A guide to the The Personal Protective Equipment Regulations

With specific reference to safety gloves.

When viewed in conjunction with other regulations in the field of health and safety such as those relating to the Use of Personal Protective Equipment in the Work Place, these new regulations have had a major impact on the use of safety gloves in the workplace throughout the European Community, particularly in those situations where gloves are used to protect workers from serious risks to their health and safety.

Product Categorisation

The Directive defines three types of personal protective equipment (PPE): i) Simple Design - PPE used to protect from minor risks of injury such as gardening gloves; ii) Complex Design - PPE used to protect the user from life threatening risks such as breathing apparatus; iii) Intermediate Design - PPE not falling into the previous 2 categories.
This categorisation of products is still subject to some dispute both within and between the member states. Whilst products of simple design can be self-certified by the manufacturer or importer (for those items manufactured outside the EC), those belonging to the other two categories must be tested by an independent test house appointed by the member state government, known as an

Approved Body, to an appropriate European Standard. Those in the complex category must also be manufactured by a quality assured source (registration to IS0 9003 being the minimum requirement) or alternatively be subject to batch testing.

As might be expected, there is considerable difference of opinion about the intermediate category with different member states apparently taking differing views on the categorisation of certain products.

European Standards

The Directive anticipates PPE throughout the Community, apart from that of simple design or that of very new and novel design, being manufactured and tested to harmonised European standards.

A great deal of work has been going on for the past few years by representatives of test houses, manufacturers, users and other interested parties not only from the EC members states, but also from other European countries, towards the drawing up of the new European Standards. In their draft form these are known as prEN's which, when adopted, will be known as EN's, sometimes proceeded by the initials of the national standards institute of the member state concerned. Most of the standards have been completeed and some in fact are now being revised. however there are a few still in a draft format.

A summary of the main glove standards is given in the table below.

The new standards involve assessing a glove's performance using laboratory tests and categorising the product into one of usually up to 4 or 5 performance levels depending on the results of the tests. These, in many cases, will give a good indication of how the product will perform in the work place. It should be noted, however, that there is no direct correlation between a product's performance level and the hazards the product will protect against; a glove offering performance level 5 blade cut resistance, for example, will not give 100% protection against all risks of this type. On the other hand these standards are being accepted worldwide as useful indications of performance.

Marking
One of the important benefits of the new standards is that of marking, which will reduce the possibility of gloves being used incorrectly. Not only will the glove itself be marked with the specified information, but a significant amount of information will be also shown on the packaging. This will include the names of the manufacture or his representative in the Community, the glove description, size, CE mark, one or more of the pictograms given below and any other relevant information. The pictogram will be accompanied by a sequence of numbers indicating the product's performance in the various tests of the particular standard indicated by the pictogram. The packaging of products in the simple design category will be marked with the words "For Minimal Risks Only".

Glove Test Pictograms
MICRO-ORGANISM HAZARDS EN 374
CHEMICAL HAZARDS EN 374
CHAINSAW HAZARDS EN 381
MECHANICAL HAZARDS EN 388
IMPACT CUT HAZARDS EN 388
STATIC ELECTRICITY HAZARDS EN 388
HEAT & FIRE HAZARDS EN 407
COLD HAZARDS EN 511
RADIATION HAZARDS EN 421

Care instructions and data on obsolescence, if relevant, will also be shown.

The CE mark

This is an area which has been subject to an amending directive. Initially products of "simple design" will be marked with the letters CE followed by the last two digits of the year of manufacture. Products in the intermediate and complex category will also have to be marked with the same CE mark together with the identification number of the notified body that was responsible for carrying out the type testing.

The amending directive (Council Directive 93/68/EEC), adopted on the 22 July 1993, will introduce a number of changes. Products in the simple design category will be marked with just the letters CE; the year of manufacture will not be included. Products in the "intermediate design" category will be marked with the CE mark together with the year of manufacture. "Complex design" items will carry the same mark but will also have to bear the identification number of the notified body involved in the production control phase or the notified body number responsible for carrying out periodic checks on the performance of the product. Any PPE that has been subject to type testing will have to include the name, address and identification number of the notified body responsible for the testing in the product's User Information Notice, or Intermediate category. This notice is to be made available once the PPE is placed on the market. This new Directive enters into force on 1 January 1995 and allows a transition period until 1 January 1997.

In all cases the form of the CE mark is to be as shown

Summary
The European Directive has led to considerable changes to the safety glove market in Europe, and has led to the introduction of many new standards for safety gloves. One of the major advantages has been the compulsory marking and data that must accompany products used in areas of risk. The Directive has also caused a surge in innovative new products.

These changes will understandably lead to greater safety throughout the Community.