IN THE previous issue of HSM I highlighted that in the King’s Speech, the new government had announced that it would create new legislation by introducing the Product Regulation and Metrology Bill (the “bill”). Well, they have not hung around and been as good as their word and the “Bill” has already begun its’ parliamentary journey with the first and second readings.

The Bill itself is relatively streamlined containing only some 14 clauses. It is an “enabling bill” which creates powers to make regulation in the interests of safety and in the interests of business. Being an “enabling bill” it allows for different targeted solutions to be introduced by using the shorter process of secondary legislation. The “bill” creates the mechanism to respond to EU rules and choose whether the UK adopts them or creates our own tailored responses to emerging product safety challenges. 

Perhaps most central, is that the “bill” will allow the UK Government to regulate online marketplaces and confirm their status as traders or economic operators, with responsibilities for product supplied through their portals. This is vital to protect people from sourcing unsuitable, unapproved and potentially unsafe product including of course PPE. 

We remain optimistic that the Product Regulation and Metrology Bill will address the problem of online marketplaces and unsafe product and we are told that the “bill” has a timeline of April/May 2025 to achieve Royal Assent, this is, again, not hanging around!

Our area of special interest is obviously PPE but the problem goes across many product categories. In their 2023 report the Office for Product Safety and Standards (OPSS) reported results from special investigations into product sold through online marketplaces covering toys, small electrical equipment, cosmetics, button batteries and category III PPE. The investigation illustrated an alarming amount of unsafe product across the types sourced, with 90% of the category III PPE being unsafe. In their 2024 Product Safety Database report 10% of the failures reported across all goods was PPE. PPE was only headed by Toys (14%), Cosmetics (20%) and the most frequently listed, Electrical Appliances at 23%. 

If we consider the volume of product sold in Electricals, Toys and Cosmetics versus the volumes of PPE sold, for PPE to make up 10% of the total failures on the Product Safety Database it just shows how much poor PPE is available online.

The BSIF Registered Safety Supplier Scheme continues to carry out market surveillance of PPE and Safety Equipment and the official government figures above show that our work is absolutely vital. 

Throughout 2023 and 2024 we have run the Check – Select - Protect campaign to highlight credible, capable and competent suppliers from whom users should source. As we move into 2025, we will continue this work and we are planning a wide-reaching campaign under the banner “PPE Saves Lives”. 

We will pre-launch “PPE Saves Lives” on the 27 of November at HSM Live in Edinburgh and include it in the “Not Fit for Work” webinar on the 29 of November.

In other news the Occupational Safety and Health Stakeholder Alliance published its’ whitepaper “Prioritising Mental Health in the Workplace” on the 10 of October to coincide with World Mental Health Day. The “Alliance” has published the whitepaper in the hope that it will be a further catalyst for change and that it will support employers to embed a safety culture that recognises the value of good mental health support for their workforce. 

The Health and Safety Executive (HSE) report that there are over 3/4s of a million people in Great Britain suffering from work-related stress, depression or anxiety and that in 2023, 17 million work- days were lost as a result. The “Alliance” white paper sets out several recommendations and central is the call for the Government to develop a national workplace mental health strategy which targets and support businesses of all sizes in building capability and capacity to manage work-related mental health risks.

The full white paper can be read here Prioritising mental health in the workplace

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

The British Safety Industry Federation (BSIF), the membership organisation for PPE and safety equipment manufacturers, distributors and specialist service providers, has launched a groundbreaking initiative. We invite employers, duty holders and safety professionals to join our exclusive Membership Pilot Project. The ‘Pilot’ was launched in June at the same event as HSM Live Coventry.

During HSM Live Scotland, which takes place on 27 November at The EICC, BSIF will be detailing the purpose and benefits of the Pilot Project and encouraging participation from visitors to enable them the opportunity to shape the future of the industry. The uniqueness of the pilot scheme is found in the ability to bring together the providers and users of PPE and safety equipment for the first time under one membership organisation. 

Why participate in the BSIF Pilot?

By joining the innovative pilot scheme, participants will gain access to a range of invaluable benefits designed to enhance safety standards and practices across the UK. You should also know that as this is a ‘pilot’ scheme, BSIF will not be seeking any membership fees to join. Members of the ‘Pilot Scheme’ will have access to a wide range of valuable assets:

Independent PPE Helpline:

Receive expert advice and support for all your PPE and safety product related queries. The helpline will cover areas such as;

• PPE Regulation 2016/425 
• Respiratory face fit testing
• PPE EN standards
• Product/documentation compliance checking 
• Height safety
• Non-compliance reporting
• Membership enquiries/help

Guidance on standards & PPE regulations:

Stay informed with regulations and compliance, get information on changes and updates as they happen.

BSIF Bulletins for industry updates:

Keep up-to-date with the latest news and developments within the industry, BSIF communicate information that keeps you ahead of the curve. 

Our mailers arrive into your inbox and cover:

• Government updates
• European PPE/safety information
• Standard changes
• BSIF member events
• Industry opportunities

BSIF qualifications:

BSIF Pilot membership gives access to industry courses & qualifications at discounted rates. For example a new publicly recognised qualification for specifiers/buyers of PPE/Safety products. This qualification will help provide the tools needed to procure compliant & safe product. It includes:

• Legal requirements
• Standardisation processes (EN/ISO standards) for PPE/safety products
• Market surveillance
• Safety In the workplace
• PPE EN standards information

BSIF industry campaigns:

BSIF have produced campaigns to raise awareness of health and safety issues. They highlight what can happen when personal safety is not taken into account. BSIF want to engage with Pilot members to develop new campaigns and posters to help people avoid hazards that can affect their life now and in the future.  

Be a pioneer in safety

Joining the BSIF Membership Pilot Scheme offers an opportunity to pioneer advancements in workplace safety. By collaborating with industry stakeholders, suppliers and buyers, we will help shape a safer future for the UK workforce.

We look forward to seeing you at HSM Live and should you wish to join the ‘Pilot’ formally ahead of the event, then please express your interest by contacting us at enquiries@bsif.co.uk or calling 01442 248744

For more information please visit BSIF at HSM Live Scotland, or visit www.bsif.co.uk

RPE Face Fit testing is a process for ensuring a specific make, model and size of tight-fitting protective face masks are suitable to  the individual wearer’s facial features and that the chosen mask seals correctly to the wearer’s face. A Face Fit test will also help to identify unsuitable face masks which should not be used by the individual. 

 Why does a Face Fit Test need to be carried out?

 Firstly, the Health & Safety Executive (HSE) state that a Face Fit Test must be carried out on any worker who is using tight fitting RPE to protect them from a hazard. It is a legal requirement for employers to make sure their employees are face fitted for any tight fitting mask they use.

The performance of tight-fitting face masks relies on a good contact between the wearer’s skin and the face seal of the face mask. Individuals facial structures vary significantly in shape and size so it is unlikely that one particular make, model or size of RPE face mask will fit everyone. 

Inadequate fit of a face mask will significantly reduce the protection provided to the wearer. Any reduction in protection may lead to immediate or long term ill health or can even put the RPE wearer’s life in danger. 

Who should be used to conduct RPE face mask Fit Testing?

 The HSE state that face mask fit testing should be carried out by an individual who is competent in face fit testing. 

So how does an individual prove they are competent to face fit test?

Under the Fit2Fit scheme, an individual offering face fitting of RPE and who seeks to be qualified as competent, must pass a written test on respiratory protection guidance and a specific written test on face fitting methodology before undertaking an observed practical assessment of a face fit against the accepted HSE / Fit2Fit guidance and syllabus. This is the accepted method of evaluating the competence of an individual carrying out this vital service. Historically, of those who apply for qualification there is a failure rate approaching 30%!

Based on reliable information it is believed that in the UK there are significant numbers of people who are offering RPE face fitting. Are they competent? The number of qualified competent individuals is at the end of 2023 approximately 490, so it is vital that the employer discharges their responsibility in managing a respiratory protection policy, by ensuring they demand evidence of competency. The easiest way to see evidence of competency….Demand Fit2Fit!

What is the Fit2Fit Scheme?

 The Fit2Fit Scheme administered by the British Safety Industry Federation (BSIF) and supported actively by the Health and Safety Executive (HSE) has a very clear mission:

“To improve the respiratory health of those wearing tight fitting RPE through being fit tested by a Fit2Fit accredited provider”.  

The Fit2Fit Qualification Scheme has for some years been premised on two key HSE publications HSG 53 – Respiratory Protective Equipment at Work: A Practical Guide and INDG479 the specific guidance on face fitting utilising accepted methodology.  In addition Fit2Fit has produced Companion documents covering the Qualitative method and Quantitative methods using Ambient Particle Counting and Controlled Negative Pressure.

The HSE took the view that as the regulator it must retain the responsibility for what must be done in face fitting and the steps required to carry out an effective face fit. However, HSE decided that the Fit2Fit Scheme was best placed to take the role of informing industry how this should be carried out.

 Where can you find a Competent & Qualified Face Fit Tester?

The easiest way to identify and source a Competent & Qualified Face Fit Tester is to use the Fit2Fit Scheme website, all qualified fit testers are listed with their contact details, method of qualification and date of expiry of their qualification.

Go to www.fit2fit.org/find-a-tester

Not only can you find the full list of Qualified Face Fit Testers but you will also find further information on Fit Testing by using the ‘Resources’ page. It features documents that can be downloaded for free that will help in your understanding of the fit testing process.

With the Health and Safety Executive (HSE) reporting 875,000 people in Great Britain suffering from work-related stress, depression or anxiety in 2022-23 – and more than 17 million working days lost in that year alone – the Occupational Safety and Health (OSH) Stakeholder Alliance is setting out several recommendations to address this concerning issue.

In a new white paper, Prioritising mental health in the workplace, the OSH Alliance calls on the UK Government to develop a national workplace mental health strategy that targets and supports all businesses in building the capacity needed to manage mental health-related risks.

It also calls on businesses to critically assess and review their safety and health leadership and commitment, strategy and culture to ensure their workplaces are conducive to positive mental health.

With the Federation of Small Businesses reporting more than 99 per cent of businesses in the UK are small or medium-sized enterprises (SMEs), meaning they employ less than 250 people, many employers lack the capacity or resources which larger businesses have access to, so the OSH Alliance’s white paper has made smaller organisations a priority in its calls to action.

It calls on occupational safety and health (OSH) professionals and others who have OSH responsibilities such as those in HR, to make use of OSH approaches and tools to support organisations, particularly SMEs, to prevent and manage psychosocial risks and to protect and promote mental health. It also wants the Government to ensure the HSE and local authorities are adequately funded and able to deliver the required levels of inspection and enforcement needed to drive the organisational approach to prevent and manage psychosocial risks.

By 2030, the OSH Alliance hopes that the combined actions in its white paper can significantly reduce the burden of work-related mental ill health, which is currently estimated by Deloitte to cost the economy £51 billion a year.

The OSH Stakeholder Alliance comprises nine leading safety and health organisations: the Institution of Occupational Safety and Health (IOSH); the British Occupational Hygiene Society (BOHS); British Safety Council (BSC); the British Safety Industry Federation (BSIF); the Chartered Institute of Environmental Health (CIEH); the Chartered Institute of Ergonomics and Human Factors (CIEHF); the International Institute of Risk and Safety Management (IIRSM); the National Examination Board in Occupational Safety and Health (NEBOSH); and the Royal Society for the Prevention of Accidents (RoSPA). It is currently chaired by the BSIF.

John Gill, chair of the BSIF, said: “The OSH Alliance was formed to harness the collective capability and influence of its members to support and enhance initiatives to improve the safety and health of workers through effective risk mitigation.

“This white paper signals the OSH Alliance’s intention to add its weight to that of others in pursuit of a sustained reduction in the incidence of mental health issues in the workplace and the personal and collateral damage they cause.”

To view the white paper, visit Prioritising mental health in the workplace

To facilitate this, BSIF have launched a free membership pilot. The Pilot seeks to deliver a structure by which BSIF can engage, embrace and support duty holders and safety professionals/ compliance managers in all things in PPE/Safety products.

There is no cost for Pilot membership, during the Pilot we will forge a form of membership that works for you, the BSIF and the wider safety industry within the UK.

The British Safety Industry Federation (BSIF) is the Trade Association for the safety industry and acts as a leading voice for the sector. Set up in 1994 the Federation has some 400 members representing the complete supply chain including manufacturers, importers and distributors of personal protective equipment (PPE) and safety products, through to test houses, certification bodies and specialist safety service providers.

The following give a brief overview of the Pilot membership benefits.

PPE Helpline

The BSIF Members PPE Helpline has been set up to reduce the complexities of PPE & Safety Products and to become the ’Go To’ for information not always easily obtainable in the market place.

The BSIF PPE Helpline is administered by PPE & Safety experts ready to assist with any questions relating to a variety of areas including product queries, standards information and help in understanding compliance of different products.

The pandemic shone a light on the need for people to be able to access free non commercially biased information. BSIF’s new helpline will cover areas such as:

OFTEN AT BSIF the summer months can provide a period of calm and stability, allowing for planning ahead of what is always a busy period in the autumn months. It hasn’t been that way this year! Yes, the planning has had to go ahead as normal, and it has, but after some years of political upset and regulatory turmoil we obviously had an election and a change of government in July. So potentially more upheaval and change in our industry on the horizon.

In the last issue of HSM I wrote that the continuing recognition of CE had been passed through the “Commons” and is now law. So, for good or ill, that is issue is done and dusted. 

The King’s Speech at the start of the new Government’s period in office, announced that the Product Safety and Metrology Bill is likely to update product safety law to reflect some of the innovations in the EU’s General Product Safety Regulation (which does not apply in the UK post-Brexit). The effect of this could be that some of the EU legislation provides market surveillance authorities with the power to order online marketplaces (OMP) to remove dangerous products from their websites, and that could be picked up now by the UK. The UK’s own independent Product Safety (recommendations) legislation did not make the “cut” prior to the proroguing of parliament ahead of the election. 

BSIF, spearheaded by the Registered Safety Supplier Scheme, have devoted a great deal of resource in trying to ensure that non-compliant and potentially unsafe PPE supplied via OMPs are removed, but the current legal framework remains apparently inadequate to deal with the situation. I say apparently, because we are, I can assure you, continuing to research means of finding the appropriate legal mechanisms to manage out, unsafe PPE and restore some fairness to the market in general.

Whether the comments in the Kings Speech herald a closer regulatory relationship with the EU remains to be seen. I personally hope that the new government is very selective and chooses well when determining which EU rules to follow. For example, currently there is the EU Deforestation Regulation (EUDR) (coming into effect by the end of December 2024). This regulation in effect requires manufacturers to be able to prove that product, including PPE, does not come from any geo-location that had been “de-forested” after 2020. This is undoubtedly a well-intentioned piece of legislation, but the infrastructure and systems for market surveillance and enforcement are simply not ready.
It is clear that good proportionate well drafted regulations make a positive contribution to our lives, and manufacturers who take responsibilities for their products put systems in place. However, without effective enforcement it means that bad actors can continue to do what they want and again an already unfair market is made more unbalanced. 

I use the example of EUDR because it is currently causing challenges, but in general terms regulation without enforcement is window-dressing and discriminatory in as far, as I mentioned above, that responsible businesses follow rules while irresponsible ones do not. It is perhaps an obvious thing to say, but enforcement requires resources and with the new chancellor recently making it clear that money remains tight it does not look like there will be much, in the world of competing priorities, to go around.

I would like to draw you attention to the impact of the lack of resources on the work of one of our most important regulators, the Health and safety Executive (HSE). HSE are responsible (amongst other things) for policing Occupational Safety and Health in the UK. This responsibility includes PPE used at work.

A recent report published by Prospect, highlighted the financial challenges within the HSE where they are required to cover wider responsibilities with lower income. It illustrates the impacts, including drops in staffing overall of 43% in the last 20 years and a fall off in the number of Inspectors (those that enforce the regulations) of 41%.

With less inspectors you get, of course, less inspections and consequently less enforcement of regulation. In the year 2010/2011 the HSE carried our over 33,000 inspections and by comparison in 2022/2023 they completed just under 15,000. That is a reduction of over 50% and a greater relative reduction than the reduction in inspector numbers!

What perhaps may surprise you, and it certainly did me, is that only 2% of the RIDDOR reports filed last year were subject to an investigation, with the HSE citing insufficient resource as a reason why some mandatory investigations were not undertaken.

The HSE is a well-run and highly valued institution and makes a major contribution to the safety and health of our society. We need it to be adequately resourced and I hope that you will join me in calling for the Government to recognise HSE and its work and resource it correctly.

ALTHOUGH THE peak of the pandemic is now four years behind us, the UK continues to face significant challenges with its PPE procurement. Financial disclosures from the Department of Health and Social Care reveal that nearly £10 billion was spent on defective or unusable Personal Protective Equipment (PPE) during the Covid-19 crisis. This troubling figure is further exacerbated by an investigation, by the National Audit Office, which is still struggling to recover millions lost to fraud.

The current government, backed by the appointment of a COVID corruption tsar, has expressed a desire to reclaim some of the funds wasted on unsuitable PPE. However, fundamental issues persist in how PPE is both purchased and distributed across the UK.

The reality is, the longstanding issue of neglecting rules in the procurement of Personal Protective Equipment (PPE) is nothing new. Coupled with insufficient official market oversight in the UK, this has facilitated the entry of substandard and non-compliant products into circulation, endangering unsuspecting users. The British Safety Industry Federation (BSIF) advocates for enhanced proficiency in PPE procurement, aiming not only to elevate safety standards significantly but also to prevent potential future crises. 

To the untrained, PPE is a complex and confusing purchase. This is well documented throughout the Covid-19 pandemic with millions consistently awarded to substandard manufacturers. At the height of the pandemic for example, a contract was given to a company which specialises in currency trading and offshore property to deliver fifty million face masks which were found to be unusable, despite being part of a £252m contract. While such figures are staggering, the cost of the potential threat to health and safety from the use of substandard PPE is even more devastating, albeit more difficult to measure.  

Under the PPE at work regulations anyone in charge of specifying, buying and providing PPE and safety equipment has a responsibility to select appropriate, approved, certified and compliant products that meet workers' specific requirements.

Due diligence is vital. Buyers and those selecting the PPE must assess the extent to which a product is fit for purpose. They should also look for wearer benefits above and beyond basic protection and make sure it fits comfortably so that it performs correctly. They must also determine whether it is compatible with other PPE that may be required. Yet many people responsible for PPE procurement are not fully aware of their responsibilities or lack the resources to fulfil them. 

79% of PPE from non-registered providers failed tests

The volume of substandard and non-compliant products on the market is showing no signs of abating. While the pandemic shone a light on this critical issue, it is still an enormous problem. The BSIF routinely tests a wide range of PPE and safety equipment available across the board, to better understand where these problems lie. In doing so, the BSIF can help to ensure that costly mistakes are avoided, helping to improve the overall standard of PPE and safety equipment available. 

The BSIF's latest investigation, spanning from December 2022 to December 2023, paints a concerning picture. Out of the 123 items spot-sourced from non-registered suppliers, a mere 21% passed, leaving a staggering 79% failing to meet even the most basic regulatory and safety criteria. These aren't just statistics; in some cases, lives are at risk.

During flame spread testing of a Flame Retardant Parka, for example, which was bought from an online retailer, the outer layer burnt through, exposing the inner layer, which then caught fire, resulting in the entire coat being consumed by flames. The garment also lacked mandatory documentation and markings in line with PPE Regulation requirements.

Elsewhere, a pair of safety glasses which were bought from a high street retailer, failed impact resistance testing. No CE markings or equivalent were found to be displayed and the product was missing essential documentation. What’s more, the product was still available to buy over two months later, despite assurances that the glasses would be removed from sale.

The consequences of such negligence extend far beyond financial losses. They manifest in the form of devastating injuries, irreparable harm and broken trust. 

The BSIF runs the BSIF Registered Safety Supplier Scheme which provides buyers with assurance that the products they are buying are coming from a compliant, competent and trustworthy supplier. With a remarkable 91% compliance rate during BSIF testing and swift rectification of any shortcomings, these suppliers exemplify high standards in safety and reliability that those specifying and purchasing PPE should demand. 

Driving out substandard PPE and safety equipment

To help drive out substandard PPE and safety equipment, sourcing from Registered Safety Suppliers needs to become standard practice. While this is not yet mandatory, the more that people insist on only using these suppliers, the easier it will become to eradicate the issue, helping to prevent a recurrence in the future of what we have seen and experienced in recent times. 

The BSIF Registered Safety Supplier Shield can only be displayed by companies whose products and services are subject to tests to ensure they are fit for purpose. This makes procurement far simpler since these audited suppliers are committed to only providing genuine, good quality, products, promising a commitment to authenticity and dedication safety and well-being. 

In addition to testing products and services the Registered Safety Supplier Scheme verification process audits that all of the suppliers regulatory obligations and responsibilities have been carried out.

We therefore encourage all those charged with specifying PPE to;

• Check that the supplier is a BSIF Registered Safety Supplier
• Select the correct PPE, using the guidance provided by their qualified staff
• Protect your most valuable asset – your people

Sourcing Safety, a course and qualification 

To further support safety and health in the UK market and help specifiers and purchasers of PPE the BSIF are launching “Sourcing Safety” a course and qualification to help educate duty-holders on Personal Protective Equipment (PPE) and assist them in coming to informed decisions when specifying and buying these safety critical items. 

To register interest and get more information on “Sourcing Safety” please e-mail enquiries@bsif.co.uk.

Alan Murray is CEO of the British Safety Industry Federation (BSIF). For more information, visit www.bsif.co.uk

Construction, manufacturing and engineering workers often face high levels of noise exposure on a daily basis. Excessive noise can impair concentration and focus, potentially increasing the risk of workplace accidents. It can also lead to permanent noise-induced hearing loss and even deafness.

The ear contains sensory ‘hair cells’ that are responsible for converting the mechanical sound vibrations into electrical signals that the brain can interpret as sound. Regular exposure to loud noise can damage these hair cells, which means they can no longer send signals to the brain and noise will not be heard. This type of hearing loss cannot be repaired – once lost, it stays lost. 

Tinnitus is another significant risk. It is a distressing condition that may include the perception of ringing, whistling, buzzing, hissing or humming, often leading to difficulty concentrating, sleep disturbances and stress.

Based on Labour Force Survey data, it is estimated that around 11,000 workers in Britain had work-related hearing problems in the period from 2020/21 to 2022/23.¹ The Industrial Injuries Disablement Benefit scheme, meanwhile, recorded 85 new cases of deafness in 2022. This is based on a measured loss of more than 50 dB of hearing in both ears.

The PPE regulation (EU) 2016/425, which came into effect in 2018, recognises harmful noise as an irreversible health risk. As such, hearing protection moved from category II (intermediate PPE) to category III (complex PPE). So what action do employers need to take to keep their workers safe?

Controlling risk

Employers have a legal responsibility not to damage the hearing of their workforce. The 2005 Control of Noise at Work Regulations require them to assess the risks to employees from noise at work and take action to reduce the noise exposure that produces those risks. 

Ideally, the source of the noise should be eliminated completely. If that is not possible, employers should investigate whether the noisy process can be undertaken in a different, quieter way. If it can’t, it may be possible to limit the transmission of noise through measures such as dampening vibrating panels, fitting silencers to exhausts, acoustically screening or enclosing noisy components, or providing noise havens at workstations. Employers should also implement administrative controls including buying or hiring low-noise equipment as policy and ensuring the equipment is properly maintained.

If these measures are insufficient, hearing protection is required. Employees should receive hearing protection if noise exposure is above the lower action level of 80dB average or 135dB peak. Noise levels above 85dB average or 137dB peak represent the upper action level and require action to reduce noise exposure with a planned programme of noise control. The exposure limit values, meanwhile, are 87dB average and 140dB peak and must not be exceeded.

All employees and visitors who are required to enter noisy areas should receive suitable hearing protection along with instructions and training to ensure it is worn correctly. It should be worn at all times in the noisy area. Removing protection for just five minutes when faced with an hour of noise will reduce the protection achieved by more than half.

Selecting safe products

It is important to ensure that the hearing protection provided is suitable for the user and their work activities, and that they can use it comfortably with any other required PPE or equipment. 

Hearing protectors receive a Single Number Rating (SNR) based on the level of noise reduction they provide when fitted correctly. Choosing the correct product for the level and duration of the noise hazard is important. This will not usually be the highest level available. Users will find it uncomfortable and isolating if they use too high a level of protection – and they will be more likely to remove it. 

PPE buyers should also take care to only buy products that perform as advertised. All hearing protection must have UKCA or CE marks and comply with all relevant PPE regulations. However, British Safety Industry Federation (BSIF) investigation has revealed that hearing protection on the UK market from non-BSIF Registered Safety Suppliers frequently shows failures against product claims and/or documentation. 

Registered Safety Supplier Scheme

We work hard to eliminate unsafe PPE from the market. Our Registered Safety Supplier Scheme (RSSS) was set up with the aim of tackling the threat posed by non-compliant and potentially unsafe products The RSSS was created to provide assurance to users that only compliant and correctly performing products are being supplied through a capable, educated, competent supply chain. 

We carry out tests on member products as well as non-member products. Annually, or in the event of a complaint, we will source on the open market one product from a registered member’s PPE or relevant related product offering. An accredited test laboratory will test the product to one or more clauses of the relevant standard. In the event of a product fail, the BSIF will contact the member to begin corrective measures – or ensure the product is withdrawn from the open market if required. Any member that refuses corrective action and communication can be removed from the RSSS and Trading Standards will be informed.

Buyers can be assured that any vendor displaying the RSSS shield has signed a binding declaration that the PPE and safety equipment they offer meets the correct standards, fully complies with the regulations, and is appropriately UKCA and or CE marked.

Harmful noise is too big a risk to take chances. Where PPE is required, UK buyers and specifiers of PPE should always look for the RSSS shield so they can be confident that products will deliver the protection that users require.

In April 2024, the BSIF released a new hearing protection campaign Just because it fits. The campaign focuses on hearing protection and making sure that the selected PPE fits and is effective when incorporating other elements of PPE such as safety helmets. 

A full list of registered suppliers is available to view at: https://www.bsif.co.uk/rsss

[1] https://www.hse.gov.uk/statistics/causdis/deafness/index.htm

We suggest buyers and end users follow a simple three-step process when buying PPE to ensure that products are fit for purpose:

1) CHECK your supplier is BSIF registered. BSIF Audited suppliers are compliant, competent and trustworthy. Don't settle for less.

2) SELECT appropriate, certified and compliant products. Registered Safety Suppliers can support the product selection process through their competence, capability and knowledge. 

3) PROTECT your workforce and your business. Registered Safety Suppliers go above and beyond, helping to keep your people safe and helping your business to thrive. 

Anyone can sell safety but you shouldn't buy safety from just anyone: Always specify the shield. 

As mentioned, the focus from BSIF has been on RPE and detailing how it should be used and selected when it has been deemed as required to protect a worker or workforce from a hazard. RPE is designed to protect the wearer from breathing in harmful substances or from oxygen-deficient atmospheres when other controls are either not possible or insufficient on their own. RPE can broken down into two main types:

• Respirators
• Breathing Apparatus

Whilst Breathing Apparatus can be used when fumigating large areas, we’ll focus on the various types of respirators shown here. 

The images above show the two different types of respirators, Tight-fitting facepieces (often referred to as masks) which rely on having a good seal with the wearer's face and Loose-fitting facepieces which rely on enough clean air being provided to the wearer to prevent contaminant leaking in (only available as powered respirators). Examples are hoods, helmets, visors, blouses and suits.

Selecting RPE

Selecting the appropriate RPE is vital, when choosing the product to use, it must be both Adequate and Suitable.

What do we mean by this? Well, Adequate means the RPE chosen is right for the hazard that the wearer is up against and wearing the product will reduce the exposure to the required level to protect their health.

Suitable means, is the RPE right for the wearer, the task and the environment in which it is being worn. When wearing the RPE, the wearer should be able to work freely and without any additional risks caused by the RPE.

Some further points to consider in the selection process are: What is the hazardous substance that the RPE is protecting against? What is the form of that substance in the air, is it a gas? A vapour or a particle? What is the task being carried out that requires the use of RPE? Does the wearer have any individual requirements that need to be considered, eg: do they wear glasses?

RPE Filters

To identify the hazard that you will be exposed to, you need to consider the safety data sheets provided by the manufacturer of any chemical being used – this can then help identify the suitable filter you may need. The MSDS should detail the CAS number of the chemical and any good provider of RPE will be able to identify the type of filter that may be required.

Different hazards require different filters or combinations of filters, As you can see in the images here these filters all have relevant codes and colours based upon what they are designed to protect against, It’s worth noting that some filters can be combined to provide protection against multiple hazards.

Filtering Face Pieces

Now we will take a look at what are commonly called ‘dust masks’. These are filtering face pieces and. They work by creating a tight seal to the wearers face and the mask filters any contaminants from entering when the wearer breaths in. The images below show the difference between a mask being fitted correctly and therefore filtering the air and a mask that doesn’t fit, this illustrates how contaminated air can be breathed in which poses a risk to the wearer.

The masks are available as cup, fold flat and may be valved or un-valved. They have a grading of P1, P2 or P3 and generally are known as FFP1, FFP2 etc.

It is worth noting that some masks available to purchase are designed with ear loop fittings. These types of mask are not suitable to be worn as a protective measure. HSE conducted 90 tests on ear loop masks and of those 90 only 2 were able to pass a fit test meaning that if worn they would not offer protection. The reason for this is that with an ear loop mask the fit to the face is not tight enough to provide an adequate seal. The HSE actually went on to state that Ear loop masks do not provide protection as tight fitting RPE. 

Face Fit Testing

RPE Face Fit testing is a process for ensuring a specific make, model and size of tight-fitting protective face masks are suitable to the individual wearer’s facial features and that the chosen mask seals correctly to the wearer’s face. A Face Fit test will also help to identify unsuitable face masks which should not be used by the individual. The HSE state that a Face Fit test must be carried out on any worker who is using tight fitting RPE to protect them from a hazard.

The performance of tight-fitting face masks relies on a good contact between the wearer’s skin and the face seal of the face mask. 

Who should conduct RPE face mask Fit Testing?

The HSE state that face mask fit testing should be carried out by an individual who is competent in face fit testing.

So how does an individual prove they are competent to face fit test?

One way to prove competency is for the fit testers to hold the Fit2Fit Accreditation, you can find all of the Fit2Fit Accredited fit testers here: www.fit2fit.org/find-a-tester/

Do you need to be clean shaven when wearing RPE?

One of the questions we get asked most is do you have to be clean shaven when wearing a mask? The Simple answer is yes, when that mask is relying on a tight seal to the face in an area that could have facial hair. 

Useful Links:

www.bsif.co.uk

www.fit2fit.org

www.registeredsafetysupplierscheme.co.uk

SO, AS I sit to write my column the Government has just announced a general election and with that comes the proroguing of parliament and a wholesale halt to the working of government. One piece of legislation that made it over the line before Westminster was wound up was the amendment which confirms ongoing recognition of the CE mark in law, alongside the UKCA/UKNI mark and processes. See link to the amendment www.legislation.gov.uk/uksi/2024/696/contents/made

Specific guidance on how this will apply will be produced shortly, when all the pertinent details are available.  

The application of the amendment had been a formality and we already knew that the intention was to maintain recognition of CE into the future anyway, but it is however an important confirmation laid down ahead of any new government coming into power in July as, I think we all appreciate, their agendas will be full and their priority list overflowing, with the any desire to focus in this area unlikely to materialise!  

So, what does the future hold for UKCA/UKNI? As we are all aware the referendum vote of 2016 saw the UK leave the EU and the institutions of union. One of the consequences being, that it was felt necessary that we had our own independent product conformity assessment regime, embodied in and by the UKCA mark. The rationale for the UKCA mark was that it would transition us away from CE and establish a separate and respected mark for the UK. The motivation in this was two-fold, on a practical side a separate mark was felt to be useful in the processes of negotiating trade deals (beyond the EU) in that we had a stand-alone product safety and conformity regime and on the political/ideological side it was it was seen as proof-positive that we do longer did the bidding of the EU.
However, the government has never really invested in the UKCA/UKNI process and has continually changed the goal posts on it when it will be “required” as a replacement for CE. Originally it was announced that it was effective from January 2021 but there would be a year of transition when CE will still be accepted. At this point all the responsible manufacturers of PPE set about engaging with Approved Bodies to have their products UKCA certified and approved. Bodies previously operating as Notified Bodies under CE became UKCA Approved Bodies right away, with a further 12 bodies going through the rigorous UKAS and government approval system. In the interim period we have seen multiple announcements moving the dates out as to when UKCA/UKNI must be applied in place of CE. In parallel we saw announcements making it easier to comply with UKCA/UKNI by (in effect) using existing CE credentials as the basis of demonstrating compliance. The impact of the changes has been that a manufacturer does not need UKCA/UKNI or a UK Approved Body to place PPE on the market and confirmed by the Product Safety and Metrology (amendment) which completed its’ parliamentary passage on the 20 May 2024. As a consequence, the declining demand for UKCA/UKNI has dropped off the cliff. 

You should remember that when UKCA announced it was clear that only UK approved Conformity Assessment Bodies could provide product approval decisions (and this goes well beyond PPE taking in some 21 different sectors) at the same time they were no longer able to provide approval decisions under CE, as they were pre-Brexit, while they were EU Notified Bodies. In short, with little or no demand for UKCA our UK test and certification industry is in peril.
This was notionally recognised by the Department of Business and Trade and all affected Approved Bodies were invited to a series of meetings last August/September to air the challenges and discuss with the Department how support could be extended. No material support was forthcoming, with a subsequent meeting called for the 1^st of May 2024, at which it was clear that no support was on the table.
It has to be remembered that the UK has never actually published a stand-alone version of the PPE Regulation (EU) 2016/425 nor any versions of a “Blue Guide” simply relying on the original EU Regulation, cosmetically altered to remove references to the commission and member states. In short, we have always used the EU Regulation as the basis for our own rules, so with the political imperatives gone, it seems that they have defaulted to just relying on what we had before under CE but being content to condone the millions already spent and sanction the failure of the UK Test and Certification industry. 

Setting aside for a moment the jeopardy put upon the Test and Certification industry, is all of this a missed opportunity for the country and control of our product safety regime? In December 2020 when the UKCA processes began all of the EU PPE Harmonised Product Standards (for design and performance) were copy pasted as UK Designated Standards so providing continuity for the market. Since the establishment of the PPE Designated Standards, the UK has created restrictions on EN149 and EN 469 on respiratory protection and firefighters clothing respectively. These restrictions arguably create safeguards on the standards and are very much a positive step. The restrictions were welcomed, and the Department of Business and Trade are to be commended for taking these actions. The restrictions mentioned above are evidence of the UK taking appropriate independent actions which make a contribution to safety and health, therefore, one could argue that in these particular examples the UKCA mark is an indication of a better and safer product. However, and while of course the potential to create restrictions still exists, the continual neglect, the existential threat to test and certification bodies and rapidly diminishing profile of UKCA will surely mean that the rationale for the UKCA mark as a mechanism to transition us away from CE and establish a separate and respected mark for the UK will not be realised within any reasonable time horizon. Perhaps a lost opportunity and a great deal of money wasted if the government does not provide a reason and an incentive for all stakeholders to get behind UKCA.