(Issued March 2013)
1. This information sheet advises the offshore industry of the need for the face fit testing of respiratory protective equipment (RPE) facepieces for escape purposes and for use by emergency response teams (ERT). It is not concerned with the provision of RPE for planned tasks such as spray painting, where face fit testing would be required.
2. The Approved Code of Practice - (ACOP) accompanying the Control of Substances Hazardous to Health Regulations 2002 (COSHH) (and, in certain circumstances, emergency procedures required under the Management of Health and Safety at Work Regulations 1999 (MHSWR)) requires fit testing of RPE that relies on a tight-fitting facepiece. This includes RPE provided for escape purposes and for use by ERTs.
3. The COSHH ACOP - covers the general aspects of fit testing. You should also read HSE circular OC 282/28 - Fit testing of respiratory protective equipment facepieces.
4. RPE is only required where the risk assessment shows that a residual risk remains after other reasonably practicable controls have been applied. Where RPE is worn but is not required by the risk assessment (ie where there is no risk), for example during offshore survival training, face fit testing is not required and would not be enforced.
5. Two areas require clarification regarding the application and practicability of face fit testing offshore, namely:
6. The COSHH ACOP requires that wearers of escape sets and BA that incorporate tight-fitting face pieces go through face fit testing. However, this approach may be difficult offshore given the number of people involved, the transient nature of many of the workforce and the potential need to carry a range of face pieces.
7. The escape RPE is provided to facilitate prompt escape. Procedures should therefore focus on this and make sure that escape is not delayed.
8. The use of escape sets and application of face fit testing must be consistent with the dutyholder’s risk assessment. If escape sets are no longer required, they can be removed without compromising escape provision.
9. Escape sets are provided in a number of ways, for example, they may be located at strategic points throughout production areas, or carried by individuals where there is a potential risk from hydrogen sulphide (H2S); potential for asphyxiation due to unignited gas; potential for asphyxiation/anaesthesia due to oil vapours etc. Escape sets may also be used to enable personnel to muster to the temporary refuge.
10. The usual arrangement is to have a single type of escape set available to everyone onboard, whether core crew, contractors or visitors. Instruction is normally given during the induction and can vary from verbal and demonstration to practical donning.
11. One approach would be to use RPE that does not rely on tight-fitting facepieces, eg hoods. Again, the use of this type of kit should be confirmed by the risk assessment, as it may not be appropriate in all circumstances.
12. Even where RPE is well fitted to the wearer it is still essential that the correct donning procedures are followed otherwise a good fit will not be achieved. Good escape sets should be capable of being donned and checked quickly. For example, where an alarm has been activated RPE should be donned as quickly as possible and then personnel evacuated to a safe area. In this situation face, fit testing would in practice be of little added benefit.
13. Review whether escape RPE is still required or whether an alternative type can be used. In these circumstances, a risk assessment and justification for removal of the RPE, including the impact on escape provision, should be made. For the dutyholder this can have a long-term benefit by reducing inspection, maintenance and replacement costs.
14. If your risk assessment indicates that face fit testing is inappropriate, you should ensure that everyone on board is fully aware of the escape procedures and the correct donning procedure for RPE. This could be part of the onshore/offshore induction process. Consider whether the RPE is suitable for different face shapes/sizes or facial hair.
15. An appropriate level of training is essential to ensure that evacuation procedures are understood and the wearer knows how to don the escape RPE correctly. Dutyholders should also consider carrying out visual checks during instruction to identify RPE, which does not fit.
16. ERTs are equipped with BA, which requires face fit testing under COSHH. Concerns over the practicalities of face fit testing, as outlined in paragraph 6, are not as significant as those for wearers of escape sets as ERTs consist of a dedicated and specifically trained core workforce.
17. Dutyholders should ensure face fit testing of ERTs as required by COSHH.
18. Alternatively, dutyholders may wish to consider a procedure that has been agreed between HSE and the onshore Fire and Rescue Service. The fit testing and BA facemask donning procedure previously given in the Fire and Rescue Service document DCOL 6/2001 and updated in DCOL 2/2004 is a valid alternative to quantitative fit testing. Where a dutyholder intends to adopt DCOL 2/2004 they should satisfy themselves that it is a suitable and sufficient alternative to that contained in OC 282/28.
This guidance is issued by the Health and Safety Executive. Following the guidance is not compulsory, unless specifically stated, and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law. Health and safety inspectors seek to secure compliance with the law and may refer to this guidance.