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Posted By dave marshall
I have carried out 3 sample workplace inspections on full body safety harnesses, and restraint landyards used in cherry pickers and scissor lifts. for tracebility 89% do not have the declaration of conformity certificates or date of issue!! as many are from different manufacturers i intend to replace all, but in order to use my powers of persuasion will need the relevant breaches of PUWER or PPE regulations could anybody please offer some advice? many thanks Dave
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Posted By Dave Merchant
There isn't a "certificate of conformity" for fall arrest or restraint equipment. You're getting confused with LOLER.
If the item has a CE marking on it, and a date of manufacture (via a serial/batch code etc.) then it's legal. The CE marking is the ONLY statement of compliance required by law for PPE, and even if you asked the manufacturer for a C of C, you won't get anywhere.
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Posted By Barry D
Hi Dave
Sorry other Dave but your right in one and wrong in the other.
Some manufacturers do provide certificate of conformity, or should I say a certificate of declaration.
But as you pointed out as long as the harness/landyard has the manufacturers lable with the CE mark, date of manufacture, serial/batch No and harness complies to BSEN361
and the restraint landyard to BSEN 354/358.
To answer the first question if you have tracability e.g. the manufacturers lable, have them tested by a competent person THEN if no good dispose of them.
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Posted By Dave Merchant
Sorry back at ya, but I'm right.
A "certificate of conformity" is a specific legal document defined under LOLER, and as such does not exist for fall arrest and restraint PFPE. A "declaration", meaning some random bit of paper saying "this harness complies with ENxxx" is legally meaningless for PPE even if the manufacturer's marketing team decides to make it look all certificate-y. It carries no more weight than the text on their website, and certainly doesn't have to be kept by a user. The only possible situation where a user may receive a genuine C of C is for specialist items of LOLER lifting equipment used for example in rope access work, where there is no direct route to compliance via product standards.
Apart from the CE marking on the item itself, the only "proof of conformity" that carries legal weight is the Type Examination Certificate, and you never get access to that, as there's only one copy. It's in a safe in the office of the guy who made the harness, and it stays there. A photocopy of the TEC is of no value either - just like a photocopy of your passport won't get you through customs.
It's understandable that people get confused, as manufacturers often slip in bits of paper with misleading titles on them - plus insurers and trade bodies regularly insist users keep copies of the "C of C" because they get confused between PPE and LOLER rules on supply.
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Posted By accessoperator
Dave,
Back to your original question, without traceability you have no history. These harnesses/lanyards may well be industry rejects and been purchased second hand from a
dodgy car boot sale (unlikely)but how would you know?
What about traceability for product recall from a manufacturer? Does a manufacturer/supplier know that you are in possession of them and able to contact you? Are you able to identify which harness/lanyard they are referring to?
Personally I Like to have records that include a manufacturers/suppliers 'Declaration of Conformity'. It provides a product description, product code and serial numbers.
Useful during the life span of the harness,
lanyard and Karabiner for checking of any unauthorised modifications by users.
Kind Regards
AL Howes
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Posted By Dave Merchant
"Industry rejects"?
I assume the OP's company does not buy their PPE from a bloke in a field. This is the UK.
"product recalls"?
Since when have ANY PPE manufacturers known who owns their products? That's not how a product recall works - unless you're recalling artificial hips, nobody has the faintest clue which retailer sold which batch code, and to whom.
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Posted By accessoperator
"Industry Rejects?"
I refer to any equipment new and old, from manufacturers to users, where the equipment has been examined and deemed no longer serviceable for use.
"I assume the OP's company does not buy their PPE from a bloke in the field. This is the UK?"
To assume anything is a dangerous trait especially for someone concerned with health and safety, an often used quote: "Assumption is the mother of the screw up". As for the comment "This is the UK!" a quick search on ebay should answer that.
"Since when have any PPE manufacturers known who owns their products?"
Well that all depends on what PPE you are talking about. I will consent to disposable earplugs and such like, but then they don't come stamped with individual serial numbers.
Going back to harnesses/lanyards, if you look on many of the suppliers 'declarations of conformity' you will see they make note of to whom it has been supplied...traceability.
But then for those that see them as "a random piece of paper...made to look all cerificate-y" with no apparent use other than for discarding what would they care!
Regards
AL
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Posted By Dave Merchant
My point (which I assumed was obvious) is that you can do stupid and illegal things if you want to, but a UK company does not design H&S procedures assuming that their safety equipment is sourced illegally. Even if it was, having a D of C tells you nothing about the condition of the item. That's what inspections are for. People who think paperwork is all-important are missing the point entirely. My car has an MOT - doesn't mean it's roadworthy. It means it was, once, 8 months ago. If it drives into a tree today the little blue sticker on the windshield isn't going to stop the bleeding.
As to suppliers operating down-traceable sales - I've been working for years with PFPE and have yet to ever see that in operation. You may have a line on a shipping note saying "10x ABC1 lanyards" but it doesn't have to trace to a database of serial numbers, and the guy in stores just takes the first 10 from a shelf and stuffs them in a box.
The last major product advisory was from Petzl, and all we saw were a few notices posted to their website. Nobody knocks on your door saying "I believe you once bought a rope clamp?..."
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Posted By accessoperator
First my apologies to Dave Marshall for what must seem as a hijacking of his thread. However if the information contained within assists him in making a suitable choice that is both workable and practical for him, all is worthwhile-debate is a good thing.
Back to the other Dave's response, your right about one thing, paperwork on its own never saved a life. Though as I see it the OP's question was not about paperwork directly but about traceability.
He is showing good initiative in not assuming anything but questioning the origins and dates of issue of the harnesses and restraint lanyards that his 'company' possess. If his 'predecessor' had documented this as a matter of company policy then he 'may' not of felt the need to address the question.
A Declaration of Conformity is a good starting block for ongoing inspection records for the life span of any given equipment. I never implied that it replaced pre use checks, periodic inspection, or a thorough inspection should the equipment be involved in a suspension or other incident.
As a matter of course and to emphasis my point on product recall, I have just come of the phone from both supplier and manufacturer regarding traceability of my own companies full body harnesses and lanyards. They have both assured me that if they needed to recall the equipment on safety grounds they have the means in place to trace and inform the purchaser/owner as long as the purchaser/owner does not then in turn re-sell on without maintaining records.
When asked "does the stores guy take the first 10 from a shelf and stuff them in a box" they informed me that they operate to a strict procedure of stock rotation working to a batch number (serial number)system.
Kind Regards
AL
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