The world of PPE one year on from new Regulation

With the new Regulation 2016/425 replacing PPE Directive 89/686/EEC, and the twelve month transitional period coming to an end, it’s imperative that changes are followed to the letter of the law, otherwise there can be serious consequences that follow. Brexit will not affect the Regulation either, with it acting as a binding legislative act that must be applied in its entirety across EU states without requiring separate national legislation, currently, with the Regulation also having been absorbed into British law.

Non-compliance can be costly, as some businesses found out in 2018, as fines reached an eye-watering £79billion! Monetary fines are one thing, but avoidable injuries to employees are another end result of poor PPE usage, with an estimated 146,000 workers in Britain thought to suffer from breathing or lung problems, which they regard as having been caused or made worse by work.

To avoid either of these scenarios taking place, we have implemented a PPE steering group, comprised of experts in the field, to ensure that we keep on top of new developments and laws to impact the PPE area. Our steering group collectively has 93 years of PPE experience allowing them to provide expertise towards our customers and ensuring that they stay on the right track in any PPE dealings.

The new Regulation that is now in place, includes the entire supply chain – which means that those involved in any line in the supply or distribution chain must abide by the Regulation and meet the standard requirements that have been set out. While the Regulation will be the only legislation that applies, any EC type-examination certificates and approvals issued under the Directive will remain valid until the 21st April 2023, unless they have an earlier expiry date.

One year on from the introduction of the new PPE Directive, we caught up with Dimensions’ Quality Assurance & Production Manager, Mick Spencer to find out how Dimensions has tackled the legislative changes.

What practical difference has moving from the old PPE Directive 89/686/EEC to the new Regulation 2016/425 made? 

Making the workplace safe is the first priority which includes providing instructions, procedures, training and supervision to encourage people to work safely and responsibly.

However, should personal protective equipment be a requirement, our customers can have peace of mind that all the necessary steps are being taken to assure all our items of PPE will be in conformance with the new regulation.

This will provide the confidence that our customers are investing in a product that will protect their greatest asset: their workforce.

What does this mean to Dimensions?

Having a dedicated coding system of PPE items has greatly improved the access speed to products. We can carry out quick audits to ensure products have the correct technical files, while ensuring we conform to the standard and meet the requirements of the regulation. We can also identify products that require ongoing testing and surveillance as part of the manufacturing process, which led us to notice that customers required hi-vis garments to be post-branded with large logos. This led to some concerns, as we felt larger logos could render the garments to a non-conforming standard.

Under the new regulation, if we as a business post-brand a garment, we change status from distributor to manufacturer. By working with SATRA, and our supply chain partners, we have restricted and standardised the size of post-branded logos to ensure the garments continue to conform to the standard.

Has it led to a general improvement in standards and compliance?

The PPE Directive is over 20 years old and needed updating in order to meet current technology, while the new regulation (2016/425) provides a level playing field for suppliers as well as enhancing end user safety.

Have we seen any older products disappear from the market as a result of the Regulation, particularly in hearing protection?

We have found some suppliers have dropped certain styles in favour of new development. The change has brought about a new enthusiasm to shake up styles that may not have changed in over two decades. We have also seen a lot of products fall into ‘category 1’ type PPE, which is for items that provide a ‘minimal risk’. The services of a notified body are not required for this category, as items can be ‘self certified’. ‘Category II’ and ‘Category III’ items must be certified by a notified body.

Is market surveillance of manufacturers’ compliance with the underlying test standards good enough?

Directive or Regulation PPE should always undergo continuous surveillance to ensure that items do not change over the course of its certification life. Periodic site audits and product testing should be undertaken in conjunction with a notified body.

With this Regulation (2016/425), the market surveillance authorities have clear enforcement guidelines, which will strengthen any shortcomings previously identified by industry professional.

Are manufacturers providing the necessary documentation to buyers and/or distributors when they ask for it? 

It is surprising how well the suppliers have responded to the changes. As well as our own internal systems, websites have been rebuilt with clear links to important documentation, user information sheets have also been reworked to include additional links to key documents. 

These changes are exactly the reasons it was necessary to bring things up to date through the new Regulation.

Do people think there is a case for further regulation and testing? 

Through the practise of continuous improvement we should always consider the possibility of additional regulation and testing. We are in an industry where we are protecting the most important asset – the employee.  This should always be taken seriously.

A biography of Mick’s career to date for timeline infographic:

I have worked in uniform manufacturing for 40 years, with most of this time spent producing for the Ministry of Defence.

My first experience of technical safety wear was producing Admiralty foul weather jackets for the Navy. The complexity of these garments provided the motivation to move into other specialist areas personal protection. I was the senior training instructor for the uniform division of Coats Viyella with responsibility for training the factory sewing machine instructors.

Following the launch of the Personal Protective Equipment at work regulations in 1992, I created a standards team. We covered all PPE items head-to-toe, I went on to develop a PPE advisory team that would visit our customers to assist with the risk assessment and selection of safety wear. I am currently responsible for PPE across our group companies.

PPE Statistics

1. 98% of employees have seen colleagues not wearing PPE when they were supposed to

2. Our PPE experts have our NINETY-THREE years of experience!

3. 30% of businesses lost £250,000 through improper use of PPE in the last year

4. 23,000 workers are estimated to be suffering from work related hearing problems

5. 146,000 people in Britain are estimated to have breathing or lung problems they regard as caused or made worse by work

6. 84% of businesses lost money from injuries due to PPE non-compliance in the last year

7. 90% of noise induced hearing loss is preventable if proper hearing protection is used

8. Wearing gloves reduces hand injury risk by 60%

9. It’s estimated that in 2018 non-compliance cost businesses £79billion

10. Last year Dimensions dispatched nearly ONE MILION items of PPE and footwear

11. 90% of workplace eye injuries are preventable with the use of proper safety eyewear

12. 25% of workplace injuries involve hands and fingers

13. Did you know? We have a PPE steering group here at Dimensions to ensure we are at the forefront of the latest developments in the PPE world

For more information, visit www.dimensions.co.uk