The BSIF’s Alan Murray clarifies some of the confusion regarding respiratory protective equipment face-fitting and the need for a clean-shaven policy.

In the autumn of 2019 the Health and Safety Executive (HSE) published its summary statistics for 2019 and within that we see that work-related lung disease is estimated to be linked to 12,000 deaths each year.

While there is obviously a historical element to these figures, the statistics clearly state that there are currently 18,000 cases of breathing or lung problems caused or made worse by work each year, on average over the last three years. Furthermore, the number of new cases of occupational asthma treated by chest physicians is the same as it was 10 years ago.

So while the UK is rightly regarded as an international leader in safety and health, we clearly have a problem with managing respiratory health in the workplace.

In the UK, if any employer and in this case any FIS member, has completed their risk assessment and has chosen to use Respiratory Protective Equipment (RPE) as part of their “controls” it is the law that it must be fit-tested on the wearer’s face so that it can provide the protection required to protect the individual from hazards.

The law states clearly that any RPE provided by an employer must be adequate for the hazard and suitable for the wearer. If RPE is not face-fit tested to the wearer, their health is put at risk.

But research indicates that a significant amount of the RPE in use does not offer the user the expected level of protection because it does not fit. The law states that, not only should the RPE be fit-tested but that it should be carried out only by a competent person. No competent fit-tester will test a wearer who has facial hair or stubble in the area of the mask / face seal.

Fit testing is so very important to the performance of tight-fittng RPE that the HSE has recently updated its detailed guidance on
how a fit-test must be carried out. The Fit2Fit organisation, at the same time, published companion guidance on the three most
commonly offered methods.

Establishing competency
How is competency established? An individual offering face-fitting of RPE who seeks to be accredited as competent, must pass a written test on respiratory protection guidance and a specific written test on face fitting methodology before undertaking an observed practical assessment of a face-fit against the accepted HSE / Fit2Fit guidance and syllabus. This is the accepted method of evaluating the competence of an individual carrying out this vital service.

Of those who apply for accreditation, there is a failure rate approaching 30%! It is believed that in the UK there are more than 3,000 people who are offering RPE facefitting. Are they competent? The number of accredited competent individuals at the end of
2019 was approximately 370, so it is vital that the employer discharges their responsibility in managing a respiratory protection policy by ensuring they demand evidence of competency.

FIS members should visit www.fit2fit.org where they will be able to contact and source an accredited fit-tester. The issue of using RPE and the need to be clean shaven is a topic that alarmingly still comes up, with many employers apparently struggling to effectively manage a clean-shaven policy. It is often stated that employers find it is very difficult to apply.

I am afraid that it is not an option for an employer to allow staff to wear tight-fitting masks and ignore the clean-shaven requirement. The employer would be failing to manage their respiratory protection policy. If an employee refuses to shave, then they cannot be deployed in an area where tight-fitting RPE is used to control exposure.

It absolutely needs to be understood that if tight fitting Respiratory Protective Equipment is being used by workers then they also need to be clean shaven. It is the law and it is consistently referred to in the HSE guidance. Tight-fitting masks rely on an effective seal between the mask and the skin. If an individual has stubble or facial hair in the area of the seal, then the seal is not effective and protection will be compromised and the wearer could be exposed to the hazard.

COSHH states very clearly that a user must be clean shaven, see page 41 of COSHH. Published in 2015 as HSE Research Report 1052 “The effect of wearer stubble on the protection given by Filtering Facepieces Class 3 (FFP3) and Half Masks” concluded that the clean-shaven guidance was indeed justified to ensure effective protection. The full research report can be found via this link https://www.hse.gov.uk/research/rrhtm/rr1052

Is there another option?
Yes, indeed there is. FIS members can provide loose-fitting headtops, normally with powered air drawn through a filter system to deliver clean, filtered air to the user. These systems do not rely on a seal to the skin. The systems are widely available and provide an ideal alternative to tight fitting masks. The unit costs for some, can be a barrier, but there is ample evidence that they
provide a beneficial cost in alternative over time. By going this way, the problem of a cleanshaven policy goes away.

But please be clear: Tight-fitting masks are being utilised to protect from a hazard therefore the wearer must be clean shaven in the area of the seal.

The Fit2Fit Scheme administered by the British Safety Industry Federation (BSIF) and supported actively by the Health and Safety Executive (HSE) has a very clear mission: To improve the respiratory health of those wearing tight-fitting RPE through being fit-tested by a Fit2Fit accredited provider.

At a glance:
1. Respiratory Protective Equipment (RPE) must always be properly fit-tested.
2. A clean-shaven policy when using RPE is required by law.
3. Always use an accredited RPE face-fitter – be sure to check credentials.
4. Loose headtops with filters are an alternative.
5. 12,000 deaths are caused by work-related lung disease each year in the UK.

FIND OUT MORE
For more information on RPE Fit Testing and Facial Hair please see the frequently asked questions on www.fit2fit.org/faqs/