Keep your kit on (PPE compliance) - AOSH

Keep your kit on(PPE compliance)

27th October 2016

Simon Field – Technical Specialist

Personal Safety Division

2. All Rights Reserved.28 October 2016© 3M 3M Confidential.

Simon FieldTechnical Specialist

3M Personal Safety DivisionSafety and Graphics Business Group

Qualifications

• Physics BSc• Workplace compliance: Risk management of UV

light exposure in the workplace from non-coherent artificial sources

• IOSH Noise at Work Risk Assessment and Management

Responsibilities at 3M

Technical responsibility (past and present):• Protective eyewear portfolio• Welding protection• Powered and supplied respiratory air systems• Detection equipment (noise, air monitoring)• EARfit validation kit• Hearing conservation

Responsibilities outside 3M

• British Safety Industry Federation (BSiF)– Eye, Face and Hearing group

• British Standards Institute (BSI)– PH/2 Eye Protection committee


Agenda

• What is non-compliance and how can it be identified?

• What are the consequences of non-compliance?

• What are the reasons for non-compliance?

• How can compliance be improved?


PPE legislation

Employer’s Duties:

• Provide suitable PPE

• Give information, instruction and training

• Ensure PPE is maintained & provide storage

•Take reasonable steps to ensure its use

Employee’s Duties:

“ Every employee shall use any personal protective equipment

provided to him...in accordance both with any training...and the

instructions respecting that use...” – Reg 10.


PPE legislation

PPE Related Accidents Classified by Failure Type –

Adapted From RR419

2% 3%

33%

17%

36%

9%Unknown

Failure to Maintain

Not Provided

Inappropriate PPE Provided

Provided But Not Used

Not Used Appropriately

N.B: Analysis of 920 PPE-related

accidents identified between 1996/7 and

2002/3. Slips & trips and “correct use

but other cause” omitted for simplicity.

“A significant number of employers, about 35% in total, had experienced problems in

implementing the PPE at Work Regulations.”

– RR419 RE: A self selecting survey conducted via the HSE website

45%


What is non-compliance & how can it be identified?


How severe is the issue of non-compliance?

“Recent research indicates that up to 50% of all RPE used does not

offer the wearer the level of protection assumed and one of the major

reasons is that it simply does not fit!” – BSIF, Fit2Fit


“The smoke’s gone, the hazard’s gone”

0.5 µm

1.5 m

2 Days

Respiratory hazards can still be present even after the source of the hazard is gone

People some distance from the source of the hazard may still be at risk


“The smoke’s gone, the hazard’s gone”

Typical settling rates for different sized

particles…from a height of 1.5m in still air

20µm 10µm 5µm 2µm 1µm3.6 mins 8.3 mins 35.7 mins 2.8 hrs 12 hrs

0.5µm41.7 hrs

Inhalable Thoracic Respirable

10. All Rights Reserved.28 October 2016© 3M 3M Confidential.Source: www.iosh.co.uk/dust

Joint report from IOSH and CDP 2014 (Construction Dust Partnership) www.iosh/co.uk/dust

Attitudes within the workplace – barriers to compliance


Workplace compliance

Silica based Enforcement Notices 2010 – 2013*

* Source: HSE Enforcement Database

Examples of HSE Notices

Failure to ensure workers are using effective control measures such as water suppression, LEV and

effective face fit tested RPE to control RCS (PN)

Using Stihl saw without LEV or RPE (IN)

Insufficient controls when cutting materials containing RCS (PN)

Failure to guarantee suitable face seal when working with substances hazardous to health (PN)

Employees exposed to RCS during work and require tight fitting RPE, but face fit testing not provided. (IN)

0

20

40

60

80

100

120

2010 2011 2012 2013

Improvement NoticeProhibition Notice


Workplace compliance

Silica based Enforcement Notices 2010 – 2013*

* Source: HSE Enforcement Database

Most common issues

0

20

40

60

80

100

120

2010 2011 2012 2013

Improvement NoticeProhibition Notice

A failure to supply RPE

A failure to face fit test

A failure to ensure RPE is worn (Compliance)


How severe is the issue of non-compliance?

“Only 60% of workers

supposedly using hearing protection are

in fact protected”

http://www.hse.gov.uk/research/rrpdf/rr720.pdf


What’s the effective protection when hearing protection is not worn for the

full shift?

91dB

103dB

100dB73

dB30 30

12 12

3 3

I wear hearing protection most of the time…


3M Copyright

PERIOD OF USE

12

3

30

dB

Hours

1 2 3 4 5 6 7 8Wearing time

Effective

protection

EN458

http://www.hse.gov.uk/noise/hearingprotection/index.htm

I wear hearing protection most of the time…


58% of successful NIHL claims include a claim for tinnitus, which increases the average damages paid by over 20%* *ABI analysis of NIHL claims

data from 2013

What are the consequences of non-compliance?


What are the consequences of non-compliance?

9000 PPE related accidents

reported per year

- (RR419)Hand, arm & foot protection

are the most common

categories of PPE cited in

accident reports. Little

information available on

PPE used to protect

against ill-health. (RR419)

Secondary causes where PPE

was provided but not used:

1. Inadequate supervision

2. Operator error

3. Unsafe routine

4. Not following instruction

5. Unsafe procedures

6. Failure to control risk

(RR419)

Cost to society of accidents in 2001/2 where PPE

was cited as provided but not used = £65.5M

(RR419)

?


What are the reasons for non-compliance?

Non-compliance

Lack of

understanding

Bravado

Discomfort

Error/ Misunderstanding

Defiance

Difficulty communicating

Difficulty carrying out

task



Research Report 798: Factors influencing the implementation of RPE programmes

in the workplace. HSL 2010

“Workers need a better understanding of

the hazards that they work with and how,

in the long term, these could impact on

their health and well being.”



“They tend to do it when you’re talking to

them...they’ll lift their mask up and put it

on their head.”







“I know best...and it won’t hurt me...that kind of

attitude. And it tends to be the people who’ve been

in the job for 20, 30, 40 years ... and its hard to get

people to change behaviour.”


How can compliance be improved?

Non-compliance

Lack of

understanding

Bravado

Error/ Misunderstanding

Defiance

Training

related



Non-compliance

Discomfort

Difficulty communicating

Difficulty carrying out

task

Product

related



Personal Protective Equipment must be adequate and suitable Control of

Substances Hazardous to Health, Reg.7Comfort Protection

It is right for the hazard and reduces exposure to the level required

to protect the wearer’s health.

ADEQUATE

It is right for the wearer, task and environment, such that the wearer

can work freely and without additional risks due to the PPE.

SUITABLE



Putting on and

removing

Getting a

good fit

Maintenance

procedures

Storage

Limitations

of use

The need for

protection



eLearning

Classroom Sessions

Posters

Toolbox Talks

Mentoring


3M Support – online content

Training videos

Online tools

Webinars

Online resources

Awareness posters

Training posters


3M Support - Safe Tea Break



• Trial products – clear involvement

• Discuss options with staff – choice?

• Issue simple PPE questionnaires

• Reward best practice

vs.

• Part of employment contract

• Disciplinary action

Is your PPEworking together?


Agenda

• Why is PPE compatibility important?

• How do I spot PPE compatibility issues?

• How do I select compatible PPE?

• How can I check I’ve made the right choice?


Benefits of compatible PPE

• Protection

• Safe, healthy workers

• Less down-time due to injury

• Legal compliance*

• Comfort

• Increased compliance with PPE requirements

• Less distraction means better productivity

• Workers are more likely to take care of their kit

What’s In It For Me?

*PPE at Work Regulations state “if risks dictate that more than one item of PPE is necessary that such equipment should be compatible”


What do we mean by PPE and PPE Compatibility?

Personal Protective Equipment:

Any device or appliance designed to be worn or held by an individual for protection

against one or more health and safety hazards

PPE Compatibility:

The ability of multiple items of PPE to be worn together in a way where no one item

compromises the ability of another to protect the wearer.

NB: This presentation will not discuss Chemical Compatibility i.e. the ability of a PPE material withstand certain chemicals – this presentation is about Physical Compatibility


What does PPE Compatibility mean to the wearer?


Why is compatibility an issue?- Competition for space


How do I know if there is a PPE compatibility issue?

• Incompatibility is often immediately obvious

• Check for people constantly adjusting their PPE

• Are there reports of accidents involving PPE?

• Are issues being highlighted by fit tests or health surveillance?

•

•

•

•

•

• Talk to the work force!


BeardsRespiratory Protection

V’s

Common compatibility conflicts

Tight fitting respirators cannot be worn with facial hair.Protection levels (Assigned Protection Factors) will only be achieved if the respirator fits correctly on the face.


SpectaclesProtective

MuffsV’s


Leak paths from spectacles reduce the performance of protective ear muffs

Up to a 9dB reduction in attenuation


Hard HatsProtective

MuffsV’s


Helmet mounted ear muffs must be approved for use with specific helmets

‘Just because it fits, doesn’t mean it protects’


Respiratory Protection

Eye ProtectionV’s


✕ Lens fogging✕ Coverage of ocular region✕ Respirator seal adjusted by user


CommunicationProtective

MuffsV’s


Watch out forthat…!

“Bigger is

Better”!/?

Too much attenuation leads to:• Poor compliance• Isolation• Reduced awareness of the work environment


Working towards solutions‘Science of Safety’

Design for People

Reduce interactions

with pressure sensitive

areas

Maximise security of fit

Using analytical methods that

seeks to improve the interactions

between PPE and the wearer

SCIENCE OF

SAFETY


Science of Fit


Achieving compatibility

~Offer a range of PPE

• Style• Size• Materials• Adjustment features•

•

•



~Talk with workers



~Talk with manufacturers

www.3m.co.uk/safety

0870 60 800 60


Easy solutions to PPE compatibility

• Remove the need for PPE

• Powered respiratory system

• Eye and face impact protection

• UV protection for eyes and face

• Head impact protection

• Integrated hearing protection


3M Respiratory Protection- Powered respirators

Draws air through filter for user Supplies large volumes of filtered air to headtop Loose fitting types do not rely on tight face seal for protection = no fit testing Continuous flow of refreshing filtered air inside headtop Benefit – PPE compatibility & increased productivity

Key benefits•Higher protection factors• Where fit testing is not possible• For facial hair• In warm environments• To replace multiple PPE


Care, Maintenance & Record Keeping


Eyewear and hearing protection

31.4

36.5

28.9

19.3

29.9

34.4

27.7

18.1

0.0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

40.0

SNR H M L

SecureFit SF400 Series and X2


Eyewear and respiratory protection


Communication and hearing protection

Watch out forthat…!


More than just PPE

Function Benefit Detail

Level Dependent Recreates sound at safe levels Limits sound to 82dB

Radio Communication Clear communication at distance Transmits up to 3 kilometres

Blue Tooth Cableless connection to phones Redial, connect, reject

VOX Hands free communication Half duplex

PTT Seize control of the airwaves Can connect to external systems

Audio Jack Direct connection to MP3 Limits sound to 82dB

Fit validation(checking performance)


• Fit testing is a means of assessing how well a respirator model seals to an individual’s face

• For ALL tight fitting respirators• CoSHH – suitable for purpose (Reg 7)• Do it before first use• No fixed repeat frequency in UK• Clean shaven for test & use!

Room Scheduling

Space, ventilation, privacy Time slots with flexibility

Well briefed wearers Failures

Shaving, eating, drinking, smoking, glasses, PPE

Identify preferred alternatives consider types, sizes etc

Fit validation (checking performance)Respirator Fit Testing


Fit testing

• Records must be kept for at least 5 years• HSE 282/28 outlines the points to be recorded.


Fit validation (checking performance)Eyewear Fit Test method


Fit validation (checking performance)3M EARfit Dual Ear Validation Kit

• Personal Attenuation Rating for each employee

• Great opportunity to refresh employee training

• Motivational tool to drive compliance


Case study


Personal Protective Equipment should be both

Adequate and Suitable

In conclusion…

Assessment of the hazard

Adequate PPE

SuitablePPE

Assessment of the hazard

Assessment of people

Assessment of the environment

Observation of use

Worker engagement

Thank you

Keep your kit on (PPE compliance) - AOSH

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