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E Bromiley  
#1 Posted : 26 June 2020 15:40:04(UTC)
Rank: Forum user
E Bromiley

I am a new member and I recently arranged face fit testing for all of our employees. Getting them to shave for the test was an ordeal in itself, but as beards & stubble are fashionable, (and some are just lazy) we are finding it impossible to get them to shave every day. We reduce dust wherever possible, and have Hilti dust extraction on our tools, but Hilti still recommend respiratory protection is used. It’s just not practicable for us to buy powered respirators for our 200+ employees, and as their requirement for respiratory protection is for very short duration tasks, the likelihood of them wearing it at all times or carrying it with them is slim to none.

The Foremen can forbid those that aren’t clean shaven to work in dusty environments, drill & create dust but unless they stand there next to them all day they are going to do it. The reality is on a building site it is extremely difficult to avoid dusty areas at all times. The Foremen are quite rightly concerned with putting them to work, but it is also not reasonably practicable for us to stop so many operatives working/drilling etc. as there are so few clean shaven ones. It is in their employment contract but again we cannot just stop them all from working, we would lose a large percentage of our workforce.

I would love some guidance on how to do the right thing by the employees and the company. Any organisation or the HSE just give me the law without any other assistance as to how to enforce it 

Roundtuit  
#2 Posted : 26 June 2020 16:01:01(UTC)
Rank: Super forum user
Roundtuit

This is a long running debate use shave as a search term. Make the controls fit the employees not the employees fit the controls. Even if they arrive clean shaven part way in to a shift some can have significant stubble are you going to provide shaving facilities? Cost is no defence under the current H&S sentencing guidelines. Regarding manufacturer advice it is just that. You need to assess your use of the equipment e.g. it may be you only truly need RPE whilst emptying/cleaning the vacuum otherwise what is its point?
thanks 4 users thanked Roundtuit for this useful post.
E Bromiley on 26/06/2020(UTC), CptBeaky on 29/06/2020(UTC), E Bromiley on 26/06/2020(UTC), CptBeaky on 29/06/2020(UTC)
Roundtuit  
#3 Posted : 26 June 2020 16:01:01(UTC)
Rank: Super forum user
Roundtuit

This is a long running debate use shave as a search term. Make the controls fit the employees not the employees fit the controls. Even if they arrive clean shaven part way in to a shift some can have significant stubble are you going to provide shaving facilities? Cost is no defence under the current H&S sentencing guidelines. Regarding manufacturer advice it is just that. You need to assess your use of the equipment e.g. it may be you only truly need RPE whilst emptying/cleaning the vacuum otherwise what is its point?
thanks 4 users thanked Roundtuit for this useful post.
E Bromiley on 26/06/2020(UTC), CptBeaky on 29/06/2020(UTC), E Bromiley on 26/06/2020(UTC), CptBeaky on 29/06/2020(UTC)
E Bromiley  
#4 Posted : 26 June 2020 17:52:47(UTC)
Rank: Forum user
E Bromiley

Thank you for the advice! I definitely think that I could get the money spent on RPE that doesn’t require a face fit but I also know that the MD will walk into a site office and find them all thrown in a box. Are there any lightweight ones anyone could recommend? I also agree that the dust extraction is to a very high standard (as you rightly say, otherwise what’s the point?), but they all have that little caveat in their guidance/user manual still recommending the use of RPE. You are the first person who has given me a proper answer, thank you!
peter gotch  
#5 Posted : 26 June 2020 18:28:55(UTC)
Rank: Super forum user
peter gotch

Emm, you might need to consider whether extraction is the only control measure to use. As example, it might be better to suppress dust with water for some operations.

Once you have your high level control measures in place, then at the end of the day if you cannot find data for airborne dust levels for a comparable scenario, you might need to look at monitoring to look at what the actual enviromental and personal dust levels exist with the controls in place.

Then compare with Occupational Exposure Levels to decide whether you also need RPE for any or all activities. Slight variance if the dust is designated as carcinogenic but still subject to reasonable practicability if you are using e.g. COSHH as your legislative guide.

Might find that you only need RPE for a limited number of people - then powered respirators might become a much easier sell, and thence avoid a debate about if and when to resort to disciplinary measures for those who choose not to shave or who grow sufficient stubble during the day to make the face fit no longer effective (which might be most of those involved - then presenting you with a new challenge - how to get people to shave during their shift!).

Many of the Workplace Exposure Limits may be for 8 hours without any 15 minute excursion level. So for short duration exposure you might be within the WELs anyway. Of course, in contrast if people are working more than 8 hours, the overall levels will be higher, when evaluated against an 8 hour standard.

thanks 2 users thanked peter gotch for this useful post.
E Bromiley on 26/06/2020(UTC), CptBeaky on 29/06/2020(UTC)
E Bromiley  
#6 Posted : 26 June 2020 18:38:44(UTC)
Rank: Forum user
E Bromiley

Thank you so much Peter, that’s a great help too - I knew this membership was a good idea :)
John Murray  
#7 Posted : 26 June 2020 18:49:26(UTC)
Rank: Forum user
John Murray

65:

"For example, it is recommended that continuous wear time for tight-fitting (unpowered) RPE is less than an hour, after which the wearer should take a break. Otherwise, the RPE can become uncomfortable to wear, leading to loosening or removal of the mask in the work area. In these situations, where RPE is required to be worn continuously for long periods, powered respirators or airline BA, for example a loose-fitting facepiece such as a hood or helmet, are better options"

https://www.hse.gov.uk/pUbns/priced/hsg53.pdf

John Murray  
#8 Posted : 26 June 2020 18:54:27(UTC)
Rank: Forum user
John Murray

http://forum.iosh.co.uk/posts/m741367-RPE--Beards-and-Discrimination---Freedom-of-Expression

thanks 1 user thanked John Murray for this useful post.
E Bromiley on 26/06/2020(UTC)
E Bromiley  
#9 Posted : 26 June 2020 19:57:54(UTC)
Rank: Forum user
E Bromiley

That thread is interesting reading. It makes me feel a bit like Coronavirus theory, there’s a lot of information, as well as opinion, and really probably no one knows for certain! Our men do have it in their employment contract from 2016 onwards and it is the younger blokes mainly. I’ll have to check out powered hood option. The guys are doing short term drilling etc. so really unless they could hang it around their neck or tool belt, I’m not sure it will get worn. This is the other point, I’m not even so much worried about the cost, as someone said in that other conversation link - it’s not my money. But if they don’t wear it they don’t get protected. I thought the idea of them contributing was interesting. We offer free boots to a certain amount, or they can buy their own with a rebate to the same amount
Roundtuit  
#10 Posted : 26 June 2020 20:03:48(UTC)
Rank: Super forum user
Roundtuit

Be very wary of attempting charges for PPE a "reasonable" range should be available free of charge.

Roundtuit  
#11 Posted : 26 June 2020 20:03:48(UTC)
Rank: Super forum user
Roundtuit

Be very wary of attempting charges for PPE a "reasonable" range should be available free of charge.

peter gotch  
#12 Posted : 27 June 2020 10:54:02(UTC)
Rank: Super forum user
peter gotch

Emm - you don't have to be a member of IOSH to visit these Public Forums. It is something that IOSH does as a charity (at least for now) and is free at the point of use.

Members of IOSH also have access to the Members' Forums.

P

Ebullient  
#13 Posted : 27 June 2020 11:21:06(UTC)
Rank: New forum user
Ebullient

I agree with Roundtuit, make the controls fit the employees not the employees.

stevedm  
#14 Posted : 28 June 2020 06:05:36(UTC)
Rank: Super forum user
stevedm

Originally Posted by: emm.plant@me.com Go to Quoted Post
That thread is interesting reading. It makes me feel a bit like Coronavirus theory, there’s a lot of information, as well as opinion, and really probably no one knows for certain! Our men do have it in their employment contract from 2016 onwards and it is the younger blokes mainly. I’ll have to check out powered hood option. The guys are doing short term drilling etc. so really unless they could hang it around their neck or tool belt, I’m not sure it will get worn. This is the other point, I’m not even so much worried about the cost, as someone said in that other conversation link - it’s not my money. But if they don’t wear it they don’t get protected. I thought the idea of them contributing was interesting. We offer free boots to a certain amount, or they can buy their own with a rebate to the same amount
You need to take out the fact that this is about COVID 19 the measures and controls that you would use still have the same rules and requirements as they did before....there are a lot of known knows here but there are some unknown unknowns :).
John Murray  
#15 Posted : 28 June 2020 10:29:09(UTC)
Rank: Forum user
John Murray

Nothing like CV theory. In respiratory protection everything you need to know is readily available. The protection you need to provide/they need to wear for what they are exposed to and for how long they are exposed to it is easily available, at a cost. If an employee has a beard and won't shave it off, you may have to either remove the employee from that job *or* provide RPE that fits the employee and provides the protection. As always, it comes down to cost. And convenience.I'm not even going to go into the cost to the employee being nil, because in the real world the cost comes out of profit and wage rises will be lower.

You'll end up like a dog chasing its tail.

As always: Provide the RPE to fit the person, don't try to make the person fit the RPE. Nobody will shave several times a day, and those with beards won't shave them off.

Originally Posted by: emm.plant@me.com Go to Quoted Post
That thread is interesting reading. It makes me feel a bit like Coronavirus theory, there’s a lot of information, as well as opinion, and really probably no one knows for certain! Our men do have it in their employment contract from 2016 onwards and it is the younger blokes mainly. I’ll have to check out powered hood option. The guys are doing short term drilling etc. so really unless they could hang it around their neck or tool belt, I’m not sure it will get worn. This is the other point, I’m not even so much worried about the cost, as someone said in that other conversation link - it’s not my money. But if they don’t wear it they don’t get protected. I thought the idea of them contributing was interesting. We offer free boots to a certain amount, or they can buy their own with a rebate to the same amount

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