If you ensure that edges are suitably 'sealed' (e.g. gloves, overshoes, elasticated hoods fitted around RPE) you should be able to control ingress of dust, in which case the main source of contamination of inner clothing would be from doffing the PPE. A common technique is to wipe everything down with moist wipes (usually a 2 person job) before removing anything.

Sealed impermeable overalls can get very sweaty - if you do need to do this it's usually much more comfortable to weared powered air respirators, and the hood options are good for keeping dust off the head and face.

If it's long, physical work, your idea of supplied underclothes, with suitable changing facilities and a laundry service that can deal with light contamination (commercial launderers do offer this), may be a better option.

Hi Paulina

Whilst I don't disagree with the answers already given, I do wonder what this hazardous material is and whether PPE as part of the solution to control exposure should be essential.

There might be some materials where the HSE party line would be technical control AND PPE as even if exposure might be at levels below any relevant Occupational Exposure Standard the hazardous component might be designated eg..carcinogenic, asthmagenic or similar such that additional requirements are incorporated into COSHH.

But all too often employers default to PPE when they should be doing a bit more to avoid the need for PPE.

So, it might help if you explain what this process involves, e.g. contamination of some other material and beyond its surface?

As this is described as a sanding/buffing process I would think investigating the on-tool extraction capabilities would be a first course of action.

If its hand sanding there are also lots of dust extraction options.

Getting the extraction right will massively reduce or even eliminate the amount of dust getting in the coveralls at all

I would question the use of disposable garments the "need" is to control the particulates being generated.

When I see the words sanding & buffing it conjours an image of abrasive paper wrapped around a block or a powered variant without on-tool extraction the operator sat in plumes of dust from their own creation.

Would the process lend itself to being fully automated and capable of enclosure?

Could the task be undertaken with dust supression e.g. water curtain?

As to site laundering IF the dust is harmful is it really fair to send this in wash water to the local effluent treatment works where it could potentially dry from solution and become airborne?

Does your site have permission for trade effluent discharge?

You would of course need a commercial machine as it is highy likley any domestic appliance would suffer frequent breakdown from the contaminants being removed.

Originally Posted by: Elfin_Safety

On that note I have found with our local inspector that in the case of asthmagens, mutagens, carcinogens (including wood and stone dust) the HSE do expect to see respiratory protection in use, regardless of the level of control by other means that you can demonstrate.

Well its 8 years since i stopped being an inspector so some things have changed, for mutagens and carcinogens the standard of control is much higher, but for asthmagens we would have been fine without PPE if LEV was in place

It is still not clear where this process is taking place. If this is some sort of manufacturing process then an LEV based approach is an absolute must. If it is  off site then relying on PPE MIGHT be acceptable  depending on the nature of the risk. But really it should be right at the bottom of the hierarchy of control.

One of the weaknesses of PPE when it is used as the sole control for an airborne hazardous substance is it’s use must be very carefully managed.

• All users must be trained
• It must be fitted to individual users
• They must have a place of store it, so it does not get contaminated, particularly the RPE.
• if as (apparently in this case) it routinely contaminated you need a system for either decontaminating  it or safely disposing of it after each use.
• As the poster says, you cannot in these circumstances wear your normal clothes under the PPE. You need something that can either decontaminated or disposed of.
• You might need provision to shower out after using the PPE
• Decontaminated  is not easy and you must be able to demonstrate that it is actually working

Overall (no pun intended) I you use PPE like this correctly it becomes an extremely complicated(and costly) exercise, which is why you want to avoid it i possible. Using PPE properly  is not the easy and cheap solution people think it might be.  

AK - this former Inspector left HSE before the tweaks to COSHH following a couple of EC Directives.

However, when I was with HSE our focus was on controls that minimised the need for PPE, mostly for the simple reason of all the things that go with the PPE if it is to be in any way effective.

We called it the "hierarchy of control".

Europe codified that and gave it a new title - the General Principles of Prevention.

For some strange reason, HSE now seems to be wanting all the technical controls but also lots of PPE - but HSE doesn't have to manage all the problems that come with said PPE.

Elfin - not going to disagree. Whilst I am in favour of the content of Section 40 of the Health and Safety at Work etc Act 1974 with its "reverse burden of proof", I think that one of the unintened consequences has been that HSE Inspectors now tend to lack the discipline to anticipate and rebut the defences that can be reasonably expected to put to enforcement action whether by prosecution, notice of the newish FFI.

I guess that this is probably partly a result of the repeated cuts to front line resources in HSE (and other regulators), though sometimes it might be a reflection that some HSE Inspectors simply don't take the time to help the next generation develop.

HSE seems to have moved to a point where they come up with a scenario, such as cutting wood or welding, do some monitoring of real live conditions in one or two workplaces and then think that these are representative of any other workplace exhibiing similar processes.

However, if we take wood dust, whether hard or soft, a huge amount of the research that is quoted was done literally decades ago. Lots of studies in High Wycombe at a time when that town was famous for furniture making. But IKEA (and others) came along and almost eliminated the furniture industry in High Wycombe. 

To suggest that what was found in studies in olden times is in any way representative of what happens in a modern UK factory-  processing, usually soft, wood with modern LEV etc is nonsensical.

To try and then take such evidence and suggest that it is relevant to the portable saw bench on a construciton site is even more ludicrous.

Why does someone use a portable saw on a construction site. More often than not to cut a length of e.g. skirting board to the right length.

If HSE enforced the duties placed on front end CDM duty holders, most of this cutting on site could be eliminated.

So, the architect designs a building with, generally rectangular rooms. It is not rocket science to work out how long the skirting boards need to be. So have them cut to size with the corners precut in the controlled environment of a factory setting and deliver to site?

Why does this not happen?

1. The industry is way behind the times in terms of "Modern Methods of Construction" including off site construction.

2. HSE hardly ever focuses on the front end CDM duty holders. The enforcement statistics can be seen.

A few days ago, I checked the number of Notices served on Designers and Principal Designers citing Regulations 9 and/or 11 a few days ago, noting that more often that not any Notice will cite more than one alleged breach.

5 years data, possibly slightly undercounting due to the level of miscoding on the HSE Notices database (roughly 25% of the data I looked at!).

Regulation 9..........

Wait for it.........

Cited just FIVE times, including twice on the same Notice.

So, FOUR Designer recipients in FIVE years.

Regulation 11.......

Wait for it......

Cited just FOUR times, in FIVE years.

However the on site joinery sub-contractor is an easy target.

Some HSE internal instruction says that the expected standard is LEV + RPE.

So, no RPE = enforcement notice.

...and as you say few small subbies are going to say "NO".

Section 40 means that the onus is on this David to take on the Goliath that is HSE and prove "on the balance of evidence" that the Inspector's opinion that No RPE = breach of COSHH is wrong.

How can they do this?

The commission expensive monitoring to conclude that the level of environmental wood dust in the joiner's breathing zone is X fraction of the occupational exposure limit.

Somebody then works out how much exposure has per 8 hour day, to demonstrate that the actual 8 hour exposure and/or 15 minute short term "excursion" is a fraction of X.

Then puts the case to an Industrial Tribunal that the RISK is so low that the provision of RPE and ALL that goes with it is NOT reasonably practicable.

HSE go to the Industrial Tribunal and says "Our policy is LEV and RPE".

The lay people on the Tribunal then have to be brave to conclude that HSE has not adequately defended its position on the basis of risk-based evidence and throw out the Notice. 

Reported due to link added to copy of original post.

PD and thunderchild.

I have absolutely no intention of clicking on that link to find out what "pinkgame" might be.

Rather doubt that it takes you to a supplier of pink hi-vis, which could be a topic for a separate thread.