PPE Requirements (Updated For 2018)
It’s that time of year again, when the PPE (Personal Protective Equipment) regulations are updated. This time, though, it’s a little different, as the new PPE requirements and regulations (which replace the outdated PPE Directive) now affect the entire supply chain, rather than just end users and employers.
Bear in mind that the Personal Protective Equipment at Work Regulations 1992, which lay down the obligations of employers to ensure the correct suitability, provision, maintenance and use of PPE, are still applicable. The 2018 revisions have been grandfathered onto the existing Regulations, bringing them up to date to take into account changing work environments, differing degrees of projected risk, and developments in the use of materials to create PPE for the modern workplace.
Everyone now involved, from manufacturers of PPE equipment down to end-users, must be aware of the changes to PPE requirements. These include:
- Getting the correct level of approval for PPE products
- Making sure the products conform to the Regulations
- Keeping clear and accurate records detailing the design, manufacturing process and testing of PPE equipment before it is offered for general use.
In addition, importers of PPE are required to sample-test where appropriate, unless they can provide clear reasons as to why they shouldn’t.
The Definition of PPE
Because the scope of the PPE requirements and regulations has changed, the definition has also been amended. PPE is now defined as:
“Equipment designed and manufactured to be worn or held by a person for protection against one or more risks to that person’s health or safety.”
This definition also includes a widening of the scope to include PPE that’s been designed for private use to protect against heat, such as oven gloves. So the definition of PPE is no longer confined to the workplace, but now also encompasses equipment sold for private use.
Movement Between Categories
Some PPE has been moved from Category 2 (Intermediate) to Category 3 (Complex). The biggest of these is all types of hearing protection against harmful noise. This includes equipment designed to protect from serious risk, even where the hazard is not immediately obvious.
Noise PPE is now subject to the strictest levels of governance, including rigorous assessment procedures and EU-type examination, as well as ongoing testing and surveillance.
Time Limits on Certificates
One very important change to make a note of is that EU examination certificates for products in Categories 2 and 3 will now be valid for a maximum period of 5 years. This is to bring the PPE Regulation in line with other EU requirements.
Declaration of Conformity
This update applies primarily to manufacturers of PPE. From February, there is now a requirement to provide a Declaration of Conformity that confirms the product meets all the requirements of the current legislation. If a manufacturer is based outside of Europe then the seller or provider bringing the product to market within the EU must provide the Declaration.
An alternative to a full Declaration is a simplified Declaration of Conformity including a single sentence and a reference to the web address where the complete Declaration can be found. These details can be included with the operating instructions.
Declarations of Conformity must be retained for 10 years after the PPE has been brought to market. During the transition period, certificates issued in 2018 will be valid for six years.
What Employers Need to Do
If you oversee purchasing PPE then not only do you need to ensure you are conforming to all Health & Safety requirements by providing the correct type of PPE to your workers, but you are now also responsible for ensuring that your PPE providers meet the new regulations too. This ‘checks and balances’ system ensures that the entire chain is properly policed, with more emphasis on manufacturers to conform to the new PPE requirements and regulations. If you have concerns about the conformity of your equipment, you can take several steps:
- Request a Declaration of Conformity from your manufacturer
- Ask suppliers for details of their sample testing process to ensure compliance, and what their quality assurance at source (at the factory of origin) are
- Make sure your suppliers are member of the BSiF Registered Safety Supplier Scheme
- Always buy from sources you trust
More information on the new PPE Regulations can be found at the European Commission website.
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