What's your head worth?

Jacques Forest, head protection committee chair of the BSIF's Personal Safety Manufacturers Association, (PSMA) discusses the need for the revision of Directive 89/686/EEC and the importance of re-categorisation of head protection

If you have an interest in PPE, then you cannot have missed the concern over fake, counterfeit and non conforming products that have been covered in the media in recent years. The same concern led the British Safety Industry Federation (BSIF) to create the Registered Safety Suppliers Scheme (RSSS) to which reputable PPE manufacturers and distributors belong. However, certain aspects of non conformance are starting to be laid directly at the door of legislation.

It is well known that workplace safety is governed by European Directives and the two most commonly referred to are Directive 89/654/EEC which deals with safety in the workplace and Directive 89/686/EEC which deals with personal protective equipment (PPE).

The latter directive regulates the requirements of PPE and was initially introduced to enable PPE to cross EEC borders to enhance free trade. The onus was then on the manufacturer to ensure that what was sold would not harm or hinder the wearer and was fit for purpose.

Instead of categorising risks and basing the requirements around expected and foreseen hazards 89/686 was written around PPE product categories. Over time, this directive evolved and now is being used to predominantly enforce the policing of the market place which has ultimately led to some incongruities.

The European Commission recognises that a revision of this directive is needed, and it has to be hoped that some of the current incongruities will be eliminated.

At the core of the 89 version of the PPE directive, it discusses the categorisation of products and PPE. The phrase "intended to protect against mortal danger or against dangers that may seriously and irreversibly harm the health, the immediate effects of which the designer assumes the user cannot identify in sufficient time" is the basis for the categorisation between cat ll and cat lll products.

The difference between these categories is that although both types require an independent evaluation of the products performance, cat lll products have to be regularly retested or their means of manufacture audited.

Currently, head protection products are not required to have either their performance or means of manufacture regularly audited. By moving head protection into cat lll the industry would be confident that the original performance evaluated at product type testing has implicitly been carried over to the product being worn.

Already included in cat lll are products protecting from air temperatures in excess of 100 °C, molten metal and electrical risks and high voltages. So head protection, especially industrial safety helmets that make any of these optional claims are automatically a cat lll product. Since most industrial safety helmets in the market place are purporting to satisfy one of these options it would seem only logical to recategorise, if not just industrial safety helmets, but all head protection.

With the recategorisation would come the recognition that head injuries are just as mortally dangerous, and seriously and irreversibly damaging to health as falls from heights or inhaling dangerous or toxic gases. Head protection would then be guaranteed to have both the consistency of performance and quality that is expected by the wearer to protect from "mortal danger or from dangers that may seriously or irreversibly harm health".

All head protection products would have to mandatorily satisfy the retest or means of manufacture audit, so as part of the revision of the 89/686 EEC directive head protection products, specifically industrial safety helmets, should fall into cat lll. The directive would be properly applied and policed and fake, counterfeit and non conforming industrial safety helmets would be driven from the market place.