Fit testing respiratory protective equipment for escape and emergency response on offshore installations

Offshore Information Sheet No. 3/2013

Introduction

1. This information sheet provides guidance to the offshore industry on the requirements for face fit testing of Respiratory Protective Equipment (RPE) facepieces for:

• Escape sets; and
• Breathing Apparatus (BA) for Emergency Response Teams (ERT).

2. ERT are appointed persons, who have specific responsibilities and are trained to respond in the event of an incident/emergency. For example, RPE may need to be provided for safe exit from an area where hazardous substances maybe released after control systems fail or during emergency rescue.

Background

3. The Control of Substances Hazardous to Health Regulations 2002 (COSHH) Approved Code of Practice (ACOP) Paragraph 160 requires wearers of tight-fitting RPE to be face-fit tested, using a suitable method, by a competent person. It also requires wearers to be clean shaven in the area of the face seal when using tight-fitting RPE. This includes RPE provided for escape purposes and for use by ERT.

4. INDG479 - Guidance on RPE fit testing highlights that the effectiveness of tight-fitting facepieces depends on achieving a good contact between the wearer's skin and the face seal of the facepiece. People's faces vary significantly in shape and size so it is unlikely that one particular model, or size, of RPE facepiece will fit everyone.

5. HSG53 RPE at work Paragraph 28 states that for tight-fitting facepieces the initial selection should include a fit test. Paragraph 72 states that tight-fitting RPE will only provide effective protection if the wearer is clean shaven, so they should also be clean shaven when fit tested. Paragraph 77 states that users of tight-fitting facepieces should have passed a fit test for the RPE device they are using.

Risk assessment

6. 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 (i.e., where there is no risk), for example during offshore survival training, face fit testing is not required and would not be enforced.

Clean shaven policy

7. A clean-shaven policy should be put in place where there is a specific requirement for certain employee roles/tasks to wear tight-fitting facepieces e.g., ERT.

Escape sets

8. The escape RPE is provided to facilitate prompt escape. Procedures should therefore focus on this and make sure that escape is not delayed. The most commonly used type of escape sets in industry are those that do not require face fit testing e.g., self-rescuers. These are designed to get personnel to a safe environment quickly.

9. The use of escape sets, and application of face fit testing must be consistent with the dutyholders risk assessment.

10. Escape sets are provided for various situations, for example, they may be located at strategic points throughout production areas or carried by individuals where there is a potential risk from specific hazardous substances e.g., toxic gas release. Escape sets may also be used to enable personnel to muster to the temporary refuge.

11. The usual arrangement is to have a single type of escape set available to everyone onboard, whether core crew, contractors or visitors. Suitable information, instruction and training should be provided by the dutyholder, which may include a toolbox talk followed by a practical donning exercise and demonstration. This is normally given during the induction.

12. One approach would be to use RPE that does not rely on tight-fitting facepieces, e.g., loose fitting hoods. Again, the use of this type of kit should be confirmed by the risk assessment.

13. 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. Suitable 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.

Action – Escape sets

14. 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.

15. Dutyholders should ensure that everyone on board is fully aware of the escape procedures and the correct donning requirements for RPE. This could be part of the onshore/offshore induction process. All staff should be suitably trained and familiar with the available escape sets.

16. 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 and promptly.

Emergency response teams (ERT)

17. The duty holder should undertake a formal risk assessment which highlights the RPE requirements for ERT duties.

18. ERT members are equipped with BA, which requires face fit testing under COSHH. Wearers of BA for ERT consist of a dedicated and specifically trained core workforce who will be aware of their specific duties and responsibilities.

Action – Emergency response teams

19. Dutyholders should ensure face fit testing of ERT as required by COSHH.

20. A clean shaven policy should be put in place for all ERT members. The dutyholder should ensure that this policy is routinely managed and enforced across all offshore assets.

21. ERT should be provided with suitable information, instruction and training for the BA that has been provided.

Relevant legal requirements

• Control of Substances Hazardous to Health Regulations 2002 (as amended)
• The Management of Health and Safety at Work Regulations 1999

References

1. The Control of Substances Hazardous to Health Regulations 2002 (as amended) Approved Code of Practice and Guidance (Sixth edition) L5
2. INDG479 (rev1) published 03/19 Guidance on respiratory protective equipment (RPE) fit testing
3. HSG53 (Fourth edition, published 2013) Respiratory protective equipment at work  

This guidance is issued by the Offshore Major Accident Regulator (OMAR). Following the guidance is not compulsory 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. Inspectors seek to secure compliance with the law and may refer to this guidance as illustrating good practice.