Posted By Dean Stevens

My view..................

Is that this would be classed as PPE, as PPE means Personal protective equipment, not just clothing.

You should of course eliminate the hazard first, so i'd suggest just coming out when it is dark ;o).

dean

Posted By Chris Packham
Suncream, as sold, is not PPE but is legally classified as a cosmetic.

However, if you then decide to use it as "protection" for your workforce it could be argued that you are using it as PPE.

The requirement to prove effectiveness for cosmetics is very different to that for PPE, so where would you stand in the event of a claim? Could you honestly state that you had sufficient evidence that the cream would provide adequate control (as required by COSHH)?

Having said this, suncream, as a last resort, can be useful protection, provided:
a) you choose the right one (not as simple as you might think!)
b) if is applied appropriately, i.e. in sufficient quantity and covering the exposed skin completely
c) it is replaced as and when this is necessary, depending upon sweating, contact with water or other chemicals etc.
d) you recognise its limitations. I would consider that in such a situation you would need to introduce skin health surveillance.

Note that it is useless to reapply once the time for which the cream will provide protection is up! In other words, you need to select one with the protection factor for both UVA and UVB that will be sufficient for the whole period for which protection is required.
Note also that the "factor" only applies to UVB. You need to check the "star" rating for UVA.

Incidentally, there is now an instrument that can be used to measure how a person's skin reacts to UV. By measuring their skin and then inputting data about exposure, e.g. time, season, location etc., you can get an indication of the factor needed.

Chris

Posted By Peter Leese
Of course you could look in the regs as a last resort!!

"PPE" means -

(a) any device or appliance designed to be worn or held by an individual for protection against one or more health and safety hazards: and shall also include -


(i) a unit constituted by several devices or appliances which have been integrally combined by the manufacturer for the protection of an individual against one or more potentially simultaneous risks;

(ii) a protective device or appliance combined, separably or inseparably, with personal non-protective equipment worn or held by an individual for the execution of a specific activity; and

(iii) interchangeable components which are essential to its satisfactory functioning and used exclusively for such equipment;


So the answer is no.

Posted By GT
Oh! Linda , You tempt me!

GT

Posted By Chris Packham
Bob

Given the facts in your last posting I would agree with you that you should stick to cover up. However, check that the clothing being worn does actually provide protection against UV. Not all does. For example, white, open weave, synthetic T-shirt has been shown to actually exacerbate the exposure.

Some manufacturers will actually provide a protection factor.

Chris

Posted By Dan dan
Sun block or sun cream although a form of protection,is a personal one. our skin reacts differently to each product or factor and / different tolerances, we could leave ourselves open for complaint due to Skin allergies etc. Personally I would recommend that the workforce wear sunscreen as personal added protection on their own volition (a personal choice of the product they wish to use), but the national or government consensus is to cover up

Posted By Raymond Rapp
Bob et al

Surely if a rik assessment was conducted and arising out of that sun protection was identified as a control, then it would be deemed as PPE.

Bearing in mind you cannot eliminate the hazard (Sun) and reducing the exposure with garments may not prevent all exposed skin.

Ray

Posted By Raymond Rapp
Ok Peter I will rise to the challenge.

PPE Regs 6.-(1) Before choosing any personal protective equipment...shall ensure that an assessment is made to determine whether [PPE] he intends to provide is suitable.
(a) an assessment of any risks to health and safety which have not been avoided by other means;

Furthermore Reg 2-(1) defines PPE as...protects him against one or more risks to his health or safety, and any addition or accessory designed to meet that objective.

Finally, if the above does not suffice; PPE in the form of barrier cream is often provided to prevent diseases, such as dermatitis. In effect, there is no difference between sun cream and barrier cream, provided 6.-(1)(a) has been adhered to.

Phew! I rest my case...

Ray

Posted By Peter Leese
But which paragraph below does it fit into?

"PPE" means -

(a) any device or appliance designed to be worn or held by an individual for protection against one or more health and safety hazards: and shall also include -

(i) a unit constituted by several devices or appliances which have been integrally combined by the manufacturer for the protection of an individual against one or more potentially simultaneous risks;

(ii) a protective device or appliance combined, separably or inseparably, with personal non-protective equipment worn or held by an individual for the execution of a specific activity; and

(iii) interchangeable components which are essential to its satisfactory functioning and used exclusively for such equipment;

Hopefully, it's not a challenge, I'm trying to have a discussion.

Posted By Evan Ying
i aggree with Sean Warburton's view

Posted By Lilian McCartney
Hi Folks,

another element to be added in

How about the areas that can't be covered up by clothes e.g. face, neck and 'follicly challenged heads' (being pc there)?

I suppose where hard hats required that 'covers' the head bit bu tthe neck and face are often exposed.

Lilian

Posted By Raymond Rapp
First, I think it is clear that the PPE Regs do not clarify the use of sun cream as PPE or otherwise, hence my highlighting those parts of the regs that could be construed as definitive.

Second, we should not lose a grip on reality. The posting refers to a hypothetical situation where in extreme weather conditions, a vulnerable person, after covering up, may be need to take extra care following the ubiquitous risk assessment. Simple as that.

Ray

Posted By Simon Rosser
on the HSE website: http://www.hse.gov.uk/ra...ion/nonionising/faqs.htm

is the statement

"There is no legal obligation for employers to provide suncream or sunglasses for outdoor workers. The information in HSE’s leaflets encourages employers of outdoor workers to include sun protection advice in routine health and safety training and advises workers to keep covered up during the summer months."

Following on from previous discussions with an HSE Inspector, the advice was that employers could issue it as an option for protection but could not enforce its use, as different people react differently to 'cosmetics' unless a full health assessment had been made for each individual.

Regards

Simon