Not all PPE equipment is created equal
Neil Hewitt, Divisional Director Quality and Technical Standards at Arco discusses the issues of non-compliant, CE marked, Personal Protective Equipment and the steps the industry can take to minimise the risk of these products entering into the European market.
Despite Personal Protective Equipment (PPE) having the required EC type approval and CE mark, recent tests have indicated that some of the products you assume to be safe, may not actually be fit for purpose.
The seriousness of this issue was recognised by the British Safety Industry Federation (BSIF), when it wrote to its members saying: ‘This situation poses an obvious risk to end users, and is a timely reminder that only relying on CE certification for certain product types is no guarantee of ongoing quality assurance.’ Furthermore, the BSIF is calling on all those in the industry to make certain and ensure their supply chain routes are fully aligned to provide safe, legal and fit for purpose PPE. As the UK’s leading safety company, with representation on the BSIF’s Federation Council, we take these issues very seriously.
In February of this year, the new PPE regulation was adopted by the European Parliament, reclassifying some products, introducing a five year limit on CE certificates and clearly identifying the obligations of all economic operators in the supply chain. Economic operators include manufacturers, distributors and importers. It also clearly defines that an importer or distributor who markets a product in Europe under their own name, brand or trademark becomes liable for the full manufacturer’s obligations. Although this will be a good step forward for the industry, and the period for these changes to be implemented could take until 2018, we need to act now.
The United Kingdom is one of the key regional markets for PPE in Western Europe, where the supply of high quality and reliable products continues to be the number one customer consideration when purchasing PPE equipment. With the continued growth of the industry and employer’s increasing concern for the safety of their employees, the importance of robust legislation to protect workers is of paramount importance.
The document that currently underpins the legislation is the PPE Directive 89/686/EEC. The role of which is to ensure that suppliers of protective equipment follow the correct approval procedures before placing the product on the market. Category two and three items of PPE must follow an EC type approval and carry the ‘CE mark’ to prove certification. Whereas category one or minimal risk PPE are self certified and CE marked by the manufacturer after they assess the product against the essential health and safety requirements of the PPE directive. However, worrying data has emerged that with the growth of the industry, comes the increased risk of CE marked products that do not conform, which could result in an individual not being adequately protected during an accident.
Inadequate PPE in the market
There appears to be procedural weaknesses within the EC type approval and CE marking process. These weaknesses can allow a less reputable manufacturer or importer to gain CE certification for products they wish to market and then subsequently make changes to the product. These changes could impact on the product’s safety performance as further testing may not be conducted as the CE certificate is already available. Although, manufacturers of category three PPE are required to have a third party monitoring process in place for the actual product or a quality management system, there is no third party production monitoring process for category one or two PPE. It is up to the manufacturer to ensure the product continues to conform to the standards. Currently the UK’s competent authorities for market surveillance of PPE are under increasing pressure due to reduced budgets and this may be exploited by less reputable manufacturers.
Toe cap failures
An example of these failures came to light when Arco performed a number of tests on safety footwear toecaps, products at the front line of safety across a wide range of industries. Traditionally toe caps were made from steel to ensure toes were not crushed in the event of an accident, but non-metallic materials have entered the marketplace, offering lightweight design and the ability to minimise disruption in security areas and specialist manufacturer where metal detection is required. Some of the non metallic toe caps in terms of construction are made from composite glass fibre and others are injection moulded thermoplastics.
Arco carried out product assurance compression testing, in our UKAS and SATRA independently accredited lab, on own brand footwear along with a sample of footwear currently available on the market. During the testing, it became apparent that the safety footwear using some injection moulded plastic toe caps in their construction performed significantly worse than the fibreglass composite toe caps during compression testing. What does this mean for the wearer of the boots? If the foot is compressed, these substandard toes caps would not protect the wearer as intended, resultant injuries being broken bones or even amputation. The use of a thermoplastic toe caps in safety footwear construction is not immediately evident and purchasers are relying on the CE mark being accurate.
This worrying issue has compelled Arco to assure our customers that we do not allow the use of sub-standard thermoplastic toe caps in the construction of our own brand products. We have also highlighted the issue to all proprietary footwear brands in the Arco catalogue and have requested they confirm the type of toe cap used within their footwear.
Safeguarding as an industry
As the UK’s leading distributor, we take the issue of safety very seriously and are the only distributor in the UK to have invested in developing our own Product Assurance Laboratory for the testing of PPE. With our own brand product offering, we comply with the obligations laid down by the EU Parliament. We ensure continued conformity via an internal testing program within our own laboratory and where necessary third party accredited testing laboratories.
We are also members of the BSIF Registered Safety Suppliers Scheme (RSSS). Companies displaying the scheme’s logo have signed a binding declaration that the safety equipment they offer meets the appropriate standards, fully complies with the PPE regulations and is appropriately CE marked. As a manufacturer, importer and distributor and being very close to the market, we recognise our responsibility to be involved in market surveillance activity carried out by the competent authorities. We are prepared to participate actively with the authorities and provide all necessary support and information.
Keeping workers safe – no room for doubt
Identifying true product compliance is difficult for the user. The responsibility falls to the manufacturer, who may not have the resources in place to ensure regular testing. Anyone who has concerns over the safety of the equipment they are being supplied should follow these steps:
- 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 UK has a strong health and safety record, of which we are very proud. As a participant in the BSIF’s RSSS and with safety at the forefront of everything we do, Arco will continue to lead the charge, working with the BSIF, to raise the standards of compliance in the UK. As an industry, we must work together. Manufacturers, Importers and Distributors need to have the necessary measures in place to ensure that the products they supply are capable of doing the job intended for. Purchasers need to remain vigilant to safeguard your workers.
- Market Research Report – Frost & Sullivan, Snap shot of UK & Ireland personal Protective Equipment (December 2015)
- Arco CVP research, published January 2016
Neil Hewitt is Divisional Director Quality and Technical Standards at Arco.
Arco is the UK’s leading safety company. It distributes quality products and training and provides expert advice, helping to shape the safety world and make work a safer place. For more information, visit www.arco.co.uk.