17 August 2020
As it is now compulsory to wear Face Coverings in shops and supermarkets in England, Alan Murray thought that it would be timely to write on the subject.
As this product type is neither Personal Protective Equipment (PPE) or a Medical Device (MD) we have, to some extent been hesitant on the topic. However as it is clearly a new category of product likely to be with us for some time, designed to mitigate the risk of COVID 19 transmission, and a product area that I know many of you are involved with commercially it is appropriate that we include it in our thinking and communications.
All of the guidance produced by the authorities remain crystal clear that the product is, as I said, neither PPE nor MD. As such Face Coverings are not regulated by either the Health and Safety Executive (HSE) or the Medicines and Healthcare products Regulatory Agency (MHRA). Face coverings sold in the UK will be regulated under the existing General Product Safety Regulations 2005, which require that only “safe” product is placed on the UK market. Full details of this legislation can be found at https://www.legislation.gov.uk/uksi/2005/1803/regulation/4
It would be unfair to say that guidance so far on Face Coverings has been unclear however, in these times of guidance overload it has been something of a challenge to compare the publications and get a clear picture of the what, where, when and the how of Face Coverings.
I am though, very clear on the why. These products are designed primarily to protect others as opposed to the wearer. COVID 19 can be spread, predominately, by droplets created by coughs, sneezing and speaking. In addition to direct transmission droplets can be picked up from surfaces and infection passed by then touching your face. Face coverings are a valuable addition to social distancing and good hand hygiene as a tool to restrict the transmission of COVID 19.
So, what are wearers to expect from a face covering? This in itself could be clearer. On July 15 the Government updated its guidance on how to make one at home, a cloth face covering which the guidance simply advises that you will need 2 or 3, 25cm by 25cm squares of cotton fabric for the body of the face covering and 2, 20cm pieces of elastic (string or cloth strips) for ear loop fixings. This guidance makes no attempt to specify the performance or filtration characteristics of the face covering.
The previous day the Government published broader guidance on Face Coverings explaining what they were, the reason for their necessity, how and when to wear one, including the listing of exemptions, use while at work and responsibilities for those involved in buying and selling product, as well as maintenance and disposal information. Full details are available through this link. https://www.gov.uk/government/publications/face-coverings-when-to-wear-one-and-how-to-make-your-own/face-coverings-when-to-wear-one-and-how-to-make-your-own.
In this document it is made clear that there are no specified product performance standards required in the UK but importantly it referenced the French AFNOR standard S76-001 for “Barrier Masks” and the CEN Technical Specification CWA 17553 (available through link on page 7 of the above guidance) both of which have a range of requirements on dimensions, components, markings and importantly performance criteria for filtration efficiency, breathing resistance and suggested test methods.
British Standards Institute (BSI) are aligning to these standards which means that the BSI Kitemark can and will be applied to products which successfully submit for assessment.
The requirement to wear Face Coverings and in what circumstances will be different through the UK and Northern Ireland as these are devolved matters, but as was mentioned earlier from the 24th of July the requirement will be widespread and failure to do so, where required, could lead to a fine of up to £100.
I hope this note is of value and as ever the BSIF will do our best to support where we can, and wish you a safe and successful period as the country returns to work.