cannot open link, can you explain - which face fit testing you are refering too please.

Freelance Safety,
The topic I mentioned is contained within this discussion forum and was initiated by cantona. It is placed about 5 topics under this. It debated the legal standing / requirement of PAT testing and where it applies etc....

The face fit testing (FFT) I am referring to are to both disposable and maintained items of RPE. I would like to have clarified, if FFT is a legal requirement for these types of RPE and if it is, which one and why?

I have a vague idea on what the answer is, but wanted to challenge others in the field, better versed on this matter.

Extraction from HSE Operational Circular- 1 -OC 282/28

LEGAL REQUIREMENTS
5 The Approved Codes of Practice (ACoPs) supporting the Control of Substances
Hazardous to Health Regulations 2002 (COSHH)3, the Control of Lead at Work
Regulations 2002 (CLAW)4, the Control of Asbestos Regulations 2006 (CAR)5
and the Ionising Radiation Regulations 1999 require that all reasonable steps be
taken to prevent exposure to substances hazardous to health, or where
prevention is not possible, to reduce exposure to the lowest level reasonably
practicable.
6 If, despite the use of suitable control measures (i.e. other than RPE) adequate
control of exposure cannot be achieved, employers must provide suitable RPE
(COSHH Regulations reg.7(3)(c), CLAW Regulations reg.6(3)(c), CAR
Regulations reg.11(4)). The RPE provided must reduce the exposure to a
concentration that is as low as reasonably practicable, and in any case below
any applicable exposure or control limits.
7 The ACoPS 3, 4, 5, supporting the COSHH, CLAW and CAR Regulations
recommend that the initial selection of tight-fitting facepieces should include a fit
test. This is to ensure that the selected RPE has the potential to provide
adequate protection for the wearer (L5 paragraph 150, L143 paragraph 196 and
L132 paragraph 133). The circumstances where repeat fit testing is needed are
referred to in L5 paragraph 151, L143 paragraph 197 and L132 paragraph 134.
8 The employer must have documented evidence of the characteristics of the RPE
to be used (CAR reg.7(4)(d)). Similar requirements are described in COSHH
reg.6(4)(b), and CLAW reg.5(4)(b). These requirements are there to ensure that
the RPE provided is suitable. The evidence to support the suitability will include
fit test reports for facepieces with tight-fitting face seals.
9 Fit test reports should be available for all employees who wear RPE
incorporating tight-fitting facepieces. Fit test records should be retained by the
employer. These records must be kept available for inspection on request.

Regards,

Stewart

I think this has been collectively well answered.

Tight fitting face pieces rely on a good seal with the wearers face. To ensure this, it is an ACOP requirement to carry face fit tests. I believe it is only required where a risk assessment shows that an unacceptable level of risk from exposure remains after other reasonably practicable controls have been applied.
If you refer to the Operational Circular previously mentioned (HSE OC 282/28) it states that where it can be clearly demonstrated via risk assessment that the respirator is being used for comfort rather than as an essential control measure, then face fit testing is not required.
One way to achieve this would be to confirm by monitoring that contamination remains (well) below any assigned workplace exposure limits.

Is there some confusion here as face fit testing has different levels dependant on the type of RPE used. For use with half mask qualitative face fit test can be carried out. With a full face mask (e.g. non-positive, positive) a quantitative test would be required. So if using a half mask it is no real hardship to test these and can be done as part of the users training IMHO.

Bob
Just to expand a little on my post.
The HSE Operational Circular is a document that provides guidance to inspectors on how to enforce face fit testing. If they inspect your site and find an operative wearing a tight fitting face piece they shall ask to see the face fit testing records for the operative. If you cannot provide them then the inspector is guided on that basis to issue an enforcement notice.

In order to avoid being issued with an enforcement notice your occupational health monitoring evidence must be very expansive and specific to the task being undertaken.
I have experience in working in the woodworking environment that you describe, and often tasks such as cleaning, hand routering and hand sanding produce dust that is very difficult to control by engineering controls alone.
As for the legal perspective; face fit testing is referenced in the ACoPs of several regulations and the HSE have been issued with enforcement guidance. This should speak volumes.
I have always taken the view, and it has been confirmed when talking with HSE inspectors on visits to woodworking premises, that face fit testing is a legal requirement.
If you still have doubts re read the ACoPs for the regulations in my previous post and take your chances.

Regards,

Stewart

"Therefore, by not carrying out fit-testing, how are you going to demonstrate that "equivalent or better" control has been acheived??"

By conducting monitoring surveys showing that exposures are well below the exposure limit, least we forget that PPE/RPE is a last resort!?

As he says "Previous monitoring history indicates that dust levels are well below the Workplace Exposure Limit."

Surely where it has been show that exposures are not a hazard to health in every job for every workplace you do not dictate that people have to wear RPE as well anyway. In this instance the choice to wear RPE is not to control hazardous exposures and thus a danger to health, it is however reduce exposure even further, perhaps due to minor irritation or discomfort. Would a face fit test prove this further reduction? Yes. Is it needed in this instance? I would still argue no.

Having recently attended a seminar were the HSE inspector with OH speciality was talking on this subject, she clearly stated that the HSE would take the opinion that anyone requiring to wear a facemask, should be FFT and records maintained

I'm wearing my Friday night mask!