Breathe Easy – RPE in the Workplace

The HSE recently published research report RR1087: Market Surveillance of FFP3 Disposable Respirators[i], an examination of the performance of ten disposable respirators. Worrying only five of the ten tested passed all the tests, “serious” faults being reported in the others.

HSE had selected ten FFP3 respirators from ten different manufacturers that are available on the UK market. Two models had a single fault on each sample, one described as “very serious” and which rendered the respirator ineffective. Three other models had multiple faults, two of them considered to be “serious”.

The information provided with the product by manufacturers was considered generally acceptable, although four out of the ten manufacturers included no or limited information on pre-use checks.

Types of RPE

Disposable respirators of the type tested by HSE are only one kind of Respiratory Protective Equipment (RPE), apparatus worn in atmospheres contaminated with hazardous substances to provide the wearer with a supply of air that is safe to breathe.

The most common forms of RPE are:

  • Disposable half-masks (respirators)
  • Half masks without inhalation valves
  • Reusable half masks
  • Full face masks
  • Powered respirators with helmets and hoods
  • Power-assisted respirators with full face or half masks

Managing RPE

As with all forms of personal protective equipment (PPE), the need for RPE should be identified through risk assessment and should be considered the last resort in the hierarchy of controls.

Anyone considering using RPE should recognise that it only protects the wearer while other preferred measures, such local exhaust ventilation (LEV), can protect everyone in the area by preventing hazardous substances entering the atmosphere.

Where RPE is used incorrectly or is poorly maintained, the wearer may gain no protection from it.

Furthermore RPE can be expensive and the true cost of implementing an effective programme is often underestimated. Although ‘collective’ measures that protect areas rather than individuals such as LEV may come with a significant short-term cost, in the long run it may actually work out cheaper and provide a higher level of protection. The employer’s decision to purchase RPE over other measures may be questioned by the authorities and they may be required to justify their choice in court if employees are made ill through exposure to hazardous substances when a higher level of protection is available.

Making RPE Fit the Individual

RPE can sometimes be uncomfortable or restrict the wearer in some ways, such as:

  • Restricted breathing
  • Build-up of moisture and heat
  • Heat rash where the mask touches the skin
  • Condensation on eye-wear when worn with RPE
  • Difficulty hearing or speaking.

As with other forms of protective equipment, if the user does not find it comfortable they may not use it correctly or at all. As such it is important to consult with users of RPE, provide face-fit testing and listen to feedback as it is used.

Beards can prevent an effective ‘seal’ with the mask and allow hazardous substances to enter. This can be difficult to manage if the beard is grown for religious reasons, as shaving it may not be an option. In such situations full hoods may need to be provided, which come with their own problems and may not be suitable for the work at hand. As such LEV and other collective measures should be prioritised.

Checklist: Controlling Hazardous Substances

To comply with the requirements of the Controls of Substances Hazardous to Health (COSHH) Regulations, the following action should be taken:

  1. An inventory of all substances used on the premises e.g. those used for cleaning and maintenance activities, and any processes where exposure to biological agents, fumes, dusts etc could arise.
  2. All relevant product health and safety data sheets should be obtained from the manufacturer.
  3. Copies of these data sheets should be made available to employees, preferably at the point of use or likely exposure.
  4. Using the information provided by manufacturers, and knowledge of the way products are used, or exposures likely to occur, an assessment should be made of likely exposure and the consequential risks to health.
  5. Where practical, exposure to hazardous substances should be avoided, preferably by eliminating use of the substance or by substituting with a safe or less harmful alternative.
  6. For substances which cannot be eliminated or substituted, the assessment should identify suitable control measures for safe storage, transport, handling and use. Where exposure cannot be adequately controlled by other means, the assessment should identify the provision, use, cleaning and maintenance of appropriate personal protective equipment and clothing. The assessments should be recorded and regularly reviewed to ensure they remain valid.
  7. Copies of the assessments should be provided to employees who could be exposed to the substances.
  8. To accurately determine likely exposure and to check that control measures are effective, some form of monitoring may be required. This may be continuous or occasional, depending on the substances and the nature of the process. For some substances, limits are specified, above which people should not be exposed. These are known as WELs (workplace exposure limits). Details of these are published annually by the Health and Safety Executive in document EH40.
  9. Personal protective equipment should only be used as a last resort method of preventing or controlling exposure.
  10. All employees using, or likely to be exposed to hazardous substances must be given information, instruction and training about hazards and control measures relating to those substances, and the use, cleaning and maintenance of any personal protective equipment required.
  11. To ensure the control measures identified by the assessment are used/applied correctly, regular checks should be carried out by management and corrective action should be taken where incorrect use, or non-use is observed.
  12. Where control measures involve the use of personal protective equipment, the use of this equipment must be monitored and regular checks for signs of wear or damage carried out. It should be replaced, as necessary.
  13. Where engineering controls or non-disposable respiratory protective equipment are used to control exposure, they must be maintained. With certain exceptions, extraction systems should receive a thorough examination and test at least once in every 14 months by a competent person. Respirators should be examined monthly. Records should be kept of these checks.
  14. Arrangements should be made to ensure that no new substance is used before a manufacturer’s health and safety data sheet is obtained, an assessment is carried out and appropriate information, instruction and training is provided for employees who are to use the substance.
  15. All employees must be informed that they are required to co-operate with management regarding the use of the required control measures and to report defects or loss of any personal protective equipment supplied.
  16. Contractors should be required to keep effective control of the hazardous substances brought onto the premises and to secure these in a locked cupboard or container when they are not being used.
  17. Contractors must provide adequate control measures to prevent harm occurring to other people on the premises.

[i] RR1087: Market Surveillance of FFP3 Disposable Respirators can be accessed at


Disclaimer: The information provided through Legislation Watch is for general guidance only and is not legal advice. Legislation Watch is not a substitute for Health and Safety consultancy. You should seek independent advice about any legal matter.

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