Access to information for compliant use of PPE is a common issue within companies. Every person must have received and must follow the correct instructions for wearing PPE, regardless of their profile (temporary worker, new hire, experienced individual). This becomes an additional challenge when carriers work outside at client sites, on construction sites.
From the manufacturer/distributor of personal protective equipment, the obligation of information lies in providing the CE notice found in the packaging of each piece of personal protective equipment. This information is sometimes accessible on the internet via a QR Code attached to the equipment, but this is not a requirement for the manufacturer.
Important information in these notices must be absorbed by the QHSE service and then communicated to users. This is even more important as this information is often poorly retained by users, as the notices often end up in the trash after unpacking the protective equipment. Let’s see together what can be done to maximize the retention of this information in the field.
Information from Manufacturers of Personal Protective Equipment
Behind a product data sheet in a catalog, there are very different levels of protection (PPE of category 1, 2, or 3 depending on the severity of risks) for identical standards, conditions of use, maintenance, control, specific reforms for each equipment.
Therefore, it is important to make information available to carriers in a format that is understandable to everyone.
You’ve probably noticed, the content of CE notices from manufacturers is often incomprehensible. It talks about limits of use, the validity of the PPE regarding an expiration date, commissioning, manufacturing, a period of storage or use, or a maximum number of maintenances. Sometimes, protective equipment is not subject to any specific management rule; it’s up to the carrier to assess the wear level of their equipment.
When a new PPE reference is delivered, a check of the new CE notice must be carried out. Even if the equipment looks identical to the previous model, the CE notice is unique for each equipment reference. It is therefore necessary to check if current management rules are impacted.
Best Practices from QHSE Services : Training and Information on PPE
The Single Risk Assessment Document (DUER) has formalized the choice of Personal Protective Equipment adapted from the identified residual risks. The next step is to provide the usage instructions for each PPE for every job position. Note that in the event of a change in equipment reference, the new CE notice must be reviewed, and if necessary, update the information intended for carriers in case of a change in management rule.
All means are good for communicating these best practices; the welcome booklet, safety training, postings at the workplace, experience feedback, supplier information supports… In all cases, it’s the result of an analysis of CE information notices in connection with the conditions of use planned in the company.
Startups offer innovative solutions for raising awareness about prevention and safety (Safety Management System) and for better use of equipment. The company can then tailor its communication to the context of its activity.
For more information, you can visit the website of CIBAKA, for example.
Properly Identifying Personal Protective Equipment
Today, there is no obligation for the manufacturer to use a standardized identifier (code recognized by the customer regardless of the supplier). Different identifiers to manage for the customer constitute the first barrier to tracking personal protective equipment as well as accessing PPE information. This is particularly important for category 3 PPE (deadly risks), especially those subject to an annual regulatory check.
Parallel to communicating information on the proper use of equipment by the QHSE service, reinforces the need for identification and tracking of all PPE. Having marking with a standardized identifier on each piece of equipment makes sense, especially if it allows access to the CE notice and your recommendations for proper use. It’s possible to use QR Code technology to access this information using a smartphone’s camera.
For more information on best practices for identifying your PPE, you can consult the ID SAFETY Equipment guide developed by GS1.
How to Check Your Personal Protective Equipment ?
Here, we are specifically talking about the check of PPE by the user before each use.
This assumes that specific information regarding risks of degradation, premature wear, poor maintenance, or reduced performance are identified and then communicated to users.
This enters into a difficulty of understanding which can lead to the use of non-compliant, potentially dangerous protective equipment.
This is a risk identified by the DGCCRF (General Directorate for Competition Policy, Consumer Affairs, and Fraud Control) which conducted an analysis following regulatory checks on personal protective equipment: Out of 98 products targeted by the DGCCRF for sampling, 85% were found to be non-compliant, with 18% presenting a danger. All dangerous products were subjected to appropriate measures, up to and including product recalls.
Rémy PRUD’HOMME: “In my experience with PPE clothing rental-maintenance, we issued a guideline to the inspection post in the laundry to set aside equipment not in compliance with the manufacturer’s rules. It’s not 100% viable since not all PPE is regularly maintained. Some never even come back for washing! It’s therefore essential for the carrier to have the means to perform this check themselves, without it substituting for regulatory control.”
When to Decommission a Piece of PPE ?
One might think that providing PPE to employees each year doesn’t prevent the use of worn-out, non-compliant PPE if they are not replaced when worn. This assumes that restitution is made to the employer, which is not always possible. The sole of a safety shoe does not wear out the same way for all carriers! Some protective equipment does not have an expiration date or maintenance limit. In such cases, unequivocal criteria must be determined to replace the equipment in time. For example, a “fault library” can be created, gathering photos of wear levels of PPE to be decommissioned and made accessible via the identification QR Code in the protective equipment.
For other types of equipment, it’s about following the rules set by the manufacturer. One might think this is simpler, but in fact, it’s very complex. It refers to several criteria such as the manufacturing date, the duration of storage before use, the duration of use from manufacturing or commissioning, the number of maintenances, the periodicity of control, the time of use…
Are these informations accessible to the carrier?
Applying these rules to the use of personal protective equipment outside the company increases the difficulty. This helps understand why the employer regularly renews PPE that is not subject to tracking. Be careful; in this case, carriers might still use old protective equipment in the field…
An Excel Spreadsheet
ERP
Dedicated PPE Management Software
This solution is gaining popularity! Generally, it allows for automatic data integration (PPE history, carriers, certifications…) and generates control alerts, manages stock. The available tools also allow for managing additional modules, such as legislative documentation (CE notice), work accident declarations… Watch out for the entry constraints and the associated errors.
This is now the moment to explain why we launched the creation of Keep Control!
Creating a link between a protective equipment carrier and their company, through the identification of their PPE. We ensure the traceability of personal protective equipment by marking with an interoperable identifier. The carrier accesses information about their equipment, uploading information via the QR Code present in each PPE.
