From the CEO's desk - December 2020

09 November 2020

As managing the Covid-19 crisis continues to take time away from other important issues, Alan Murray looks at what the PPE industry can do to ensure a more sustainable future.

2020 HAS been the most incredible year in our working lifetimes, and the social and economic effects will be with us for a long time to come. Covid 19 has caused deep disruption and the effects are far from over, with the pandemic still driving events across many societies.

As we come towards the end of this year, we have to look forward with optimism and ensure that the phrase “new normal” which we heard so often, actually has a chance to become a “better normal” for us all. There are still many changes that we have to accommodate and absorb, not least being those caused by the UK leaving the European Union. I do not intend to dwell on Brexit in this column or the impacts on the Safety and Personal Protective Equipment (PPE) industry, as there is ample coverage in the accompanying “Guide to the UK Safety Industry” publication, rather I would like to look beyond that onrushing event.

Dealing with, and managing the Covid 19 crisis has seen many of our other priorities displaced, if not overlooked. The political imperatives on environment and sustainability issues seem to be an area where focus has temporarily been lost, but I would like to reassure you that those in the PPE industry continue to work to ensure that this vital industry makes its own contribution to the “green deal” and a more sustainable future. The following content comes from, and is inspired by work currently underway through the European Safety Federation (ESF), seeking to encourage the authorities to act and support the efforts of PPE producers, to allow our industry to avoid needless waste. 

There are already many laudable manufacturer led initiatives in this area with a focus on packaging reduction being one of the most obvious however, the Covid crisis has thrust PPE into the public consciousness like never before, and in the pandemic we have seen huge amounts of disposable PPE being used. Vital of course, but in itself also a significant source of waste.

The current proposals on sustainability being championed, as I said through ESF splits the sustainability challenge into 4 different categories, where we see opportunities for waste reduction and environmental improvement. These are 1. The printed user instructions 2. The packaging 3. The product and 4. The logistics.

In this column I would like to deal with the problem of printed user instructions. This element, it could be argued, represents to most obvious area where significant waste could be effectively and quite easily addressed. The PPE Regulation 2016/425 requires manufacturers to provide these instructions in printed form in the appropriate languages with each and every piece of PPE, in their smallest commercial units. The purpose of “user instructions” is to inform on the protective properties of the product, and provide instructions for its safe use and information on maintenance and care. However, much of the information required by the Regulation to be included in the instructions seems to be “technical information” which would really only be necessary for specialists seeking to select and maintain the correct PPE. Often this information is of no particular use or to the wearer, meaning that the instructions for use are not read, and their main stated purpose is lost. 

In this discussion on printed user instructions accompanying each piece of PPE, we are looking at this topic in 2 categories, separating professional users (B2B) and private / consumers, but first let us look at some of the impacts.

Based on estimates made by ESF, there are 700 million pieces of PPE traded in Europe each year (in its smallest commercial units). A typical weight of accompanying printed user instructions is 15g but there are instruction books for some complex products which go to 700g. All of this adds up to 10,500 tonnes of paper each year which in turn requires 250,000 trees! 10,500 tonnes of paper equates to a volume of 19,000 square metres filling 625 containers. Trying to estimate the journey that the paper and the user instructions then make, is very difficult, but has to include the miles from the paper mill to the printer, then to the PPE manufacturer then onward with the PPE through import and distribution before finally to waste or recycling centres after, in most cases, not being read. The environmental impact of printed user instructions accompanying every piece of PPE is significant.

As I said earlier we are looking at the issue and separating professional use at work, and consumer / private use. The vast majority of PPE consumption is through use at work. And in this case the wearer will not make decisions on purchasing or selecting the PPE. This must be done by the employer. The employer is responsible for selecting and sourcing the PPE and importantly by law, must provide the wearer with all the necessary training. Of note, of course is the fact that once the PPE has been selected and the training provided the wearer will typically use the same or fresh items of the same PPE, day after day after day. So in a work environment where the employer is responsible for the PPE it is vital that they are provided with all the necessary information enabling them to select and maintain whatever PPE is necessary for their workforces and then to train the workers on its correct use, to ensure that they are safe at all times.

Surely in this context all the PPE information can be provided separately to the employer who will then pass on all the necessary information to the wearer, without it having to be included in a printed form with each and every piece of PPE! If a wearer does however wish to see manufacturer’s instructions this can be easily facilitated through a digital mechanism like a QR code affixed to the product. This way much more information can be made available, without the need for printed user instructions.

In the case of the private consumer where the wearer is making their own decisions on PPE selection then access to the necessary information is very important. But it is vital to stress that this information should be available before the product is selected, not after it has been purchased. So in our petitioning we are calling for all relevant information to be available digitally where PPE is offered for sale. If this process were adopted the need for printed user instructions would also be removed or greatly reduced, even outside of the work environment.

I hope that you will agree that PPE can play its part in the sustainability drive, and that a very quick win would be to allow manufacturers to provide user instructions electronically rather than insisting on them always being in a printed format. This is what is currently being proposed to the EU Commission.

Alan Murray is chief executive of BSIF. For more information, visit