Personal Protective Equipment Policy

1.1 Purpose

To state how the University seeks to comply with the requirements of the Personal Protective Equipment Regulation (EU) 2016/425 (a directly acting EU regulation) and the Personal Protective Equipment at Work Regulations 1992 (as amended).

1.2 Objectives

To inform staff, students and visitors to the University of the requirements that the University places on them with regard to personal protective equipment that is being used to protect individuals from a range of hazards.

2. Policy statement

The University of Dundee aims to minimise risks to staff and others affected by its activities through the implementation of appropriate controls such that personal protective equipment is only needed in circumstances where risks cannot be otherwise managed. Where personal protective equipment (PPE) is necessary, it must be effective against the risk, suitable for the wearer, inspected, cleaned, maintained and recorded according to statutory requirements and best practice.

This policy applies equally to students and visitors partaking in activities under the University’s control. Contractors working for the University are required to comply with the relevant health and safety legislation and the University will make such enquiries as it considers necessary to satisfy itself of their compliance.

3. Definition of PPE

PPE includes clothing and equipment intended to be worn or held by a person at work to protect against one or more health and safety risks to that person. It does not include uniforms or sports clothing and equipment worn in competitive sports, but it does include protective clothing or equipment worn by sports instructors in the course of their work and clothing for anyone working in adverse weather and extremes of temperature. Motorbike and bicycle helmets are also excluded.

4. Arrangements

The following arrangements will apply to the use of PPE within the University.

4.1 Risk assessment

Deans/ Directors are responsible for ensuring risk assessments are documented for any activity for which PPE has been specified. These risk assessments must apply the hierarchy of control (See HSE Management of risk when planning work) and evidence that there is no other reasonably practicable means of satisfactorily protecting people from health and safety risks. They must also specify any future proposals planned for controlling the risks by means other than PPE and the time scales for their implementation. They must also document the selection process to ensure that the PPE is effective against the risk(s) and suitable for the wearer, is inspected, cleaned, maintained and stored appropriately.

4.2 Provision

Deans/Directors are responsible for ensuring that when PPE is needed for tasks undertaken by staff that it is provided free of charge to the employee. This includes specialist eye protection and prescription protective eyewear for people who use vision-corrective eyewear. However, it should be noted that for people who only need to use eye protection infrequently or for short duration, protective eyewear that fits over regular spectacles may be adequate. In areas where chemical contamination of the eye can occur people should not wear contact lenses and instead should use eye protection that fits over their vision correcting spectacles or should be issued with prescription protective eyewear.

Students and visitors may be required to provide suitable PPE before being allowed to take part in certain activities under the University’s control and will be advised of suitable types of PPE to obtain. For example, students may be advised to provide their own laboratory coats or waterproof outer clothing and sturdy footwear for field trips. In rare circumstances where the PPE required for students or visitors is of a specialised nature, needing technical approval by the University, it will be provided by the University together with training in its appropriate use.

4.3 Management

Deans/Directors are responsible for ensuring that PPE is worn by people identified as requiring it (either through risk assessment or due to a mandatory requirement), that staff maintain and store PPE appropriately and that records of use, maintenance, testing, etc are kept as necessary. Training must be given to ensure that staff understand the need for and the use of PPE, and when to use it, together with maintenance and storage requirements. Some types of PPE require special set-up or fitting to the individual (for example, face fit testing for close fitting RPE – see section 4.5 below). Dean/Directors are responsible for ensuring that this happens. Local Rules should incorporate information on PPE and internal disciplinary procedures for non-compliance with this Safety Policy Arrangement.

Staff must co-operate by wearing/using/maintaining/storing the provided PPE as instructed and should raise any difficulties with their School/ Directorate Safety Adviser, a Union Safety Representative or their line manager.

Safety Committees should discuss any difficulties that arise and should review Local Rules, referring to Safety Services if matters cannot be resolved locally.

The University understands that specific styles or fit of PPE may be needed to be accommodate religious, cultural or other requirements. Whenever possible, such accommodations should be made. However, the PPE must function equally as well as equivalent PPE used by other people.

4.4 Mandatory use of eye protection

The University requires all people working in a situation where there is a foreseeable risk of eye injury to wear a suitable specification of protective eyewear (noting that regular vision corrective eyewear is not acceptable). Situations where this requirement applies will be determined through overarching risk assessments undertaken by safety advisers within each School/Directorate (in consultation with Safety Services if necessary) and will as a minimum include all wet scientific laboratory areas, workshops, plant rooms and individual work activities not confined to a specific location where a foreseeable risk of eye injury exists.

In the case of discrete locations, signage mandating the wearing of eye protection will be displayed at entrances and visitor eye protection will be available. In the case of individual work activities, the safe system of work for the activity will specify that eye protection must be worn by all those engaged in the activity and what appropriate steps will be taken to protect individuals not wearing eye protection.

4.5 Face fit testing of close fitting RPE

The use of RPE presents a number of technical, operational and maintenance challenges which need to be thoroughly researched before relying on human protection by this means. Safety Services must be contacted in any circumstances where it is considered necessary to use RPE for a routine activity.

Close fitting RPE (that relies on the user drawing air through filters) requires to be face fit tested for each user. Leakage around the face seal of RPE must be below a certain level to ensure that the use of that RPE is as effective as it can be within its specification. Face fit testing must be undertaken by a competent person and the results recorded. Face fit testing must be repeated whenever there is a reason to believe that the fit of the RPE may have been affected and in any event at least every three years. See the PPE handbook for further details.

Thorough instruction, training and supervision of the staff using RPE is required and records must be kept of RPE issue, inspection, cleaning, repair and maintenance, as well as a record of training.

4.6 Latex allergy

The University recognises that exposure to latex occurs through contact with many products used in normal daily activities but that users of disposable latex gloves face significant work exposure.

Therefore, the University permits the use of latex gloves only when there is a documented justification for using them. The University is committed to providing full information on latex allergy to all users of latex gloves.

Deans/Directors are responsible for ensuring that:

• Latex gloves are not used unless a written risk assessment and justification for their use has been approved by him/her
• Any latex gloves that are used must be low in protein and powder free
• A sufficient range of synthetic non-latex disposable gloves are provided suitable for the activities in the School/Support Service
• All their staff are informed of this policy and its requirements

Staff who need to use latex gloves following risk assessment must:

• Read the advice on Latex Allergy contained in the PPE handbook
• Wear gloves only when necessary
• Not use barrier creams or lotions unless they have been shown to reduce exposure to latex and maintain glove barrier protection
• Wash their hands after wearing gloves
• Be aware of the symptoms of latex allergy: skin rashes, hives, flushing, itching; nasal, eye or sinus symptoms; asthma; anaphylactic shock (possibly fatal)
• If they develop symptoms of latex allergy they should cease to use latex, and inform their supervisor and obtain an Occupational Health Service referral promptly

5. Further information

5.1 Related policies, procedures, guidelines and local protocols

• Control of Substances Hazardous to Health Policy
• Control of Substances Hazardous to Health Handbook (see Safety Services Sharepoint website)
• Personal Protective Equipment Handbook (see Safety Services Sharepoint website)

5.2 Definitions and abbreviations

COSHH – Control of Substances Hazardous to Health

PPE – Personal Protective Equipment

RPE – Respiratory Protective Equipment

Approvals and renewals