Rank: Forum user 
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"Facial hair – stubble and beards – make it impossible to get a good seal of the mask to the face." is a quote from the HSE website
http://www.hse.gov.uk/re...t/fit-testing-basics.htm
How do you make sure that where items such as FFP3 are needed to be worn that employees are 'clean shaven' as stipulated, in a round-about way by the HSE in the quote?
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Rank: Super forum user 
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............using an old fashioned concept called discipline
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walker wrote:............using an old fashioned concept called discipline
Being ex-Navy I love a bit of discipline, but how do you go about it?
Do you line the employees up and have a 'duty watch muster'? This is a bit hard for my scenario as I could have 30 engineers in 30 locations all over the country!
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Explain to them all that the RPE is used to keep out harmful gases and vapours and if they are not clean shaven they could become extremely ill or they could die.
Make sure their wives/partners have all life insurance fully paid up as well.
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Rank: Super forum user
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I have nearer 300 all around the UK
Simple really - they know tomorrow's job might require RPE if they turn up unfit, they don't work.
Which means they can kiss goodbye to their bonus.
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FireSafety101 wrote:Explain to them all that the RPE is used to keep out harmful gases and vapours and if they are not clean shaven they could become extremely ill or they could die.
Make sure their wives/partners have all life insurance fully paid up as well.
We avoid employing people who are too thick to work that out for themselves
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We have just gone the next stop where I work and do not allow FFP3 masks to be worn and now require half masks with disposable filters as a minimum.
We have and are struggling with getting operatives to shave so we have looked at shaving points on site and so you are either clean shaven to come to work, get shaven or you do not work.
We have also looked at some operatives who work in a team taking it in turns to do the cutting or job that requires wearing a half mask.
what happened to turning up to work ready for the day anyway?
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walker wrote:FireSafety101 wrote:Explain to them all that the RPE is used to keep out harmful gases and vapours and if they are not clean shaven they could become extremely ill or they could die.
Make sure their wives/partners have all life insurance fully paid up as well.
We avoid employing people who are too thick to work that out for themselves
First of all the RPE we use if for particulates (no gas or vapours) hence FFP3 as stated.
Secondly our employees are not at all thick and will use the said masks in accordance with their training.
I was just looking for ideas or best practice etc in light of the HSE statement (which implies that any facial hair growth renders RPE masks US). The number of 300 employees was stated in a post, were these 300 'clean shaven' this morning?
Discipline is great but I was taught that it is well done the hierarchy of control measures to be implemented!
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Sean Brill wrote:We have just gone the next stop where I work and do not allow FFP3 masks to be worn and now require half masks with disposable filters as a minimum.
We have and are struggling with getting operatives to shave so we have looked at shaving points on site and so you are either clean shaven to come to work, get shaven or you do not work.
We have also looked at some operatives who work in a team taking it in turns to do the cutting or job that requires wearing a half mask.
what happened to turning up to work ready for the day anyway?
Does somebody check every individual, every day? Is this policy strictly enforced? Have you a written policy I could have a look at please?
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Yes we have a procedure but its just a simple reminder of what the regs require.
Yes there is tight supervision.
As Sean says, what happened to turning up to work ready for the day anyway?
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Not easy, I had to lose my beard when I took my current role for that reason.
But it does, obviously, come down to management. It's part of the management of health and safety that you need to do your face fits, but if guys aren't clean shaven the face fit is invalid.
Is it worth reminding guys that, in the event that they developed work related ill health related to the efficacy of RPE, they may struggle to make a claim for damages if they haven't complied with the companies requirements with regards to shaving. Obviously there is an obligation on you/the company to audit the compliance with these arrangement and to ensure that any non compliance is captured, and put right and repeat offenders are dealt with in an appropriate fashion.
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Where ever we can, we use postive pressure RPE.
The lads (and lasses) are more likely to cooperate if they know you have gone the extra mile to find the most appropriate and comfortable PPE (or RPE in this case).
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walker wrote:Yes we have a procedure but its just a simple reminder of what the regs require.
Yes there is tight supervision.
As Sean says, what happened to turning up to work ready for the day anyway?
What regs?
I cannot remember reading anything in the COSHH ACOP with regards to facial hair and RPE (I may be wrong and will look again)? If somebody can quote a specific regulation this will help me as a write a policy and liaise with our management team. I have guidance (HSE, as stated) but no specific regulation.
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walker wrote:Where ever we can, we use postive pressure RPE.
The lads (and lasses) are more likely to cooperate if they know you have gone the extra mile to find the most appropriate and comfortable PPE (or RPE in this case).
Positive pressure masks may be the way forward as I can see problems with enforcing a 'clean shaving policy'.
Another thing is that the RPE is invariably used for very short periods during a day if any. Air cubes and dust extraction on tooling reduces the risk from dust to a very low level but our clients would still expect our employees to wear suitable RPE which could be very, very expensive if positive pressure masks are to be used!
I'm thinking of getting air sampling done, but will our clients take any notice of the results if the hazards are very low?
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Colossians 1:14 wrote:The number of 300 employees was stated in a post, were these 300 'clean shaven' this morning?
Discipline is great but I was taught that it is well done the hierarchy of control measures to be implemented!
Of the 300 -the blokes who know they might need RPE will be.
I don't think the women bother ;-)
The hierachy points to other means of control
If we resort to PPE then positive pressure first if possible, because its easier & cheaper in the long run
Getting back to basics you will remember PPE is at the bottom because:
It controls residual risk
Is unreliable
Requires to be worn correctly - regs clearly state to be worn correctly you need a good seal hence clean shaven.
You say your folks are trained, if so they already know the RPE will not work unless a seal can be achieved. I'm not sure why anyone needs words from HSE to understand that.
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walker wrote:Colossians 1:14 wrote:The number of 300 employees was stated in a post, were these 300 'clean shaven' this morning?
Discipline is great but I was taught that it is well done the hierarchy of control measures to be implemented!
Of the 300 -the blokes who know they might need RPE will be.
I don't think the women bother ;-)
The hierachy points to other means of control
If we resort to PPE then positive pressure first if possible, because its easier & cheaper in the long run
Getting back to basics you will remember PPE is at the bottom because:
It controls residual risk
Is unreliable
Requires to be worn correctly - regs clearly state to be worn correctly you need a good seal hence clean shaven.
You say your folks are trained, if so they already know the RPE will not work unless a seal can be achieved. I'm not sure why anyone needs words from HSE to understand that.
I think the problem for me is that the HSE or guidance hasn't been as prescriptive as the statement posted is with regards to facial hair being now a definite 'No No'. This may be on the back of the research report recently published, I don't know?
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Air sampling will be meaningless unless every job is identical and under identical conditions.
And then you need to convince your client.
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walker wrote:Air sampling will be meaningless unless every job is identical and under identical conditions.
And then you need to convince your client.
I would make sure the scenario is worse case i.e. time on tools, small room etc
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Colossians 1:14 wrote:walker wrote:Colossians 1:14 wrote:The number of 300 employees was stated in a post, were these 300 'clean shaven' this morning?
Discipline is great but I was taught that it is well done the hierarchy of control measures to be implemented!
Of the 300 -the blokes who know they might need RPE will be.
I don't think the women bother ;-)
The hierachy points to other means of control
If we resort to PPE then positive pressure first if possible, because its easier & cheaper in the long run
Getting back to basics you will remember PPE is at the bottom because:
It controls residual risk
Is unreliable
Requires to be worn correctly - regs clearly state to be worn correctly you need a good seal hence clean shaven.
You say your folks are trained, if so they already know the RPE will not work unless a seal can be achieved. I'm not sure why anyone needs words from HSE to understand that.
I think the problem for me is that the HSE or guidance hasn't been as prescriptive as the statement posted is with regards to facial hair being now a definite 'No No'. This may be on the back of the research report recently published, I don't know?
I have just got a copy of HSG53 from 2013 out and it seems today is a good learning day for me. It seems my perception of 'facial hair' not being prescriptive is flawed. It clearly states that wearers of RPE must be clean shaven. I wont forget this now!!!
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Rank: Super forum user
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This is how I view it:
PPE/COSHH regs say face fit training is required when using RPE.
All face fit training (often wrongly referred to as FF testing) I have seen, stresses the need to get a seal AND stresses it can't be achieved unless you are clean shaven.
Therefore you need to be clean shaven to wear RPE that requires a seal.
If you attempt to wear RPE whilst stubbly or worst, you are ignoring your training.
Which puts your health at risk (important) and breaches section 7 of HSWA (less important)
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Rank: Super forum user
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Great!
Its a common error to miss that, so you are not alone also FF training is poorly understood in my experience.
I had a similar discussion with a senior person working for a client only last week.
One for your CPD methinks
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walker wrote:This is how I view it:
PPE/COSHH regs say face fit training is required when using RPE.
All face fit training (often wrongly referred to as FF testing) I have seen, stresses the need to get a seal AND stresses it can't be achieved unless you are clean shaven.
Therefore you need to be clean shaven to wear RPE that requires a seal.
If you attempt to wear RPE whilst stubbly or worst, you are ignoring your training.
Which puts your health at risk (important) and breaches section 7 of HSWA (less important)
You are correct Walker. I've got a meeting with management planned for tomorrow to clarify the issues and apologise for being a numpty!!!!
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You can't be expected to know everything.
There is not a week goes by where I don't learn something on this forum
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walker wrote:You can't be expected to know everything.
There is not a week goes by where I don't learn something on this forum
That's very true Walker!
I really do appreciate this board and the wealth of knowledge that posters bring to the discussions.
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Also, the ACoP to Regulation 7 of COSHH includes the following extract:-
".........the proper training and supervision of employees in its use. This will include wearers being clean-shaven in the area of the face seal when using tight-fitting RPE"
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There is a very good research document out on the HSE website that covers this. I have similar issues but read the document. It does have some good items of fact.
RR1052 The effect of wearer stubble on the protection given by filtering facepieces class 3 (FFP3) and half masks.
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I was a fireman for 25 years and our policy was clean shaven when on duty.
Wearing a BA face mask requires a good seal and even positive pressure BA is more crucial to be clean shaven as any air leaking out reduces the duration of the set.
Cannot afford the air to run out early as could be life threatening.
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FireSafety101 wrote:I was a fireman for 25 years and our policy was clean shaven when on duty.
Wearing a BA face mask requires a good seal and even positive pressure BA is more crucial to be clean shaven as any air leaking out reduces the duration of the set.
Cannot afford the air to run out early as could be life threatening.
I was a 'water wall' no 1 in a 4 man fire-fighting team in the RN. On one of my first days at sea there was a laminator fire in one of the compartments below decks. I can't remember how long the air in my BA was supposed to last (I have 20 mins in my head) but after about 5 mins my whistle went off due to my very scared, heavy breathing (I was petrified and couldn't see a thing due to smoke). They had to get a second team down to replace us as my whistle had blown so early!
A couple of weeks later we had another 'young un' put a couple of barrels of AFFF down into the engine room during a drill. The stokers loved him!
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I was an NBC Instructor in the forces, where clean shaven was the order of the day, so this topic is of great interest to me.
I have recently reviewed my company's RPE policy, including re-writing the policy and procedures, as well as procuring and supplying my operatives with half-face respirators. I have also put together and delivered a full training package, highlighting the need to create a good seal between the respirator face piece and the 'face'. Upon mentioning the need to be clean shaven, I was hit by a barrage of "it's my right to have a beard". Not to be undone, I consulted our employment law specialists and yes, it is a persons right to have a beard or moustache etc. After having thought about this for a while, I re-worded my policy to say that "while it is recognised that a person has a right to grow facial hair, facial hair is to be such, that it doesn't prevent an effective seal from being formed between the respirator and the face". This was acceptable wording under employment law, because you are not telling a person that they can't have facial hair, only that any facial hair that they do have, must be 'controlled'.
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Archer80088 wrote:I was an NBC Instructor in the forces, where clean shaven was the order of the day, so this topic is of great interest to me.
I have recently reviewed my company's RPE policy, including re-writing the policy and procedures, as well as procuring and supplying my operatives with half-face respirators. I have also put together and delivered a full training package, highlighting the need to create a good seal between the respirator face piece and the 'face'. Upon mentioning the need to be clean shaven, I was hit by a barrage of "it's my right to have a beard". Not to be undone, I consulted our employment law specialists and yes, it is a persons right to have a beard or moustache etc. After having thought about this for a while, I re-worded my policy to say that "while it is recognised that a person has a right to grow facial hair, facial hair is to be such, that it doesn't prevent an effective seal from being formed between the respirator and the face". This was acceptable wording under employment law, because you are not telling a person that they can't have facial hair, only that any facial hair that they do have, must be 'controlled'.
Does not H&S policies take precedent over 'employment law'? I seem to remember the guy who wouldn't wear safety boots because of psoriasis of the feet but the company policy stipulated protective footwear to be worn. The guy lost his job because H&S policy was paramount and they couldn't find him another job in a different department!
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Rank: Super forum user
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http://www.bohs.org/uplo...s/3b%20-%20N%20Grace.pdf
Looking further down the subjects list, Sikhs are back on the menu.
What are you going to do about Sikhs then, after all; hair is part of their religion.
Or will it be another fudge issue....where HR/H&S makes other "races" "religions" inferior and insists some are clean shaven......
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We have several Sikhs working for us.
Its just accepted there are some tasks they cannot be involved in, its no big deal.
So far as I'm aware no other religion have a theological problem with shaving.
Members of the awkward squad (I know my rights) have the choice of seeing the light or relinquishing their well paid jobs.
Maybe more people ought to concentrate on putting controls into place so that PPE is not an issue.
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walker wrote:We have several Sikhs working for us.
Its just accepted there are some tasks they cannot be involved in, its no big deal.
So far as I'm aware no other religion have a theological problem with shaving.
Members of the awkward squad (I know my rights) have the choice of seeing the light or relinquishing their well paid jobs.
Maybe more people ought to concentrate on putting controls into place so that PPE is not an issue.
Positive discrimination.....
Oh well, in the UK it is legal to discriminate against facial hair (unless due to religion)
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Hows this for a racist remark: I've never met a practising Sikh who was not a nice person and a good worker. Nor do I know any with a "I know my rights" chip on their shoulder.
I'm well aware I should not generalise.
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Rank: Super forum user 
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Not sure how much facial hair is a problem, but I for instance am the sort of person who can be clean shaved in the morning but have that 5 O clock shadow well before 5pm. (for those old enough -think Desperate Dan)
So do we all do our fit testing in the morning or late afternoon?
Ok some people only shave twice a week. I think Waker has it perhaps less reliance on PPE and more effort in other forms of control. Not always possible I know, but probably more than it is.
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