Are you providing a Perfect Fit?
I know that I have covered this before but I have been asked about Face Fit Testing 3 times over the last week so thought I should cover it again. The legal requirement of employers who require operatives to wear Respiratory Protective Equipment, RPE, is to have that RPE specifically Fit Tested to the wearer. But this is not always happening.
So let us look again at the health risks, the types and use of RPE and the legal requirement of employers to ensure operatives are Face Fit Tested.
This week’s 2 recent HSE case look at:
- Taunton Magistrates Court heard how Lewis Harding, 28, had been fitting solar panels on a fragile roof at Venn Farm on the 19 May 2015. He fell more than three metres through a fragile skylight and broke his back in three places.
- On 31 July 2014 he was struck by the reversing tele-handler in the farm yard. He died from crush injuries sustained to his chest and body.
As ever, if you have a subject that you would like us to cover one week, please contact us by phone 01458 253682, email or via our Facebook page or by Twitter
Are you providing a Perfect Fit?
Many workers wear respirators or breathing apparatus to protect their health in the workplace. These devices are collectively known as respiratory protective equipment (RPE). Respirators filter the air to remove harmful substances and breathing apparatus (BA) provides clean air for the worker to breathe.
So what are the risks?
Work activities may result in harmful substances contaminating the air in the form of dust, mist, vapour, gas or fume. For example, when:
- cutting a material such as stone or wood;
Silica is a natural substance found in varying amounts in most rocks, sand and clay. It is found in many of the building products that are used on sites every day of the week. For example,
- sandstone contains more than 70% silica,
- granite might contain 15-30%.
Silica is also a major constituent of construction materials such as bricks, tiles, concrete and mortar.
The law requires companies to make sure employees are breathing in levels of Silica dust well below the amount illustrated in the picture above.
Many woods, especially hard woods, are carceongenic and yet I have seen workshops covered in a layer of hardwood dust
- using a product containing volatile solvents;
- handling a dusty powder;
- welding stainless steel.
Workers may also need to work in areas where oxygen levels are or may become low, for example:
- confined spaces, such as a trench, silo or tank.
Table 1 Examples of the different forms of hazardous substances
Form | Properties | Examples |
---|---|---|
Solid particles | Particles of solid material, including aerosols, dusts, fibers, smokes and fume |
|
Liquid particles | Fine sprays, mists and aerosols made up of small droplets of liquid | Sprayed liquids:
Mists:
|
Vapour | Gaseous forms of a solid or liquid |
|
Gas |
|
Incredibly there are over 13,000 deaths each year in the UK as a result of Occupational Respiratory Diseases. Yes, many of these are as a result of past practices but there are around 10,000 new cases of lung and workplace caused respiratory diseases reported each year.
Occupational resiratory disease is widely recognised as a major cause of work related ill health and fatalities.
RPE types
There are many different RPE types designed to:
- protect the wearer from a variety of hazards;
- suit a variety of work situations;
- match the specific requirements of the wearer.
Warning: Respirators must not be used in oxygen-deficient atmospheres. You will require suitable breathing apparatus and should seek professional advice. The HSE publication L101 Safe work in confined spaces2 provides further information.
RPE is available in different sizes to allow for the facial differences of workers. Gender, ethnicity, build and many other factors mean that one size of facepiece will not fit everyone.
RPE must be both adequate and suitable:
- Adequate – It is right for the hazard and reduces exposure to the level required to protect the wearer’s health.
- Suitable – It is right for the wearer, task and environment, such that the wearer can work freely and without additional risks due to the RPE.
The two main types of RPE are respirators and breathing apparatus:
- Respirators (filtering devices) use filters to remove contaminants from the air being breathed in. They can be either:
- non-powered respirators – relying on the wearer’s breathing to draw air through the filter;
- powered respirators – using a motor to pass air through the filter to give a supply of clean air.
Breathing apparatus needs a supply of breathing-quality air from an independent source (e.g. air cylinder or air compressor)
What the law says
The laws governing the control of harmful substances in the workplace, and their supporting ACOP, say that you should only use RPE after you have taken all other reasonably practicable measures to prevent or control exposure.
By going through the risk assessment process required by these laws, you can determine whether the use of RPE is necessary in your workplace. If you write your justification for using RPE on your risk assessment record you should remember the reasons behind your chosen control regime and be able to adapt it in the future as necessary. If you have fewer than five employees you are not legally required to record your risk assessment.
The Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999 require you to provide and maintain a safe working environment, so far as is reasonably practicable. They set out the basic requirements for you to follow.
In addition to the COSHH Regulations 2002, RPE may need to be used to satisfy requirements in the following pieces of legislation. You will need to consider whether any of these Regulations apply to you and comply with any specific requirements they contain on RPE:
- Control of Asbestos Regulations 2012;
- Control of Lead at Work Regulations 2002;
- Ionising Radiations Regulations 1999;
- Confined Spaces Regulations 1997.
For RPE use that is not covered by any of the above Regulations, employers and employees have duties under the Personal Protective Equipment at Work Regulations 1992.
For all tight fitting RPE, including industry disposable, half and full face masks, it is a legal requirement that at the initial selection of the product the face piece is specifically Fit Tested to the wearer.
RPE must be Adequate and Suitable
This means:
- Adequate – It is right for the hazard and reduces exposure to the level required to protect the wearer’s health.
Hazardous substances can be present in the air as particles (solid or liquid), vapour or gas. Under certain conditions, they can exist in more than one form at the same time (eg during paint spraying). You need to identify the form of the hazardous substances in the air to select the right RPE. Note that:
- solid and liquid forms will be present as particles;
- fine sprays and mists are made up of liquid particles (droplets);
- fumes are very fine solid particles and not gas or vapour;
- smoke, fume and airborne liquids require RPE that is suitable for use against particles.
In addition to the above, volatile liquids may under certain conditions become airborne as both particles and vapour.
- Suitable – In addition to making sure the RPE you use is adequate to control the hazards, you need to ensure it is suitable for:
- the individual wearer – Do they have facial hair or markings that could prevent a good seal between the wearer’s face and the RPE? Do they have any pre-existing medical conditions? Do they wear spectacles or contact lenses?
- the tasks they are doing – including work-rate. Wear-time. Vision requirements. Other head-worn PPE can potentially interfere with RPE, preventing one or more of the components from working correctly (eg eye protection, ear protection and safety helmets. Where possible, choose equipment where the different forms of protection required are combined, eg eye, face, head and respiratory protection provided by a powered helmet respirator.
- the environment in which they are working for example temperature or humidity.
Carrying out a fit test
If you are considering RPE with a tight-fitting facepiece, you should make sure that each wearer undergoes a fit test. Remember, people come in different shapes and sizes, so facial differences will mean that one kind of RPE is unlikely to fit all. The differences are even more significant between men, women, and people of different ethnicity. If the RPE does not fit, it will not protect the wearer.
Facepiece fit testing is a method of checking that a tight-fitting facepiece matches the wearer’s facial features and seals adequately to their face. It will also help to identify unsuitable facepieces that should not be used. Remember that tight-fitting RPE will only provide effective protection if the wearer is clean shaven, so they should also be clean shaven when fit tested. But note that you cannot make an employee shave. So you must consider if somebody else in your employ can do the work instead, and the bearded employee do their job or, if you must have the bearded employee do this task, they must be given a powered respirator.
The following chart looks at Suitability factors to consider
Suitability factor | Why | Solution | ||||||
---|---|---|---|---|---|---|---|---|
Work rate | Higher work rates may increase breathing and sweating, which can affect the performance of some types of RPE. Higher breathing rates can cause contaminants to leak in, and sweating can cause facepieces to slip and leak. |
| ||||||
Wear time | Unpowered tight- fitting masks become uncomfortable to wear for long periods and wearers may be tempted to loosen or remove the RPE. |
| ||||||
Abnormal temperature or humidity |
|
| ||||||
Facial hair and markings | Affects where a face mask seals to the face and will cause leakage. |
| ||||||
Spectacles | Spectacles with side arms are incompatible with full face masks as they break the face seal and they may also interfere with the fit of half masks. | RPE manufacturers can supply special frames, which fit inside their masks. It is the responsibility of the employer to find and provide an appropriate solution. | ||||||
Vision | If you need to see fine details when wearing RPE, but don’t need to protect the eyes from the airborne hazard, RPE types which include face protection (full face masks, visors, hoods) may not be ideal because they can be prone to scratching, misting and surface contamination. | Consider half mask RPE, provide adequate lighting, or choose designs that resist scratching and internal misting. Powered respirators or airline BA are more resistant to misting. Some types include ‘tear-off’ consumable visors. | ||||||
Communication | All RPE affects your ability to communicate. | If your work requires clear and precise communication you should use RPE incorporating proprietary communication devices (ranging from simple speech diaphragms to complex radio intercom systems), or other suitable forms of communication. | ||||||
Flammable or explosive atmospheres | RPE can be a source of ignition. | If you cannot avoid working in potentially flammable or explosive atmospheres, including oxygen-enriched atmospheres (levels above 21%), you may need to use intrinsically safe, light alloy-free and antistatic RPE. | ||||||
Use of air power tools |
|
| ||||||
Contact lenses | Wearers may suffer discomfort or, if the lenses are dislodged, the wearer may remove the RPE to replace them while still in the hazardous area. * | Use spectacles (in mask if necessary) instead. | ||||||
Mobility | Snagging and damage to trailing hoses. Added bulk of fan units/air cylinders in tight spaces. | Ensure adequate inspection regime and consider other RPE types. |
* The lenses can also jam in the RPE valves, leading to loss of protection.
The Wilkins Safety Group offer a Face Fit Testing Service
If you need further information please call us on 01458 253682 or send us an email.
Taunton & Somerset CPD Group at The Lawns Taunton
These CPD seminars are open to everybody and, should you wish to be included on all future TSCPD emails please let Martin Kent know, see below.
Well Martin Kent our Customer Relations Manager has taken on the challenge. Initially we aim to run monthly meetings hopefully then becoming fortnightly or even weekly as before, So Martin is looking for any speakers that may be interested in giving a 40 minute talk on a Wednesday Lunchtime. Please contact him.
The second of these new seminars is on Wednesday 24th May at 12-30pm at The Lawns Taunton.
We have a Speaker from the Thorn Lighting, and he will be giving a presentation about the recent changes to LG7 which we hope will be of high value to your business.
If you haven’t already booked your place, or if you are not on the CPD Seminar mailing list but would like to be please drop Martin an email and he will deal with your request.
Introducing our latest team member
Liz Bennett BSc CEng MICE PGCE CMIOSH FRSA has joined us primarily as support for Jon Wilkins, as Liz is also a fully qualified Principal Designer.
Liz is a Tutor for the Institution of Civil Engineers (ICE), ICE South West and the Institution of Structural Engineers on application of construction health and safety legislation. She is a thought leader in this topic area and is promoting the importance of technical and managerial excellence over health and safety knowledge together with professional approaches to risk management.
Liz is also a Lay Member of UWE Faculty of Environment and Technology Research Ethics Committee.
She is fully confident to debate safety issues with HSE, ORR, other Regulators and Government at the highest level and we welcome her to our team here at The Wilkins Safety Group
Training Courses
We are pleased to announce that we are in the process of being appointed as a British Safety Council approved Training Centre.
This will allow us to run Ofqual accredited qualifications. These Qualifications sit on the Regulated Qualifications Framework and include such courses as:
- the CSCS Green Card which was developed in partnership with the Construction Industry Training Board (CITB) for people wishing to apply for a CSCS card.
- Level 2 & 3 Supervising Staff Safely mixed with Risk Assessment which is comparable to IOSH Managing Safely
There are more courses to follow in May and June – See below.
We are also looking to run some short Health and Safety awareness sessions to emphasise the need for improving your H&S procedures.
Also remember we are still available for running “In House” courses and are looking to add new training courses to our list.
If you have any questions about these courses or any other training or would like us to run a particular course for you, call Jon Wilkins of the Wilkins Safety Group on 01458 253682 or email him.