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From the CEO's desk - February 2020 12/02/2020

Brexit has happened, so Alan Murray looks at what this means for the safety industry and asks what happens now.

The General Election of Thursday December the 12th 2019, saw the Conservative Party returned to power with a significant majority. After basing their campaign on “getting Brexit done” and with the withdrawal legislation cleared, the UK left the EU at 11pm on the 31st of January. 

So what happens now in the PPE and Safety Industry? Since the early nineties the industry and the conformity assessment of personal protective equipment has been subject to EU legislation and based upon the framework of CE marking and it’s approvals processes. Will that all now change?

The answer in the immediate term is no! Below is the official communication from the Department of Business Energy and Industrial Strategy (BEIS), released on February 5th 2020.

Communication from BEIS

As you will be aware, the UK left the EU on 31st January.

We are now in a transition period until 31st December 2020. 

During the transition period, the requirements for placing CE marked goods on the UK and EU markets will remain the same as now. This includes the arrangements for conformity assessment, marking and labelling. If you currently use a UK Notified Body, you can continue to do so during this period.

The UKCA marking, which is intended to indicate compliance with UK rules in the same way the CE marking does for EU rules, will not come into effect during the implementation period. The CE marking will continue to be required, however businesses can still place the UKCA marking on their products as long as the CE marking is also used.

For further information on using the CE marking, please refer to the following guidance: https://www.gov.uk/guidance/ce-marking

We will communicate the arrangements at the end of the transition period as soon as further information is available, including on the outcome of negotiations with the EU and what that means for the actions you’ll need to take.

Therefore as can be seen from the communication CE marking of PPE is still required to place goods on the UK market. The communication above from BEIS also states that UKCA (United Kingdom Conformity Assessment) marking can also be used alongside CE marking. We believe that this is somewhat misleading in that there are currently no bodies approved to provide UKCA marking. Therefore it is safe for us all to work on the assumption that until the end of December 2020 CE marking of PPE will be the requirement.

Previously UK representatives from the industry played a major part in EN PPE standards management and development but the EU Commission has now made it very clear that UK bodies and UK representatives are not to attend any meetings (whether physical /phone /web) unless their participation is necessary from an EU standpoint. This is a very clear example of the UK’s ability to influence PPE standards being removed.

What will happen at the conclusion of the transition period? That will of course depend on what happens during the discussions on our future trading relationship with the EU. It is difficult to interpret signals or mood music and work out what positions, are negotiating points, and what are genuinely desired routes forward. What is clear is that under Teresa May’s proposals the default positions reflected a desire for regulatory alignment and a light touch on border checks for goods, under Boris Johnson this position has changed.

Without a Free Trade Agreement with the EU after December 2020 our position on import tariffs will change and the UK government through the Department of International Trade (DIT) has launched a consultation seeking views on the creation of a bespoke UK tariff position. Currently the UK accepts the same level of tariffs as the EU, again this is likely to change with the UK consulting around 3 specific questions.

  1. Simplifying and tailoring UK tariffs
    Removing completely tariffs below 2.5% 

  2. Removing tariffs on key inputs to production
    While this may be helpful to OEMs importing components it would be potentially damaging to UK manufacturers of such

  3. Removing tariffs where the UK has low or zero domestic production

Some tariffs that currently exist are inherited from the EU which exist to protect producers elsewhere in Europe

Personal Protective Equipment production is biased to the far east, so the changes in the tariffs regime will definitely have an impact. The current HMRC list of commodity codes does not make the art of understanding PPE tariffs easy and would benefit from further description rather than material types, but I suggest that will be a longer term exercise.

In summary it will be business as usual within the transition period but we must be prepared for eventual changes, the difficulty being that we do not know yet what the changes entail.

The BSIF are fully committed to passing on the pertinent information as soon as it becomes available. Additionally we are planning a range of roadshows to keep members informed of the changes and their impacts.

Alan Murray is chief executive of BSIF. For more information, visit www.bsif.co.uk

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BSIF welcomes new member 04/12/2019

“BKS Made to measure” recognises that widespread non-compliance within it’s industry has continued since standards were first introduced in 2002 and wants to help raise much needed and long overdue awareness of Motorcycle clothing’s very clear definition and now legal standing as ‘Personal Protective Equipment’ or PPE.  

Unfortunately a great deal of Motorcycle clothing available now on the open market is NOT made to the correct standards currently. All BKS suits, jackets and trousers are made in accordance with the PPE Regulation 2016/425. By joining the BSIF and its Registered Safety Supplier Scheme we aim to raise the bar of Motorcycle clothing compliance/safety and therefore aid peoples overall Health and Safety”.
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BSIF Guide 2020 04/12/2019

The 2020 BSIF Guide to the UK Safety & Health Industry, Keeping People safe and healthy at Work.

The 2020 edition of the BSIF Guide to the British Safety Industry will be published by Western Business Publishing (WBP) in December of this year.

The powerful combination of the team that publishes Health and Safety Matters (HSM) coupled with the unrivalled market knowledge and influence of The BSIF will again ensure the significant impact of this now widely respected reference guide for the industry.

Whether you are seeking to raise awareness for your product and service range, or to reinforce your position as a market leader in the UK safety market The Guide should feature as an essential component of your advertising plans

• The Guide reaches in excess of 25,000 key decision makers, (Including the 18,000 strong HSM circulation)

• Distributed alongside the December / January issue of HSM

• Available Digitally through the HSM website , HSM newsletters, BSIF Newsletters and the BSIF APP

• Available at all HSM and BSIF Exhibition stands throughout the coming months.

• The guide includes a broad spectrum of relevant and pertinent advice and guidance for safety professionals and business owners, originated by the BSIF.

• Advertising options have been carefully structured to suit all budgets

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Events - Intersec 2020 04/12/2019

The world’s leading trade fair for Security, Safety & Fire Protection, Intersec is where business, technology and innovations come together.

BSIF is organising the UK Safety Pavilion and can offer TAP grants to companies interested in exhibiting, get in touch with us now for further details.

Date: 19th – 21st January 2020

Location: World Trade Centre, Dubai

www.intersec.ae.messefrankfurt.com/dubai

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HSE Statistics 2019 04/12/2019

THE HSE have released their annual statistics for Health & Safety at work. The full report can be downloaded below, some headlines include:

The rate of self-reported work-related ill health showed a generally downward trend but has been broadly flat in recent years. Similarly, working days lost per worker due to self-reported work related illness showed a generally downward trend but has been broadly flat in recent years.

This year has seen a fall in the number of cases prosecuted, continuing the trend from the previous year. The number of notices issued by all enforcing bodies showed a decrease compared to the previous year, continuing the long-term downward trend in notices issued. The level of fine issued in 2018/19 has decreased compared to the previous year. The average fine per conviction is at the same level as 2017/18 so this decrease is related to the fall in the number of cases completed.

https://www.bsif.co.uk/wp-content/uploads/2019/11/hssh1819.pdf

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BSIF Awards 2020 01/04/2020

The prestigious BSIF Safety Awards recognise the fantastic work that occurs within the UK Safety Industry. The Awards specifically celebrate excellence within customer service, product innovation and safety solutions, all with the key goal of improving occupational health and safety.

After the success of the 2019 Safety & Health Excellence Awards held at The Vox, Birmingham in April, the BSIF awards will once again be a key part of the evening. This year’s Awards will be held on Wednesday 29th April at The Vox, Birmingham. The Awards evening is the perfect place for our awards as it highlights and celebrates the innovation found within the UK safety market.

Following the same format for entry as last year for the product innovation award, all products will be considered based on their submissions. The finalists will then go forward to the judging day which will be held at the end of February. The judging panel is made up of independent industry experts who will consider each product on its merits. The companies that make the finalist shortlist will have the opportunity to present their products to the judges allowing them to highlight the innovation contained within.

The judges will then score the products and the winner will be announced alongside the winners of the Safety Solution Award and Customer Service Award winners, at The Safety & Health Excellence Awards at The Vox, Birmingham on Wednesday 29th April.

Finalists and award-winning companies will receive immediate benefit as they will be featured in the pre/post exhibition publicity. Additionally, the winners and finalists will feature within the BSIF Industry guide.

2020s BSIF Awards sees the introduction of a new category to be recognised alongside the existing three. The Water Pollution Prevention Award, supported by the Environment Agency and the Scottish Environmental Protection Agency, will recognise the efforts made by business to protect the environment and ensure that all water pollution risks are managed in an effective and efficient way. The Water Pollution Prevention Award is a fantastic opportunity for your environmental efforts to be recognised, providing great PR both inside your business and to the wider market.

The four award categories are:

Product Innovation: An award for products that are new and innovative and will contribute to improvements in occupational Health & Safety.

Service Awards: An award for companies in the safety field offering exceptional and innovative service solutions. Voted for by the entrants’ own customers.

Safety Solution Award: Based on case studies submitted by members, these recognise major improvements in occupational safety created in 2018/2019.

Water Pollution Prevention Award: Based upon a submitted case study demonstrating how the entrant company managed the risk of incidents that could lead to the pollution of the water environment, surface water or groundwater.

https://www.bsif.co.uk/wp-content/uploads/2019/11/BSIF-Safety-Awards-2020-Brochure.pdf

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From the CEO's desk - December 19 09/12/2019

As 2019 comes to an end, Alan Murray takes this opportunity to look back at what's been happening in the health and safety industry.

AS WE reach the close of 2019 it is the right time to look back on the year just gone. This year has seen our, on – off departure from the EU almost blocking out the sun, as we attempt to prepare contingencies in the event of an “no deal”. Despite all this however, now in our 25th anniversary year, the BSIF membership has passed the 300 barrier. This is really great news for the market with more suppliers able to demonstrate quality and capability through being members of the Federation and the Registered Safety Supplier Scheme. 

The Federation terms and conditions require that members submit PPE and safety products for independent testing, educate their customer facing staff and be able to demonstrate that they fulfil the obligations and responsibilities required under the PPE law. The BSIF is, along with the cooperation of the membership, transforming the quality and capability in the market, delivering a safer working environment in the UK.

Product audits

Since march 2019 the BSIF has undertaken 102 product tests across all types of PPE and we have seen a failure rate of 11%. On its own a concern, but in each case the supplier has had the chance to react and make good the non - compliances found. This ensures that non-compliant products ae removed and safety improved. The Federation has also conducted product tests in non - member suppliers which show a much higher failure rate. Again corrective again is underway. 
Only BSIF is undertaking proactive market surveillance.

Capability

The Safe Supply Accreditation qualification now has over 350 participants at various stages of the training and education programme. In all cases the candidates have benefitted from an education package covering, Legal Essentials – Managing Safety – CE Marking and how the Market is Policed.

Response has been tremendous and capability and the confidence levels of those involved has increased dramatically.

Responsibilities and obligations

The PPE Regulation, the law, requires that economic operators operators fulfil their “Obligations and Responsibilities. BSIF within the Registered Safety Supplier Scheme, audits that these are being adhered to. No other body carries this out, so again the Federation is providing quality assurance within the safety supply chain. What should be noted of course is that, there are business who sell safety products and PPE as non core items. They often do not see themselves as being part of the safety industry, claiming that the regulations don’t really apply to them. They absolutely do, and we have been reaching out and helping to educate those in the MRO, Auto Aftercare and laundering market to help them comply.

Another outreach effort that the Federation has undertaken is helping those in the motorcycling industry to appreciate that the law also applies to them. Since April 2018 Motorcycle Clothing has been included in the scope of EU 2016/425. Whether through ignorance or design the Motorcycle Clothing Industry were very slow to do the necessary work to comply. This industry is not the natural home for BSIF but we have been working hard to help them understand what they have to do. We created a list of frequently asked questions both for suppliers and consumers to help them.

So the pillars of transformation are there, truly delivering the quality and capability that the industry and users deserve.

Moving from the present to the future. By the time you read this the UK General Election will have taken place and and we will know what the new political landscape has in store for us. Throughout the electioneering the parties seem to be tripping over one another in their claims to be spending more and more money to right the the wrongs of the past 12 years. It seems pretty apparent that none of them seem to be too clear on where the money is coming from.

But how about this situation?

The cost to the UK economy, taken from figures just published by the Health and Safety Executive, of work related injury and ill health is £30 billion. Yes £30 Billion.

This figure of £30 billion is made up by…

£9.8 Billion: being the annual costs of new cases of work related ill health

£5.2 Billion: being the annual costs of workplace injury in 2017 – 2018

£15 Billion : Being the annual costs of workplace injury and new cases of ill health

In terms of days lost to absence through work related injury and ill health that number is over 28 million days!

A staggering set of figures which has not come down much in recent years. Consider this in the context of the UK spend on running our country. The amount spent on Defence £46bn (cost of injury and ill health £30bn), on Transport £29bn (cost of injury and ill health £30bn) Housing and Environment £34bn (cost of injury and ill health £30bn), Health and the NHS £145bn (cost of injury and ill health £30bn).

Cuts to the resources of the HSE should be reversed and, if we got safety and health right it would free up so much more money in the economy. But getting safety and health wrong is obviously not just about the money. The HSE figures show us that 147 people lost their lives at work and that there were 12,000 deaths from lung disease estimated to be linked to past exposures to hazards at work. Further, an incredible 600,000 non fatal injuries were sustained.

Good Safety and Health at work is a right that everyone has but, we still have much work to do and surely,everyone deserves to go home safe and well.

Despite the figures quoted above the UK has a great record in occupational safety when compared to the record of other countries. In terms of fatal injuries the UK is the best performing European State, followed by Germany, Poland, Italy, Spain and France* 

* France reports somewhat differently including fatal road accidents while at work.

While we should be proud of our performance, these comparisons are often quoted by government to justify reductions in spending within HSE. But this conveniently ignores the fact that the UK no longer has any significant primary industry such as coal mining, ship building or steel making. Therefore BSIF continue to raise the conversation on the need for good proportionate Safety and Health regulation, properly policed in the UK, and we continue to call for the HSE to be properly resourced to build on the good work of the past and improve safety and health regulation and surveillance into the future.

So with a new decade is now in front of us. BSIF will continue to champion safety and health as the positive force for good that it is.

BSIF welcomes new member

“BKS Made to measure” recognises that widespread non-compliance within it’s industry has continued since standards were first introduced in 2002 and wants to help raise much needed and long overdue awareness of Motorcycle clothing’s very clear definition and now legal standing as ‘Personal Protective Equipment’ or PPE.

Alan Murray is chief executive of the BSIF. For more information, visit www.bsif.co.uk

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From the CEO's desk - October 19 15/10/2019

Alan Murray gives an overview of the recent European Safety Federation's open workshop on the implementation of the PPE Regulation.

WHILE PENNING this article the talks go on between the UK and the EU in an attempt to uncover a way forward which will avoid the UK leaving the EU without a deal. BSIF have written extensively on the potential consequences of a no deal and what that may mean for the Personal Protective Equipment (PPE) industry, let us hope that by the time you are reading this the issue has been decided and we have a better understanding of our ongoing relationship.

As we all know the PPE industry has operated for many years under EU directives and regulations. The latest major change being PPE Regulation (EU) 2016/425 which has been in operation since April 2018. Regardless of Brexit this regulation heralded changes which the market has adjusted to over the last few years. On October the 2nd the European Safety Federation (of which I through the BSIF am President) held an open workshop on the implementation of the regulation. 
The workshop was attended by over 60 stakeholders from the industry and heard a presentation from the EU Commission Officer responsible, covering the current state of play with the implementation of the regulation.

The agenda of the workshop enabled 3 distinct workshop groups to break out and share experiences and concerns covering the important topics of 1. Market Surveillance 2. Notified Bodies and 3. Product Standards. All of these breakout groups had the opportunity to have concerns debated and have them directly addressed by the Commission. Following the individual workshops there was a panel session where the audience was able to air questions to experts.

Given that in the event of a Brexit deal we will continue to use the Regulation and even in the event of a “no deal” the UK conformity assessment process will mirror the existing EU regulation I think it is useful for you to share in what was discussed in the workshop.

On Market Surveillance – The experience across the EU markets is broadly similar to the experience in the UK. That is, that the authorities are under - resourced and do not prioritise PPE. It is all relative of course and hearing from the Belgium authorities I can tell you that they have an proactive annual plan for PPE inspection, but that is the exception. The regulation and the legal frameworks delegate the responsibility for market surveillance to national authorities in each member state. This by its nature means that there will be differences. What is clearly consistent is that whatever each member state is doing is seen as inadequate, to prevent sub standard and non compliant product from entering the market. The Commission accepted the situation is not good enough but reassured the audience that the new EU Regulation (EU) 2019/1020 on Market Surveillance and Compliance of Products will go some way to addressing this. Within market surveillance there are always technical, legal and political elements to consider, however the new regulation (EU) 2019/1020 will provide financial resource and a new network to address issues with energy and dynamism. We shall see!

On Standards – The workshop recognised that there were strengths and weaknesses in the current situation. Strengths cited were that harmonised standards did provide a statement on “state of the art” , they provide a useful means to compare PPE performance and are a useful tool in enabling end user selection. Weaknesses agreed, were that uncertainty of test measurements were unclear and a source of confusion and further that some member states require PPE to be to the latest standard when placed on the market. It was agreed by all that improvements can be realised by simplifying the revision process and only allowing changes to test methods if they closer reflect “real life use” as opposed to laboratory tests. It was universally agreed that we must move away or find a solution to non value adding requirements such as the need for hard copy instructions for use. All agreed that the production of instructions for use and the need for them to accompany each item of PPE was expensive, wasteful and unnecessary. The Commission acknowledged the points raised.

On Notified Bodies – The workshops raised concerns that within the C2 and D modules for quality assurance there is a need to make sure this is being carried out consistently – it is not currently, which can lead to problems. In the implementation of the Regulation there was concern expressed at the delay in providing product certification. The concern over the view that sub contracting of testing by Notified Bodies should not be allowed (except in certain circumstances) was also raised as this would fracture the existing model and lead to significant delays. Once again the problem of different test results from different test labs was raised and is was noted that while there are round - robin processes to establish commonality the results of these are never shared.

The workshop was a great success enabling the Commission to hear at first hand the concerns of the market and it was clear that inconsistencies in the areas covered have the potential to undermine the effectiveness of the Regulation and the industry.

Alan Murray is chief executive of BSIF. For more information, visit www.bsif.co.uk

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A focus on fit testing 13/06/2019

WHEN SPECIFYING Respiratory Protective Equipment (RPE) which includes Respiratory Protective Devices (RPD) it is important to consider the role of Fit2Fit and the needs of the user in addition to the performance characteristics of the RPE.

The importance of protecting workers from hazardous dust and fumes is not a new topic of debate. For some 2,000 years, the potential dangers have been recognised.

Fast forward to the present day and the issue remains a hot topic for debate and a key area of international safety legislation. So much so that 2018 has seen the introduction of the ISO 16975-3:2017 – a new standard specifically designed to provide guidance on how to conduct a fit testing of tight-fitting Respiratory Protective Devices (RPS)

Designed to evaluate the effectiveness of the seal between the wearer’s face and the respiratory interface specific requirements for conducting RPD fit testing outlined in the new standard include:

- Qualifications/competencies of fit test operators

- Specific fit testing procedures

- Interpretation of fit test results

- Record Keeping

We need to drive mindsets away from pure respirator performance to the relationship between respirator and each individual user. In the past a lot of disposable respirators were introduced to the market to purely meet the EN 149:2001+A1:2009 standard, without necessarily considering the individuality of the user, how it fitted them and how it was used.

If someone fits a particular disposable FFP3 mask – that would then apply to any FFP3 mask product – These are assumptions that are being made – WRONG! It is important to reinforce the message that if a respirator model is changed then the wearer needs to undergo a new fit test.

Where a tight-fitting face mask is required, a fit test on that mask and the person wearing it needs to be carried out. This is a legal requirement detailed in the CoSHH regulations.

Some people still don’t understand whether fit testing is a requirement for them or don’t know enough about it to make an effective judgement. Fit testing is also seen by some as time consuming, expensive or not applicable to them e.g.: ‘I only wear a mask once a week, so its OTT and not needed’.

Regardless of how often a mask is used – if its being used as an item of PPE it needs proper fit testing. Its also recommendable that regular fit testing is undertaken – ideally at least once every two years.

Recent research indicates that up to 50% of all RPE used does not offer the wearer the level of protection assumed and one of the major reasons is that it simply does not fit! Yet, under the regulations RPE must be correctly selected and this includes, for many types of RPE, a face piece Fit Test conducted by a competent person. So how can you be sure the person conducting the fit test is competent?

Despite not being qualified to do so, some people think they are competent enough to fit test. RPE fit testing should be conducted by a competent person, anyone carrying out the fit test must be appropriately trained, qualified and experienced.

In view of these major concerns the British Safety Industry Federation, along with the HSE and other industry stakeholders have developed a competency scheme for Fit Test Providers. The Fit2Fit RPE Fit Test Providers Accreditation Scheme is designed to confirm the competency of any person performing face piece fit testing.

What makes a Fit2Fit accredited tester competent? They have passed an industry recognised exam and therefore demonstrated they have a thorough knowledge of the HSE guidance on fit testing and can demonstrate they have the know how to fit test in practical circumstances.

If you or your employees require a fit test, then by using a Fit2Fit accredited tester you will be doing enough to demonstrate best practice and making sure the user of RPE is properly protected and has an effective seal on their mask.

A list of accredited, competent fit testers can be found by going to www.fit2fit.org and clicking on the ‘Find a tester’ tab. Why take the risk of using a non-accredited tester when it’s so easy to source a fit test from a competent Fit2Fit tester?

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Federation welcomes new member 13/06/2019

BSIF WELCOMES Buckler Boots and Buckbootz to the Federation who are products of BMF Supplier member Buckler Boots Ltd , the independent UK safety footwear company which has been at the forefront of European groundbreaking product developments for the past twenty years.

These include :

Hard As Nails , the UK’s first ever full range of safety footwear fitted with anti – penetration midsoles.

Buckbootz , Europe’s first EN S5 standard neoprene / rubber safety wellington .

Hybridz , EN S3 standard safety boot which combines lace and dealer boot convenience .

Buckz Viz , the new design protected range of EN S3 high visibility / reflective safety boot styles.

Sling those Hooks , the company’s long running campaign to have speed hooks banned from safety footwear specifications .

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