‘PPE’ - Meeting international standards

Who can hope to be safe? Who sufficiently cautious? Guard himself as he may, every moment’s an ambush.
~Horace

Mr. Nishith A Dand - Director,
Sure Safety

Abstract:

As India becomes the factory of the world, adoption of hazards makes worker’s Safety and Health very important as not only life is important but to live healthy is more important. This is besides the creation of an environment which ensures safe and healthy living. But though this is possible where the hazards are seen or visible but what about unseen hazards?

As we all know ‘PPE’ comes last in the control of hazards hierarchy, but cannot be negated, moreover when we all are trying to elevate standards of safety ‘PPE’ plays a pivotal role in addressing safety where hazards are unseen or cannot be quantified: Natural calamities, Fire Services, Military operations-warfare, Disaster Management etc. all these encounter unpredictable and unforeseen situations or emergencies where the only thing which probably works is the courage to face a situation and the preparedness to meet any eventuality and this is possible only thro use of ‘PPE’.

This is when we talk about the National Bodies which are directly or indirectly involved in the safe keep of the country but when it comes to Industries things are differently perceived and looked upon. Interestingly there has been a shift in the attitude both of employee and employer besides the statue becoming stricter and highly enforcing its commitment in ensuring safety of the stake holders at all levels.

While Safety is being brought to apex attention with different means like workers health, lower liability, higher productivity and global market participation, global risks and the new terrorism to bring international perspective to important issue of ‘PPE’ becomes inevitable hence also the standard of ‘PPE’ used gains prime importance as it is directly linked both with the Health of the asset and the productivity of the organization in every respect.

This does not end here because sourcing the right ‘PPE’ which is most suitable Technically does not solve the problem it has to be used in the correct manner, maintained and serviced only then will it ensure protection. So when we are talking about the ‘PPE’-MEETING INTERNATIONAL STANDARDS it is to be understood that we are talking about Product / Usage / maintenance/ Servicing and disposal all meeting Global perspectives to ensure all round protection and productivity.

Introduction:
Nature has given a sense of self-protection to all living beings be it Men or Animals. While Men have been given the sense of thought and innovation Animals have been provided with natural protection against Natural hazards. Since time immemorial protection used by primates whether made of leaves or animal skin from ‘Stone Age’ to the ‘Iron Age’ or the ‘Neolithic age’ where innovation with metal like Brass and Iron besides farming led to the change in the Human approach to survival and heralding the beginning of the New era in human history.

This transition continued and converged till the starting of the Industrial Revolution which was during the period between the 18th to the 19th century where major changes in agriculture, manufacturing, mining, transportation, and technology had a profound effect on the socioeconomic and cultural conditions of the times. Although large mills and workshops were established in ancient China, Rome and the Middle East, the ‘Venice Arsenal’ provides one of the first examples of a factory in the modern sense of the word. Founded in 1104 in Venice, Republic of Venice, several hundred years before the Industrial Revolution, it mass-produced ships on assembly lines using manufactured parts. And this led to the creation and identification of the Man-Made possible Hazards in any activity.

This is the story of ‘PPE’ while on one hand if we look at it, it speaks of the armour or ‘KAVACH’ worn by the Armies at War and on the other hand it is the first DRAPE or Cloth in which a new born is wrapped to shield it from any external injury on birth. This goes on through shields of the warriors to the modern ‘PPE’ of an industrial worker BUT the purpose in this unique journey remains the same and that is "Personal Protection" and needless to say this is achieved only by use of proper "PPE" or Personal Protection Equipment.
Citing another example it is seen that our Modern day cricketers are draped in full cricketing gear [Industrially PPE] and as we see the confidence in them while they just duck under the swinging ball and hook it for a six over the ropes. It is because they are well aware that they are potentially safe and can do what they want in all trying situations.
Now when we visualize the ‘PPE’ with the above examples it is quite evident that the use of ‘PPE’ enhances the confidence which is the first step in taking longer strides{Risks} and the longer the stride you take you reach faster towards your Goals which in our case is Profitability and productivity which is the need of the hour.

Clear ‘PPE’ applications are a result of organized studies like ‘PPE’ audit.
Few examples are given below for a hazard study resulting in the use of "PPE":

Area / Department	Process	Process description	Hazards	PPE used [currently]	Suggested PPE	Applicale standards & protection levels
Machine Shop Area	Machining	1] uses different types of lathes, Hazards : exposure to kerosene and manual interaction with chips dipped in kerosene	Kerosenet	Standard PPEs, cotton gloves for material movement	1] Faceshield	1]Faceshield - EN 166
					2] Neoprene apron
			Coolant		3] Respiratory Protection [based on exposure levels to kerosene] R95 is suggested for immediate	2] Gloves - Cut Level 2t
		2] drilling and honning and boring machines as well as CNC, Hazards : exposure to coolant	Chips dipped in kerosene			3] Respirator - R 95
					4] Gloves - nitrile coated safety cuff for cut and hydrocarbon implementation	4] Apron - refer specificaiton worksheet
	Special processes like liner fitting [usage of press, oven, freezer	1] heating of cylinder at 200°C Hazards : exposure to metal fumes, high level temperatures	Metal fumesMetal fumes	Standard PPEs, kevlar gloves	1] Respiratory Protection [based on exposure levels to metal fumes] - immediate implementation for provision of N95t	1] Gloves - EN Cat. 03
			High temperatures			2] Apron - Refer specification worksheet
		2] cooling of liners in freezer at -80°C Hazards : low level temperatures	Low temperatures		2] Gloves - Insulating gloves of basofile / kevlar / leather
		3] handling of cylinders and liners by cranes manually fitting, Hazards : cold burns			3] Apron - Leather apron with sleeves with insulation liner
					4] Gloves - cryogenic gloves for low temperatures
	Hydrotesting	1] hydrotesting is done through addition of 5% chemical in water Hazards : Oil mist exposure, noise	Oil mist	Standard PPEs, cut resistant gloves	1] Helium : Oxygen detector should be placed in area during job, for early detection of Oxygen depletion.	1] Hard Hat - EN 397 / IS 2925
			Helium Gas			2] Chemical resistant jacket and trouser - Fabric approval type 3
		2] usage of helium gas at 200 kg pressure. Helium is odorless and simple asphyxiant and thus, correct levels of oxygen is to be maintained, Hazards : exposure of helium gas	Material handling		2] Chemical resistant jacket and trouser
					3] Hard Hat
			hot job handling		4] Gloves - Nitrile coated safety cuff gloves
		3] handling of cylinders and heavy jobs, Hazards : cuts, bruises	Oil mist		5] Respiratory Protection [based on exposure levels to kerosene] immediate implementation for provision of R95	3] Gloves - CE / CAT II
		4] usage of overhead cranes, Hazards : maintenance of cranes
	Chemical cleaning of component	1] manual application of chemical on machine surface, Hazards : contact with chemical [Z-10 - lubricating oil]	Oil mist	Standard PPEs, brush is used during monsoon season only to apply the chemical	1] Respiratory Protection - R95	1] Glove - CAT III
			Dust		2] Gloves - Nitrile gloves 26 MILL 18"
		2] Scapping with the help of scrapper [scotch-brite], Hazards : dust exposure, brusies and cuts on hands

1. The international way of looking at the subject of ‘PPE’.

1.1 Exposure Assessment / ‘PPE’ audit:
Globally when any manufacturing facility is created the core safety hazard identification tools like exposure assessment / hazard analysis / safety audit etc. are done to understand the requirements of keeping the facility devoid of such hazards or a study is done to anticipate unseen hazards to quite an extent which may be detrimental to the workers health or day to day performance leading to loss of productivity. Normally established organizations specializing in such studies / audits are pressed into service and a clear road map is drawn to control hazards. Once a control hierarchy and priority is drawn unseen hazards are focused onto and as you know what is seen is often addressed but unseen hazards are neglected.
Example: 1
Let’s take the case of welding process normally associated with all Engineering Industries and heavy metal shops. The first thing which comes to mind during a welding operation is whether the correct eye protection is deployed as UV Rays generated during welding is seen or an apron is provided to protect the body against flying weld splinters por a hard shoe is provided to protect against heavy metal or hand protection is provided for the unforeseen but the fact is more workers suffer with Metal Fever caused due to exposure of welding fumes. This is not a priority area or even if it is addressed it is taken as alight hazard??
1.2 Selection of ‘PPE:
Once the exposure / hazard is understood a systematic and technical method is deployed to arrive at a appropriate ‘PPE’ clearly defining the purpose, standards followed in the Industry and as accepted by the statutory bodies prevalent in the country, ease of usage, maintenance procedures, safe keeping after use etc are also clearly defined besides issuance of usage instructions with clear warnings etc. are provided. In certain cases program for awareness and training in usage is also provided for the purpose. For e.g.
A respirator protection factor is a measure of the degree of protection a respirator design provides to the wearer. Thus if Protection Factor of dust mask is 10; it means it can provide protection 10 times TLV.

Example:Table for ‘PPE’ procurement specifications:

‘PPE’	Specification	Standards Quantity
Hand Gloves	Nitrile Flocklined gloves	EN – 374-1
	Size – Length – 14"
	Palm Size – 9
	Thickness – 19 mil
	Palm grip – textured

1.3 ‘PPE’ Procurement and Availability:
The ‘PPE’ to be used are very well specified as per the selection procedure with usage, safety expected and standards complied to. The recurrent and ease of availability and training are then addressed with manufacturers instructions, disclaimer, insurances and training needs are then addressed to ensure correct and 100% usage and protection of the user. Training where required are also taken care of either by internal executives well versed with systems or external trainers are employed for the purpose.

Vendor Selection: - Vendor is selected appropriately so as to supply the material with updated test reports and proper certifications like EN / NIOSH etc. . The packaging should be such that every pair is supplied in a separate poly-bag. Usage instructions and disclaimers to be clearly communicated on the package with disposal procedure clearly mentioned on them.

1.4 Usage:

‘PPE’ usages are monitored and documented to ensure the right protection is delivered. Usage training and worker awareness is regular to ensure correct and proper usage of the ‘PPE’.A fit test like drill is a very well acceptable practice while using a typical face Mask in a respiratory ‘PPE’

1.5 Maintaince And Decontamination:
Cleaning, Maintaince and upkeep of ‘PPE’ is regularly monitored and checked for possible contamination, wear and tear etc. to ensure Safety of the User and compliance with the norms. ‘PPE’ can become hazards themselves if not maintained as contaminated ‘PPE’ themselves can degenerate causing health problems.
1.6 Disposal:
‘PPE’ in themselves use many polymers and materials which need systematic disposal according to relevant environment regulations. Hence proper procedures are followed to ensure such disposals to protect the user as well as the environment.
Many international organizations participate in various subjects of ‘PPE’. Few organizations are as below:
ILO – This international body provides guide lines in every sphere of activity for the safe working practices in the Industry or any facility employing workmen. Till date it has adopted more than 40 standards of safety and more than 40 codes of practices on occupation Health and safety. Like: Occuptional Safety and Health Convention, 1981 (No. 155) - [ratifications] and its Protocol of 2002 / Promotional Framework for Occupational Safety and Health Convention, 2006 (No. 187) - [ratifications] etc to name a few
GLOBAL SAFETY ORGANISATIONS WHO HAVE ACTIVE ROLE IN ‘PPE’:
NIOSH - Task is to undertake Research and develop standards for health and Safety of Industrial workers.
EN / MSHA /ISO /HSE - are the enforcers or Guiding Bodies which help an Industrial facility maintain standards for the safety of its workforce.
ANSI /UL – are the laboratories which conduct research and come out with minimum standards as relevant to a particular segment.
2: THE INDIAN ‘PPE’ CHALLENGE
After we have understood the international way of understanding the ‘PPE’ the next step is to understand the current challenges in India and the way ‘PPE’ is largely seen and implemented.
Few of the challenges in the way are:
2.1Process:
The biggest challenge today in India is the process of establishing the hierarchy of controls. Many a times the users deploy controls without technically establishing the risk / exposures. Thus, often these ‘PPE’ over or under protect the user. The ‘PPE’ issued to workers are often considered as uncomfortable due to this challenge. It is always not the case of ‘PPE’ quality but often the case of incorrect selection due to lack of technical assessment of hazards.
Example:
Usage of filter cloth / fabrics where a qualified respirator is required.
2.2 Cost vs Price:
India is a price sensitive country and it should be like that. However it is important to understand the difference between cost and price. Price is what you pay at the point of purchase and cost is a measurement over the product life-cycle. Many a times we go wrong in understanding that we need to see overall payback considering product value, usage safety enhancement and lower maintenance cost.
Example:
Usage of PAPR against normal respirator where the protection is far greater than the cost of human life where as a normal respirator is replaced again and again and is still not fully safe.
2.3 Awareness:
"We know everything", "I have worked 20 years and nothing has ha’PPE’ned to me" "This is not my priority" – these are common feedbacks and are clear signals of low awareness and attitude. These statements also boast of overconfidence. The deficit of knowledge results in non-usage of ‘PPE’ and leads to chronic / acute occupational diseases, unsafe conditions and / or even fatalities. Awareness of ‘PPE’ is a big challenge in India as participation and balance between supply side and user side still has a long way to go.
Example:
"Kevlar gloves are replacement of asbestos gloves" – Kevlar is a brand of a fiber which belongs to the aramid family of fibers. It is cut and flame resistant but as stand alone cannot be used in high insulation. It needs additional insulating layer to resist heat.
2.4 Information & Training:
Right product may have been identified but till product usage is not properly established or the user is not educated in its benefits it offers to him / her and information on regular up-keep and timely disposal is not provided the ‘PPE’ shall have lost its value hence this area needs further reinforcement with the involvement of both the provider and the enforcer. Products are often supplied without usage, storage, maintenance information; this also needs to be further improved upon.
Internal communication to the users on product specifications and limitations of use needs further reinforcement.
Example:
Even 5% of non-usage of hearing protection in a high noise area could result in a high exposure, similarly after every fall a harness needs replacement.
2.5 Statue Enforcement:
The statute in India – The Indian Factories Act – 1948 has got very limited mention on the subject of ‘PPE’. Often in growing economies people follow only what are the basic requirements in the statute resulting from exposure and exploit this to their advantage. A strong Statue ensures strong adoption and enforcement of usage of the right protection. In India the enforcers of the statute which is basically the Department of Industrial Safety and Health though have undertaken an uphill task of educating and enforcing still have a lot to be done and they also recognize their own limitations to enforce this issue as there are different priorities before them.
2.6 Standards:

As we all know that BIS - ISI is the organization governing standards of ‘PPE’ though it is a well known fact that a majority of the standards need an update. The modern ‘PPE’ which are largely used are yet not covered. The standards which exist are not more than replicas of international standards though it may be difficult in practice to follow / implement them in India.

The most important fact is that working conditions of a typical Indian worker vis-à-vis his counterpart in any developed nation differs in every manner. The fact that an average Indian worker works for longer duration, in more extreme conditions with a limited budget are very important points to be considered during development of a standard.
It is time now that priority should be given not only to develop the appropriate standards but also have the right infrastructure / laboratories to test and qualify the ‘PPE’ as per Indian Standards and again these standards must be followed in letter and spirit.
3. The advantages of meeting International Standards
The Topic of ‘Advantages of meeting International standards” can only be justified if we clearly see the advantages. In India, it matters more to see quantified advantages of almost everything which is being implemented. The issue of higher safety and better human life as stand-alone are not the key drivers of safety. Thus, below are the few specific advantages of meeting international standards of ‘PPE’.
3.1 SUSTAINABLE GROWTH
The 12th NSCI National Conference title is "Safety, Health and Environment for Sustainable Growth: Challenges & Responses" Sustainable growth can only be achieved by adoption of Global Practices and participation. There needs to be a visible shift in the attitude of all stake holders in the implementation of what is good for them leading to growth and productivity. As boundaries of nations get shrunk, trade becomes global; it has become extremely important to benchmark international standards or in fact exceed it.
3.2 Quality
It is a funny thing about life: if you refuse to accept anything but the best you very often get it. What is needed is the will to get it. The need of the hour is to accept quality which is established globally by years of usage and feedback and the Technology behind it. It can straight away be implemented in India, we don’t have to waste our time and resources to re-invent the wheel.
3.3 Cost v/s price
The idea of cost v/s price as explained in point 2.0 above is recognized and accepted as we definitely get a better cost advantage by bench marking an international standard and the product therein.
3.4 Comfort
Most of the ‘PPE’ standards internationally have stringent test conditions considering the human comfort. By enhancing comfort the adoptability of ‘PPE’ increases dramatically and implementation need not be harsh.
3.5 Safety
Safety is paramount and apex for any ‘PPE’ user as the user depends on his / her ‘PPE’ for reduction of risks and exposure. By adopting International Standards we assure higher performance from the ‘PPE’ and thus, reinforce user confidence.
3.6 Easier adoption by global employees
Today’s employee is a global employee. A common standard of ‘PPE’ helps him / her work in different geographical locations with the same ‘PPE’ and this reduces an important aspect of training and adoptability.
4: Way Forward
While we have recognized the INTENATIONAL way of approaching ‘PPE’, the national challenges and advantages we have to also draw a road map to reach where we want to few of the steps to meet international practices and standards could be as follows.

4.1 Adopt Process
All the stake holders in the ‘PPE’ vertical need to know the importance of adopting a systematic way of approaching this vital issue. The basic risk assessment at so many small medium enterprises and large enterprises has to be adopted. The very process of establishing, selection of ‘PPE’ needs reinforcement and thus all stake holders need to insist on this.
4.2 Role of enforcers
The new Factories Act is getting upgraded and is going to be tabled soon in the parliament. It is the right time to elaborate the ‘PPE’ subject and its aspects like usage, standards and the details of ‘PPE’ need to be suggested. Enforcing agencies need to priorities this issue. To start with at least a soft copy of existing local standards need to be acquired by them, studied, commented and implemented.
4.3 Draft Standards
BIS or other agencies who govern the standards of ‘PPE’ need to expedite covering new ‘PPE’ and also upgrade standards of the existing ones to meet International standards. The Indian conditions need to be very much considered while doing so. Simply adopting to a international standard may always not be the right way. Various International standards need to be studied and then a local standard needs to be established.
4.4 Role of NGO , Associations etc.
Various NGOs need to spread awareness in workers and, good case studies need to be circulated for motivation. Awards for innovation and best practices shall go a far way. Association could liase effectively with government bodies and end users to create a sounding board.
4.5 Role of Manufacturers and Users
Responsible manufacturers should make few things a must in their system; First and the foremost is the understanding of the product and what it is supposed to ultimately deliver besides implementation of guidelines in every aspect of requirements for the safety of the user. This could be followed with simple user guides to disclaimers and providing training in ‘PPE’, to help users reach the right selection process as per International guidelines. This is then to be sustained in every production cycle to ensure the user develops the trust and feels safe while using a particular ‘PPE’ from a particular manufacturer.
On his end the user needs to be very careful firstly in expressing his requirement which could be done by studying the hazard carefully and then laying down standards to meet his requirement. Then the user or provider has to be particular in internally communicating about the use and advantages of ‘PPE’ to all users. The selection criteria and the specification of ‘PPE’ needs to be studied although ‘PPE’ sits last in the hierarchy of control it still is the saviour in many many ways. Eleanor Everet said ‘For safety is not a gadget but a state of mind’. The shift will happen only if all and sundry believe in the above and join hands in its implementation and enforcement.
‘The safest risk is the one you didn’t take’
Implementation of Safety Standards in the industry holds true only if ‘PPE’ provided provide the protection they are made for. As mentioned earlier in my paper we don’t have to re-invent the wheel when Technology is readily available. What is needed is the will to adopt and make a resolve that we shall achieve our goals come what may and when it is concerning the Human safety why not?
This is not a single individual’s job it is a combined effort of the Industry and the Statue and the stake holders who may like to believe that if they want Productive gains then they will have to believe in the safety of their workforce as only a protected workforce can give growth and lead to profits not only for themselves but for the nation at large.