PPE Directive - when is an “old” standard too old?

The use of harmonised ENs is the most transparent and convenient route for products to evidence that they comply with the PPE Directive. These standards are in the public domain and, therefore, are readily available to purchasers and those deploying PPE. The fact that these harmonised ENs have a "presumption of conformity" with the PPE Directive relieves Notified Bodies of any requirement to exercise judgement regarding compliance and present clear and concise obligations on manufacturers.

The current lack of any transition arrangements means the immediate withdrawal of the original standard when the newly revised standard is publicised as harmonised within the EU's Official Journal. Because of this "immediate" withdrawal of the "presumption of conformity", purchasers and users assume that products conforming to the original standard are no longer suitable. This results in products, which remain safe and effective, being rejected and presents the supply chain with significant difficulties regarding supply inventories, stocks held by users and shortages whilst products tested to the new standard come on stream.

The solution is simple and applied to other product areas. With all electrical standards there is a three year transition period when both the original standard and the revised standard carry a "harmonised" presumption of conformity unless the original standard has been withdrawn for safety reasons. With the impending revision of the PPE Directive, the BSIF sees this as an opportunity for this problem to be resolved.