Face Fit Testing and the Problem With Stubble
Face Fit Testing is a legal requirement for everyone who has to wear tight-fitting masks in the workplace. When masks are worn inadequately, it significantly reduces the protection to the wearer and could even put their life in danger and lead to long-term ill health.
Face Fit Testing
Face Fit Testing is a method for checking that a tight fitting facepiece matches an individual’s facial features, and can provide an adequate seal to the wearer’s face. As people come in all sorts of shapes and sizes, it’s unlikely that one particular type, or size of RPE facepiece, will fit everyone. Inadequate fitting masks will significantly reduce the protection provided to the wearer and could potentially put their health and life in danger.
The supporting guidance for COSHH (Control of Substances Hazardous to Health), CLaW (Control of Lead at Work) and CAR (Control of Asbestos Regulations), recommends face fit testing as a method of ensuring an adequate face seal.
Face fit testing is required for the following types of masks:
- Disposable half masks
- Re-usable filter or cartridge half masks
- Powered respirators
- Full face filter or cartridge masks
- Escape set masks
- Full breathing apparatus masks
However, the COSHH Regulations reg.7(1), The CLAW Regulations reg.6(1), The CAW Regulations reg.10(1)(a) place the duty on the employer; to prevent the exposure of their employees to hazardous substances; where prevention of exposure is not reasonably practicable, the employer must reduce it to the lowest concentration reasonably practicable by means other than the use of RPE.
If, despite the use of suitable control measures (i.e. other than RPE) adequate control of exposure cannot be achieved, employers must provide suitable RPE (COSHH Regulations reg.7(3)(c), CLAW Regulations reg.6(3)(c), CAW Regulations reg.10(4)). The RPE provided must reduce the exposure to a concentration that is as low as reasonably practicable, and in any case below any applicable exposure or control limits.
The law states that:
All UK employees who wear tight-fitting respiratory protective equipment (RPE) should 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.
The ‘Trouble With Stubble’
One common problem when Face Fit Testing is the issue of facial hair and stubble. In many cases, individuals are choosing to ignore the fact that they have to be clean shaven when a fit test in being carried out. Guidelines state that when being tested on, a tight or close fitting face mask, facial hair is not permitted in the face seal area as facial hair can force the mask seal away from the face and allow contaminants into the mask. This applies during both a fit test and when wearing a mask for work.
To sum it up, here is a section from the Frequently Asked Questions on the HSE website:
Stubble – is it OK to have a face fit test if I keep my facial hair short?
“No. Any facial hair in the face seal area may interfere with the seal and cause your mask to leak. You should be clean shaven at the time of the test and on every occasion you wear your mask for work. Facial hair that is wholly contained inside the mask, e.g. a very small beard or moustache is permitted providing that it is not in the area of your face that touches the mask seal.”
Wearing the Right PPE
Here at Baker Flooring, it is our duty to ensure we follow all of the legal requirements and our workers are equipped with the correct Personal Protective Equipment. As a company, we are qualified to carry out our own Face Fit Testing, and to ensure we continue to follow legal requirements, we have therefore had to purchase other alternative forms of RPE.
As a CHAS accredited company, and proud of our professional guidelines, we are implementing a no tolerance policy; warnings and further action will be taken if workers/fitters are seen not using the proper RPE they have received.
However, despite this, we are still facing problems surrounding the issues of facial hair and our workers wearing the correct RPE. Currently, we have workers on two sites (under the same contractor), one of which are allowing a battery powered full face mask which is suitable for working with stubble, but the other site is demanding that regardless of mask type, operatives still have to be clean shaven.
This then brings confusion as two sites under the same company are operating different rules. Therefore we believe that clear guidelines should be put in place across all sites so companies know where they stand.
To find out more about complying by HSE and the rules and regulations for Face Fit Testing, CLICK HERE