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GB1977  
#1 Posted : 21 November 2018 12:20:09(UTC)
Rank: Forum user
GB1977

After a bit of advice in relation to how you manage facial hair and use of RPE. If somebody refuses to be clean shaven how have you managed this/enforced the need to be clean shaven to get a good seal on the masks?

Is this something that can be enforced? I appreciate that if we don't get a pass on a face fit then they can't work in that area but the operational implications are significant as we are talking about sites that have very small staff groups without the option of transferring them onto other tasks or sites.

Any advice or help would be appreciated.

Thanks

Roundtuit  
#2 Posted : 21 November 2018 13:24:38(UTC)
Rank: Super forum user
Roundtuit

Appreciate your question is slightly differently worded to the usual RPE / Facial Hair enquiry but plenty of threads that may supply your answer, including:

http://forum.iosh.co.uk/posts/t126600-facial-hair

http://forum.iosh.co.uk/posts/t125192-Facial-hair-and-FIT

http://forum.iosh.co.uk/posts/t122830-Face-Fit-Testing-and-facial-hair

Remember you get the RPE to fit the individual not make the individual fit the RPE - there are options which do not require a tight face seal

Roundtuit  
#3 Posted : 21 November 2018 13:24:38(UTC)
Rank: Super forum user
Roundtuit

Appreciate your question is slightly differently worded to the usual RPE / Facial Hair enquiry but plenty of threads that may supply your answer, including:

http://forum.iosh.co.uk/posts/t126600-facial-hair

http://forum.iosh.co.uk/posts/t125192-Facial-hair-and-FIT

http://forum.iosh.co.uk/posts/t122830-Face-Fit-Testing-and-facial-hair

Remember you get the RPE to fit the individual not make the individual fit the RPE - there are options which do not require a tight face seal

Woolf13  
#4 Posted : 21 November 2018 13:30:44(UTC)
Rank: Forum user
Woolf13

I am presuming that even with engineering controls in place there is a requirement for wearing RPE, so there are other types of RPE you can select which can be worn without having to be clean shaven e.g. hoods etc. You could go down this route. However, this normally increases costs as the RPE tends to be more expensive.  

It is a legal requirement to wear tight fitting half and full masks for certain activities and with that comes the legal requirement in order to achieve a good seal that the wearer is clean shaven (COSHH Regulations). In these cases you should have a robust policy, procedures including risk assessment of the activities which clearly explain the requirement to be clean shaven.

Remember employees also have a duty of care to ensure they are following training instruction and utilising RPE as intended etc. to assist employers with complying with their legal duty.

If you have the odd employee who is refusing then simply they cannot do the assigned tasks safely and you should look at assigning them somewhere else. If this an issue and your orgnisational size/tasks do not allow this then they should not be working for you in those environments. Ultimately and this sounds brutal, if it is a legal requirement and your company policy to comply with the law then they have a choice plain and simple, either comply with the requirements or look elsewhere for work.

You would not tolerate them not wearing a seatbelt when driving on work business, the principle is the same.

Edited by user 21 November 2018 13:32:03(UTC)  | Reason: Typo

aud  
#5 Posted : 21 November 2018 16:23:48(UTC)
Rank: Super forum user
aud

You might find this thread on HSE Construction forum of interest. https://webcommunities.hse.gov.uk/connect.ti/construction/messageshowthread?threadid=105262

peter gotch  
#6 Posted : 21 November 2018 17:21:27(UTC)
Rank: Super forum user
peter gotch

You also need to consider whether someone who has a tight fit at the beginning of a shift will still have one a few hours later.

There was research ages ago to indicate that facial growth during a shift negated the efficacy of RPE that is dependent on that tight fit.

Which means considering an alternate type of RPE which is not reliant on passing face fit test, which then might deal with your current HR issue.

Kate  
#7 Posted : 21 November 2018 19:10:22(UTC)
Rank: Super forum user
Kate

I managed it by getting RPE that was compatible with facial hair.

Our HR were very reluctant to consider other options.

aud  
#8 Posted : 22 November 2018 09:15:28(UTC)
Rank: Super forum user
aud

I can't find any legal requirement for face fit testing per se - am I missing something? ACOPS supporting the COSHH and CAW Regulations recommend that the initial selection of tight fitting facepieces should include a fit test, and I accept that RPE - if required which surely is key - must be 'adequate / suitable' etc.

One of my bugbears is our construction clients insisting on RPE - against our own thorough RA - when a small amount of drilling creates some dust which is collected and contained as part of the SSW (think drilling a few holes in plaster). If they insist on RPE, then FFT then also comes in - but we don't think RPE is needed in the first place. Now the job becomes unviable.

Which is why I was interested to see the discussion on HSE construction forum - is there really value in FFT of RPE for 'dust' where exposure is limited to say the least? I have no argument if exposure is to a high hazard substance, or for extended lengths of time or volumes. Controversial I know.

Kate  
#9 Posted : 23 November 2018 12:47:37(UTC)
Rank: Super forum user
Kate

The ACoP doesn't just recommend, it sets the legal standard.  Unless you can meet the same standard in another way (which in this case you can't), it's required.

Of course the fit test requirement only comes into play where the RPE is actually required and isn't just a preference.

A Kurdziel  
#10 Posted : 23 November 2018 13:12:44(UTC)
Rank: Super forum user
A Kurdziel

Face fit testing is required under regulation 9 (Maintenance, Examination and Testing of Control Measures) of COSHH which requires you to prove that any control that are adopting as based on YOUR risk assessment actually works. Note that the risk assessment is YOURS not what the bloke on the site office thinks.

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