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Tinkerbel7  
#1 Posted : 09 July 2018 09:13:20(UTC)
Rank: Forum user
Tinkerbel7

Good morning to the bank of advice here!

I have a question, one of my clients is a food production company and they are struggling with keeping a register for the issue of disposable PPE such as hairnets and earplugs.

Usually I would advise that they generally keep an issue register of who has been issued what and/or make use of a vending machine with fobs for the larger companies etc.  In my experience this helps protect companies where employees may make a claim and then say they were never issued with the correct PPE etc.

Can someone clarify the requirement for me please?  Is there a requirement to have a PPE issue register (I couldn't find it) or is it just to protect.  Is it adequate to obtain signatures against training in the use, storage and maintenance of the equipment (and refreshers) and then keep records of workplace inspections that cover the use of PPE?

Your expertise is greatly welcome!

HSSnail  
#2 Posted : 09 July 2018 10:21:19(UTC)
Rank: Super forum user
HSSnail

Firstly I would not consider hair nets PPE – they are there to protect the food not the individual – unless you are looking at an entanglement issue. No need to keep a register – its just one way to monitor use of PPE supplied. Been a while since I worked in a large food factory, but in the past I have seen  ear plug dispensers at the entrance to a work room, and staff and visitors just helped themselves as needed.

Hsquared14  
#3 Posted : 09 July 2018 11:26:02(UTC)
Rank: Super forum user
Hsquared14

There is no legal requirement for any sort of PPE register.  In practical terms you would want a register to keep a track of items with an expected lifespan, maintenance requirements or to comply with something like COSHH (respiratory protection for example).   There is no legal need to keep a register of disposable items and trying to do so is a logistical nightmare with no practical purpose.  So you can tell them they don't need to do it.

chris.packham  
#4 Posted : 09 July 2018 12:02:16(UTC)
Rank: Super forum user
chris.packham

I agree with the previous posting. If, for example, single-use gloves (we use this term as all gloves are 'disposable} are being worn to protect the product from the wearer then they are not PPE. They only become PPE if their purpose is to protect the wearer from the product. Of course, they can be fulfilling both purposes at the same time when they would have to be regarded as PPE and meet the appropriate standards of protection.

Chris

aud  
#5 Posted : 10 July 2018 14:31:05(UTC)
Rank: Super forum user
aud

This comes up often. The employer concern is 'but how can I prove they have been issued with gloves / goggles etc? Staff will just deny they had it if they have accident / make claim . . .'

Is it realistic to document every single pair of gloves for 100 recycling workers? As said, no.

Suggested system:

New employees issued with ALL PPE identified as necessary for the task, and can sign for this in some form. This is the baseline but obviously as time goes on . . .

Induction includes when / where / how to replace consumable items. These are accessible and simple to get - ie no formality needed. The induction framework will be documented (this is evidence).

There are toolbox talks or refreshers at intervals reminding of PPE - usually these are documented anyway.

Supervisory overview assures that PPE is worn or used properly - this aspect might need thought on how to evidence.

This adds up to a workable system, without undue beaurocracy. 

More evidence? Photos. Video the shop floor / line to show how workers are dressed in required kit & PPE. 

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