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Murra1960  
#1 Posted : 22 May 2017 15:15:48(UTC)
Rank: New forum user
Murra1960

Looking for practical advice about the introduction (consultation, information, instruction, etc.,) of a clean shaven policy. Any ideas from those who may already have introduced such a policy or are presently going through the procedures.

I'm aware this can be a contentious subject and we've had issues of 'human rights' already raised. We are also aware of the religous element.

freelance safety  
#2 Posted : 22 May 2017 15:21:39(UTC)
Rank: Super forum user
freelance safety

Can you detail why you want such a policy?

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

Murra1960  
#3 Posted : 22 May 2017 15:25:07(UTC)
Rank: New forum user
Murra1960

The nature of work may require the wearing of RPE when other more suitable means of duct control cannot be employed or the use of RPE is additional to other measures.

freelance safety  
#4 Posted : 22 May 2017 16:05:56(UTC)
Rank: Super forum user
freelance safety

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.

Murra1960  
#5 Posted : 22 May 2017 16:11:33(UTC)
Rank: New forum user
Murra1960

Thank you for your reply but it's not a matter of RPE suitability but creating and implementing a 'clean shaven' policy. We already have policies and procedures for the selection and fitting (using Fit2Fit assessors) of RPE (generally FFP3 unless assessed otherwise.

freelance safety  
#6 Posted : 22 May 2017 16:26:50(UTC)
Rank: Super forum user
freelance safety

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. 

 

A Kurdziel  
#7 Posted : 22 May 2017 16:54:35(UTC)
Rank: Super forum user
A Kurdziel


I am assuming that you have assessed the risk and are sure that the only reasonably practical method of control is to wear RPE as oppose to some other form of control (LEV etc). Then the question is what your policy should say if someone refuses to shave if they need to wear RPE?

If so then you can either say that they cannot work in those areas that require negative pressure RPE or you can invest in positive pressure RPE which does not require face fit testing.


freelance safety  
#8 Posted : 22 May 2017 17:02:07(UTC)
Rank: Super forum user
freelance safety

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.

Kate  
#9 Posted : 23 May 2017 15:00:25(UTC)
Rank: Super forum user
Kate

When I discussed this very topic with our HR, they said that due to the manifold difficulties in introducing what would be a very unpopular policy, they would like me kindly to implement a technical solution instead.  So we got some powered RPE.

I'm not saying it can't be done - but consider whether it's worth all the trouble it will inevitably be.

Shopland23872  
#10 Posted : 27 May 2017 08:55:25(UTC)
Rank: Forum user
Shopland23872

As everyone has said above, you can get suitable RPE for beards, goatees etc. The introduction of a clean shaven policy could take you into the Human Rights territory, which could prove very costly if an employee decided to take it to court. It could be classed as a breach of a basic human right of expressionism. I know of one company that tried something similar with regards to stubble and the showing of tattoos. This policy was dropped as the employees solicitor stated that the employer has no right to tell a human being that they must not grow a beard and as long as the tattoos were not offensive the employer also had no right to insist that they were covered up, due to their basic human right of expressionism
johnmurray  
#11 Posted : 27 May 2017 14:55:11(UTC)
Rank: Super forum user
johnmurray

As the user has a.ready said: it is not a health or safety reason.
It a an employer clean shaven policy for staff to not have facial hair that the users employer wants to institute.
Not safety:social.

"Thank you for your reply but it's not a matter of RPE suitability but creating and implementing a 'clean shaven' policy. We already have policies and procedures for the selection and fitting "

Read and digest....
Many bearded males are proud of their facial hair...all you are going to do is create, at the best, resentment.
Of course, if you have a Sikh employee, you will be buried in litigation. If you have one apply, you cannot discriminate!
Still....
damian2701  
#12 Posted : 01 June 2017 13:30:36(UTC)
Rank: Forum user
damian2701

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  

jprictor  
#13 Posted : 01 June 2017 19:09:14(UTC)
Rank: Forum user
jprictor

Clean shaven. Open question, that I have expressed as <24hrs. this would cover shift work and is a requirement for EEBA for confined spaces for negative presure RPE including paper.

JYoung  
#14 Posted : 13 June 2017 11:21:15(UTC)
Rank: Forum user
JYoung

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.

MaxPayne  
#15 Posted : 13 June 2017 13:04:30(UTC)
Rank: Super forum user
MaxPayne

I know what we did on this subject several years back, and all I would add is that whether or not you choose a clean shaven policy or opt to deploy loose fitting RPE is dependant on a number of factors.  For us those included:

  • The size of the workforce and an options appraisal based on cost, quality, etc.
  • The environments in which staff are operating, customers homes, construction sites, manufacturing, etc. 
  • Practicality of the deployment and use of loose fitting RPE in various environements, i.e. they're bulky and may restrict users in certain situations.  The whole question of risk assessment, safe systems of work and training comes into play here.
  • Decontamination procedures
  • Compatability with other PPE
  • Image

Yes we had a lot of work at the front end, but everyone is now used to it and we don't have too many issues.  It sounds straight forward to say we'll just offer loose fitting equipment - it's not an easy option!

I expect some will disagree, which is fine; weight up the options through a robust appraisal is all I'd advise.

MikeSweeney  
#16 Posted : 14 June 2017 12:50:46(UTC)
Rank: Forum user
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 thats 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 wouldnt 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.


Invictus  
#17 Posted : 14 June 2017 13:02:51(UTC)
Rank: Super forum user
Invictus

Originally Posted by: MikeSweeney Go to Quoted Post


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 thats 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 wouldnt 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.



I love those R/A's when they can't be bothered to read it but look at the subject i.e. sweeping and just adopt it for all sweeping jobs.
MaxPayne  
#18 Posted : 15 June 2017 10:51:07(UTC)
Rank: Super forum user
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 Go to Quoted Post


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 thats 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 wouldnt 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.




johnmurray  
#19 Posted : 15 June 2017 12:53:39(UTC)
Rank: Super forum user
johnmurray

Again: This not about H&S, this is about the use of H&S as a means of instituting the social policy of no facial hair:

"Thank you for your reply but it's not a matter of RPE suitability but creating and implementing a 'clean shaven' policy. We already have policies and procedures for the selection and fitting (using Fit2Fit assessors) of RPE (generally FFP3 unless assessed otherwise"
MikeSweeney  
#20 Posted : 15 June 2017 15:50:17(UTC)
Rank: Forum user
MikeSweeney

Originally Posted by: MaxPayne Go to Quoted Post

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 Go to Quoted Post


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 thats 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 wouldnt 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


MaxPayne  
#21 Posted : 15 June 2017 21:01:48(UTC)
Rank: Super forum user
MaxPayne

Originally Posted by: MikeSweeney Go to Quoted Post
Originally Posted by: MaxPayne Go to Quoted Post

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 Go to Quoted Post


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 thats 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 wouldnt 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 did, it works, we monitor, we don't have problems, we don't have staff complaints, happy days!  But good luck with that - well it's like this your honor, I couldn't be bothered, it was all too difficult so I thought it best to ignore beards and rely on users testing themselves.  Brilliant !!!

http://www.breathefreely.org.uk/assets/rpe-fact-sheet.pdf

http://www.hse.gov.uk/research/rrpdf/rr1052.pdf

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