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Posted By lauraw
Does anyone have any advice on asking/enforcing by way of policy, employees to shave any facial hair off which is detriment to them wearing a full face mask. All our employees are face fit tested but those with facial hair usually always fail.
Is it possible to enforce a clean shaven policy on H&S grounds?
I would think if people refused on religious grounds we couldn't do much about it except stop them from carrying out the task requiring the face mask or get them to wear a hood???
Any advice much appreciated, thanks
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Posted By Bill Fisher
Laura
Why are the Respirators worn? Under what legislation?
Regards
Bill
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Posted By lauraw
Hi Bill,
They are used under COSHH, the people are working with various chemicals.
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Posted By Jeff Manion
The recommendations for face fit testing or RPE can be found in several areas: -
HSG53 selection use and maintenance of RPE
HSE 282/28 Fit testing of RPE facepieces
BS 4275 guide to implementing an effective RPE programme.
If persons presented for fitting with facial hair they should be failed / rejected.
There can be an inward leak if facial hair present.
These can affect the use of RPE - this includes hair trapped under face seal / beard growth and stubble / forward hairline / sideburns
There is available "plastic hoods" that can be used.
The advice is face hair is no good it does effect the seal.
Face fit testing is required for compliance with COSHH lead and asbestos.
Not sure on policy but if persons present are to be tested they should NOT have face hair, likewise for any use they should be clean shaven
JM
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Posted By Jez Corfield
You can make the respirators have a fitted seal by using an appropriate petroleum jelly, if they really want to have a beard and wear RPE.
Jez Corfield
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Posted By lauraw
I like the idea of using petroleum jelly, sounds a lot better than making someone have a shave! thanks for the advice
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Posted By Bill Fisher
Laura
Don' be fooled by the use of petroleum jelly, Jeff was right in his points and whilst answering your question didn't give the full picture.
HS(G) 53 states:
"Wearer-related factors
Any items worn on the head for fashion, cosmetic or religious reasons can restrict the choice of RPE (eg incompatibility with face mask head harnesses). If they cannot be eliminated, a loose-fitting hood worn over the
accessory may be acceptable, provided it gives the required level of protection.
Facial hair: Any beard, stubble, thick sideburns, long hair or moustache in the region where a face mask is intended to seal to the face will cause leakage. If this facial hair cannot be eliminated, you should consider the use of loose-fitting facepieces which do not rely on a tight seal in this region.
Facial markings: Deep cuts or scars, wrinkles, moles, warts etc can affect the seal of masks to the face. If these are present in the face seal area, consider the use of loosefitting facepieces.
Spectacles or contact lenses worn: Spectacles with side arms are incompatible with full face masks because they break the face seal.
Spectacles may also interfere with the fit of half-masks - contact lenses may be preferable. Careful consideration and additional training is needed for contact lens or spectacle wearers and those using full-face RPE (masks, hoods etc)".
If you take the "easy" route you can be sure it will come back to haunt you.
Regards
Bill
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Posted By Merv Newman
Jeff and others are correct. If a good fit cannot be garaunteed - without the use of petroleum jelly or whatever which may or not be applied correctly each day, then that person cannot be passed as suitable to wear a respirator.
Respirator wearers must be clean shaven in the area of the seal. Goatee type beards or moustaches can be acceptable so long as they do not enter into the seal area.
But again, this depends on the expected atmospheric concentrations and the protection factor of your respirators. A qualitatitive or quantitative fit test is normally required. With such and such scars or facial deformations or facial hair, could the TLV, within the repirator, be exceeded ? If the answer is yes then that person cannot wear a respirator and thus cannot work in that area.
This said, it is our responsibility to find ways of facilitating such persons to do their job. (jargon, sorry !)This could be by researching more efficient/effective protections or by implementing administrative controls ( you can only work 2 hours per shift in that area so as not to excede your 8 hr average (we can demonstrate that you will not in any case exceed the (god, i've forgotten, whats it called, the 15 minute maximum limite ?))
Look, sorry about this everyone, I'm in the north of France, after a 10 hour behavioural training session, a good dinner - apero, wine, digestive, so if I'm not totally with it. Tough. But I'm sure you know wht I mean. Innit ?
Merv
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Posted By Jeff Manion
I am not sure about the petroleum gel - it still may not seal.
I think that quantitive testing is best - qualitive testing relies on information provided by the wearer / user, who may provide a false answer as they may feel they will loose their job if the seal (qualitive) does not work.
I think you should contact the "health and safety laboratory" in Derby and have an "open discussion" with them - they are the ones who are involved with the testing - they will be able to provide the authoritive answer.
You can contact them and they will discuss and offer expert opinion - they do not need to know who you are.
JM
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Posted By Frank Hallett
Hi Laura
The majority of the respondanetshave already given you chapter & verse which you should not ignore.
The observation about Petroleum jelly should be discounted - it's not defensible nor a recognised means of achieving a suitable level of protection.
Merv - you meant the STEL - short term exposure limit. Not normally a valid reference for the wearing of RPE as you can't measure it under practical use conditions.
Laura; what is the RPE provided for - routine reduction of exposure to below the WEL[s] or for some form of Emergency Response? If it's routine, you should explore the suggestion of hoods and possibly some of the range of powered respirators. If for emergencies - it's face masks and NO facial hair that interferes with the seal of the facemask on the face.
There are situations where religious convictions must take 2nd place to other considerations and h&s is one of them.
If you need more info, drop me an email.
Frank Hallett
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Posted By steven bentham
The HSE on asbestos removal contracts have either gone for clean shaven opertives or operatives to where a hood or a Prohibition Notice.
My advice would be to look at the risk of what your trying to protect against; if its a high risk problems you should be reducing the risk by engineering means if possible.
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Posted By Richie
lauraw,
This is an employee/contract law issue. You obviously are aware of the requirement for a face fit.
My advice is to get the unions on your side (In my experience they are usually pro-safety) and place the requirement to achieve a face fit in the 'terms of reference' portion of the employees contracts.
This falls under the 'reasonable requirements' portion of contracts normally, however where there are particularly bolshy workers a specific inclusion is best. Medical / religeous reasons aside.
It's only a shave. It is not like you are requiring them to eat their own feet off!!
Richie
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Posted By Jonathan Sandler CMIOSH
Proven fact that in the Asbestos industry,some HSE Inspectors do issue improvement notice if the operative has not shaved twice, or has a stubble on his face, even if the operative has shaved in the morning!!! Speak to them, they will confirm.
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Posted By Linda Crossland-Clarke
Hi
I have mailed you direct the HSE circular - if it helps?
Regards
Linda
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Posted By Adrian Watson
Dear All,
Whilst, I agree with all that has been said about facial hair I would add firstly state that qualitative fit testing of RPE is not the bee’s knees, principally because face fit testing is in reality type testing. How many people are tested on their personal set of RPE? Secondly qualitative fit testing is not supplemented by daily qualitative fit testing.
Furthermore my experience is that the main reasons for RPE affording poor protection in practice is not the growth of facial hair but the use of RPE with loose or tight head straps which distort the seal.
Regards Adrian Watson
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Posted By Adrian Watson
Dear All,
Whilst, I agree with all that has been said about facial hair I would add that qualitative fit testing of RPE is not the bee’s knees! This is principally because face fit testing is in reality type testing; how many people are tested wearing their personal RPE?
Secondly, qualitative fit testing needs to be supplemented by daily qualitative fit testing for toxic substances, with acute affects.
Furthermore, my experience is that the main reasons for RPE affording poor protection in practice is not the growth of facial hair but the use of RPE with loose or tight head straps which distort facial seals.
Regards Adrian Watson
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Posted By Frank Hallett
Dear all
I go back to my original response to this question of several days ago.
The majority of subsequent responses have generally supported that approach; but just to reinforce:- NO vaseline; NO hair that interferes with the area of seal; NO exceptions!
Just remember what the "face-fit" test is really about.
It's all about ensuring that the exposure of the individual wearer of the RPE is maintained at or below the WEL; or if there isn't one, a defensible level. In other words, it's about demonstrating compliance with CoSHH Regs 7, 9 & 12 and intended to keep the wearer acceptably safe.
Adrians point is also well made. Any face-fit test that isn't undertaken on the actual facemask [or type of facemask] to be used is a total waste of time, effort and money.
Hair grows, and for work activities where the WEL or equivalent is extremely low and the necessary Workplace Protection Factor is high, there should be a face-fit testing regime that recognises that. The current HSE Guidance is, in this case flawed, as it requires all testees to be freshly shaven and makes no mention of what may happen to WPF after 4 - 6 hours beard growth.
All facial paramenters must be checked thouroughly; and any dental or facial surgery, or even a new set of dentures, should trigger another face-fit test.
Additionally, it must be clearly borne in mind that this test must be applied to females as well as males using exactly the same criteria.
Frank Hallett
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Posted By ANDY1967
Hi Laura,
I know all about your problem first hand. I work in the oil industry and have to enforce a clean shaven policy when dealing with potential releases of toxic gas. Employees tend to put up a fight to keep their facial hair. Most of the companies I work with have a clean shaven procedure written into their SMS. If conditions exceed set parameters, usually an OEL, the procedure kicks in. When employees sign an employment contract they are obliged to adhere to that particular companys SMS under HASAWA 1974. It has been known for disciplinary proceedings to be intiated because employees failed to follow laid down safety procedures, which have after all been developed after a thorough risk assessment process. As previously mentioned, employees required to wear RPE should be fit tested, preferably using a quantitative method (Portacount system etc), as a qualitative method relies on the wearers judgement. I've used the Potacount system to fit test, and facial hair nearly always fails the wearer in the tests.
An idea would be to supply PRE wearers with supplied air "positive pressure" breathing apparatus i.e. the pressure inside the mask is greater than that outside. If a leak occurs it's only fresh air that escapes and contaminated atmosphere cannot get in. Don't even think about using jellies or lubricants to seal a mask, it'll bring you trouble! But remember one point, PPE is the last resort for any problem. Maybe you could try substituting your hazardous substances with something more user friendly, or introduce engineering solutions such a ventilation systems to reduce the hazard and risk to employees.
Andy
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Posted By Descarte
Depending on the degree of severity exposure to the substance is (which I don think has been stated on here yet) you could maye use powered respirators, like visors but which supply a excessive quantity of air to the face area. I htink we have used ones called "Cobra" in the past. But if you are currently using BA then I would presume the risk to be quite high and this may not be a realistic option.
Good luck
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