How are you going to check that the equipment has not been in a situation that might have impaired its integrity? I can envisage a scene where a hard hat has been exposed to a chemical that could have done just that. Would you be confident of identifying this, considering there may be no visible indication that this has occurred? What would then be the legal situation were the helmet to fail with the next wearer?

I suspect that the cost of the inspection and cleaning would be greater than any saving on sharing equipment.

Chris

I think the use of the word 'personal' in the title of the regs is more related to the fact that the protection is personal or individual rather than collective. You might want to have a look at Reg 4 (4) and Para 23 http://www.hse.gov.uk/pubns/priced/l25.pdf The regs were amended some years ago - 2005 rings a bell and with additional emphasis on the issue of PPE on a personal basis i.e. reg 4 (4)

There are cases where I suggest that sharing some PPE is appropriate, e.g. it is common place for there to be certain PPE available for visitors to some sites, such as hi vis, helmets and safety specs.

You can get paper liners for wearing inside Hard Hats, we use these as an option for visitors (they decide if they want to wear a paper cap under the Hard hat.

As for sharing, last time I went 10 pin bowling, I have no idea how many others wore the shoes before me.

I guess with both of these scenarios, duration and an ability to isolate contact would be the deciding factor.

It is a competitive world we live in, we must be efficient to survive.

Reading between the lines; "18 offices, 600 staff and 3 SPs", would I be correct in assuming these people only need to wear PPE on an occasional basis?

I wouldn't advocate people taking off their steel toe capped boots at the end of a shift and handing them over to the oncoming shift (I'm lead to beleive this happens). But then I would think it reasonable to use a pool hi-vis jacket if I was only going to wear one once a week.

So you could say it would depend on the findings of your............

Sorry, lets not go there. ;-)

I suppose it would be ok, as long as all concerned had medicals to ensure they do not have verrucae or athletes foot...etc...etc...etc...or tuberculosis in the case of rpe....etc...etc...etc.
Or extremely poor personal hygiene......
Still, times are hard and costs are high......so I suppose transferring disease from one to the other should be seen as "sharing"

I have always taken the term Personal from the regs to refer to as personal protection for a specific individual, hygiene elements from Reg 4 etc refer to maintaining the kit hygienic for when it is used next time and provides a mechanism for cleaning the PPE/RPE - this is quite important in RPE to keep the kit good.

However we all have pooled PPE for visitors such as goggles, high viz, hard hat. I normally instruct individuals to bring their own safety boots to site or entry is refused (no if's), ditto for our contractors etc.

A lot depends on the environmental risks where they are working, and what systems you have in place for highlighting health concerns.

I would agree with our colleagues regarding sharing kit for visitors but not for permanent members, again a risk assessment with occupational health input on transferrable diseases is most useful.

The HSE have brilliant guidance on Blood Borne Viruses which may add weight to your argument as they are transferrable for all bodily excretions. One of the reports has a very useful table which simplifies the whole risk of contraction and how scenario, worth a look.

It would not be feasible to check all PPE before/after use except by the individual, which of course implies knowledge/training.

If you have a sliding scale for site work/PPE need you could apply a cost based approach

On-site up to 6 times a year – boots up to £20 / pool resource possible
On site weekly – personal issue – boots up to £40
On-site daily – personal issue – boots up to £50 etc

You have raised a really interesting topic.

PPE Reg’s, paragraph 31, and Reg’s 6 & 7 should aid your argument further.

Regards

Rick

It's a while since I read the PPE Regs. but it does require personal issue.

I always wonder why employers try to get away from their responsibilities by interpreting Regulations and occasionally throwing/deflecting their responsibility on the health and safety officer.

HSE Inspectors do not interpret so why should the employer?

Why not contact the HSE and ask them the question.

The infoline has now gone Chris :-(
I am sure people will not want to ring their local office for advice for fear (unfounded?) of a visit resulting from a simple and perhaps innocent question.

I can’t help but feel we’re going ‘circular’.

Chris, the regs do NOT require the issue of PPE on a personal basis per se. Reg 4(4) is quite clear. Both para’s 23 and 48 of the guidance also deal with this.

Leaving the old chestnut that interpretation of the law is (ultimately) a matter for the courts (which I accept that it is), to one side for a moment, I suggest that interpretation of the regs, ACoP, guidance etc is an inevitable and inherent part of our work; and that of the HSE. I don’t see that there is any possible ‘way out’ of this. If not whatever purpose does it serve for us to read the published information? Surely having read it, it follows that some degree of interpretation is an inevitable, unavoidable, inescapable part of our thought process; isn’t it? I along with most others are called upon to give their advise and/or opinion on countless issues, scenarios etc and interpretation of the law is a key consideration in that. We might not always get it right (i.e. the court may decide differently) but that doesn’t mean that we don’t interpret.

Surely the variation of views on these forums is an indication that we have interpreted things differently from others.

canopener I agree with what you say. I also interpret reguations as an integral part of my role of H&S adviser. I do it to assist the employees to work safely.

It's when the employer seeks to interpret for the employer's benefit that I do not agree.

H&S is for the employees at work, some may say different.

I was never worried about sharing the gloves or pads (we never had hats). My memory concerns a few issues.

1. Summer in Cyprus.
2. A hot day at Nicosia.
3. Cricket.
4. Sweaty bodies.
5. Sharing one of only two, er, em, er, other things........Euuuuuw.

PPE being passed between people? This is a joke yes?

This is a Health and Safety site is it not?

Anyone got a pair of bootsI can borrow for the weekend? I will wash them before I hand them back...honest but I do have a fungal infection to share with you.

Zimmy, scratching head and wondering why I got into this world!

Get real please. Stand up tall. PPE for the individual.

What does a full BA set cost? 1500 quid? If you have someone that uses it once every two years or so (during which time you'll spend even more on maintenance of it) would you really buy a dedicated set just for that individual?

As I said earlier, it depends upon what the item is, but 'pool' PPE is perfectly reasonable in some cases.

Shared PPE is acceptable subject to the sorts of issues others mention:
e.g. hygiene
is it readily available when needed
does it fit all those required to share it etc etc