From the CEO’s Desk

BSIF remains committed to keeping members fully advised of the impacts and we will begin the process of guidance as soon as the publication dates are confirmed. Up to this point we have kept the market fully briefed and while there appear to be many positives in the latest text the concerns we have with Category II PPE remain.

We have over recent months become increasingly concerned about performance and compliance issues on some key PPE product types. The situation was highlighted when a UK accredited laboratory ran tests on ranges of safety footwear and leather gloves which illustrated, that despite carrying EN approvals many models failed to comply with the standards against which they were originally certified. This situation poses an obvious risk to the end users and is a timely reminder that only relying on the CE certification for certain product types provides no guarantee of ongoing quality assurance.

Both of the above product types fall into Category II of the PPE Regulations and as such sit outside sections 11(a) or 11(b) which provides re-assurance through ongoing quality testing. The BSIF has long felt that this is a real vulnerability as there is no protocol demanded by the regulations for checking that these items and their constituent parts are the same as the samples that were originally submitted for certification testing, which could have been years ago. The latest texts for the new regulations do not alter or remedy this situation.

These products in Category II can often be imported from afar and are subject to long supply chains where control is a potential problem. Safety footwear and safety gloves are front line safety products handling and in contact with potential hazards all day long. Users of these products deserve to know that they perform as they should.

With safety footwear the problem identified was with the toe cap which is designed to protect the front of the foot from the effects of heavy objects falling or rolling on to it. In order to check performance a compression test is carried out. Safety toe caps were originally made from steel however, in recent times composite moulded toe caps have often been the component of choice. There appears to be no distinct definition of "composite” and in the tests it was found that 'compression moulded' caps performed as they should but several 'injection moulded' caps did not. In the case of the gloves that were tested the failures  occurred where the fabric of the gloves was found to contain banned substances including Chromium VI and/or Aromatic Amines often associated with AZO dyes.

As in the situation with the toe caps a user cannot check for himself that the product complies so it falls to producers and suppliers to be extra vigilant in  ensuring that only materials and parts that were utilised in the original product submitted for approval are still being used and that full traceability is in place.

Safety footwear and safety gloves play a vital role in user protection; they must be fit for purpose and comply with the regulations. It should be noted that safety helmets also fall into this category and are subject to the same vulnerabilities when it comes to ongoing quality assurance. BSIF championed the elevation of safety helmets to Category III in the new regulations. Unfortunately it looks unlikely that this will be adopted. We will of course continue to promote the case.

We are committed to ensuring the quality of product in the market and it is clear that product in Category II provides a real challenge for us all. Using the examples that we have seen with gloves and footwear we call on all those in the industry to make doubly certain and ensure that their supply routes are fully aligned to providing safe, legal and fit for purpose PPE. End users of Personal Protective Equipment rely on the protection levels claimed.