PPE Policy

Loughborough University will ensure that suitable and sufficient arrangements are in place to ensure that risks posed to the health and safety of employees, students and others by its activities, that cannot be prevented so far as is reasonably practicable, are controlled by the provision of suitable Personal Protective Equipment (PPE).

Key Legislative Requirements

• Health and Safety at Work etc Act 1974,
• The Management of Health and Safety at Work Regulations 1999
• The Personal Protective Equipment at Work Regulations 1992 (PPE Regs)
• Control of Substances Hazardous to Health Regulations 2002 (COSHH)
• Workplace (Health, Safety & Welfare) Regulations 1992 - Control of Noise at Work Regulations 2005
• Dangerous Substances and Explosive Atmosphere Regulations 2002
• The Work at Height Regulations 2005
• The Health and Safety (Safety Signs and Signals) Regulations 1996

Duty Holders

The definition of PPE accepted by Loughborough University is:

Personal protective equipment means all equipment designed to be worn or held by a person at work specifically to protect them against one or more defined significant hazards, and any addition or accessory designed to meet this objective.

Protective clothing and equipment fall within the terms of this definition, but clothing provided which is not specifically designed to protect the health and safety of the wearer does not. An example would be a uniform provided with the primary aim of presenting a corporate image. Protective clothing provided for hygiene purposes in food preparation areas is not included in the definition. A nurse's uniform would not be considered to be PPE, whilst a plastic apron would. Certain PPE is also covered by the Medical Devices (Amendment) Regulations 2008 when used in a medical context e.g., medical examination gloves.

Current legislation has been considered when formulating this policy/guidance. It sets out the requirements to be followed by Loughborough University employees and students for all PPE.

Signage

Signage must be displayed on entrances to rooms or in other prominent positions in areas where PPE is mandatory. Safety signs and signals are required where, despite putting in place all other relevant control measures, such as soundproof enclosures, a significant risk to the health and safety of employees and others remains.

To comply with the Health and Safety (Safety Signs and Signals) Regs 1996, signs must be clear and legible, and should be used to identify safeguards that must be followed (e.g. ear protection must be worn).

Selecting Personal Protective Equipment

The PPE Regs require that an employer must provide suitable PPE to each of their employees, (and students), who are exposed to a hazard while at work which is harmful by inhalation as required by the relevant COSHH assessment. PPE is to be used as a last resort if that hazard has not been controlled by other means. PPE can be used in combination with other control measures such as engineering or procedural controls.

An assessment must be made to determine which PPE is suitable to control the exposure of the employee to the hazard being considered, in conjunction with the COSHH assessment. This assessment should be in writing if the PPE is to be used in a high-risk situation. The risk assessment must be reviewed if it is suspected that the previous assessment is no longer relevant or valid, after an accident or near miss, when legislation changes or where health and safety policy require it.

Some or all of the following may need to be taken into account in the risk assessment.

• The risks in the workplace,
• The parts of the body which may be affected,
• The nature of the task,
• The degree of physical effort involved,
• Methods of work,
• How long PPE must be worn,
• Any special requirements e.g., ease of use when wearing spectacles or with other PPE.

The PPE provided to employees and students must be suitable for the purpose and person. In selecting the appropriate PPE, the health of the wearer must be taken into consideration. Conditions may exist where it is not advisable to use PPE, especially Respiratory Protective Equipment (RPE). If there is any doubt as to the wearer's health the Occupational Health Service should be contacted for an assessment. Selection of hand protection / gloves should also be made giving consideration to the composition of gloves, e.g., latex, protein content and chemicals from processing, whether powdered or not.

As well as considering control of exposure to hazard, other factors must be considered when choosing PPE: -

• The PPE must fit the wearer properly, especially after any necessary adjustments, within the range for which the PPE is designed, are made. It should cause minimum discomfort to the wearer. RPE which requires a face seal, is not suitable for persons with facial hair. Filtered air hoods will be necessary for such individuals. Face fit testing (qualitative), is mandatory for all FFP3 face masks. (For more information on face fit testing, go to Section 13 below).
• Ergonomic factors.
• Where more than one item of PPE must be worn, they should be mutually compatible and continue to be effective against the individual hazards in question.
• The School or Support Service must ensure that any PPE provided to employees and students is maintained in efficient working order. Arrangements must be made to ensure that any PPE provided is suitable and fit for purpose.

This includes ensuring it is cleaned and disinfected, where appropriate.

• The School or Support Service must ensure that any PPE which they provide for use by employees and students complies with UK legislation covering the design or manufacturer of PPE with regard to health and safety. PPE of the approved standard must bear the ‘CE’ mark if a British or European Standard exists for that equipment. Many British Standards, (BS) will be replaced by a harmonized European Standard. When the European Standard is introduced, it will be prefixed by “BS EN”. Those that are seen prefixed ‘pr’ are provisional. It is recommended that PPE be purchased from a reputable supplier.
• PPE must not be worn if the hazards caused by wearing it, are greater than the hazards against which it is meant to protect

Paying for Personal Protective Equipment

The School or Support Service must not charge for any PPE provided for employees. The University’s policy and any additional costs in respect of the provision of PPE to students, is set out here.

Storage of Personal Protective Equipment

• Some means of storage must be provided for PPE when it is not in use, so as to protect it from loss or damage. E.g. pegs or lockers for clothing or a protective box or case for safety eyewear or RPE.
• A storage facility should be provided for PPE which has become contaminated during use and this should be separate from that provided for ordinary clothing. If the PPE contains hazardous materials, it may need special storage arrangements.

Maintenance of Personal Protective Equipment

Generally, make sure PPE is kept clean and in good order.

Manufacturer's maintenance schedules and instructions must be followed. Any significant departure from them should be discussed with the manufacturers. Consideration should be given as to who carries out the maintenance. Simple maintenance can be carried out by the trained wearer. More intricate repairs or repairs on complex equipment should only be done by specialist personnel.

Where appropriate, records of checks and maintenance, and where appropriate examination and tests, must be kept. Any defects must be reported to the appropriate person e.g. line manager, lab or workshop supervisor / technician etc and the RPE replaced or repaired before re-use.

Spillages and Other Emergencies

PPE provided for use to manage spillage or other emergencies should, wherever reasonably practicable, be stored outside the laboratory/area of intended use. The spillage/emergency kit must be stored in a suitable cupboard close to the main access/egress.

Where this is not possible, face masks/filters etc. must be stored in sealed containers where they cannot become contaminated.

Face fit testing of Respiratory Protective Equipment

The University Health and Safety Service (UH&SS) will advise on face fit testing and can provide a qualitative face fit testing service. (Tel; 222181 or email; hse@lboro.ac.uk for further information).

If Schools or Support Services purchase their own face fit test kits, with the intention of carrying out their own face fit tests, the kits must conform to the relevant legislation and standards, e.g. COSHH. It is also the School’s responsibility to comply with current regulations in providing face fit testing for RPE. RPE face fit testing should only be conducted by a competent person. Competence can be demonstrated through staff receiving training from an accredited trainer Accreditation is achieved under the ‘Fit2Fit RPE Fit Test Providers Accreditation Scheme’. This Scheme has been developed by the British Safety Industry Federation (BSIF) together with industry stakeholders and is supported by the Health and Safety Executive (HSE).

(The scheme is not compulsory. However, the University, in order to demonstrate best practice and compliance with the law, requires that face fit testers are appropriately accredited by the “Fit2fitscheme).

Further details on the scheme can be found at the web site: http://www.fit2fit.org, or from the UH&SS.

Under COSHH, Face Fit Testing records must be given to the individual concerned and kept by the tester and the University for a minimum of three years.

Eye Protection

Eye protection is the most frequently used item of protective equipment within the University. The Personal Protective Equipment at Work Regulations 1992 (as amended), apply to all workplaces. Thus, eye protectors or eye shields of the appropriate specification must be issued and worn when there is a foreseeable risks to people’s eyes associated with the following:-

1. Machining of metal, wood and plastic.
2. Grinding and chipping with power operated tools.
3. The use of hand tools, chisels and wire brushes for certain operations.
4. The handling of molten metal.
5. The use of compressed air "blow guns".
6. Handling and use of caustic, corrosive or irritant chemicals.
7. Work in laboratories containing experiments involving chemicals which are liable to react violently.
8. Exposure to certain types of non-ionising radiations.

Eye protectors should be "suitable and sufficient" for the risk identified; e.g. impact, hazardous chemicals, ultra-violet light. (See BS 7028: 1999; “Eye protection for industrial and other uses. Guidance on selection, use and maintenance”).

Prescription safety eyewear

With respect to employees who wear spectacles, there is no specific obligation for prescription lens safety glasses to be provided by the University and in some instances goggles or overglasses may be worn on the top of normal spectacles. However, in some circumstances the wearing of safety glasses over existing spectacles can become impracticable and in such instances Heads of Schools, Departments or Support Services are authorised to approve the purchase of prescription lens safety spectacles.