Neil Hewitt, Divisional Director Quality and Technical Standards at Arco discusses the need for employers to be vigilant when purchasing PPE as new findings show manufacturers of substandard products are being worryingly slow to remove non-compliant products from the marketplace 

Two years on from raising concerns that some safety footwear with EC type approval and CE marking is not fit for purpose, Arco has found evidence of products that failed safety testing still being sold along with further evidence of CE marked PPE products failing to meet required standards. There is no room for doubt when it comes to protective clothing and these findings raise serious concerns about how widespread the problem might be, highlighting complacency in addressing the issue.

Testing undertaken by Arco has found that, not only are some CE marked safety footwear models continuing to fail standard safety tests, but has also identified samples of non-compliant leather gloves. This suggests that as Arco extends its testing, it is likely that further failures may be exposed, indicating that the issue could potentially affect several types of PPE. The latest findings reinforce the message that CE markings cannot currently be completely relied upon as a guarantee that PPE is fit for purpose and it is essential for employers to closely scrutinise their supply chains to ensure workers aren’t being put at risk.

What’s the problem with CE Marking?

There appears to be weaknesses in the current EC type approval and CE marking process which are allowing less responsible manufacturers or importers to gain CE Certification for products they wish to market, and subsequently make changes to the product due to market pressures. Consequently, the altered products may then not meet the required safety performance. Even though the product should be retested when significant changes are made, this may not be happening for category two items which continue to be presented with CE Certification. 

Evidence of this issue first came to light when Arco performed a number of tests on non-metallic safety footwear in 2015. During compression testing, it was apparent that, despite being CE marked, some samples of safety footwear with injection moulded plastic toe caps performed significantly worse than the fibreglass composite toe caps and that, if compressed, these substandard toes caps would not protect the wearer’s foot as intended, potentially resulting in severe injuries if an accident occurs

Concerning results continue…

More than two years on, further market surveillance by Arco in March 2017 has discovered a number of safety footwear styles available on the market are continuing to fail standard safety tests according to EN ISO 20345: 2011. In addition to this, Arco has identified further non-compliant products. In one example three non-metallic footwear styles from one brand were randomly purchased from several distributors and of the eighteen products tested, fourteen showed significant failures. The failing results are some of the worst Arco has ever seen with many toe-caps losing structural integrity through cracking. With compression failures down to 2mm, an injury while wearing this footwear is likely to fracture the bones of the foot, leading to possible amputation.

The same brand of footwear has also been observed to fail on a number of other occasions and the manufacturer has been made aware of the failures. The fact that the products are still available on the market suggests that the distributors in question do not have robust Quality & Product Assurance processes and are contravening the PPE legislation EU2016/425 which states that distributors of non conforming PPE must make sure: “corrective measures are taken to bring it into conformity, to withdraw it or to recall it, as appropriate.”

The potential cost of these failings should not be underestimated; there are over 5000 reported injuries each year to feet and toes leading to time away from work. Over 4000 of these injuries are to the feet; 45% of which result in a worker taking more than seven days off work while almost another one thousand are specifically injuries to the toes; 98% of which result in a worker taking seven or more days off work. Injuries of seven or more days cost the economy in the region of £4.8 billion annually (according to 2014/15 HSE figures: www.hse.gov.uk/statistics/cost.htm).

Leather gloves

The presence of banned substances of very high concern in leather gloves is a known issue with rigorous quality assurance processes required to monitor and control the presence of these restricted substances. Random sampling of a leather glove supplied by one distributor was found to contain excessive levels of Azo dyes, substances restricted under REACH when in contact with the skin. These substances are used as a colourant in textiles and leather gloves. Some Azo dyes have been found to be carcinogenic. It is recommended by notified bodies that testing of dyed textiles and leather with potential for skin contact is conducted. This is to ensure that the products meet the requirements of Regulation (EC) No 1907/2006 REACH and, therefore, the innocuousness requirements of the PPE Directive. The finding of illegal levels of Azo dyes in a glove sample is therefore of serious concern and represents a failing in quality assurance processes.

Change and action needed

With a growing body of evidence to suggest substandard PPE is common in UK workplaces and beyond, Arco believes it is time for change and action. Arco believes reputable suppliers and customers must lead the way by ensuring that necessary standards are being met.

Leading market surveillance

To assure our own customers that our products meet the safety standards, Arco has invested more than £1.5m in a state of the art Product Assurance Laboratory for the testing of PPE. Arco is the only distributor in the UK to have made such an investment, affirming its position as a trusted supplier and leader of market surveillance and the UK’s leading distributor of safety products. With its own brand product offering, Arco complies with the obligations laid down by the EU Parliament and ensures continued conformity via an internal testing program within its own laboratory and, where necessary, third party accredited testing laboratories.

Why employers must challenge suppliers

Unfortunately, some of the substandard products we identified in our testing have come from well known industry distributors. Of further concern is the fact that all of the manufacturers whose products failed our tests two years ago were advised of the results, yet some of these same products are still available to buy, despite the fact that they fail same tests even now.

If a worker is involved in a life changing accident, while wearing substandard PPE, aside from the human costs, the associated implications could be very damaging to an employer’s reputation, regardless of whether or not they bought the PPE in good faith that it met CE standards.

Arco believes the issue requires serious and urgent attention from everyone involved in the PPE distribution and purchasing process, and those buying PPE must challenge their suppliers to ensure the goods they are supplying are fit for purpose. It can be extremely difficult for those buying PPE to identify true product compliance but there are three simple steps that employers can take in order to be confident in the performance of the PPE they are purchasing:

•      Ask suppliers for a declaration of conformity showing original certification for the PPE 

•      Ask suppliers to define their process for sample testing to ensure safety products continue to meet the required standards

•      Ask suppliers to define their process of quality assurance to ensure products are being manufactured as originally certified.

There is no room for doubt when it comes to employee welfare. If those responsible for buying PPE only do business with manufacturers and distributors who can prove they are reputable suppliers, operators compromising on standards will be forced to change their practices, helping to drive substandard products from the market and ultimately ensuring the UK workforce stays protected.