What’s your head worth?

Jacques Forest, head protection committee chair of the BSIF’s Personal Safety
Manufacturers Association, (PSMA) discusses the need for the revision of Directive
89/686/EEC and the importance of re-categorisation of head protection

If you have an interest in PPE, then you cannot have missed
the concern over fake, counterfeit and non conforming
products that have been covered in the media in recent
years. The same concern led the British Safety Industry
Federation (BSIF) to create the Registered Safety Suppliers
Scheme (RSSS) to which reputable PPE manufacturers and
distributors belong. However, certain aspects of non
conformance are starting to be laid directly at the door of
legislation.

It is well known that workplace safety is governed by European
Directives and the two most commonly referred to are Directive
89/654/EEC which deals with safety in the workplace and
Directive 89/686/EEC which deals with personal protective
equipment (PPE).

The latter directive regulates the requirements of PPE and was
initially introduced to enable PPE to cross EEC borders to
enhance free trade. The onus was then on the manufacturer to
ensure that what was sold would not harm or hinder the wearer
and was fit for purpose.

Instead of categorising risks and basing the requirements
around expected and foreseen hazards 89/686 was written
around PPE product categories. Over time, this directive evolved
and now is being used to predominantly enforce the policing of
the market place which has ultimately led to some incongruities.

The European Commission recognises that a revision of this
directive is needed, and it has to be hoped that some of the
current incongruities will be eliminated.

At the core of the 89 version of the PPE directive, it discusses
the categorisation of products and PPE. The phrase “intended to
protect against mortal danger or against dangers that may
seriously and irreversibly harm the health, the immediate effects
of which the designer assumes the user cannot identify in
sufficient time” is the basis for the categorisation between cat ll
and cat lll products.

The difference between these categories is that although both
types require an independent evaluation of the products
performance, cat lll products have to be regularly retested or
their means of manufacture audited.

Currently, head protection products are not required to have
either their performance or means of manufacture regularly
audited. By moving head protection into cat lll the industry
would be confident that the original performance evaluated at
product type testing has implicitly been carried over to the
product being worn.

Already included in cat lll are products protecting from air
temperatures in excess of 100 °C, molten metal and electrical
risks and high voltages. So head protection, especially industrial
safety helmets that make any of these optional claims are
automatically a cat lll product. Since most industrial safety
helmets in the market place are purporting to satisfy one of these
options it would seem only logical to recategorise, if not just
industrial safety helmets, but all head protection.

With the recategorisation would come the recognition that
head injuries are just as mortally dangerous, and seriously and
irreversibly damaging to health as falls from heights or inhaling
dangerous or toxic gases. Head protection would then be
guaranteed to have both the consistency of performance and
quality that is expected by the wearer to protect from “mortal
danger or from dangers that may seriously or irreversibly harm
health”.

All head protection products would have to mandatorily
satisfy the retest or means of manufacture audit, so as part of the
revision of the 89/686 EEC directive head protection products,
specifically industrial safety helmets, should fall into cat lll. The
directive would be properly applied and policed and fake,
counterfeit and non conforming industrial safety helmets would
be driven from the market
place.