Understanding EU and US PPE Standards
07 October 2021
AS THE world gets smaller, it becomes increasingly anachronistic that different regions use different standards for the same PPE. Here, Martin Lill provides an insight.
Global manufacturers develop facilities in multiple regions, so it’s not uncommon to try to standardise PPE used. After all, its common sense that a business ought to have the same minimum PPE performance requirements and PPE in every factory. Yet despite this well-meaning objective, the strategy often comes unstuck, partly because of the problem of meeting the differing standards that apply in the different regions. A useful approach however might be that various standards can be used as opportunities to improve safety globally by developing an understanding of both (or all).
The different approaches of North American and European standards are nowhere more apparent than in those for chemical protective clothing, starting with different governing principles; in Europe the approach is prescriptive; CE certified products are a legal requirement. In the US however the approach is advisory; most standards in the US are optional. There are no legal obligations to sell or buy firefighters clothing, FR workwear or chemical suits that are certified to a standard.
In the case of chemical hazmat suits the different approaches are stark.
European EN Standards for Chemical Protective Clothing
Four standards define five “Types” of clothing based on the protection offered: gas-tight protection (Type 1), liquid jet spray, spray and aerosol protection (Types 3, 4 and 6), and dust protection (Type 5). Certification involves three types of testing: physical properties of fabric, chemical penetration resistance (for Type 6) or permeation resistance (for Types 1, 3 and 4), and whole garment “Type Tests”.
It is the “Type Tests” that assess the whole suit, attempting, with limited success, to provide an indication of real-world performance. They include very specific criteria for pass or fail. To be certified a chemical suit must have passed its relevant Type test.
There are drawbacks. Attempts in a lab to replicate real-world scenarios always fail to some extent. Real-world scenarios are never standard, so any test will almost never cover the parameters of a specific variation. The consequences are users’ risk assuming misleading indication of protection offered for their own specific application – especially when in many cases users too often assume certified PPE is safe to use in any circumstance within the protection type anyway.
Worse, the prescriptive nature of EN standards can result in a tendency to fail to properly understand the application, the protection and the PPE, simply shifting the responsibility for selection onto the question of “is it certified or not?”. (Every PPE sales representative has been involved in a negotiation that consist of two questions: “Is it Certified?” and “How much is it?”)
And because prescriptive standards fail to cover all possibilities there is a tendency to try to expand the scope. Hence EN standards are growing and become more complex with each new version (witness the new versions of standards for gas tight suits and fire-fighters clothing!). When users’ understanding of the most basic standards is often already limited, increasingly complex standards make the problem worse. There is a real danger they become so complex, and that so few properly understand them, that the standards themselves become a hazard, because what accompanies misunderstanding, is assumptions that are often just wrong.
Finally, the European focus on product means standards tend to address different types of PPE in isolation, whereas in the real-world it is invariably used with other PPE. This, again, risks users making assumptions about protection. (A classic case is wearing a standard disposable coverall over FR workwear when flame and chemical protection are both required. Many fail to realise that the disposable will literally destroy the protective properties of the FR coverall).
North American OSHA Protection Levels
The US approach is very different. In fact, for chemical suits there are no specific standards. Rather, OSHA, the Occupational Safety & Health Administration, has developed the simple guidance of four general protection levels for chemical hazards. These focus on the level of hazard and give prime importance to respiratory protection. The highest is Level A (High level respiratory, dermal and optical hazards) down to the lowest, Level D (no respiratory or dermal hazard)
These protection levels provide general guidance for users on the totality of protection required, including suit, respiratory protection, gloves, boots and so on. Arguably, this approach scores some benefits over the EN counterpart: -
It addresses the whole PPE ensemble rather than individual items of PPE seperately
Not only is it easier to understand, it allows more flexibility in PPE selection and combination
Rather than attempting to prescribe PPE with specific minimum performance levels, it provides a simple overall PPE framework, thus shifting responsibility to the specifier, and forcing better understanding of the application and individual PPE. There is at least a case to argue this is a safer policy, given that no matter how prescriptive and complex is a standard, it can never cover all eventualities in the market, whilst the specifier that properly understands his individual application can account for all the possibilities that could develop.
On the other hand, the lack of testing and prescriptive elements of the U.S. guidance also has drawbacks.
It fails to provide any or easy performance comparison of different chemical suits.
It fails to identify minimum performance requirements, design features or construction elements, and therefor fails to indicate whether any individual PPE product will do the job of protection that it should. (Again, this responsibility falls back to the specifier)
There are other advantages and drawbacks of both systems. However, the obvious conclusion for the diligent safety manager is that both may be of use. It is worthwhile taking the time to understand both as each has its place in contributing to effective PPE selection. In the case of chemical suits, OSHA protection levels provide a useful framework guide to selection of the overall ensembles of PPE required. Meanwhile EN standards provide a more detailed guide to assessing performance of individual PPE, ensuring that it achieves minimum performance and will do the job it should.
So, ignoring standards that don’t apply in your region might not be the best policy if your objective is to ensure the best protection. Whether European, US or any other standard, each can play a role and offer useful tools in ensuring the best PPE for the job.
For a more detailed review and comparison of European EN standards and U.S. OSHA Protection Levels for chemical protection, and how they can both contribute to better PPE selection, read our recent blog here
Martin Lill is international marketing director at Lakeland Industries. For more information, visit www.lakeland.com”