Can you detail why you want such a policy?

e.g. do personnel need to wear RPE as an example?

Sorry for not replying straight back as my phone keeps ringing. In terms of any RPE you need to address the basis after following a detailed hierarchy of control.

So after establishing RPE is required you should address the risk associated, this might include:

• Being appropriate for the risk(s) involved
• Being appropriate for the conditions at the place where exposure may arise
• Being appropriate for the period of time it is to be worn
• Being compatible with any other PPE or clothing requirements
• Take into account ergonomic requirements
• Take into account the health of the user
• Take into account workstation characteristics
• Fit comfortably, if necessary by means of adjustment
• Prevent or adequately control, so far as is practicable, the risk of exposure without creating overall risk
• Be designed and manufactured to an approved standard
• PPE must be supplied for the sole use of individual workers when necessary to ensure that such PPE is hygienic and free from health risks.

Certainly line managers must ensure that suitable training (including suitable refresher training), instruction and information (the extent of any information, instruction and training will vary with the risk and complexity of the RPE being used) is provided to employees and in some cases visitors?

The training should incorporate manufactures’ instructions and should in my view include:

• Why the RPE is needed
• How the RPE is to be used;
• The limitations of the RPE;
• Visual inspection to identify defects (pre-use);
• The arrangements for loss/defect reporting;
• Fitting and removing of the equipment correctly
• Testing before use; including face-fit testing and refresher training
• Cleaning and correct storage.

Above and beyond the detailed free HSE information available. HSE inspectors were issued with a FOD doc in terms of enforcement and practice of RPE, if you can’t find it PM me and I’ll sort a PDF copy for you.

Yes, creating the actual policy is not that difficult really, it depends to a degree what your company structure does and why it believes that a clean shaven policy has to be mandated?

This is why I’ve mentioned the bulleted points to see if that’s actually the case. Generally RPE & PPE policies (including clean shaven policies) are just denoting an enforcement for individuals rather than addressing the actual risk factors.

Without knowing the organisation, tasks and culture it’s hard to provide a written definition or even if they fully take into account the risks associated with such a policy. Maybe read the internal FOD HSE Inspectors documentation which provides a full detail on their expectations which may assist you and even details what enforcement they take when those expectations are not met, I think that may help you develop your clean shaven policy thats realistic for whatever tasks your undertaking. 

That’s a very valid point from another Yorkshire individual…lol

My view is that you fit the PPE to the person, not alter the person to fit the PPE. So rather than this mandated clean shaven policy you have highlighted, address the use of other RPE where this policy would not need to be enforced e.g. forced air breathing hoods are fairly cheap technology these days etc. lots of options before you mandate a policy like this.

I would also be careful about attempting to change people’s contract of employment hence the need to address certain areas of risk management first. Enforcing could, in certain circumstances, engage a process of constructive dismissal in an employment tribunal and you need to remember that the policy you mention needs to be agreed with each person if you were to make it part of their contract of employment.

As you have already noted a clean shaven policy may not be possible to enforce in certain circumstances such as where beards are worn for religious reasons, or someone has a genuine skin complaints that makes it impractical to shave every day.

In these instances you may have to revert in supplying alternative RPE that does not rely on a tight seal, which overall maybe the better option as it could be easier to enforce and monitor.

Good afternoon the IOSH community.

A quick observation, I carry out Face Fit Testing to all of the staff I represent, going off historical comments and I would like to flag this issue up.

1 The employee who requires to wear a Tight-Fitting Face Mask has passed the Face Fit Testing course

2 The employee in question is presented with a workplace situation involving exposure to Respirable Crystalline Silica(RCS).

3 The risk assessment has arrived at the conclusion that engineering controls are not practicable i.e. LEV or dust suppression, Tight-Fitting Face Mask are the only option on offer to resolute the situation.

4 The employee consults his employer’s RA which states Tight Fitting Masks will be manufactured to the relevant standard which will be provided and will be used.

5 The employee is presented with the situation that he if he does not carry out a particular task which involves generating RCS following trades will not be able to carry out their undertaking.

6 The employee in question suddenly remembers his training and the fact remains, for the Face Mask to be effective he must be clean shaven.

Does this mean all employees on site must be clean shaven daily should an unforeseeable situation arise that involves generating and exposing an employee to RCS?

I have seen many times on site that in order to permit following trades to carry out their particular tasks and to avoid further expense ,liquated damages etc. employees will crack on regardless if they are clean shaven or not contrary to S7 Health and Safety at Work Act 1974  

Morning

A few companies in the Rail Industry are going down the route of setting up a Clean Shaven policy, where by all staff on site must be clean shaven due to the possible need to wear RPE. There are exceptions to this and those are medical reasons or religion. They ahve even started putting shaving stations in place and if you have more than a days worth of growth they are requesting you shave.

Firstly I would look at avoiding entering an area that may be dust generating (for those that do not need to be there), eliminate as best you can the dust being produced etc.. The issue with FFP3 Dust Masks are that they are only suitable for use for upto an hour on the basis that after this time they become warm and sweaty and thus those using them start to remove/move them about making them less effective as seal is broken.

From what I can tell there is nothing to say that you cannot put a policy in place, however you may find it has a negative impact due to either guys not wanting to work on site or Senior Management refusing entry etc.

I am aware that this subject is about clean-shaven policy but for my tuppence worth; I visited a site in Central London a couple of months ago which, on the face of it was ultra-compliant.  Vast majority of operatives were East European though that’s the norm– London would come to a grinding halt, building wise, without them nowadays.  I spotted a worker (definitely not clean shaven) in the canteen sweeping the floor with a FFP3 NR mask.  Apparently it was in the risk assessment, the fact that about 50 people were eating in the canteen at the time was irrelevant.  Which all points to the fact that in the real world there are degrees of risk.  The vast majority of my clients’ employees are exposed to some RCS while working with drills, cutters and abrasive wheels.  They certainly do not perceive the threat to their health as being particularly high. They would also certainly object to having to be clean-shaven every day, or to wear a positive pressure system.  My solution has been to stress strongly the long-term effects of RCS to their lungs; they are aware of the dangers of asbestos, I tell them that asbestosis and silicosis are similar and they wouldn’t work with asbestos without a god fitting mask. Having accepted that they are not going to be clean-shaven then the face fit tests are nugatory.  They are only effective for that day, with that mask and for the short time that the wearers are impressed with the need to wear them properly. 

My solution has to been for my clients to supply the self-test re-useable masks such as JSP supply.  They are actually more cost effective, one PC required operatives to replace the NR masks every time one was taken off.  The re-useable ones have filters that can last up to a month before needing changing.  I train the operatives to fit the mask properly and carry out the simple self-test. That together with educating them about the long-term dangers to their health has brought much greater awareness and compliance.  My risk assessments now state that self-test masks must be worn correctly and tested before each use.  Reasonable and proportionate I think.

The user self test which comes with most half masks these days does not constitute or replace a fit test.  The manufactures literature for close fitting RPE will state clean shaven, and I wouldn't want to have to defend a PI claim years down the line for reliance on the user self test (with facial hair).

Originally Posted by: MikeSweeney

I am aware that this subject is about clean-shaven policy but for my tuppence worth; I visited a site in Central London a couple of months ago which, on the face of it was ultra-compliant.  Vast majority of operatives were East European though that’s the norm– London would come to a grinding halt, building wise, without them nowadays.  I spotted a worker (definitely not clean shaven) in the canteen sweeping the floor with a FFP3 NR mask.  Apparently it was in the risk assessment, the fact that about 50 people were eating in the canteen at the time was irrelevant.  Which all points to the fact that in the real world there are degrees of risk.  The vast majority of my clients’ employees are exposed to some RCS while working with drills, cutters and abrasive wheels.  They certainly do not perceive the threat to their health as being particularly high. They would also certainly object to having to be clean-shaven every day, or to wear a positive pressure system.  My solution has been to stress strongly the long-term effects of RCS to their lungs; they are aware of the dangers of asbestos, I tell them that asbestosis and silicosis are similar and they wouldn’t work with asbestos without a god fitting mask. Having accepted that they are not going to be clean-shaven then the face fit tests are nugatory.  They are only effective for that day, with that mask and for the short time that the wearers are impressed with the need to wear them properly. 

My solution has to been for my clients to supply the self-test re-useable masks such as JSP supply.  They are actually more cost effective, one PC required operatives to replace the NR masks every time one was taken off.  The re-useable ones have filters that can last up to a month before needing changing.  I train the operatives to fit the mask properly and carry out the simple self-test. That together with educating them about the long-term dangers to their health has brought much greater awareness and compliance.  My risk assessments now state that self-test masks must be worn correctly and tested before each use.  Reasonable and proportionate I think.

Originally Posted by: MaxPayne

The user self test which comes with most half masks these days does not constitute or replace a fit test.  The manufactures literature for close fitting RPE will state clean shaven, and I wouldn't want to have to defend a PI claim years down the line for reliance on the user self test (with facial hair).

Originally Posted by: MikeSweeney

I am aware that this subject is about clean-shaven policy but for my tuppence worth; I visited a site in Central London a couple of months ago which, on the face of it was ultra-compliant.  Vast majority of operatives were East European though that’s the norm– London would come to a grinding halt, building wise, without them nowadays.  I spotted a worker (definitely not clean shaven) in the canteen sweeping the floor with a FFP3 NR mask.  Apparently it was in the risk assessment, the fact that about 50 people were eating in the canteen at the time was irrelevant.  Which all points to the fact that in the real world there are degrees of risk.  The vast majority of my clients’ employees are exposed to some RCS while working with drills, cutters and abrasive wheels.  They certainly do not perceive the threat to their health as being particularly high. They would also certainly object to having to be clean-shaven every day, or to wear a positive pressure system.  My solution has been to stress strongly the long-term effects of RCS to their lungs; they are aware of the dangers of asbestos, I tell them that asbestosis and silicosis are similar and they wouldn’t work with asbestos without a god fitting mask. Having accepted that they are not going to be clean-shaven then the face fit tests are nugatory.  They are only effective for that day, with that mask and for the short time that the wearers are impressed with the need to wear them properly. 

My solution has to been for my clients to supply the self-test re-useable masks such as JSP supply.  They are actually more cost effective, one PC required operatives to replace the NR masks every time one was taken off.  The re-useable ones have filters that can last up to a month before needing changing.  I train the operatives to fit the mask properly and carry out the simple self-test. That together with educating them about the long-term dangers to their health has brought much greater awareness and compliance.  My risk assessments now state that self-test masks must be worn correctly and tested before each use.  Reasonable and proportionate I think.

Firstly, I again apologise for hijacking this thread though I think what I say is very germane.  In the real world, you are not going to have 100% confidence that every wearer of a face mask throughout the country on a daily basis will be clean-shaven. It is not going to happen.  You say that you wouldn’t like to defend a PI claim years down the line – well, I think any court would state that it was foreseeable that operatives would not shave every day and unless you do a daily muster as in the Armed Forces you cannot have confidence that masks will be worn totally safely.  Even clean shaven does not guarantee that the mask is worn properly. Indeed, that would require a face fit test prior to every wearing which is an obvious nonsense.  Pedantry aside, my solution is as above. You say that manufacturer’s literature states clean-shaven.  Well, JSP’s doesn’t.  The test is a pass/fail.  If the facial hair prevents a seal it will be a fail, else it’s a pass.  What can be simpler. 

And, to get back to the thread, you can now do your risk assessment and re-consider the need for a clean-shaven policy.  All the above is predicated on the substances being on the lower-risk end of the spectrum.  For more obviously dangerous substances then I too would be pedantic

We have certain areas where by die to sieving flour despite the fact we have LEVs up and working the levels are still outside the exposure limits and we suppy full face powered respirators.

Regardless of facial hair for jobs of prolongued duration (after engineering controls) these are the best option and much easier to manage than disposbale or other half mask respirators. Training is much easier, and theer is no worry of a failed fit if all pre checka nd maintenance controls are in place

I know 3m offer discounted rates and gave us a free test kit for the half masks but we only use these for lower shorter time activities and wold only issue training to those unlikely to grow facial hair and happy to be clean shaven,

They are aware during training that they must be clean shaven and no mask will be issued to anyone who is,

I think a policy on no facial hair isnt ideal as there are other options and can disgruntle the workforce, Happy to disgruntle if this has to be done as can generate buy in with knowledge  but in this case alternative options are availble and im sure these will be challenged at some point should such a policy be rolled out