PPE: Up close and personal11 November 2021

In the wake of supply failures and often mediocre quality PPE equipment during the pandemic, a new conformity assessment process is now in force for placing all forms of such protective wear on the market. By Brian Wall

What happened when COVID-19 struck was beyond all previous living experience. No one was prepared for the devastation the emerging pandemic would cause and the impact this would have on the whole population. When it came to PPE (personal protective equipment) for the front-line staff battling to save hospitalised patients, supplies fell woefully short and often were not fit for purpose.

It’s only right to acknowledge there was a powerful element behind all this where everyone was ‘learning on the go’ at the outset and that mistakes were inevitable. Yet, even allowing for this, the parliamentary public spending watchdog concluded in a scathing report that the UK government wasted hundreds of millions of pounds of taxpayers’ money on poor quality and unusable personal protective equipment (PPE), while leaving front-line workers insufficiently protected from the virus.

The House of Commons Public Accounts Committee painted a picture of an emergency scramble for PPE in which government contacts were handed contracts through a special channel without tendering. But the “inadequate” pandemic plan left front-line workers “risking their own lives to provide treatment and care”, the MPs’ report said.

BEYOND COVID-19

Looking wider than the pandemic itself, there is a broader discussion to be had about PPE in all its manifestations. How do consumers of such equipment across industry protect themselves from inferior products? Where do they go to be reassured that what they are being offered ‘in theory’ is what they will actually get ‘in practice’? What has happened during the pandemic has proved a powerful catalyst for greater control and protection against low-quality PPE. The British Safety Industry Federation (BSIF), for its part, is acutely aware of the scale of the challenge: “A number of items are available that claim CE approvals, but, in reality, they have not been appropriately certified,” it points out. “Even worse, some items are in fact counterfeits of existing products.”

All PPE must be correctly tested and certified to meet the appropriate European standard, states the BSIF. Its CEO Alan Murray is in no doubt what the goal of the federation has to be: “It must make sure that only compliant, safe PPE is on sale in the UK.”

Beyond just the products, do the people selling them have any qualification to sell PPE? How does the salesperson know what they’re selling is appropriate for the end user? With safety equipment often used in areas of high risk as a final safety backstop, it’s a real concern. As an end user, how can you be sure the advice you’ve got from your supplier is correct?

SAFETY SUPPLIER SCHEME

The pandemic notwithstanding, the quality of PPE and general lack of market surveillance has long been an issue that has concerned the BSIF and the reason why many years ago it set up its Registered Safety Supplier Scheme (RSSS) to support the UK safety market. The mission of the scheme is to provide assurance to users that only compliant and correctly-performing products are being supplied through a capable, educated, competent supply chain.

The RSSS is open only to members of the BSIF, and a mandatory requirement for all members engaged in PPE manufacturing, marketing and supply. Companies displaying the scheme’s logo have signed a binding declaration that the safety equipment and services they offer meet the appropriate standards, fully comply with the PPE regulations and are correctly CE-marked. “The scheme provides a recognised route to enable a member to demonstrate compliance and due diligence – discharging the obligations of an economic operator under PPE Regulation (EU) 2016/425,” says BSIF.

New members to the BSIF need to work towards achieving Registered Safety Supplier Scheme status within the first six months of BSIF membership. Who benefits? The purchasers and end users of safety products and PPE, states the BSIF, by purchasing only from capable, value-adding suppliers products that perform as they should.

WINDS OF CHANGE

As far as legislation affecting PPE goes, there has been a great deal of change following the UK’s exit from the EU, particularly the requirement for UK legislation to be put into force where previously EU legislation applied to PPE. The approval bodies in the UK that were previously notified bodies for assessment/approval of CE-marked products have now become approved bodies for assessment/approval of UKCA-marked products. This means anyone placing Category II and III PPE on the UK market must ensure their products have been assessed and certified to the requirements of UKCA marking by an approved body (for GB) or to CE marking requirements by a Notified Body (for Northern Ireland). See also www.is.gd/ecahuz.

This has not impacted the Registered Safety Supplier Scheme, asserts its manager at the BSIF, Roy Wilders. “The RSSS will continue to audit our members as we have done for many years now to ensure that claims made about products or services provided to UK end users meet those claims, that they conform to any relevant legislation or approved codes of practice and have relevant processes in place to manage the supply of the product or service.”

He confirms that the change to UKCA marking has a transition period in legislation until 31 December 2021. “This means that products can be marked as CE only up until this point; as from 1 January 2022 all products must be assessed/certified [if relevant] and then marked with the UKCA marking.” Until the 31 December 2022, manufacturers are allowed to add a UKCA sticker to product packaging and documentation [User Instructions/Declarations of Conformity for example] – but only if relevant assessment and certification has been carried out beforehand, he adds.

If keeping pace with the legislation and regulations around PPE was challenging before the UK left the EU, it is even more so now for purchasers/end users. How can be sure that they are buying equipment that is safe and bona fide?

They should always look for the Registered Safety Supplier Scheme ‘Shield Of Protection’,” advises Wilders. “This lets them know they are buying from organisations that not only meet the requirements of the relevant legislation, but who also take safety seriously, and are educated and qualified to provide information and advice in relation to the UK safety market. They should always check that the PPE being provided is suitably assessed and certified by ensuring they are receiving the user instructions and access to a declaration of conformity – and that the product is correctly marked and matches the paperwork.”

Brian Wall

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British Safety Industry Federation

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