A topical podcast from Dr Steve Cowley and Sue Dearden on the risks of describing face coverings or masks, and gloves, as PPE, and the limitations on their effectiveness as a control measure against COVID 19 infection.
Please click the video to listen to the podcast or alternatively you can read the transcript below.
Steve:
Hi, my name’s Steve Cowley and I’m a Consultant with Finch Consulting and I’m talking today to Sue Dearden who is one of Finch Consulting’s Health and Safety Lawyers.
Sue:
Hello everybody.
Steve:
As we start to come out of the lockdown period following the Covid 19 infection, personal protective equipment is a highly topical issue and it has caused a few problems Sue.
Sue:
Yes it is. Thanks Steve. The issue is that I think people are writing their risk assessments and quite rightly thinking about what controls they need to put in place in order to manage the infection so that their employees are protected, their customers are not only protected but have sufficient confidence to return, and they want to avoid criticism and prosecution potential. The issue is that the masks are being described as PPE and the problem with that is that PPE has a specific meaning under the Personal Protective Equipment at Work Regulations 1992. Now under those Regulations, PPE means equipment which is intended to be worn by someone at work which protects THEM against one or more risks to THEIR health and safety.
Steve:
Yes my concern from an Occupational Hygienist’s point of view Sue, is that we are misleading people and increasingly with the risk assessments that we are reviewing on behalf of our clients, we are hearing people talking about providing PPE for their employees when really they mean masks. If we confuse the two and confuse the language about the two it can get us into a bit of a tricky situation.
Sue:
Yes, if you are resorting to PPE for personal protection then you would need respiratory protective equipment with filtering face pieces, and I think it must be CE marked mustn’t it? Certainly, tight fitting, and I don’t think I’ve yet seen a mask in use or in response to the virus that anyone would regard as anything like tight fitting.
Steve:
Yes and CE marking is really important and, just as an aside there has been advice from the HSE in the last few days warning people to look out for fake masks, as in they have been marked as complying with certain standards but they are actually fakes. We need to be aware of that.
The other thing we should be aware of is that respiratory protective equipment is the bottom of the hierarchy of controls and it is predicated on the fact that we get a good seal around the face as you were saying Sue, and a face seal with a respiratory protective device like and FFP1 or an FFP2 requires us to test that we do have a good face seal.
Many people will be familiar with the idea of fit testing where we put a mask onto someone and we test whether they have a face seal by spraying a saccharin substance in the air around them to see if they can taste it and if they can taste it well then we know they have a leak. Leaks around masks are very, very common. Large numbers of people think they are protected whilst not actually having the face seal that they think they’ve got.
Sue:
Yes, so maybe it would be better to avoid calling it PPE altogether and bearing in mind the original Government advice which was that there should be a layer of other protections involving social distancing and frequent hand washing and frequent cleaning before you even come on to face covering as a factor in this, and use the word face covering or face mask rather than calling it PPE.
Steve:
Yes, there is an issue I think of there also being a false sense of security in that people think they can get closer to other people because the risk is better controlled but it is only protecting other people and we haven’t got a face seal especially with a face mask. And there’s additional problems of people repeatedly touching their mask. The masks are single use. They should be disposable, or disposed of, and washed if they are a reusable mask, after each use. Each time you take it off you should be throwing it away.
Sue:
I think we saw some of it on the television over the weekend with the raves and things, and also some of the gatherings that have been going on where people have obviously thought about wearing a face covering or mask to give some sort of protection, but it doesn’t take very long before those masks are down below the nose so they are actually only being used to cover the mouth and that seems to be what it descends to because they are hot, they are uncomfortable, and, as somebody who wears glasses I find that when I put a mask on my glasses steam up all the time so there’s just quite a practical difficulty with sustained wearing of them and enforcing that is going to be difficult. So, let’s not have any illusions about the protection for anybody that they provide.
Steve:
Yeah, and of course a lot of these issues we are discussing are what people who have to use respiratory protective equipment every day at work in normal times experience.
The problem we have here is perhaps the misuse of the term PPE and the inappropriate use of face masks and the fact they give people a false sense of security. And linked to that is something we have been discussing Sue, and that’s the use of gloves.
Sue:
Yeah, only in the sense that if you’ve got employees with gloves, again they might feel that they are protected but actually if gloves are touching all surfaces regularly and perhaps not everyone has got gloves on and then touching their faces any infection they have transfers to their gloves and then to the surfaces in the same way that it would if they’d got bare hands, so it is more effective to handwash is it?
Steve:
Yes. It’s similar principles isn’t it. That we don’t want this false sense of security. And quite often because we are wearing these devices we think we are protected, and we let our guard down. Back in “normal” times it used to really offend me that you would go into a sandwich bar and someone’s got the protective gloves on for hygiene reasons and then handles the money, puts it in the till and cuts another sandwich. It’s a similar principle.
Sue:
Absolutely. So, to summarise then don’t call face coverings and the typical paper and cloth masks PPE, because it isn’t.
- They don’t meet the regulatory standards required by the regulations which will put you in breach of those regulations and vulnerable to enforcement action.
- It gives the wearer a false sense of security which encourages behaviours that you don’t want which compromise your other risk control measures in place, such as social distancing
- Any protection for others disappears if the masks are pulled down below the nose, if paper ones aren’t changed frequently, and cloth ones washed frequently. It is not usually going to be practicable to ensure that happens so this has to be a last resort measure when there are absolutely no alternative means available of protecting staff and others.
Can I just also finally mention that at Finch Consulting we are offering fixed price reviews of Covid 19 risk assessments by our H&S lawyers and industrial hygienist, and behavioural expert, among others. If you would like an independent check and practical advice and assurance about your controls then please do get in touch with Steve or me or via our website. Our details are on the written transcript that accompany this podcast.
Steve:
Great well thanks Sue. It’s been good to talk to you as usual.
Dr Steve Cowley, Chartered OHS expert and experienced OHS Manager and industrial hygienist with airborne contaminant PPE expertise
+44(0) 780 921 3653
Susan Dearden, specialist Health and Safety Solicitor
+44(0) 790 968 2688
