Whenever you put on Personal Protective Equipment, you expect it to perform. After all, it is the last barrier between you and the hazards that surround the environment you are in. However, research has found an alarming number of counterfeit and non-compliant PPE products on the market, which are putting wearers at genuine risk of injury or death.
CE marking
Traditionally, the most obvious sign of ‘quality’ on PPE has been the CE (or Conformité Européene) mark. This is only allowed to be put on products that meet strict criteria relating to quality and reliability within the European Economic Area. Indeed, the CE mark is so important that, as Alan McArthur, technical supervisor at 3M, explains, “Without CE, you don’t have PPE. Manufacturers are required by law to use it, and users are required by law to only select CE-marked equipment.”
And yet, at their million-pound Product Assurance Lab in Hull, Arco have found a worrying number of products that do not meet the CE criteria – despite being marked as such. “In our testing of non-metallic toecaps, we found that 40% of those product types showed issues during compression tests,” says Lee Morton, Arco’s brand manager. “This means that if they had a vehicle run over their foot, the PPE would not protect them from serious injury – it’s a very big, and worrying, problem.”
So how is this happening? Well, explains Arco’s head of quality and technical standards, Neil Hewitt, the problem lies with the current regulations. “There’s nothing saying that a CE mark has to be validated by the distributors or the retailers. Under the current regulations, once a product has been tested and certified, the manufacturer can swap out the materials used for a cost or operational benefit. Stainless steel baseplates in boots, for example, offer a lot more protection than low-carbon ones, but also cost a lot more. The manufacturer doesn’t have to notify anyone that they’ve swapped it”
Yes, you read that right – manufacturers are able to swap materials in and out of their products at will after they have been tested. And, as Hewitt says, “There’s no obvious way of telling between them. If anyone took a new product and tested it for puncture resistance, they wouldn’t notice any difference [between stainless and low-carbon steels]. The issue is with the longevity and reliability. Low carbon steel corrodes at a much higher rate that stainless steel; a year or so down the line, you could be having some serious problems.”
A widespread problem
And there’s more. The problem, it seems, isn’t confined to one region. “It’s across the board,” says Hewitt. “We’ve seen issues within China and the Indian Subcontinent, which isn’t too surprising, but we’ve also seen issues with European manufacturers. We’re not sure what the root cause is.”
“I’m not sure customers are aware that the problem is as big as it seems to be,” adds Morton. “We are trying to give customers some reassurance but there’s still a need to make the marketplace more aware of the risks. There are still tens of thousands of injuries that occur each year in the workplace. Of course, not all of those are attributable to non-compliant PPE, but as long as people are exposed to risks and hazards, then the quality of the products needs to be relied upon.”
A need for regulation?
The British Security Industry Federation’s Registered Safety Supplier Scheme (RSSS) has been established to provide manufacturers with a way of guaranteeing that their products are compliant. Members selling or marketing PPE “must now be willing to submit products for random testing to ensure compliance with current standards,” explains Alan Murray, CEO of the BSIF. This means that the issues with longevity that Arco have discovered should be remedied. This, as Murray continues, has multiple benefits, and not just to the wearer. “Purchasers and users of PPE get the assurance that the product they are buying is from a reputable supplier. RSSS members also benefit, as they become suppliers of choice within the market. Finally, the market itself benefits as over time unscrupulous suppliers are deselected and the playing field becomes fairer.”
On a wider scale, CE regulations are due to change – regular retesting and monitoring will be written into law, which, as Morton says, “does go some way to put obligations for testing back onto importers and distributors. If your suppliers are pushing back onto a factory in the Far East, you should ask them about how the suppliers themselves are ensuring quality. The manufacturer has an obligation for quality, but the rest of the supply chain has some responsibility.”
Unfortunately, the regulations don’t come into force until April 2018. In the meantime, an increased level of vigilance is needed from the market – questions need to be asked, pressure applied and awareness raised. Luckily, some action is being taken. A number of product recalls have already taken place, and authorities have taken action thanks to the growing awareness of the problem. But it’s not enough: as Arco’s studies have found, this problem doesn’t look like going away any time soon.
The BSIF's RSS Scheme
To help combat the influx of counterfeit and illegal PPE, the British Safety Industry Federation (BSIF) has introduced the Registered Safety Supplier Scheme (RSSS). This scheme allows members to identify themselves as having made a formal declaration that they are selling only products that are genuine and legal. The Scheme acts as a signpost for people to ensure they can buy from a reputable company that they can trust to supply genuine legal products and provide good advice.
Requirements of the Scheme include a binding declaration that the safety equipment supplied meets the appropriate standards, fully complies with the PPE regulations and is appropriately CE marked. This declaration is, as a condition of the scheme, audited through special provisions set out within the company’s ISO9001 Certification. Under the Registered Safety Supplier Scheme this independent audit is one of the key requirements to independently verify conformance; it is the BSIF’s belief that the independent audit is a key part of the robustness of the scheme. Each member of the scheme is subject to standards’ audits and undertakes to comply with the rules relating to quality conformance and compliance with regulations.
Arco’s advice for avoiding sub-standard PPE
- -Ask questions - People should ask about the product quality assurances at the factory where the equipment was made to make sure everyone is aware of the materials and components being used
- -Apply pressure – Don’t be afraid to ask difficult questions, and apply pressure along the entire supply chain – how do your suppliers choose their suppliers?
- -Don’t take certification as gospel – Original CE marking is not a guarantee of on-going conformity. New regulations are looking to enforce regular retesting of products to ensure they remain conformant
- -Look for RSS Scheme members – these companies have voluntarily offered to have their products audited and tested by the British Safety Industry Federation. The Scheme goes above and beyond a simple CE mark
