Regulations and standards keep firefighters safe and provide reassurance that Personal Protective Equipment (PPE) is of good quality, fit for purpose and adequately protective. Richard Ballheimer, Compliance Manager at Bristol Uniforms looks at new European PPE regulation, what it means for manufacturers and customers, and brings us up to date on the latest European, USA and international standards to be published and reviewed.
Standards strengthen overall product safety and quality. They offer customers the reassurance that equipment meets appropriate global standards and help to break down technical and language barriers between countries, making it much more straightforward for manufacturers to trade goods and services.
There are currently three major standard-setting bodies on the world stage: the National Fire Protection Association (NFPA), which develops standards for the USA; the European Committee for Standardization (CEN) which creates EN standards for the European Union (EU); and the International Organization for Standardization (ISO) which sets standards worldwide. Along with ISO standards, EN and NFPA standards are often adopted by other countries who don’t have their own standards system. In addition, many individual countries also have their own National Standards Bodies (NSBs), such as the British Standards Institute (BSI) and Standards Australia (SA).
It is usually up to a customer to specify what standards they would like their goods to comply with. A Fire Authority’s procurement department, for example, can choose whether or not they would like PPE to be manufactured to EN, ISO or NFPA standards.
If selling PPE in Europe, there are also stringent regulations that must be adhered to. The PPE Directive EC 89/686 was replaced by PPE Regulation EU 2016/425 in April 2018. The new regulation has resulted in a few changes to the way manufacturers like Bristol Uniforms do things.
When introducing new fabric combinations or PPE ranges we now:
- include a risk assessment in the PPE technical file, summarizing the identified risk to the wearer and how this was tested for during the certification process;
- obtain an examination certificate showing compliance to the new Regulation not the old Directive; and
- follow a new (albeit very similar) conformity assessment procedure.
From 21 April 2023, we will also do this for existing certified fabric combinations and PPE ranges as well – all of which still have certificates issued under the PPE Directive. Certificates to the Directive will no longer be valid after April 2023.
The new Regulation will also tighten up the information we as manufacturers must provide about PPE. From 21 April 2023 we will:
- provide a user manual in the buyer’s native language;
- ensure all PPE bears a CE mark, serial number and our name and address (if this isn’t possible, it must be included on the packaging or in the user manual); and
- supply the EU declaration of conformity for each PPE product, or provide easy access to it online, and make it available along with the technical documentation for ten years after the PPE has been placed on the market.
From April 2023, the new regulation also puts the onus on those selling PPE to check items comply fully with the new regulation. If in any doubt, they must not sell the product and recall any sold items. They must also ensure that, while PPE is in their care, its storage or transport conditions do not jeopardize its conformity with the applicable essential health and safety requirements set out in Annex II of the Regulation.
For the customer, these changes only go to further strengthen the safety and quality of PPE, and provide added reassurance that PPE being sold is fit for purpose and meets all appropriate standards.
Questions are being asked about whether in the future, the UK will diverge from EU PPE regulations and standards. It’s too early to say, but BSI has confirmed that if this or future governments wish to diverge from regulatory requirements in the EU or other countries, they will ensure that any industry standards needed to underpin new laws will represent international best practice.
In addition, we are being asked whether we, through BSI, will continue to participate in the development and review of PPE standards for use across the European single market. This will be discussed during the transition period, and potentially beyond, and no decision has yet been made.
What we can confirm though, is that Bristol Uniforms’ conformity to PPE Regulation EU 2016/425, and indeed European PPE standards will be unaffected by the UK’s exit from the EU. Like most manufacturers, we will continue to make PPE to European standards after 31 December 2020 in order to continue trading in the EU.
Latest standards in development and under review
Standards recently updated
AS 4967: 2019 Protective clothing for firefighters – Requirements and test methods for protective clothing used for structural firefighting
This standard is targeted at manufacturers, suppliers, laboratories and end users and outlines the minimum requirements for structural firefighting PPE. It was updated in June last year and after consultation, Standards Australia and Standards New Zealand decided it would be an Australian Standard rather than an Australian/New Zealand Standard. Key changes, although not exhaustive, include improvements to water-vapour resistance, addition of a 15cm overlap between jacket and trouser, and new clauses covering innocuousness and compatibility.
NFPA1851: 2020 Standard on Selection, Care and Maintenance of Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting
This recently revised standard outlines the requirements for the selection, care and maintenance of firefighting PPE to reduce health and safety risks associated with improper maintenance, contamination, or damage. This new edition now requires a swatch of fabric to be contaminated in a laboratory, sent to those responsible for laundering to be washed, and then returned to the laboratory for confirmation that it meets the required level of cleanliness.
BS8617: 2019 Personal protective equipment for firefighters – Cleaning, maintenance and repair
This has now been published in the UK as a Code of Conduct, but has the status of a standard. It was introduced in response to the mounting evidence that contaminated PPE increases a firefighter’s risk of developing cancer. In the absence of an EN standard, this was a priority for the BSI committee that is responsible for firefighter PPE. This standard provides clear guidance on the cleaning, maintenance and repair of firefighters’ PPE (helmets, gloves, footwear and fire hoods), to reduce the potential health and safety risks associated with poorly maintained, contaminated, or damaged equipment.
Standards currently under review
EN 469: 2005 Protective clothing for firefighters – Performance requirements for protective clothing for firefighting
This European standard specifies the minimum levels of performance requirements for firefighter PPE. I sit on this committee, which is in the process of revising this standard. A final draft is being prepared for formal vote in April, which if positive would see the standard published in the summer.
EN 13911: 2017 Protective clothing for firefighters – Requirements and test methods for fire hoods for firefighters
This European standard specifies the minimum safety requirements and test methods for a fire hood. This standard is currently under review. The next Project Group meeting was due to take place in April, but due to the Coronavirus pandemic, will now be rescheduled for later this year.
ISO 15384: 2018 Protective clothing for firefighters – Laboratory test methods and performance requirements for wildland firefighting clothing
This international standard specifies testing methods and minimum performance requirements for PPE, designed to protect the wearer’s torso, arms and legs during wildland firefighting and associated activities. It was updated back in 2018 and it has now been agreed that it will be published as an EN ISO standard replacing EN 15614: 2007, which will be withdrawn.
ISO 13506: 2017 Protective clothing against heat and flame — Part 1: Test method for complete garments — Measurement of transferred energy using an instrumented manikin
This standard applies to Europe and specifies the overall requirements, equipment and calculation methods to provide results that can be used for evaluating the performance of complete garments or protective clothing ensembles exposed to short-duration flame engulfment. Plans are afoot to revise this standard again, and trials are being carried out under a confidentiality agreement.
ISO 23616 Cleaning, Inspection and Repair of Firefighters’ PPE
ISO is also developing a new international standard for cleaning and repair of PPE and I am Joint Project Leader with Vera DeGlas. It will cover garments, helmets, gloves, footwear, fire hoods and respiratory protection devices – the latter of which gets the most contaminated and is the most difficult to clean. The standard is currently in second draft and comments on this draft will be reviewed at the next committee meeting, which is due to take place later in the year.
For more information, go to www.bristoluniforms.com