls being put in place, there will almost always be situations where a risk of head injury remains. Where there are such risks, for example, from falling objects or hitting the head against something, suitable head protection should be provided and worn (except for turban-wearing Sikhs). Where turban-wearing Sikhs are working in areas where a significant residual risk of head injury remains, employers should pay particular attention to the control measures that they have in place.
Hazards: Dust, vapour, gas, oxygen-deficient atmospheres.
Options: Disposable filtering face-piece or respirator (FFP1, FFP2, FFP3), half- or full-face respirators, air-fed helmets, breathing apparatus.
Note: The right type of respirator filter must be used as each is effective for only a limited range of substances. Where there is a shortage of oxygen or any danger of losing consciousness due to exposure to high levels of harmful fumes, only use breathing apparatus – never use a filtering cartridge. Filters only have a limited life; when replacing them or any other part, check with the manufacturer’s guidance and ensure the correct replacement part is used.
If you are using respiratory protective equipment, look at HSE’s publication Respiratory protective equipment at work:
A practical guide (see ‘Further reading’). Face fit courses can ensure good fit and practices of Breathing Apparatus.
Hazards: Temperature extremes, adverse weather, chemical or metal splash, spray from pressure leaks or spray guns, impact or penetration, contaminated dust, excessive wear or entanglement of own clothing.
Options: Conventional or disposable overalls, boiler suits, specialist protective clothing, eg chain-mail aprons, high-visibility clothing.
Note: The choice of materials includes flame-retardant, anti-static, chain mail, chemically impermeable, and high-visibility. Don’t forget other protection, like safety harnesses or life jackets.
Is it okay to wear shorts on a construction site?
If the site has a policy on clothing that does not allow shorts then you are expected to follow this rule.
Clothing needs to protect against hazards on site. The main reason for protecting the lower legs is to help guard against cuts, grazes and splinters etc in an environment where any skin damage can lead to infection. Some trades need to keep skin covered for other reasons – eg arc welders are exposed to high levels of ultra violet light that will cause skin damage.
During summer on very bright days it is important to protect against over exposure to sunlight which can cause skin cancer. Cases of malignant melanoma have increased dramatically in recent years.
During cold weather it is important to keep warm, especially when, for example, working at height where the cold can distract and lead to loss of concentration.
The Personal Protective Equipment at Work Regulations 1992 require many factors to be taken into account to ensure that the correct clothing is chosen for a particular task.
Is it suitable for the risk?
Choice of clothing should take into account ambient and artificial lighting conditions at the workplace, and the effect of conditions such as fog and snow.
For some jobs an HV waistcoat, for example, may be all that is needed, but those workers who are particularly at risk, eg from moving vehicles (marshallers or maintenance workers), may need full body HV clothing so that they are as visible as possible to the driver. HV clothing should provide adequate protection both during the day and at night, as well as in adverse weather. As a rule: the darker the conditions or worksite, the greater the amount of HV clothing required.
To be effective HV clothing should be of a colour that will allow the wearer to stand out against the ambient background found in the working environment. In practice the best colours for this purpose are likely to be day-glo, or fluorescent yellow. Where necessary the clothing should also incorporate retroreflective material to make the wearer visible when seen in headlights in poor lighting conditions or during darkness. This may require reflective strips at or below waist level on waistcoats or jackets, or strips on trousers.
Is it suitable for the job?
People working in warehouses may find that some types of loose fitting tabard may snag on moving machinery parts. Also HV coats may be too warm in summer months, in which case, waistcoats or overalls with the appropriate HV qualities could be supplied. Remember: PPE must always be suitable for the work; if the way of working changes – check that the PPE is still suitable.
Is it suitable for the wearer?
HV clothing should be comfortable and fit the wearer properly. It should cause the minimum of restriction in the wearers movement.
Is it compatible with other forms of PPE?
If two or more types of PPE are worn, they should not interfere with each other. Therefore, in the case of aircraft servicing staff for example, protective clothing for chemical spills should also provide the necessary level of conspicuity. Similarly, wet or cold weather clothing should have suitable HV qualities or be capable of being worn under HV garments.
Are there any standards which the clothing should meet?
HV clothing should be manufactured to a recognised standard. The new British Standard for high visibility warning clothing is BS EN 471. This is a harmonised European standard produced with the legal requirements for PPE in mind. Clothing which conforms to the standard is marked with a pictogram like this:
Image of high visibility warning clothing, This is the European standard mark
The first number (X) indicates the class of conspicuity, this depends on the minimum area of conspicuous materials that are incorporated into the clothing, with Class 3 being the best and Class 1 the lowest; the second number (Y) indicates the retroreflection performance with Class 2 being more visible than Class 1 when seen in headlights during darkness. The standard gives specifications for coveralls, jackets, waistcoats, tabards, trousers and harnesses.
From July 1995, new clothing must be ‘CE’ marked to show it meets the new European rules on the manufacture of PPE. Remember: the CE mark only means that the clothing meets the standard. It does not mean it can be used in all situations. HV clothing must be suitable for the actual conditions of use.
● provide any HV clothing needed for the job free of charge to any employees who may be exposed to significant risks to their safety;
● maintain HV clothing in a clean state and in good working order. It should be checked before being given to employees;
● provide storage facilities for clothing when not in use;
● provide adequate information, instruction and training to enable employees to use HV clothing correctly. This should include an explanation of the risks, why the clothing is needed, how and when it should be worn;
● And supervise employees to ensure that they wear the clothing correctly and whenever it is needed.
● Employees should wear the HV clothing provided as instructed by your employer.
● Look after clothing issued to you, check for and report any damage or defects to your employer.
● Use the storage facilities provided when the clothing is not in use.
Remember: damaged or ill-fitting clothing will not protect you properly.
When must high-visibility clothing be worn?
If a construction site has a high-visibility policy then you must follow it. Your employer will provide the equipment and you do not have to pay for it (so long as you look after it and make it last a reasonable time).
High-visibility clothing should be worn in all construction locations where vehicles or plant are operating. This includes drivers when they leave their vehicle. For routine site use it is often sufficient for a tabard (sleeveless top) to be worn.
Some construction operations – for example temporary traffic management workers need a higher standard of high-visibility. This is because public vehicles are moving nearby at higher speed than most construction plant, meaning that drivers need to see hazards from further away to give them time to react. Because of this the requirement includes high-visibility long sleeved jacket and high-visibility trousers.
Hazards: abrasion, temperature extremes, cuts and punctures, impact, chemicals, electric shock, skin infection, disease or contamination.
Options: Gloves, gauntlets, mitts, wrist-cuffs, armlets.
Note: Avoid gloves when operating machines such as bench drills where the gloves could get caught. Some materials are quickly penetrated by chemicals so be careful when you are selecting them, see HSE’s skin at work website (www.hse.gov.uk/skin).
Barrier creams are unreliable and are no substitute for proper PPE. Wearing gloves for long periods can make the skin hot and sweaty, leading to skin problems; using separate cotton inner gloves can help prevent this. Be aware that some people may be allergic to materials used in gloves, eg latex.
Gloves can also be used to minimise the vibration of machines (in accordance with the machines Risk Assessment), and there for the exposure to HAVS – Hand Arm Vibration syndrome.
Hazards: Wet, electrostatic build-up, slipping, cuts and punctures, falling objects, metal and chemical splash, abrasion.
Options: Safety boots and shoes with protective toe caps and penetration-resistant mid-sole, gaiters, leggings, spats.
Note: Footwear can have a variety of sole patterns and materials to help prevent slips in different conditions, including oil or chemical-resistant soles. It can also be anti-static, electrically conductive or thermally insulating. It is important that the appropriate footwear is selected for the risks identified.
Do I have to wear safety footwear on a construction site?
Yes. Construction workers are expected to wear protective footwear whilst on site and doing heavy work. The bones in the foot are quite delicate and easily damaged and any muscle or tendon damage can prevent normal movement for several months. Steel toecaps (or equivalent) protect against dropped objects. Midsole protection (usually a steel plate) protects against puncture or penetration if you tread on a nail. If you need to enter or work on a construction site your employer will provide a basic standard of safety footwear. You do not have to pay for this so long as you look after it and make it last a reasonable time. If there are medical reasons why you cannot wear basic safety footwear your employer will pay for
Ensure any PPE you buy is ‘CE’ marked and complies with the requirements of the Personal Protective Equipment Regulations 2002. The supplier/manufacturer should be able to tell you if the PPE is suitable for the type of task.
Is it okay to wear Rigger boots on a construction site?
Over recent years rigger boots have become popular because they are easy to put on and are a cross between lace up boots and wellingtons. However some companies have found that wearers of rigger boots are much more likely to suffer twisted or sprained ankle injuries. They think this is because rigger boots are a looser fit and the wearer is less able to prevent the foot from twisting to the side on uneven ground. This is the reason that some contractors will not allow them on site. This is an acceptable argument and you need to understand and comply with this rule.
Lace up boots are not normally suitable for licensed asbestos work within an enclosure.
There is a history of cement burns where cement has gone into the safety shoe or boots and wellington boots may provide more protection for groundwork using cement.
Is there a noise problem where I work?
If any of the following apply, your employer would be expected to be doing something about noise:
● the noise is intrusive – like a busy street, a vacuum cleaner or a crowded restaurant – or worse, for most of the working day;
● you have to raise your voice to have a normal conversation when about 2 m apart, for at least part of the day;
● you use noisy powered tools or machinery for over half an hour a day;
● the type of work is known to have noisy tasks, eg construction, demolition or road repair; woodworking; plastics processing; engineering; textile manufacture; general fabrication; forging or stamping; paper or board making; canning or bottling; foundries; waste and recycling;
● there are noises because of impacts (such as hammering, drop forging, pneumatic impact tools etc), explosive sources such as cartridge-operated tools or detonators, or guns.
Another sign that something should be done about the noise is having muffled hearing at the end of the day, even if it is better by the next morning. If you have any ear or hearing trouble, let your employer know.
What does my employer have to do?
Your employer should be looking at:
● using quieter equipment or a different, quieter process;
● engineering/technical changes to reduce the noise at source;
● using screens, barriers, enclosures or absorbent materials; laying out of the workplace to create quiet workstations;
● improved ways of working to reduce noise levels;
● limiting the time you spend in noisy areas.
Your employer should be consulting you or your workplace representatives on these things.
What do I have to do?
Co-operate Help your employer to do what is needed to protect your hearing. Make sure you use properly any noise-control devices (eg noise enclosures), and follow any working methods that are put in place.
Wear any hearing protection you are given Wear it properly (you should be trained how to do this), and make sure you wear it all the time when you are doing noisy work, and when you are in hearing protection zones. Taking it off even for a short while really reduces the overall protection you get, meaning your hearing could still be damaged
Look after your hearing protection Your employer should tell you how to look after it and where you can get it from. Make sure you understand what you need to do.
Attend for your hearing checks It is in your interest that any signs of damage to your hearing are detected as soon as possible, and certainly before the damage becomes disabling.
Report any problems Report any problems with noise-control devices or your hearing protection straight away. Let your employer and any workplace representative know.
Note: all of the above are legal duties on you.
Hearing protection such as earmuffs and earplugs is your last line of defence against damage. Your employer should provide it, and train you how to use it and how to get replacements. There are many different types and designs available,
and your employer should consult you and offer a choice.
They should totally cover your ears, fit tightly and have no gaps around the seals. Don’t let hair, jewellery, glasses, hats etc interfere with the seal. Keep the seals and the insides clean. Don’t stretch the headband – the tension is crucial to protection. Helmet-mounted earmuffs can need particular care to get a good seal around your ears.
They go right in the ear canal, not just across it. Practise fitting them and get help if you are having trouble. Clean your hands before you fit earplugs, and don’t share them. Some types you use only once, others can be re-used and even washed – make sure you know which type you have.
These are held in or across the ear canal by a band, usually plastic. Check for a good seal, every time you put them on. Follow the same general advice as for earplugs and make sure any band keeps its tension.
● Make sure anyone using PPE is aware of why it is needed, when to use, repair or replace it, how to report it if there is a fault and its limitations.
● Train and instruct people how to use PPE properly and make sure they are doing this. Include managers and supervisors in the training, they may not need to use the equipment personally, but they do need to ensure their staff are using it correctly.
● It is important that users wear PPE all the time they are exposed to the risk. Never allow exemptions for those jobs which take ‘just a few minutes’.
● Check regularly that PPE is being used and investigate incidents where it is not.
● Safety signs can be useful reminders to wear PPE, make sure that staff understand these signs, what they mean and
where they can get equipment, eg for visitors or contractors.
● equipment is well looked after and properly stored when it is not being used, eg in a dry, clean cupboard, or for smaller items in a box or case;
● equipment is kept clean and in good repair – follow the manufacturer’s maintenance schedule (including recommended replacement periods and shelf lives);
● simple maintenance can be carried out by the trained wearer, but more intricate repairs should only be done by specialists;
● replacement parts match the original, eg respirator filters;
● you identify who is responsible for maintenance and how to do it;
● employees make proper use of PPE and report its loss or destruction or any fault in it.
Make sure suitable replacement PPE is always readily available. It may be useful to have a supply of disposable PPE, such as dusk masks for visitors etc who need protective clothing.
Ensure any PPE you buy is ‘CE’ marked and complies with the requirements of the Personal Protective Equipment Regulations 2002. The CE marking signifies that the PPE satisfies certain basic safety requirements and in some cases will have been tested and certified by an independent body.
The PPE at Work Regulations do not apply where the following five sets of regulations require the provision and use of PPE against these hazards. For example, gloves used to prevent dangerous chemicals penetrating the skin would be covered by the Control of Substances Hazardous to Health Regulations 2002 (as amended). The Regulations are:
● The Control of Lead at Work Regulations 2002.
● The Ionising Radiations Regulations 1999.
● The Control of Asbestos Regulations 2012.
● The Control of Substances Hazardous to Health Regulations 2002 (as amended).
● The Control of Noise at Work Regulations 2005.
Key points to remember
Are there ways other than using PPE to adequately control the risk, eg by using engineering controls? If not, check that:
● suitable PPE is provided;
● it offers adequate protection for its intended use;
● those using it are adequately trained in its safe use;
● it is properly maintained and any defects are reported;
● it is returned to its proper storage after use.
Can I charge for providing PPE?
An employer cannot ask for money from an employee for PPE, whether it is returnable or not. This includes agency workers, if they are legally regarded as your employees. If employment has been terminated and the employee keeps the PPE without the employer’s permission, then, as long as it has been made clear in the contract of employment, the employer may be able to deduct the cost of the replacement from any wages owed.
This information was gathered from the HSE website, on various pages and publications and compiled to help with the understanding of personal protective equipment (PPE) requirements as work.
If you would like to discuss this or any training please Contact us at Kentra Training.