7.3 CE Marking

Employers should ensure that any PPE they buy bears a ‘CE’ mark and complies with Regulation (EU) 2016/425 on personal protective equipment. (The full title is Regulation (EU) 2016/425 of the European Parliament and of the Council of 9 March 2016 on Personal Protective Equipment, repealing Council Directive 89/686/EEC). Not to be confused with the Use of Personal Protective Equipment Directive (89/656/EEC) covered previously, the regulation lays down requirements for the design and manufacture of PPE, which is to be made available on the market, in order to ensure protection of the health and safety of users and establish rules on the free movement of PPE in the European Union. It requires manufacturers to CE mark their products to show compliance. If you use PPE for providing protection against arc flash hazards, you should ask for confirmation, from the supplier, that the PPE certified satisfies the requirements of the PPE Directive.

Following Brexit, things are different in the United Kingdom. The UKCA (UK Conformity Assessed) marking is a new UK product marking that is used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking. The UKCA mark will not be recognised for products being placed on the EU market.

The UKCA marking alone cannot however, be used for goods placed on the Northern Ireland market, which require the CE marking or UKNI marking. There is a separate Northern Ireland Protocol which, for as long as it is in force, Northern Ireland will align with all relevant EU rules relating to the placing on the market of manufactured goods.

7.4 Types of Arc Flash PPE

When considering protecting persons against the arc flash hazard, much of the focus seems to have been on providing clothing made from FR fabrics in the form of shirts, polo tops, trousers coveralls and so on. However, as I mentioned earlier, it has been shown that the parts of the body which have been most frequently affected by arc flash have been the hands, arms and face. Some years ago, when researching the subject, I remember being told by a HSE Specialist Electrical Inspector about an horrific injury to a young man injured in an arc flash accident. He suffered permanent and debilitating injuries to his respiratory system due to the inhalation of toxic and super-heated gases. I have been very fortunate to have made the acquaintance of experts in hand and face protection with whom I have used this observation on several occasions. Fortunately, the standards for face and hand protection have caught up in recent years and details of the different types of arc flash protection and related standards are detailed as follows.

7.4.1 FR Protective Clothing

Compliance is required with Standard IEC (EN) 61482-2: 2018, Live working - Protective clothing against the thermal hazards of an electric arc - Part 2: Requirements. This standard will give some assurance that the garments comply with rigorous minimum standards of inspection and testing. The subjects covered are; tear resistance, tensile strength, burst strength, shrinkage and other effects of cleaning, arc thermal performance, marking/labelling, user instructions specification and flame resistance. There are also inspections of construction and workmanship, size designation and ergonomics, ageing and threads and closures.

All flame-resistant garments are made from fabrics which are in turn, made from fibres which are woven together to form the fabric. The term “Inherently Flame Resistant” means that the fibres are naturally flame resistant and when woven into a fabric require no further treatment and can be made into garments to withstand levels of the thermal hazard from an arc flash event. The flame resistance is an inherent property of the polymer chemistry and will not diminish during the lifetime of the garment.

Then there are those garments made from “Permanently Treated Fabrics”. They tend to be made from cotton fibres which acquire their flame resistance from a treatment received after it is woven into fabrics. Permanently treated fabrics were often characterised by the treatment washing out over a period of time which is determined by the frequency of washes that the fabric was exposed to. This is less of a problem nowadays although the life expectancy of inherently flame-resistant fabric appears to be longer through anecdotal evidence and published data. Those manufacturing FR garments from permanently treated fabrics would say that they are more likely to naturally wear out before losing flame resistance.

Whether inherent or treated, sewing thread used in the construction of FR garments have to be inherently FR fibre except for where threads in seams that have no influence on protection, such as hems and pocket seams.

My own preference is for garments made from inherently flame-resistant fibres and my reason is supported by my house building analogy. A house may be built out of several different materials. I love to see a house made out of kiln fired bricks, but I have to accept that a house made out of concrete blocks will probably be cheaper and perform just as well. The fact is, that the cost of the bricks or the concrete blocks, will be a fraction of the total building costs and the manufacturer of the materials will not be the company that builds the house. This is the same for PPE where the weavers will mostly be separated from the manufacturers of the fibres. So, for larger bespoke procurement of PPE it is preferable, in my view, to specify the type and even the producer of the fibre and drive the value for money through the weaving and manufacturing of the garments. For smaller, off the shelf procurement exercises, the comparison of apples with pears starts with being aware of the performance of the various fibres that go into the garments. The following information will help with the comparison.