An HSE Inspector

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An HSE Inspectors View of RPE

• Duncan Smith
• FOD SG Occupational Hygiene

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Contents

• RPE in the Hierarchy of Controls
• Inspections
• Common RPE Issues
• RPE Enforcement
• - Hazards, Industries Notices
• Benchmarking for Inspectors

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RPE in the hierarchy of controls

• Several measures from the COSHH hierarchy of
  control will usually be needed to ensure
  effective control
• RPE is all too often provided as the only means
  of control
• Only suitable as a primary control measure when
  other means of reducing exposure are not
  reasonably practicable

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RPE in the hierarchy of controls

• RPE is an important control technique in many
  situations
• - where other methods of control are not
  technically feasible or are prohibitively
  expensive
• - where exposure only occurs occasionally e.g.
  some mainenance tasks
• - where exposure occurs intermittently during a
  shift
• - during emergencies e.g. spillages
• - as a secondary control measure

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FOD Inspections

• Approx ¾ million premises regulated by HSE
• Around 1100 frontline FOD staff
• 22000 proactive inspections agreed annually
• 70/30 reactive-to-proactive resource split
• reactive investigations into fatalities,
  accidents, ill health, dangerous occurrences and
  complaints

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Common RPE Issues

• No RPE
• RPE not suitable and sufficient
• No maintenance programme
• No face fit testing
• No breathing air quality checks
• No training

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Most Frequent Hazards

• Most common hazardous substances enforced on are
• - silica (construction)
• - isocyanates (motor vehicle repair)
• - asbestos (non-licensed work)

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Enforcement COSHH Regs ACoP

• An Approved Code of Practice (ACoP) has a special
  legal status and gives practical advice on how to
  comply with the law
• If you follow the advice therein you will be
  doing enough to comply with the law in respect of
  the matters on which the ACoP gives advice
• You may use alternative methods to those set out
  in the ACoP in order to comply with the law.
• However, if you are prosecuted for breach of
  health and safety law and you did not follow the
  ACoP, you will need to show compliance with the
  law by some other way or you will be found at
  fault.

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Enforcement - Guidance

• Inspectors seek to ensure compliance with the law
  and may refer to guidance as illustrating good
  practice
• Guidance is not compulsory and dutyholders are
  free to take other action
• Verbal advice by Inspectors is not enforcement
  action

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Benchmarking for inspectors

• Sector guidance e.g. Topic Inspection Pack,
  Sector Information Minutes, Operational Guidance
• Internal Training
• Specialists

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Extract from MVR TIP
Activity Paint Spraying Benchmark Air-fed RPE and other PPE should be worn for spraying and during the booth/ room clearance period Control measure problem Air-fed BA not worn during 2-pack isocyanate paint spraying Risk Gap Extreme Indicative Action PN
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Fee For Intervention

• Where a material breach of regulation is
  identified and the breach is severe enough to
  necessitate the need to write to the dutyholder,
  HSE will recover their costs until the breach is
  rectified

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Take home messages

• RPE is an important part of any control strategy
• Key stakeholders have an important part to play
  in education of dutyholders
• HSE target high risk activities and do enforce
  where necessary

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Questions?

• Email duncan.smith_at_hse.gsi.gov.uk