The UK has one of the most robust and exacting health and safety regulatory frameworks to be found anywhere in the world.
Compliance with the various H&S laws is crucial for employers and this is true of the regulations for the appropriate and correct use of Personal Protective Equipment (PPE) for outdoor workers.
PPE is equipment designed to protect employees against health or safety risks in the workplace, where hazards are present.
More often than not it applies to outdoor workers, especially those operating heavy machinery like chainsaws. It includes such items as safety helmets, gloves, high-visibility jackets, protective footwear and respiratory protective equipment.
What the UK Legislation says on PPE
In this guide, we will look at some of the basic principles of the regulations, legislation, and the responsibilities of both employers and employees regarding PPE. Let’s begin with some questions and answers.
What is the legal source of the rules regarding PPE?
The rules are established by Personal Protective Equipment at Work Regulations 1992 (the Regulations).
What is the general requirement of the regulations?
Regulation 4(1) requires that:
“every employer shall ensure that suitable personal protective equipment is provided to his employees who may be exposed to a risk to their health or safety while at work except where and to the extent that such risk has been adequately controlled by other means which are equally or more effective.”
What is considered personal protective equipment?
Regulation 2(1) defines PPE as follows:
“…all equipment (including clothing affording protection against the weather) which is intended to be worn or held by a person at work and which protects him against one or more risks to his health or safety, and any addition or accessory designed to meet that objective.”
Risk Assessment and Hierarchy of Controls
The accepted interpretation of the rules is that personal protective equipment should be used as a so-called “last resort” in the protection of health and safety of employees, when assessing risks.
In other words, every effort must have already been made to put in place measures to make the workplace as safe as possible.
This is known as a hierarchy of control measures (see image below) and it is the basis of a proper risk assessment.
In the case of a tree surgery work for example, the first question would be can you physically remove the hazard. If the hazard is falling branches or debris, then it would be the job of the employer to assess and deal with this risk based on the hierarchy of controls.
Since the hazard cannot be eliminated or substituted then every effort must be taken to isolate those workers who do not need to be in harm’s way and introduce proper safe practice measures and training to keep those workers who are at risk as safe as possible.
Only at the bottom of the hierarchy does PPE come into play as a final protective measure, should all others fail and someone is hit by falling debris.
The same example could be used in the construction industry where, although in these environments there might be more propensity to erect safeguards such as scaffolding and barriers.
Use of dangerous tools
It goes without saying that the use of power tools such as chainsaws and pneumatic drills presents serious risks in the workplace.
If we take our example of forestry workers or tree surgeons, the Health and Safety Executive (HSE) states that, in the course of the past few years, there have been several fatalities and many serious injuries among workers using chainsaws.
It is therefore a legal requirement that any employees in direct contact with chainsaws are provided with all the appropriate PPE, including chainsaw boots, trousers and helmets with face visors and ear protection.
Risks are increased significantly in the case of tree surgeons when working in trees at height with chainsaws. A balance must be struck between PPE that protects them from their equipment but does not impede their ability to see and hear their immediate environment.
The PPE required for all chainsaw workers, includes the following :
- Chainsaw Trousers to EN 381-5.
- Chainsaw Boots to BS EN ISO 20345:2004 (showing a shield depicting a chainsaw to comply with EN 381-3)
- Chainsaw Helmets to EN397 or for aerial use of a chainsaw
- Chainsaw Helmets with chinstrap to EN12492
- Chainsaw Hearing Protection to EN 352-1.
- Mesh Visor or safety glasses to EN 166.
- Chainsaw Gloves to EN 381-7.
All workers using chainsaws and other heavy equipment must be properly trained and also assessed on their health and fitness. Any conditions that affect mobility, vision, dexterity or balance may mean that these workers are unsafe to use this kind of equipment.
In our hierarchy of controls, it’s fitting in these cases to think of the worker themselves as the hazard, in which case if they can be replaced by a worker who doesn’t represent a risk due to an existing medical condition then this should be done.
Personal Protective Equipment by body area
Depending on the nature and the risks of the work, employees will require different types of PPE for the protection of specific parts of their body. As an example, we will look in general terms at the requirements of the chainsaw operator;
Helmets will protect the head in the case of a fall but they will also protect workers on the ground from falling debris. For those employees working at height, the helmet should have a 4 point chinstrap.
It’s easy to think of injuries in the outdoor workplace as taking place in an instant but some serious conditions can be the result of prolonged exposure to certain conditions. In most outdoor working environments this will be extreme noise.
Workers using or working around loud power tools or equipment must have proper ear protection.
Eye and face protection
Eye and face protection is essential if flying debris, dust or other particles are present in the workplace.
Steam, gasses and hazardous liquids may also require partial or full face protection, especially if there is a risk of them hitting the face.
The risk of cuts to hands and fingers from machinery, sharp objects in the environment such as foliage, thorns, nails, broken glass, etc will require suitable protective gloves to be supplied. Gloves will also protect hands from the extreme cold.
Strong footwear is always required in outdoor environments, especially where there is a risk of heavy objects falling onto feet or equipment such as chainsaws or drills hitting someone’s foot.
Leg and groin protection
Protecting the legs and groin area is essential when using cutting tools that can easily ricochet or fly off when being used.
Even in good good daylight conditions, it is almost always necessary for outdoor workers to wear high vis clothing, whether that’s a high-vis jacket or something more substantial. At night or in poor conditions this is especially true.
PPE Safety Standards
The PPE needs to be manufactured to the relevant legal standard and the Personal Protective Equipment Regulations 2002 require that it must be “CE” marked. This means that that the equipment in question has been rigorously tested and conforms with European Union standards.
PPE must be carefully stored when not in use and should be adequately maintained and monitored for damage and wear and tear. Employees must be trained in its proper use and be made aware of its location.
All personal protective equipment must be supplied free of charge by an employer to those employees who require it.
Employers should also take care to supply PPE in a range of sizes to accommodate all heights, shapes and weights of employee. This is partly to ensure that discomfort doesn’t distract a worker who is operating dangerous machinery, and partly because badly-fitting clothes present their own risks.
The HSE website has a full breakdown of all safety standards and requirements for individual pieces of PPE.
This guide is intended as a basic introduction. If you have any doubts about your company’s PPE and wider health and safety provisions, you should check the various HSE guidance on their website, speak with an occupational safety consultant or engage a specialist health and safety lawyer to make sure that you are fully compliant with the law and giving employees the protection they need.
About the author
This guide has been written exclusively for ByteStart by Paul George, managing director of Landmark Trading Ltd, the UK’s leading supplier of arborist equipment, tree surgery and tree climbing equipment.