Everyone involved with Personal Protection Equipment (PPE), from the manufacturer down to the employees, is responsible for providing and using suitable PPE in the workplace.
Under the latest EU Regulations PPE compliance has been broadened to ensure that more is done to avoid work related injuries. This article looks at the implications of the new regulations, the true scale and cost of PPE violations, and how they can happen despite employers’ best intentions. You will find out how you to ensure your PPE is up to scratch and learn key tips to help reluctant employees wear it.
Personal Protection Equipment (PPE) is equipment designed and manufactured to be worn or held by a person to protect them against the health and safety risks it is intended to, as well as its changeable components and connections to external devices or non-permanent anchoring systems (EU Regulation 2016/425, which is legally applicable in the UK at the time of writing).
PPE is split into three categories:
Category I is simple PPE designed to protect against minimal risks such as weak cleaning materials and prolonged contact with water. Manufacturers do not need to get Cat I items certified by the national body.
Category II items do need official certification, and cover items not covered by the other categories, such as safety spectacles and hi-vis clothing.
Category III PPE protects from serious or life-threatening risks including noise (moved from Cat II), chainsaws, extreme temperatures, falls, and electric shock. Cat III manufacturers being subject to ongoing assessment for compliance.
Legislation prescribes the wearing of PPE in industries with a risk of injuries to employees, though it’s not all you need to keep your employees safe. PPE should be viewed as the “last resort” for protection, with general H&S procedures,training, guidance and supervision in place first and foremost.
Safety and Health Practitioner (SHP) reveals some eyebrow-raising statistics on the lack of use of PPE:
· A quarter of all workplace injuries are to hands which could be reduced by 60% with safety gloves.
· 84% of workers sustaining head injuries were not wearing head protection.
· 90% of eye injuries could be avoided with protective glasses.
· 99% of noise-induced hearing loss could be prevented with hearing protection.
The UK has recently become more serious than ever about protecting its workers. Health and Safety fines in general in 2018 were 400% higher than 2014-2015 as a result of the 2016 Sentencing Guidelines for Health and Safety Offences. And it’s not just large organisations who receive big fines – a public sector organisation and a smaller company received a £1m plus H&S fine in 2018.
As well as the direct costs of accidents such as fines, compensation and lawyer’s fees, there are indirect costs associated with workplace accidents which can be twenty times the direct costs. These include accident investigation, lost worker productivity, training a replacement employee, absenteeism due to lower workplace morale, and the impact on the company’s reputation.
It is the responsibility of manufacturers, importers and uniform and workwear suppliers such as Uniforms by Creative, to ensure that PPE meets the requirements of the 2016 Regulation.
It is the employer’s responsibility under the Personal Protective Equipment at Work Regulations 1992 to pro-actively issue the correct CE-marked PPE to employees and ensure they understand the risks, how to use and store it, and, most importantly, wear it.
It is also the employees’ responsibility to use and store their issued PPE in accordance with their training, and report any loss or defect.
Even if you have supplied suitable PPE there are a number of additional considerations to ensure you protect both your employees and your business.
· You need to ensure a proper risk assessment has been carried out to ensure the PPE is suitable for the risks and workplace conditions, and takes account of the wearer’s health issues and ergonomic requirements. PSL Worldwide Projects Ltd were fined £150,000 in 2017 for not assessing the risk assessment and providing the correct PPE and equipment when workers received life-threatening chemical burns.
· You need to ensure employees do actually wear their equipment: SHP found that 98% of employees have seen fellow employees not wearing PPE when they were supposed to, with 30% saying it happens on a regular basis.
· Your PPE must fit correctly and be compatible with each additional item of PPE worn. It must be stored appropriately and maintained in good repair and efficient working order.
· You also need to provide instructions on the risks which the PPE will avoid or limit, the reason for using the PPE, and how to use, clean, and store it safely and effectively, and acquire replacements when required.
Review your PPE regularly to ensure that it still meets standards. Look for visible holes or damage. If there are holes, replace the item immediately. Also look for worn down surfaces as this could mean any protective layer has perished. For hi-visibility equipment ensure that the colours have not faded or become dirty, this could mean that they no longer confirm to safety requirement EN ISO 20471:2013.
If you need to upgrade your workwear, our Uniforms by Creative range not only meets safety requirements, but your brand and design requirements as well.
Employees can refuse to wear PPE where it exacerbates a medical condition, for certain religious reasons, or where PPE could actually compromise safety such as loose-fitting hi-vis jackets which may get caught in machinery. Employers must do all they can to find appropriate PPE or task alternatives in these circumstances before considering the employee unsuitable for the work.
It’s important to carry out spot checks, discipline staff who don’t wear their PPE, and even incorporate terms into the employment contract indicating that failure to follow reasonable Health & Safety instructions qualifies as gross misconduct. However, as well as laying down the law, it’s important to find out why your employees aren’t wearing their PPE.
Safety and Health Practitioner found the top four reasons for not wearing PPE are that it looks unattractive, is a poor fit, is too hot, or is not easily accessible. You can address issues such as these through:
Regular and impactful training is key so that workers understand the consequences of any accident, not just for themselves, but for their loved ones too. YouTube has many examples of short videos where real-life workers talk about their injury. Workers also need to be clear on where to find their equipment, how to store and maintain it and get replacements.
Training such as this also helps when workers may have become complacent about the risks of their job after carrying out the tasks all day every day without incident.
There is constant technological and ergonomic innovation in PPE, so tackling lack of wear issues relating to comfort and dexterity could be as simple as upgrading PPE. For example, hand protection is often removed as it can reduce manual dexterity – yet hand injuries are the second most common work-related injury. At Uniforms by Creative, we can supply industry-leading gloves specifically designed for comfort and fit. Keeping up with the latest advances in PPE may cost you more, but it costs a lot less than the million pound fine and indirect costs highlighted above.
PPE that looks good
Training will help towards tackling the issue of PPE being unattractive, but again, there are innovations you can take advantage of to help your employees look “cool”. We can supply safety footwear that looks like high street trainers but is fitted with midsoles and steel toe caps. We can also provide combat trousers with a choice of zip-colour – allowing people to personalise their workwear in this way increases engagement which encourages use of their full uniform including the PPE.
However, do ensure employees don’t push too far with their fashion and source their hi-vis gear from fashion brands which often set trend mimicking construction clothing which won’t conform to the EU Regulations and legal safety standards [link].
Offering an element of personal choice, as well as any personalisation, can also encourage workers to wear their PPE. Having some input into the selection gives workers a sense of control which helps them feel valued as an individual. This is one of the reasons that we always work with the final wearers on a company uniform, allowing them to see, try out and feedback on the options to ensure their PPE and workwear is fit for the purpose and for the people, ensuring it gets worn.
You can find out more about the legal requirements for safety wear here. If you need new PPE and workwear, you can get a flavour of Uniforms by Creative’s PPE solutions here, and our Workwear solutions here.
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