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Face Fit Testing

Published: 10th Jun 2011 in OSA Magazine

This article reviews UK practices and improvements made by stakeholder bodies supported by the Health and Safety Executive - including a professionally recognised accreditation scheme which aims to ensure the competency of fit test providers.

While legislation to protect workers included in OSA’s demographics is emerging, consistent regulations have yet to be established. Citing the quite specific experience of UK health and safety practitioners will give Asian readers an idea not only of how lengthy the process of creating coherent safeguards for workers has been, but will also give them insights into the many nuances and subtle distinctions the various elements of legislation embrace, plus the support systems that have developed in terms of  legislative enforcement.

UK face fit testing legislation is now nearly ten years old. UK employees who wear tight fitting respiratory protective equipment (RPE) should, by now, have received a certificate confirming 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, research indicates that not all such employees have received a certificate.

Expanding upon the European Directive 98/24/EC of April 1998 1, the UK Health and Safety Executive (HSE) updated the Controls OfSubstances Hazardous to Health (COSHH) regulations in November 2002, and included the requirement that any RPE supplied by the employer is fit tested with the wearer. This is to ensure that the RPE is not only suitable for the conditions?in which it is being used, but that, by fitting the wearer correctly, it provides fully effective protection.

In addition to the requirement to be face fit tested, full RPE programmes must be in place. This includes the selection of the correct RPE by means of an appropriate risk assessment that not only takes into account the hazard but, importantly, the work performed, the environment and the individual wearer.

Once the RPE is selected, the wearer must be trained in its correct use - and the equipment must thereafter be maintained in accordance with the manufacturer’s instructions. Only with a full RPE programme of selection, training, fit testing and maintenance can RPE be considered to be effective.

The need for effective protection

In the UK, respiratory-related diseases and conditions account for the third largest work related illness. Those affected include metal plate workers, vehicle body builders, plumbers, gas fitters, carpenters and bakers 2.
The most common type of respiratory hazard is dust - which can cause significant ill health and can be generated by multiple processes from a broad range of industries.

The important dust fractions to consider are the inhalable and respirable fractions. Inhalable dust approximates to the fraction of airborne material that enters the nose and mouth during breathing, and is therefore available for deposition in the respiratory tract. This material can stay in the upper lung and cause long term ill health.

Respirable dust approximates to the fraction of airborne material that penetrates to the gas exchange region of the lung. The respirable fraction varies for different individuals; however, it is possible to define a target specification for sampling instruments that approximates to the respirable fraction for the average person. The target specification given by ISO and CEN and published in the UK as part of BS EN 481:1993 has been adopted in the UK. This fraction, and specifically the 6-4 micron material, remains in the lung and cannot be removed, causing serious breathing problems.

In 2006/07 a survey of self-reported illnesses indicated that there were around 142,000 people with breathing or lung problems which they believed to be work related.

Face fit testing

Faces need to be carefully matched to the most appropriate make/model of RPE. Effectiveness 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. It is important to remember that faces also change with time and this can have a significantly adverse affect on the effectiveness of a tight fitting facemask.

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 determined

• 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

A contentious area of the fit test is the requirement that all persons must be clean shaven within the area of the face/mask seal. Research carried out in the UK indicates 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.

The author appreciates there may be some Asian readers who, for religious reasons, are unable to shave; however, it should be noted that hooded respiratory protection is available for use in such cases which may - depending on the context of use - be a perfectly adequate alternative to a tight fitting facemask.

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 during the working day in conjunction with the RPE must also be worn during the test. This is to ensure that safety helmets, safety spectacles/visors, ear defenders and the like 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 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.

Re-testing

In the US, yearly re-testing is mandatory and in Canada it is mandatory on a bi-yearly basis.
Under present UK legislation, re-testing of personnel is required only when significant changes to the face have occurred (e.g. scarring, moles, extensive dental work, extreme weight loss/gain) or if the size, make or model of the required RPE changes. However, data presented by the HSE 3 suggests that re-testing should be performed in the UK more frequently. It is therefore likely that face fit testing will become an increasingly important issue.

Respirator fit testing practices

Findings from a recent national survey of respirator programmes, published by the National Institute for Occupational Safety and Health (NIOSH) and the Bureau of Labor Statistics in the US, revealed some worrying issues. The survey questionnaire targeted 40,000 private sector organisations where RPE use was mandatory.

The questionnaire contained 37 questions. A request was made that the person most knowledgeable about the use of RPE within the establishment completed the questionnaire. Of the 37 questions, six applied to both voluntary and mandatory use of RPE. The other 31 questions referred to mandatory RPE use. Three of the questions related specifically to face fit testing of tight-fitting RPE.

Analysis of the returned data 4 concluded, among other things, that:

• Many of the establishments using tight-fitting RPE, where a respirator is required, seemed not to understand fit testing requirements or were unfamiliar with the fit test terminology used in the questionnaire

• There was significant confusion between a wearer ‘fit check’ and a ‘fit test’

• Only around 50% of the establishments where tight-fitting RPE is used carried out fit testing

• Qualitative tests were used far more often than quantitative tests

The most fundamental issue was that a large number of establishments using tight-fitting RPE did not conduct any fit testing. This clearly indicates a need to improve the awareness, understanding and implementation of a respirator programme in general - and fit testing in particular.

A similar survey of more than 5,000 Health and Safety representatives was carried out in the UK during 2004. Approximately 90% of the respondents had not previously heard of face fit testing, and of these, more than 10% remained unconvinced that it either applied to them, or was relevant to their activities. This highlights the concern that face fit testing is not being carried out in accordance with national legislation and European guidance. It also confirms the requirement for a greater awareness of the need for comprehensive respiratory protection programmes in the UK.

To this end, an industry regulated accreditation scheme has now been developed in the UK. With the support of industry stakeholders, the HSE and the British Safety Industry Federation (BSIF), all persons carrying out fit testing can undergo both theoretical and practical examinations to achieve accredited competency status. This ensures that fit testers within the UK achieve a minimum standard.

Competency of Face Fit testers

It has always been a concern when introducing ‘best practices’ as to how to deem individuals competent with respect to a certain skill set. When that competency can affect the health and wellbeing of others it is imperative that individuals carrying out face fit testing have been assessed as competent to a minimum standard. That minimum standard must ensure the safety of the RPE wearer.

The accreditation scheme is designed to confirm the competency of any person performing facepiece fit testing. Accreditation confirms that the tester has:

• Passed an industry-recognised examination and therefore demonstrated that they have a thorough knowledge of the HSE guidance on fit testing

• Demonstrated that they know how to fit test in practical circumstances

There are four types of RPE fit testing methods covered by the scheme and the employer must ensure that the Fit2Fit accredited provider is certified for the testing method being used. The four types are:

1. Qualitative Method (taste test)
2. Quantitative Method (ambient particle count/portacount test)
- with N95 Companion or equivalent
- without N95 Companion or equivalent
3. CNP (Controlled Negative Pressure)
4. Test Chamber

Fit2Fit Accredited testers can hold accreditation for one, two, three or all four methods.
The test for competence, which leads to accreditation by the BSIF is conducted in two parts. These are:

1. An examination paper of 30 questions using multiple choice answers (only one answer is correct). The minimum pass requirement is 80%. The questions are aimed at ensuring individuals have appropriate underpinning knowledge to carry out the fit test functions. The questions are based upon the HSE guidance document OC282-28.

All candidates, regardless of which fit test method they wish to become accredited in, must successfully pass
this examination before accreditation will be granted.

. A practical assessment of the candidate undertaking ‘actual’ fit testing will occur, using trained and experienced fit test assessors. The examination/assessments will be undertaken at an ‘assessment centre’, where the competence of an individual to carry out fit testing, with
fit testing equipment provided by the candidate, will be undertaken. Competence will be measured using the guidance provided in OC282-28 and ‘what if’ questions will provide part of the assessment process.

The accreditation will apply for a maximum period of three years, during which time a further reassessment will be required to extend the period by a further three years, and so on. The reassessment process will include verbal questions relating to changes or updates.

Although the accreditation process is not currently a legislative requirement in the UK, the HSE have endorsed it with the following statement:
“In preparing the Fit2Fit RPE fit testers’ accreditation scheme, BSIF and other industry stakeholders have worked closely with experts in the Health and Safety Executive (HSE). The scheme is not compulsory and employers are free to take other action to comply with the law. However, if you follow the accreditation scheme you will be doing enough to demonstrate good practice.”

Legislation (UK)

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.

Approved Codes of Practice (ACoPs) and HSE Operational Circular 282/28, Fit Testing of Respiratory Protective Equipment Facepieces, have been issued outlining the options for compliance and recommending how face fit testing should be performed. ACoPs have ‘special’ legal status within the UK in that, if a prosecution takes place and it is proved that these recommendations were not followed, it would then need to be proven by the employer that compliance with the COSHH requirements had been achieved in some other way. Recent discussions with the HSE indicate that the OC 282/28 may be upgraded to an ACoP - giving it the same legal status as the current COSHH ACoPs.

European Standards - EN 529:2005

In July 2005, a European Standard was approved by the Comité Européen de Normalisation (CEN) which supersedes CR 529:1993. This requires that all member countries must introduce the European Standard as a national standard without amendment. In the UK it is known as BS EN 529:2005, Respiratory protective devices - Recommendations for selection, use, care and maintenance - Guidance document.

Introduction of this standard into CEN member countries was required by March 2006. It provides guidance on establishing and implementing a suitable respiratory protective device programme to provide a European-wide baseline for the selection, use, care and maintenance of respiratory protective devices.

It is not intended to be exhaustive, but highlights important aspects to which attention should be given. These recommendations will help organisations comply with the national legislation of CEN member countries - where such legislation exists - or with European legislation.

Importantly, the guidance helps to ensure that RPE is suited to:

• The substances of potential exposure

• The individual wearer

• The task to be performed

• The environment in which the RPE is to be used

With particular reference to the wearer, Section 9: Adequacy and Suitability, sub-section 9.3.4 Assessing suitability for the wearer, requires that both the “facial characteristics of the wearer including facial hair”, and the “physical characteristics of the wearer” be considered when selecting RPE. In particular, Annex D defines the requirement to be clean-shaven if tight-fitting RPE is selected, and even defines the term ‘clean-shaven’. Annex E outlines the requirement for ensuring that tight-fitting RPE is fit tested to the wearer during the selection process, and clearly explains the requirements for - and the differences between - ‘fit checking’ and ‘fit testing’.

Conclusions

With the number of compensation claims increasing, employers who do nothing could be increasing their exposure to legal action 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.

One shipbuilding company had to pay out an average of £17,000 per employee with a further £15m being set aside for future claims 5 due to insufficient RPE protection/testing during asbestos removal operations. It is probably only a matter of time before similar judgments affect chemical and other process industries.

National Legislation in CEN Member Countries - and European and National Guidance documents - outlines the requirement for organisations to implement a complete RPE programme that covers the correct selection, use, care and maintenance of suitable and adequate RPE where there is a respiratory risk to the health of workers due to their activities. This includes the requirement to carry out face fit testing for tight-fitting RPE and to introduce a clean-shaven policy where applicable.

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. ?

References:

1. Official Journal of the European Communities: Council Directive 98/24/EC of April 1998 on the protection of the health and safety of workers from the risks related to chemical agents at work (fourteenth individual Directive within the meaning of Article 16(1) of Directive 89/391/EEC

2. Health & Safety Matters: August 2004

3. HSE Meeting of Stakeholders on Face Fit Testing of Respiratory Protective Equipment: 22 April 2005

4. Journal of the International Society for Respiratory Protection, Vol 22 Spring/Summer 2005. ‘Respirator Fit Testing Practices in the US’: Brent Doney et al

5. Times Online: March 17, 2004

Author Details:

Scott Campbell is Operational Director at RPS. He is a member of the BSIF (British Safety Industry Federation) and sits on the committee tasked with developing an industry-regulated accreditation and qualification system for face fit testing providers within the UK.

The RPS Group is an international consultancy providing advice on the responsible development of natural resources, land and property, the management of the environment and the health and safety of people.

http://www.rpsgroup.com

 

www.osedirectory.com/health-and-safety.php

Published: 10th Jun 2011 in OSA Magazine

Author


Scott Campbell


Scott Campbell is Operations Manager with RPS Laboratories.  He is a member of the BSIF (British Safety Industry Federation) and sits on the committee tasked with developing an industry-regulated accreditation and qualification system for Face Fit Testing providers within the UK.

The RPS Group is an international consultancy providing advice on the responsible development of natural resources, land and property, the management of the environment and the health and safety of people.


Scott Campbell

Website:
http://www.rpsgroup.com


http://www.rpsgroup.com

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