Regulation on Personal Protective Equipment

Managing Personal Protective Equipment (PPE) is regulated to ensure worker safety.

We have prepared a checklist template that allows verification of the main points of vigilance to ensure a company’s compliance.

Regulation

Here are the main steps a company must follow to be compliant:

1. Risk Assessment: The employer must conduct an occupational risk assessment (Single Document for Risk Evaluation, DUER) to identify situations that require the use of PPE.
2. Choice of PPE: The equipment must be selected based on identified risks and comply with European standards (CE). The employer must ensure that the PPE is suitable for the user and the work environment.
3. Training and Information: Employees must be trained and informed about the correct use of PPE. This includes wearing, adjusting, maintaining, and the limitations of the equipment.
4. Provision and Accessibility: PPE must be easily accessible to employees and in sufficient quantity.
5. Maintenance and Verification: PPE must be regularly maintained and checked to ensure they remain in good condition and functional. This may include cleaning, repair, and replacement.
6. Record Keeping: The employer must keep updated records of PPE, including purchases, maintenance, employee training, and inspections.
7. Withdrawal of Defective PPE: Any damaged or defective PPE must be removed from circulation and replaced.

These requirements are primarily governed by regulations such as the Occupational Safety and Health Administration (OSHA) standards, which outline specific obligations regarding the provision and use of PPE. Additionally, it is a good practice to stay updated with legislative changes and follow guidelines from agencies such as the National Institute for Occupational Safety and Health (NIOSH), which offer practical guidance and standards for PPE.

The Checklist

In more detail, here is a checklist that gathers about thirty points to check in your organization.

Here is a summary of the points addressed:

1. Identification and Analysis of Risks: The employer identifies and analyzes potential risks and sets up protective measures, favoring collective measures over individual measures for employee safety.
2. Communication about Risks and Usage Instructions: Employers communicate to PPE users the risks associated with their tasks and the appropriate PPE to use, as well as the conditions and instructions for their use.
3. Involvement of the Health Service: The occupational health service is informed and involved in communication with PPE users.
4. Training and Signage: Clear signage indicates the obligations to wear PPE and the associated risks. Users are trained, especially for complex protection systems.
5. Restrictions on Used PPE : Used PPE that is single-use, expired, damaged (even if repaired), or intended for head protection against mechanical impacts, infectious agents, and category III (except for diving equipment) should not be purchased or transferred.
6. Certification and Compatibility: Employers ensure that the provided PPE is certified and compatible for use together in case of wearing multiple PPE.
7. Consultation of Users in the Provision of PPE: Employers provide PPE taking into account feedback from end-users, work constraints, and the comfort and morphology of users. PPE is provided free of charge to those who need it.
8. Hygiene and Accessibility: Employers provide facilities to maintain the hygiene of PPE, ensure that sharing PPE does not pose health or hygiene risks, and make PPE and consumables easily accessible to users.
9. Protection for All Users: Users with medical restrictions are not exposed to risks without protection. Temporary workers are equipped with the necessary PPE by their agency or the hiring company.
10. Cooperation Between Companies: Companies cooperate on a prevention plan that describes the risks and necessary PPE for common tasks.
11. Maintenance of Rented PPE: Rented PPE is maintained in compliance by the lessor.
12. Verification and Instructions: Employers provide manufacturers’ instructions for PPE, and users can verify PPE compliance before each use. Periodic checks are performed in accordance with the manufacturer’s instructions by qualified internal or external inspectors.
13. Storage, Disposal, and Expiration: Proper storage, disposal or recycling of unusable PPE, and regular checks on expiration dates and conditions of PPE are ensured by the employer.

Evidence of Compliance with Regulations

In the event of an audit, here are the main documents that will be requested to verify your compliance with the regulations:

Risk Analysis Report: This is the document that identifies potential hazards in the work environment and proposes measures to mitigate them.

Internal Regulations and Communiqué: These documents define the internal safety policies and procedures that employees must follow. They are communicated during information meetings on the subject of PPE and at the time of hiring or at the start of the mission.

Safety Signage: These alert employees to specific hazards in work environments by providing direct safety instructions (e.g., wearing specific PPE).

User Training Register: This register details the employee training sessions, topics covered, and renewal dates for future training, ensuring that all employees are well-trained to use PPE safely and expose themselves to risks (e.g., working at heights, electrical).

Purchase Documents and PPE Safety Records : These documents include proof of purchase and detailed records of maintenance, inspections, and CE certifications of equipment, ensuring that PPE meets European safety standards. The register must contain the entire history of PPE. The PPE in use must be compliant according to this register.

Special Procedures and Agreements: Like conventions or collective agreements, these documents formalize the company’s commitments to safety and risk management, including prevention plans.

Management and Storage of PPE : Guidelines for the cleaning of PPE, their storage under controlled conditions, and the accessibility of user manuals ensure that the equipment is kept in optimal condition.

By following the provided checklist and gathering all the required evidence, your company will establish a solid framework to ensure compliance during any audit. These documents not only demonstrate adherence to current safety standards and regulations but also attest to your company’s commitment to maintaining a safe and well-regulated work environment. By preparing and keeping these records and procedures up to date, you minimize the risk of non-compliance and enhance the safety of your employees.