PPE

Introduction

This article provides information on the use of personal protective equipment (PPE) in the workplace. Special attention is paid to the use of selecting PPE for specific circumstances and various types of work, including technical aspects, ergonomics and end-users’ acceptance. The issue of providing proper information to employees and how the PPE should be labelled will be discussed on the basis of the information supplied by the manufacturer (manufacturer’s instructions). The importance of practical training in the workplace, and the adjustment of PPE by individuals will also be considered.

Basic definitions

According to the EU Directive 89/656/EEC article 2 personal protective equipment (PPE) means all equipment designed to be worn or held by the worker to protect him against one or more hazards likely to endanger his safety and health at work, and any addition or accessory designed to meet this objective. ^[1]

This definition excludes:

• ordinary working clothes and uniforms that do not specifically protect the safety and health of the worker;
• equipment used by emergency and rescue services;
• PPE worn or used by the military, the police and other public order agencies;
• PPE for means of road transport;
• sports equipment;
• self-defence or deterrent equipment;
• portable devices for detecting and signalling risks and nuisances.

EU Legislation on PPE

In the area of occupational safety and health (OSH), the main legislative act is the Framework directive 89/391/EEC ^[2] and the 23 related directives. These 'daughter directives' focus on specific aspects of safety and health at work. One of these directives is Directive 89/656/EEC of 30 November 1989 on the minimum health and safety requirements for the use by workers of personal protective equipment at the workplace ^[1]. This directive lays down minimum requirements for PPE used by workers at work and sets out the obligations for employers. The directive has been transposed in national law by all member states. Other 'daughter directives' also contain provisions on personal protective equipment and stipulate that, where risks cannot be adequately controlled by engineering controls, adequate PPE must be provided and properly maintained, e.g. directive 98/24/EC^[3]

Apart from that, the EU also provides for harmonised requirements and procedures to establish compliance for PPE placed on the EU market and to ensure free movement in the EU. Regulation 2016/425/EU of 9 March 2016 on personal protective equipment ^[4] contains provisions on the design, manufacture and marketing of PPE. The EU Regulation is applicable to all PPE that is placed on the market (not only PPE used in the workplace) and sets out the rules for manufacturers. An EU Regulation applies automatically and uniformly to all EU countries without needing to be transposed into national law. Regulation 2016/425/EU defines legal obligations to ensure that PPE on the EU internal market comply with the essential health and safety requirements and provide the highest level of protection against risks. The CE marking affixed to PPE provides evidence of compliance of the product with the legal requirements. The Regulation is applicable from 21 April 2018, replacing the previous directive 89/686/EEC with provisions on the placing on the market of PPE ^[5].

General rule

In accordance with general occupational safety and health (OSH) provisions, the employer shall ensure employees’ safety and health with respect to every aspect of work. A comprehensive OSH strategy is based on a workplace risk assessment evaluating risks to workers' safety and health from workplace hazards and possible prevention measures for controlling the risks. For any risk in the workplace, the general prevention hierarchy should be used i.e. elimination or substitution of the risk at source should be given priority followed by or combined with technical measures, organisational measures, and PPE as a last resort. All risk control measures, including the provision of PPE, should be regularly reviewed to ensure that they are still effective, check whether changes in work processes require new/additional measures or whether more effective control measures are available (new prevention techniques).

The role of PPE is solely to reduce the possibility of exposure to a hazard (e.g. high-visibility clothing is designed to increase the employee’s visibility), it does not eliminate the hazard. Before providing PPE as a means to protect the workers, the employer should consider and implement the following measures if possible:

• elimination of hazards;
• substitution (replacing the cause of hazard (e.g. a chemical product used or machinery/equipment) or work process by one that presents a lower risk);
• engineering controls (physical means that limit the hazard);
• administrative controls (organisational measures).

If after all the above measures there is still a residual risk, PPE should be provided to further minimise the risk. However, PPE only protects the person wearing it, whereas other prevention measures can protect everyone in the workplace.

Following from the above, because PPE is the last resort after other methods of protection have been considered, it is important that users wear their PPE properly when they are exposed to the risk. On the other hand, wearing PPE may cause additional physical workload and limitations in ability to move for workers. Therefore, manufacturer's recommendations and other approved codes of practice and standards on the duration of use of PPE and breaks when using such PPE need to be followed and workers instructed accordingly.

Employers have an obligation to ensure that suitable PPE is provided to all employees who may be exposed to a risk to their health or safety while at work except where and to the extent that such risk has been adequately controlled by other means which are equally or more effective.

The employer shall:

• ensure that employees receive PPE free of charge;
• choose appropriate PPE depending on the risks;
• specify the conditions of PPE use;
• organise training sessions;
• ensure suitable storage, cleaning, disinfection and maintenance.

Worker and/or their representative shall be informed of all measures to be taken with regard to the health and safety when PPE is used at work. Involving employees in the risk assessment process is a highly effective way of identifying hazards and developing solutions that work. They will be able to bring in their knowledge, experience and understanding of the activity. Consultation and participation of workers and/or of their representatives shall take place in accordance with Article 11 of Framework Directive 89/391/EEC.

It is important, whenever possible, that workers are given a chance to choose a specific model of PPE, however only if it ensures appropriate protection against the risks.

Provision of PPE

In order to ensure appropriate protection, PPE should:

• comply with the relevant Community provisions on design and manufacture with respect to safety and health,
• be appropriate for the risk involved, without itself leading to any increased risk,
• be suitable for the conditions in a given workplace,
• meet ergonomics-related requirements and take into account the employee’s health condition,
• be tailored to the user i.e. fit the wearer correctly, after necessary adjustments.

CE marking

It should be emphasized that only PPE bearing the CE mark may be regarded as complying with the basic health and safety requirements, therefore employers should always choose PPE for their employees from amongst these. For this purpose, it is necessary for employers to have a basic knowledge and understanding of the rules for placing PPE on the EU market.

Regulation 2016/425/EU ^[4] divides PPE into three categories according to the level of risk against which PPE is intended to protect users. The categories are described in annex 1 of the Regulation. Category I includes PPE that protect against minimal risks such as superficial mechanical injury or contact with hot surfaces not exceeding 50 °C. Category III includes PPE that protect against risks that may cause very serious consequences such as death or irreversible damage to health. Category II includes PPE that protect against risks other than those listed in Categories I and III.

Different conformity assessment procedures apply to each of these categories. Conformity assessment is the process carried out by the manufacturer of demonstrating whether the essential health and safety requirements have been fulfilled. A PPE is subjected to conformity assessment both during the design and production phase. The manufacturer must ensure that the essential health and safety requirements remain fulfilled during the lifetime of the PPE. The manufacturer must provide information about the measures taken in order to ensure the conformity of the PPE to the requirements in the technical documentation. The presumption of conformity of PPE is confirmed by the use of harmonised European standards. A list of harmonised standards for the PPE regulation is available at https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/personal-protective-equipment_en

Figure 1 gives an overview of the conformity assessment procedures for the three categories of PPE. For Category II and III PPE, before serial production starts, the model (type) of the PPE has to be submitted for an EU type-examination to a notified body. For Category III PPE, before placing on the market, the manufacturer must also involve a notified body for supervised product checks at random intervals or for assessment of his quality system. Once the manufacturer has undertaken the appropriate procedures to assure conformity with the essential health and safety requirements of the PPE Regulation, the manufacturer draws up a written EU declaration of conformity and affixes the CE marking. The declaration of conformity contains information such as the product name, the name and address of the manufacturer and references to the relevant harmonised standards. For category II and III PPE, when notified bodies are involved in the conformity assessment procedure, the EU declaration of conformity also contains the name and the identification number of the notified body. For category III PPE the identification number of the notified body is also added to the CE mark ^[5].

Types of PPE

PPE may be divided into the following groups based on the impact of hazardous and harmful factors on the human body:

• protective clothing
• hand and arm protection
• foot and leg protection
• eye and face protection
• hearing protection
• head protection
• respiratory protection
• personal fall protection
• skin protection – barrier creams

Selection of suitable PPE

Prior to choosing PPE, the employer should identify all hazards (chemical, biological, physical, environmental) existing in the workplace and assess their occupational risk ^[6]. An elaborate table describing work activities and sectors of activities which may require the provision of PPE can be found in Annex III of directive 89/656/EEC (new version of the annex introduced by Commission directive 2019/1832 ^[7]).

Table 1. Non exhaustive list of hazards and harmful and examples of PPE

Source:^{[1] [8]}

In order to conduct the risk assessment, it may be necessary to carry out measurements that quantify the level of exposure to the risk such as noise levels in the workplace, the concentration of a hazardous substances, etc. These measurement results can then be compared with action or limit values to determine whether action is necessary. The necessity to provide PPE must be based on a workplace risk assessment determining appropriate measures to eliminate and/or minimise risks by collective protective measures. If these measures are not sufficient, only then should PPE be used to protect against the hazards that are unavoidable (see above).

• the risks in the workplace;
• the parts of the body that may be affected;
• the nature of the job or task;
• the degree of physical effort involved;
• the workplace conditions;
• working hours and how long the PPE must be worn;
• requirements for visibility and communication;
• ...

It is important to check that the use of PPE does not bring about new risks or increases the level of risk. PPE must not be worn if the risk caused by wearing it is greater than the risk against which it is meant to protect. It should be emphasized that if there is more than one type of risk, then as a consequence, it might be necessary to use more than one type of PPE. The construction of the equipment must allow to adjust it without compromising its protective capacity i.e. compatibility of different classes or types of PPE designed for simultaneous use.

The aim should be to choose PPE which gives maximum protection while ensuring minimum discomfort to the wearer. Therefore, it is important to involve the workers. Workers are familiar with the workplace and the circumstances. They should be consulted and involved in the selection and specification of the equipment. There is a better chance of PPE being used effectively if it is accepted by each wearer. Whenever possible, a workplace trial should be organised to test and compare different types of PPE before buying.

Employer’s checklist

In order to support the employer, the checklist below can be used for selecting the appropriate PPE ^{[8] [9]}:

• Is it suitable given the occupational risk involved and the workplace conditions?

For example, eye protection designed for providing protection against agricultural pesticides will not offer adequate and sufficient face protection for someone using an angle grinder to cut steel or stone.

• Will the use of the PPE not increase the general level of occupational risk?

For example, the use of a mask or protective glasses against splinters of solid objects may limit the worker’s vision and, as a consequence, lead to the collision with moving parts of the machinery.

• Does PPE fit the user, after the necessary adjustments have been made?

It is necessary to check if clothes, gloves and footwear have been tailored to the user. It is especially important when women use PPE, since frequently they are smaller in size than men, which may lead to ill-fitting of commonly manufactured oversized PPE^[10]. The aim should be to choose PPE which will give maximum protection while ensuring minimum discomfort to the wearer, as uncomfortable equipment is unlikely to be worn properly. Not fitting the wearer correctly may lead to a significant reduction of effectiveness of PPE which may result in leaving the employee unprotected.

• Does it take account of ergonomics and the employee’s health condition?

The PPE selection procedure should also take account of employees’ health condition, especially any disorders which may hinder or prevent the use of the PPE. For instance, sight defects may be an impediment to wearing masks or eye protection, whereas claustrophobia may prevent a person using respiratory protective devices. Another important problem is that it is difficult to tailor PPE specifically to the needs of people with untypical body shape (e.g. body deformation or facial hair), as it may prevent the proper adjustment of respiratory protective equipment. With regards to respiratory protective devices, fit tests should be carried out.

• Are there any conditions for using the specified PPE, in particular instances and times when it should be worn?

For example, it is essential to establish breaks when wearing leak-tight clothing to protect against chemical agents when working in a warm environment or when wearing respiratory protective equipment for long periods of the day (e.g. health care personnel wearing FFP2 masks during COVID-19 pandemic). Another important example is the specification on the maximum working time of gas filters protecting against chemical substance vapours or the protection time/period for gloves protecting against organic solvents, oils and lubricants.

• If there is more than one type of risk and it is necessary to use several types of PPE - is it possible to adjust the pieces of equipment to one another (without compromising their protective capacity)?

For example, wearing filtering half masks may prevent adjusting protective goggles.

There are many guides and brochures aimed to help employers and safely use PPE safely (e.g. Respiratory protective equipment at work^[11] , Effective PPE Program^[12] , Selecting protective gloves^[13].

Useful information

When selecting the appropriate PPE, guidance provided by the manufacturer provides useful information, e.g. on the duration of use. Harmonised standards set criteria for different levels of performance that must be met for different properties related to risks. For instance, particle filters used for respiratory protection protect against solid and liquid particles including micro-organisms. They are classified and marked as P1, P2 or P3, with P3 providing the highest level of protection. PPE user instructions and labels include information on these performance levels as well as symbols indicating the risk against which they offer protection. Table 2 presents some of these symbols.

Information supplied by the manufacturer should be written in the official languages of the country where the PPE is used.

The information supplied by the manufacturer (manufacturer’s instructions) must contain a description of the identification symbols on the product.

All types of PPE (and/or packages) should bear appropriate identification in accordance with respective harmonised standards.

The manufacturer’s instructions should contain:

• the manufacturer’s name and address;
• instructions concerning storage, use, cleaning, maintenance, expiry date and disinfection;
• additional equipment to be used with PPE and description of spare parts used with it;
• protection class at different risk levels and the scope of use relating to them;
• type of packing suitable for transport.

Training

Both workers and persons supervising PPE usage should know:

• the protective properties of the PPE;
• why PPE are needed and the consequences of not using PPE;
• how to use PPE properly, in accordance to its function as stated in the information supplied by the manufacturer and including information on the duration of use and appropriate breaks. Clear instructions for the users should be easy accessible and understandable, and be based on the manufacturer’s instructions;
• how to maintain PPE and when to change it e.g. when expired, damaged or no longer appropriate for the type of activity being undertaken.

The employer is legally obliged to organise training on how to wear and use PPE. If necessary, training sessions should include appropriate demonstrations. PPE-related training should be organised at the employer’s cost during working hours. It should also include new and changing risks and be repeated periodically.

Maintenance and inspection

 

PPE should be kept clean and repaired as appropriate, in accordance with the information supplied by the manufacturer. The manufacturer’s instruction should include recommended replacement periods and duration of use.

Simple maintenance works may be conducted by trained employees. In turn, complex repairs should be carried out by specialists.

PPE is intended for personal use. Whenever a given piece of equipment is worn by more than one person, action should be taken to ensure that the use of equipment does not pose any threats to health and hygiene of different users. The employer’s obligation is to ensure that the washing, maintenance, repairs or disinfection of PPE is free of charge.

Management

The use of PPE should be supervised. Areas where the use of PPE is mandatory need to be identified and adequately indicated (safety signs) so that all workers are aware of the requirements. Specifying smaller areas where it is actually necessary to wear PPE is more efficient than an obligation to wear PPE in the whole workshop or unit (92/58/EEC)^[14]. Key elements of PPE management system are presented in Figure 2.

It should be noted that management is also obliged to use PPE in all areas where hazardous and harmful factors exist. In particular, employers and their delegates are obliged to draw up and implement procedures and instructions to be followed in the event of any of the following:

• there have been changes in technological process being used in the workplace,
• there has been a change in the materials being used in a process,
• there has been a reduction in the hygiene standards,
• there have been changes in staff, e.g. new employees or employees being transferred from other areas of the workplace,
• there are possibilities to obtain and use new, more effective and more comfortable PPE,
• essential types of PPE cannot be obtained.

If workers and/or their representatives use PPE, they should be notified of all actions related to safety and health.

While choosing protective equipment, the employer should attempt to find a balance between the need to ensure effective protection and the requirements of the production process.