I have identified some gaps in my organisations RPE policy. Employees were sporting beards and stubble while working in areas requiring tight fitting face pieces. This practice has been stopped and policies and procedures updated. However, some employees are refusing to ensure they are clean-shaven. Their argument is that they were not told at their interview or at induction that there is a requirement to be clean-shaven when RPE is required. If an employee cannot shave for religious reasons we supply alternative RPE. I was wondering if anyone else has faced this issue and approach was taken?

Interview or induction are irrelevant IMO. If your risk assessment for RPE specifies that colleagues must be clean shaven then that is what you should apply. The argument that they weren't told at interview or induction means that you could never review a risk assessment or update any control measures because it wasn't mentioned at induction or interview. Legally a completely indefensible point of view.

Always go with the pragmatic and common sense approach if possible. However if specific particulars are not noted on recruitment, induction etc to the employee they may be indefensible in a case thereafter as how do people know about a given thing e.g. they need to be clean shaven if they are not told about the given thing at a suitable time?

Employment /transfer etc interviews should cover the post and its needs but time and time and time again its only after a person is employed / has been offered the job or been transfered to another area do they find out critical things such as the need to be clean shaven

This is a case were production, H&S & HR should be working together but alas I feel that to get these parties working together could be a bridge too far!

You could consider face fit testing for the RPE provided to ensure suitability for purpose and use? Your policy should assist to give direction in the use and standards required in line with the RPE maunfacturers guidance. In addition the individual is responsible for their own safety to a certain degree as the PPE provided is the last line of defence?

We had an issue about 2.5 years ago, resulting in a visit from HSE. We were using RPE to control exposure to dust (about 2.5 x WEL). The inspectors observation at that time was that an operator had beard growth and that the seal (on filtering facepieces) would be unreliable at best.

We discussed 'enforcement' and we were advised that employees cannot normally be compelled to shave. Further advise in our case was that powered hood respirators would be a suitable alternative but a move towards alternative controls would be a better solution.

As with all PPE people will find excuses not to wear, either through obstinacy or for reasons like comfort. Are they just been awkward, an axe to grind or are there cases of for example sensitive skin. Was the change in policy well communicated with training / re-training? Has the case for RPE against say LEV been properly evaluated and those concerned involved?

Talk to people, if you can win some over, peer pressure can turn things around, for genuine cases alternative RPE or a side ways move may be an option?

Jon

Working in the asbestos industry our procedure is very clear. Clean shaven, minimum annual face fit test. If the guy hasn't shaved that morning they are not allowed to work until they have shaven. And the onus is on them to do that, not the Company. Different types of RPE are available for bearded people, where face shape renders fit testing unnecessary or superfluous. It sounds like your colleagues are just resisting change, that's all. Whilst this is not insurmountable, it can present a challenge. You mention a review of policy and procedure. These revised procedures must be conveyed to all staff where appropriate if they haven't already been. The argument about not being told at induction etc. should be treated with total contempt. The substances being used that merit RPE will no doubt have been COSHH assessed, these assessments will also inform the need for RPE and how it should be used correctly.
Using vaseline for people with beards is a complete no-no. You'll never get a guaranteed seal. The mask will 'float' and/ or move around. Traces of the substance may become attached to the vaseline, etc, etc.