keep your kit on (ppe compliance) - aosh
TRANSCRIPT
Keep your kit on(PPE compliance)
27th October 2016
Simon Field – Technical Specialist
Personal Safety Division
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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
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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?
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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.
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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%
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What is non-compliance & how can it be identified?
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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
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“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
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“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
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Joint report from IOSH and CDP 2014 (Construction Dust Partnership) www.iosh/co.uk/dust
Attitudes within the workplace – barriers to compliance
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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
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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)
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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
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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…
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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…
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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?
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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)
?
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What are the reasons for non-compliance?
Non-compliance
Lack of
understanding
Bravado
Discomfort
Error/ Misunderstanding
Defiance
Difficulty communicating
Difficulty carrying out
task
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What are the reasons for non-compliance?
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.”
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What are the reasons for non-compliance?
“They tend to do it when you’re talking to
them...they’ll lift their mask up and put it
on their head.”
Research Report 798: Factors influencing the implementation of RPE programmes
in the workplace. HSL 2010
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What are the reasons for non-compliance?
Research Report 798: Factors influencing the implementation of RPE programmes
in the workplace. HSL 2010
“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.”
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How can compliance be improved?
Non-compliance
Lack of
understanding
Bravado
Error/ Misunderstanding
Defiance
Training
related
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How can compliance be improved?
Non-compliance
Discomfort
Difficulty communicating
Difficulty carrying out
task
Product
related
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How can compliance be improved?
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
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How can compliance be improved?
Putting on and
removing
Getting a
good fit
Maintenance
procedures
Storage
Limitations
of use
The need for
protection
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How can compliance be improved?
eLearning
Classroom Sessions
Posters
Toolbox Talks
Mentoring
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3M Support – online content
Training videos
Online tools
Webinars
Online resources
Awareness posters
Training posters
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3M Support - Safe Tea Break
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How can compliance be improved?
• 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?
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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?
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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”
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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
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What does PPE Compatibility mean to the wearer?
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Why is compatibility an issue?- Competition for space
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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!
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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.
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SpectaclesProtective
MuffsV’s
Common compatibility conflicts
Leak paths from spectacles reduce the performance of protective ear muffs
Up to a 9dB reduction in attenuation
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Hard HatsProtective
MuffsV’s
Common compatibility conflicts
Helmet mounted ear muffs must be approved for use with specific helmets
‘Just because it fits, doesn’t mean it protects’
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Respiratory Protection
Eye ProtectionV’s
Common compatibility conflicts
✕ Lens fogging✕ Coverage of ocular region✕ Respirator seal adjusted by user
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CommunicationProtective
MuffsV’s
Common compatibility conflicts
Watch out forthat…!
“Bigger is
Better”!/?
Too much attenuation leads to:• Poor compliance• Isolation• Reduced awareness of the work environment
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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
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Science of Fit
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Achieving compatibility
~Offer a range of PPE
• Style• Size• Materials• Adjustment features•
•
•
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Achieving compatibility
~Talk with workers
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Achieving compatibility
~Talk with manufacturers
www.3m.co.uk/safety
0870 60 800 60
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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
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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
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Care, Maintenance & Record Keeping
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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
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Eyewear and respiratory protection
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Communication and hearing protection
Watch out forthat…!
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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)
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• 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
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Fit testing
• Records must be kept for at least 5 years• HSE 282/28 outlines the points to be recorded.
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Fit validation (checking performance)Eyewear Fit Test method
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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
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Case study
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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