ANNEXE 1: CE MARKINGS, EUROPEAN STANDARDS AND LEGISLATIVE FRAMEWORK
1 For a comprehensive exposition and clariﬁ cation on PPE Directive 89/686/EEC please refer to: Guidelines on the Application of Council Directive 89/686/EEC of 1 December 1989 on the Approximation of the Laws of the Member States Relating to Personal Protective Equipment Version(2010).
9 Compliance with a standard, while generally representing a minimum acceptable quality level, can confer unwarranted credibility and status to companies and products that are not necessarily of a good merit. An ISO certiﬁ cate, for example, is, in itself, no guarantee that a company manufactures superior quality products. It merely proves a degree of procedural compliance and this can be a misleading indicator.
9 A blind adherence to standards can mitigate against the application of common sense in situations where this is more appropriate.
9 Due to their universality, international standards can be open to interpretation since they are enacted across many states (for example, in the case of CE marking, these apply across the entire 33 member states of the European Economic Area).
9 International harmonisation results in an approximation of existing national laws and can result in a dilution of some national standards which is detrimental to overall levels of safety.
9 Users and speciﬁ ers can be lulled into a false sense of security by an over-reliance on published technical standards. The use of standards can lead to decision abrogation and accountability transfer effects due to a myopic over-reliance on the perceived safety attributes of certiﬁ ed products.
9 Compliance with standards, especially those involving inordinate amounts of paperwork or high ﬁ nancial outlays, can divert resources away from improving genuine quality and safety issues.
9 By practical necessity, standards tend to be data-driven and based on recognised test methods , i.e. laboratory tests and simulations, and do not necessarily take into adequate account the real life and in-service aspects of product usage.
9 Similarly, many standards are based on a necessarily limited amount of data and risk scenarios which reduces their applicability to all hazard situations.
Standards, therefore, supplement but are no substitute for a thorough assessment of hazards and the protective options available. All this, however, is not to downgrade the importance of standards. They are absolutely vital tools in establishing minimum safety and quality performance, of ensuring product and process consistency and repeatability, and in establishing cross-industry and cross-market compatibility. It is, however essential to be aware of their limitations and never use them as an excuse for not conducting a proper evaluation of protective garments or any other PPE.
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