Respiratory Protective Equipment
- Appendix 1: RPE Inspection Guideline Summary
- Appendix 2: Enforcement Guidance Summary Table
- Appendix 3: Inspection Aide Memoire
- Appendix 4: Example Improvement Notice Templates
- Appendix 5: Compliance Gap Letter Template
- Appendix 6: EMM1 Sections 1-4 worked example
This guidance document provides information to support inspectors in reaching conclusions, decisions and actions on enforcement relating to respiratory protective equipment (RPE).
HSE statistics show that ill health is the biggest cause of days lost at work and deaths from workplace injury and ill health are dominated by respiratory disease, accounting for 99% of all workplace deaths. Employers often use RPE as a control measure to reduce exposure to inhaled substances. It can be used in combination with other controls, or as the main control measure itself where the tasks involved do not make other measures reasonably practicable.
An inspection should initially focus on the degree and effectiveness of other control measures eg containment systems, enclosure, LEV, dust suppression. If engineering controls are absent or ineffective, these will have to be dealt with before concentrating on RPE, other than as an interim measure. RPE should only be selected and used in the following situations:
- Where an inhalation exposure risk remains after other reasonably practicable controls have been put in place (residual risk) (eg spraying paint containing isocyanates inside a spray booth)
- While the employer is putting in place other control measures (interim measures)
- For emergency work or temporary failure of controls where other means of controls are not reasonably practicable
- For short-term or infrequent exposure, such as during maintenance work eg changing dust collection bags and filters, where other controls at the source of the exposure are not reasonably practicable
This document will assist inspectors by outlining the necessary steps in the selection process to ensure the correct type of RPE is provided by dutyholders. The RPE provided must be both 'adequate' and 'suitable'. These are key concepts in RPE provision and have the following meanings:
Adequate – RPE is right for the hazard and reduces exposure to the level required to protect the wearer's health. Employers can follow guidance in HSG53 or use the online RPE Selector Tool to determine the appropriate type of RPE and protection factor.
Suitable – RPE is right for the wearer, task and environment, such that the wearer can work freely and without additional risks due to the RPE. Wearers of RPE with tight fitting face-pieces should have a face fit test.
Use this OG, together with the other information on RPE. The links are provided in the Resources section of this document and include:
- HSG53 (4th edition), Respiratory Protective Equipment at Work, a practical guide.
- OC 282/28 Guidance document: Fit Testing of Respiratory Protective Equipment - a guide for users and testers.
- An on-line RPE selector tool.
Inspectors should take appropriate enforcement action when RPE is deemed inadequate or unsuitable and therefore not protecting the health of the wearers from the airborne hazardous substance present.
If RPE is being used to control exposures to substances which have potentially serious health consequences, then it is important to focus the inspection on ensuring the correct type of RPE has been selected (ie adequate and suitable) and that it is used and maintained correctly. As the RPE is the last line of defence in protecting the health of the workers, a breakdown in the RPE programme is likely to give rise to a risk of serious personal injury/ill health effect.
Where tight-fitting face masks are used, a facefit test should be carried out by a competent person as part of the RPE suitability assessment to ensure that there is a good face seal with each person who is required to wear RPE. This will also help to identify unsuitable facepieces which should not be used. There should be a certificate for each face fit test. The face mask should pass for each exercise carried out in the test. Quantitative facefit test certificates with a fit factor of 100,000 or more for all exercises are questionable and you should seek assistance from an Occupational Hygiene Specialist Inspector to determine the potential risk to health of the worker. See HSE OC282/28 for further information on RPE Fit Testing.
It is not possible to list all the tasks when RPE is used as a primary or secondary inhalation exposure control measure; therefore assistance should be sought from an Occupational Hygiene Specialist Inspector when there is an element of interpretation required to help with the completion of the Enforcement Management Model (EMM1) form and the decision-making process.
- There are also specific situations when regulatory inspectors should seek specialist advice from the Occupational Hygiene Specialist Group, these include:
- Emergency escape – RPE needs to be provided for safe exit from an area where hazardous substances may be released suddenly in the event of control systems failures
- Emergency rescue
- Oxygen-deficient atmospheres
The information contained in the Appendices of this document should be used as a guide to the level of enforcement required in common situations.
Appendix 1 contains a summary table with key discussion points needed to draw out necessary information on the RPE programme in place from the duty holder during an inspection
Appendix 2 contains an enforcement summary table to illustrate the appropriate enforcement action for risk scenarios identified during inspections.
Appendix 3 contains an inspection Aide Memoire for RPE, it is intended to highlight the key issues with RPE management and use and give an indication of the expected level of enforcement for each scenario.
Appendices 4 and 5 contain examples of improvement notices and letters which can be used by regulatory inspectors when they identify a gap in the employer's RPE management programme.
Appendix 6 has a worked example of the completion of sections 1-4 of the EMM1 form for a scenario which inspectors may come across during the course of their work.
The main regulations covering the provision and use of RPE are:
- The Control of Substances Hazardous to Health (COSHH) Regulations 2002 (as amended)
- The Control of Lead at Work Regulations 2002
- The Control of Asbestos Regulations 2012
- The Ionising Radiation Regulations 1999
- The Confined Spaces Regulations 1997
- Personal Protective Equipment at Work Regulations 1992 (as amended)
HSE research (research report RR798) carried out in 2010 identified a wide variation in employers' ability to implement a good RPE programme. The research determined that just less than half of the companies surveyed had significant failings that were likely to result in inadequate levels of protection to RPE wearers. The lack of training, fit testing, maintenance and proper storage has been identified in other research. Nearly all companies needed to improve their performance in relation to:
- Less reliance on the common sense of the workers.
- Knowledge of good RPE storage and maintenance.
- The need for refresher training
- Supervision/enforcement of RPE programmes.
No specific organisational requirements are required.
Assistance can be obtained from FOD specialist group's occupational hygiene sections.