Certifying Personal Protective Technologies Improving Worker Safety (2011) / Chapter Skim
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WHY CONFORM? Although safety and health professionals rank it low on the hierarchy of hazard controls, personal protective technologies continue to provide the primary means of risk reduction in workplace settings where risks or exposures change rapidly, where process change or engineering controls 1
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mechanisms needed to ensure the efficacy of non-respirator personal protective technologies (PPT)
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In discussions on product conformity assessment, the term first party refers to the manufacturer, second party to the purchaser, and third party to an independent entity, which is neither the seller nor the buyer. Conformity assessment processes for products in the marketplace are focused on product effectiveness -- verifying and ensuring that a product meets specific criteria.
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Products that have extensive conformity assessment processes often are those whose failure could significantly impact the health or safety of the worker. A COMPREHENSIVE RISK-BASED FRAMEWORK FOR PPT CONFORMITY ASSESSMENT Given the wide range of current approaches used to conduct conformity assessment for PPT products, the committee saw the need for a structured framework to evaluate products protecting against comparable risks.
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a Environmental Protection Agency standards for noise reduction ratings. b Not federally mandated, but required to meet National Fire Protection Association criteria.
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The degree of potential risk to the user from the failure of a PPT product during use in a specific task should determine the rigor of the conformity assessment process, particularly decisions regarding whether the process calls for first-, second-, or third-party declaration of conformity. The potential risk is a function of the probability of product failure and the impact on user health and safety due to the failure, assuming proper use of the product.
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Estimates of the occupational health and safety risks due to hazardous exposures can be quantified based on knowledge about the exposure. However, health surveillance data on PPT use in the workplace are limited or missing, including data on the extent and nature of PPT use and on adverse outcomes that occur related to PPT use (those that occur due to PPT failures, while wearing PPT, and when not wearing PPT in work situations requiring PPT use)
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Third party agency High Third party Third party Third party Third party Third party Federal govt. Third party Federal govt.
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To develop this framework and implement the conformity assessment processes, the committee recommends that • Components of the tiered PPT conformity assessment framework include the following categories and actions: o Low risk -- manufacturer's attestation to meet relevant standards, o Medium risk -- third-party testing and certification, and o High risk -- third-party testing and certification with government involvement to provide oversight and to as sist in enforcement; • Current processes and innovative models (e.g., probabilistic models) should be explored, where adequate data exist, for assessing the level of risk and incorporating other feasibility factors into categorizing PPT; • NIOSH NPPTL should work with other relevant federal agencies, manufacturers, organizations, and end users to identify current gaps and priorities in conformity assessment for medium- and high-risk PPT use, and to subsequently en gage in developing and implementing the appropriate con formity assessment processes;
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, are currently hindering improvements in PPT and PPT conformity assessment processes. A surveillance network that draws on and expands current surveillance systems already in place could provide information needed to identify workplace tasks where injuries, illnesses, or deaths are occurring because of noncompliant and/or poorly manufactured PPT, inadequately or incorrectly labeled PPT, PPT not being provided by the employer, and/or any end-user performance
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. The fragmented nature of current PPT conformity assessment has resulted in multiple and diverse sources of information that employers, workers, and others need to consult in order to identify certified equipment or find independent information on non-respirator PPT.
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, Oc cupational Safety and Health Administration (OSHA) , third party certifying organizations, and other relevant organizations to establish an electronic PPT and Occupational Safety and Health Surveillance System that includes data on PPT product effectiveness in the workplace.
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OSHA and the Mine Safety and Health Administration regulations that stipulate requirements for third-party testing and certification, where applicable, can provide the impetus to drive the change that will result in a more consistent, comprehensive, and risk-based approach to PPT conformity assessment. This commitment to improve non-respirator PPT by strengthening the conformity assessment processes also necessitates an equally strong commitment to training and use of PPT.
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