Health and Safety Policy PERSONAL PROTECTIVE EQUIPMENT POLICY & GUIDANCE ROYAL FREE HOSPITAL NHS TRUST & SCHOOL OF MEDICINE
CONTENTS 1. SUMMARY OF THE REGULATIONS 2. INTRODUCTION 3. DEFINITION OF PERSONAL PROTECTIVE EQUIPMENT 4. RESPONSIBILITIES OF HEADS OF DEPARTMENT AND LINE MANAGERS 5. RESPONSIBILITIES OF EMPLOYEES 6. REFERENCES APPENDIX 1 - Construction (Head Protection) Regulations APPENDIX 2 - British and European Standards APPENDIX 3 - Selection of Personal Protective Equipment APPENDIX 4 - Personal Protective Equipment Assessment Form 1. SUMMARY OF THE LEGAL REQUIREMENTS * Personal Protective Equipment should only be used as a 'last resort' or as a short term emergency measure while other control measures are assessed. It should only be used for occasional work of short duration when there is no other alternative. * Where Personal Protective Equipment is used it must: - be selected taking into account the nature of the hazard and the task, - be provided free of charge to employees, - carry a CE or BS mark (these are detailed in appendix 2), - be maintained in an efficient working order and in good repair, - be compatible with other PPE, - be stored in an assigned and suitable area, - be provided in conjunction with appropriate instruction and training for the wearer. 2. INTRODUCTION 2
This policy and guidance document forms part of the Royal Free NHS Trust and the School of Medicine Health and Safety Policies and is one of the measures taken by the Trust and School in compliance with the Personal Protective Equipment at Work Regulations 1992 1 and also requirements that deal with personal protective equipment in other legislation such as the Control of Substances Hazardous to Health (COSHH) Regulations 1988 2, the Construction (Head Protection) Regulations 1989 3 (see Appendix 1) and the Electricity at Work Regulations 1989 4. The aim of this policy is to provide guidelines on the safe procedures that must be adopted for the use of Personal Protective Equipment in the Royal Free Trust and the School of Medicine. 3. DEFINITIONS Personal Protective Equipment (PPE) is defined in the Personal Protective Equipment at Work Regulations 1992 1 as meaning all equipment '...which is intended to be worn or held by a person who is at work and which protects him or her against one or more risks to his or her health and safety'. This policy does not apply to ordinary working clothes and uniforms which do not specifically protect the health and safety of the wearer. This policy does not apply to sportswear. This policy does not apply to work with Lead or Asbestos. Personal Protective Equipment therefore (for the purposes of this policy) includes items such as the following when they are worn for purposes of health and safety: 3
* aprons * gloves * protective clothing for adverse weather conditions * safety shoes * hard hats * high visibility waistcoats * eye protection * lab coats * face masks 4. RESPONSIBILITIES OF HEADS OF DEPARTMENT AND LINE MANAGERS The Head of Department or Line Manager has the following responsibilities: 4.1 To ensure suitable and appropriate PPE is provided. This means that the PPE should be appropriate for the risk or risks involved and the conditions where it will be used. The PPE should take account of ergonomic requirements and the state of health of the person who is required to wear it. Guidance on the selection of PPE is found in other documents. For guidance on personal protective equipment against ionising radiation please refer to page 5 of the document 'Radiation Local Rules' 5. For guidance on personal protective equipment against biological hazards please refer to the Infection Control Policy 6. This includes the Universal Precautions Policy. Other documents such as Laboratory Local Rules also contain guidance. If specific guidance is not available in the documents detailed above due to the specific nature of the work then managers must ensure that guidance on suitable and appropriate PPE is detailed in local policy. Guidance on selection of PPE is provided in appendix 3. 4.2 To carry out the assessment on the suitability of the PPE (shown in appendix 4) on all items of PPE prior to starting work. A record should be kept. 4.3 To maintain and replace PPE as necessary. This should be done in accordance with 4
the manufacturers advice where appropriate. A record should be kept of this. 4.4 To provide adequate and suitable storage for all PPE. 4.5 To provide information, training and instruction for employees therefore enabling them to make proper effective use of PPE. Training for PPE users must include the following: 1. An explanation of the risks present and why the PPE is being used. 2. How to operate the PPE and any limitations of the equipment which may affect the protection offered. 3. Instructions on the storage of the PPE. 4. The arrangements for reporting loss or defects of the PPE. 5. RESPONSIBILITIES OF EMPLOYEES It is the responsibility of an employee to use PPE in accordance with training and to report any loss or defect immediately. The employee also has a responsibility to return PPE to its place of storage after use. 6. REFERENCES 1. Personal Protective Equipment at Work Regulations 1992. Guidance on Regulations, L25, HSE Publication. 2. The Control of Substances Hazardous to Health Regulations with Approved Code of Practice 199-. HSE Publications. 5
3. Construction (Head Protection) Regulations 1989. HSE Publications. 4. The Electricity at Work Regulations 1989. HSE Publications. 5. Radiation Safety Local Rules. The Royal Free Hospital and School of Medicine Radionuclide Laboratories (1994). 6. Infection Control Manual, Royal Free Hospital. 7. Respiratory Protective Equipment, 3rd edition. 1992. HSE, London. Produced by the Occupational Health and Safety Unit C:\Policy\PPE 11/94 6
APPENDIX 1 - Construction (Head Protection) Regulations The Construction (Head Protection) Regulations 1989 require suitable head protection to be worn on construction sites where there is a risk of injury. Sikhs wearing turbans are exempt from these regulations, however they may not be eligible to claim for injury in all circumstances. Managers have a duty to ensure that head protection is provided and worn in all situations where an employee may be working on a building site. Individual employees have a responsibility to wear head protection as directed by their manager. APPENDIX 2 - - British and European Standards NB. At present not all PPE is covered by CE standards therefore the relevant British Standard should be used. Head Protection BS 5240 Part 1: 1987 Industrial Safety Helmets - specification for construction and performance (To be replaced by BS EN 397) Eye protection BS 1542:1982 Specification for equipment for eye, face and neck protection against non-ionising radiation arising during welding and similar operations BS 2092:1987 Specification for eye protection for industrial and non industrial use. (Suitable for laboratory use). To be replaced by BS EN 166,167 and 168. BS 7028:1988 Guide for the selection, use and maintenance of eye protection for industrial and other uses BS EN 169 Personal eye protection: Filters for welding and related techniques: Transmittance requirements and recommended use BS EN 170 Personal eye protection: Ultraviolet filters: Transmittance requirements and recommended use BS EN 171 Personal eye protection: Infrared filters: Transmittance requirements and recommended use Footwear BS 1870: Part 1: 1988 Specification for safety footwear other than all rubber and all plastic 7
compounds BS 1870: Part 2: 1976 (1986) Specification for lined rubber safety boots BS 1870: Part 3: 1981 Specification for polyvinyl chloride moulded safety footwear BS 4972:1973 Specification for women's protective footwear BS 7193: 1989 Specification for lined lightweight rubber overshoes and overboots The following will probably replace BS 1870 and BS 953: pren 345 Specification for safety footwear for professional use pren 346 Specification for protective footwear for professional use pren 347 Specification for occupational footwear for professional use Gloves BS 697: 1986 Specification for rubber gloves for electrical purposes BS 1651: 1986 Specification for industrial gloves pren 374 Protective gloves against chemicals and micro organisms pren 388 Protective gloves: Mechanical test methods and specifications pren 407 Protective gloves against thermal hazards pren 420 General requirements for gloves pren 511 Protective gloves against cold Protective clothing BS 2653: 1955 Specification for protective clothing for welders Respiratory Protection At present many of the European standards (EN) are in preparation and not all British Standards (BS) are currently acceptable, therefore please consult reference 7, if in doubt. Furthermore all respiratory protective equipment needs to be HSE approved. If in doubt contact supplier/hse. 8
APPENDIX 3 - SELECTION OF PERSONAL PROTECTIVE EQUIPMENT Guidance on PPE for staff handling blood and body fluids is given in the Infection Control Manual. 6 LABORATORY COATS In a laboratory it is necessary to wear a lab coat. Staff must be provided with a lab coat suitable for the tasks they are expected to perform. For example a Howie coats should be worn for microbiological work. Staff should not wear the lab coat into rest rooms or areas where food is being eaten. GLOVES Gloves are worn to protect against a variety of hazards such as thermal, mechanical or chemical hazards. Thermal hazards - contact with very hot or cold objects, including molten metal splash, sparks or flames when welding or cutting hot metal. Mechanical hazards - the skin can be torn or cut by rough or sharp surfaces. Chemical hazards - substances containing strong acids, alkalis, solvents or irritants may cause dermatitis, ulcers or similar problems. It is important to select the right type of gloves for the task. The type and degree of protection depends on the material of the glove and the way in which it is made. A compromise may need to be made between comfort, sensitivity of touch, grip and the degree of protection for the job. The following factors should be considered. Gloves should be the right size, and fit comfortably - too loose a fit will impede work, while too tight a fit may increase the load on the hand. Gloves should be chosen with the task in mind, for example long gauntlet type gloves may be particularly suitable for handling man made mineral fibre insulation whilst short gloves may suffice for handling materials with no dermatitis potential. Offer a selection of suitable gloves, this will make it easier for users to find a good fit. Care must be taken when selecting gloves, for example: Loose fitting gloves should never be used when using machinery where an entanglement risk exists. Gloves (especially if worn with inner gloves) which may impair sensitivity, finger dexterity and grip strength could result in other hazards being created. 9
Gloves which are used with chemicals should be selected bearing in mind: Chemicals may eventually penetrate the glove. Gloves highly resistant to one chemical, for example acid may give no protection against others, for example solvents, alkalis and so on. EYE PROTECTION Many processes present a risk of injury to the eyes and face. For example, protection will needed against flying chips or particles when using a disc cutter; against arc eye and molten metal splash when using welding equipment or hot cutting metal; and against corrosive or irritant chemical splashes when working with epoxy resins and concrete. Eye protection is also required where splashes from blood and body fluid are foreseeable. When selecting eye protection the following should be considered: Does the work involve chemicals, dusts, welding/hot cutting or flying particles/chips? Eye and face protection should be selected with the particular risk in mind. Is the protection comfortable and does it fit properly? It should not hinder movement or visibility. Is it compatible with other forms of PPE for example spectacles or goggles may interfere with some forms of respiratory protection equipment (RPE) or hearing protection. The working environment, for example spectacles or visors may be preferable in or hot conditions as goggles may steam up. humid FOOT PROTECTION Foot injuries may be caused by the following: Crushing caused by heavy objects falling onto part or all of the foot, eg oxygen cylinder falling onto foot. Foot penetration due to standing or walking onto a sharp object, eg nails left embedded in timber. Contact with irritant or corrosive chemicals, for example cement burns when pouring concrete. Protective footwear should be strong enough to withstand the stresses placed upon it, have protected (steel) toecaps capable of resisting a heavy falling object. If there is any risk of a penetration injury then the footwear should incorporate a steel mid-sole or similar armoury. 10
RESPIRATORY PROTECTION Respirators do not supply oxygen so must not be used where oxygen concentration may be significantly reduced. Beards or other facial hair may prevent a good seal between respirators and the face. The more sophisticated respirators to be used with greater hazards are graded in terms of maximum exposures or in terms of the multiples of Occupational Exposure Limits (OELs). Where contaminants are immediately hazardous to life or health, a respirator should not be used if the concentrations are unknown or above the specified limit of the respirator. Follow the testing and fitting instructions supplied by the manufacturer/supplier. See also Reference 7. 11
APPENDIX 4 - Risk Assessment form. Personal Protective Equipment Assessment - KEEP THIS FORM AS A RECORD Name of Assessor Department Activity Hazard (Specified Protection) Type of PPE When does the PPE require servicing (date) (Indicate if disposable) Comments Is PPE provided when required? Yes No Have all other methods of controlling the risks and therefore avoiding the need for PPE been investigated? Yes No Is the PPE provided suitable and practical for use? Yes No Is the PPE appropriate for all risks? Yes No Does the PPE consider the ergonomic needs of the user? Yes No Can the PPE be adjusted to fit the user correctly? Yes No Does the PPE avoid the introduction of extra risk to the user? Yes No Does the PPE comply with the relevant British or European standard? Yes No If more than one item of PPE is to be used at the same time are they compatible? Yes No Does the user know where defects or loss should be reported to? Yes No Is PPE properly stored when not in use? Yes No Are staff adequately instructed and trained on the use of PPE? Yes No Signature NAME Department Date 12