The legal requirement for face fit testing in the UK has been with us for over 15 years.
All UK employees who wear tight-fitting respiratory protective equipment (RPE) should, by now, have a certificate to prove that the protective equipment they wear during work not only fits them, but also affords them the effective protection necessary for the task being performed. However, every week we are delivering face fit tests for clients whose employees are being face fitted for the first time, having worked in environments where a mask has been required for many years.
The need for protection
In the UK, respiratory-related diseases and conditions account for the third-largest work-related illness. Those affected come from a cross sector of industries including construction
In 2017 there were a further 18,000 estimated annual new cases of self-reported work-related breathing or lung problems; this is just the tip of the iceberg.
Keep it clean
Because faces are of all shapes and sizes, they need to be carefully matched to the most appropriate make/model of RPE, one mask is unlikely to be suitable for all of your employees. Faces also change with time and this can have a significantly adverse effect on the effectiveness of a tight-fitting facemask. The reliability and performance of the RPE depends on there being a good contact between the wearer and the mask - and the contact can only be assessed by performing a Face Fit Test.
A somewhat contentious area of the Fit Test is the requirement for all persons to be clean-shaven within the area of the face/mask seal. Research carried out by Health & Safety Laboratories in the UK shows that facial hair - even stubble - can adversely affect the fit of a mask to the extent that it is difficult to ensure that it fits correctly and thus provides effective protection for the wearer.
If this worker is found wearing an RPE device by an Enforcement Officer there are likely to be serious implications for the worker and employer.
If the worker is also found to have facial hair then this will execrate the situation and may call in to question the validity of the face fit test. UKHSE conduct face fit tests for clients and take photographs of all attendees and attach this to the face fit record to confirm that they were clean shaven at the time of the Face Fit test.
Types of face fit test
There are two types of Face Fit Testing - Quantitative and Qualitative.
Quantitative testing is performed using particle counting or controlled negative pressure devices. From the direct numerical measurement, a calculation of the effectiveness of fit - known as a Fit Factor - can be calculated.
Qualitative testing is a method based on the tasting or smelling of a bitter, sweet or odorous compound. It depends on the mask wearer being able to detect the test compound
During Fit Testing, a series of short exercises are performed to simulate the wearer’s movements during a normal working day. This allows the mask/face seal to be assessed under realistic conditions. Any other Personal Protective Equipment (PPE) that is worn, in conjunction with the RPE, during the working day must also be worn during the test. This is to ensure that safety helmets, safety spectacles/visors, ear defenders etc. do not interfere with the correct wearing of the mask.
Face Fit Testing should not be confused with a Fit Check - which should be carried out by the wearer whenever donning a tight-fitting facemask. The Fit Test is to ensure that the device will fit the individual correctly when donned and worn in accordance with the manufacturer’s instructions. The wearer should carry out a Fit Check, each time he or she dons their facemask, to ensure that it is being worn correctly. The Fit Check should only be carried out on a make/model/size of facemask for which the wearer has already completed and passed an appropriate Fit Test.
There are a number of regulations relating to the correct selection, use and maintenance of RPE. Specifically, the Control of Substances Hazardous to Health (COSHH) Regulations require that
“Employers should ensure that the selected facepiece is of the right size and can correctly fit each wearer. For a tight-fitting facepiece (filtering facepieces usually known as disposable masks, half and full-face masks) the initial selection should include Fit Testing to ensure the wearer has the correct device. The test will assess the fit by determining the degree of face-seal leakage of a test-agent while the RPE user is wearing the facepiece under test.”
Any person performing the testing must be a ‘Competent Person’ as per the minimum requirements detailed by the HSE in their Operational Circular OC282/28. The testing must be documented and records kept for at least five years. UKHSE are recognised under the Fit-2-fit scheme to conduct qualitative face fit testing.
The requirement for Face Fit Testing is also covered in the Control of Asbestos at Work Regulations (2012) and the Control of Lead at Work Regulations (2005).
How fit are you?
It appears that there are still many employers who are not compliant with the current legislation in both conducting the initial testing and ensuring compliance with the wearing of the RPE.
Since the introduction of the legislation in the UK, a number of companies have been served Improvement Notices by the HSE. This requires them to implement a RPE Fit Testing programme for all employees that wear tight-fitting RPE. Although having such a programme in place may indicate to the HSE an employer’s ‘intention to comply’ it does not necessarily protect the employer from retrospective prosecution.
With the number of compensation claims increasing, employers who do nothing are increasing the risk of legal action being taken against them by both current and ex-employees. The potential for retrospective litigation is considerable - and without clear evidence that employees were tested for the fit of their RPE, claims may become increasingly difficult to defend against.
Clearly, there is a need for individuals to be trained correctly in the use and maintenance of any device with which they are provided - and for employers and health professionals to fully understand all the risks associated with poorly selected, incorrectly fitting, RPE.