TECHNICAL STANDARDS AND THEIR LIMITATIONS Standards, particularly international standards, play a vital role in ensuring that certain agreed and minimum standards of quality, interoperability and performance are adhered to. This is in order to protect both the consumer and the environment, and to facilitate the transfer of trade and technology. However, although common standards play a huge role in the speciﬁ cation of protective apparel and other safety equipment, it is not possible to select protective clothing for a given hazard situation simply by relying on industry-wide standards or certiﬁ cations.
This is partly due to the fact that there can be very wideranging quality and performance latitudes within a given Standard and these permitted margins can equate to big differences in product capabilities.
For example, there is a huge number of protective suits available commercially and although each may carry the European-wide CE mark, there are very wide ranging performance differences for products meeting the same certiﬁ cation Type . For example for the Type 5, 80% inward leakage average results must be lower than 15% of inward leakage. The same applies to the different garment Classes relating to nuclear particulate protection where the very broad performance spans of the three bands render them, at best, a very blunt instrument for evaluating the relative performance of different garments (please see Annexe 5 - Nominal Protection Factor).
From this it is easily seen that the allocation of a garment to a speciﬁ c protection type does not necessarily provide an indication that all suits of this type offer the same protection. It is also important
to understand that a CE mark in itself does not signify approval of any kind. The underlying EU legislation in the form of Directive 89/686/EEC makes these limitations abundantly clear and in its own words says that the Directive merely deﬁ nes the basic requirements to be satisﬁ ed by personal protective equipment . In other words it represents the bare minimum rather than the ideal or preferred protective standard. Such standards therefore correspond to an absolute entry level of garment performance and represent only a baseline, or starting point, for satisfactory garment selection. There are other limitations relating to standards which should also be understood. These include:
9 Standards, and international standards in particular, take a long time to develop, agree and harmonise. The requirement for lengthy consultation periods adds to the problem. The same applies to their subsequent review and revision. This means that standards tend to be quickly out of date and out of line with technological developments, modern safety criteria and the latest scientiﬁ c knowledge in the market place.
9 Although some standards may be performance- driven, as opposed to speciﬁ cation-driven, and are claimed to be ﬂ exible enough to be independent of technical progress, in practice the lowest common denominator effect of standards can serve to mitigate against innovation and creativity. Their prescriptive nature tends to force manufacturers along set paths when there may be other options and solutions that are as good, or better than those dictated by a prescriptive standard.
ANNEXE 1: CE MARKINGS, EUROPEAN STANDARDS AND LEGISLATIVE FRAMEWORK
DUTY OF CARE Employers have a Duty of Care to their employees and must take all reasonable and practicable steps to ensure the health and safety of staff in the workplace. This means that it is not sufﬁ cient to merely be in compliance with the basic health and safety legislation that is in place which might be unsuitable, inadequate or simply out of date. Employers are obligated to keep abreast with contemporary knowledge and technology and be fully conversant with potential workplace risks. Note that failure to comply with health and safety legislation can be a criminal offence and in particular, individual directors and company ofﬁ cers may have
a personal responsibility and liability under certain national laws such as the UK Health and Safety at Work etc. Act 1974.
Regulations often impose absolute obligations on employers to put speciﬁ c safety measures in place or to avoid particular hazards. As a consequence, employers are required to implement a management system for identifying and managing any exposures, or potential exposures, to risks and, in practice, this invariably means that adequate risk assessment exercises have to be carried out and documented on a periodic basis (please see Annexe 2).