Is Face Fit Testing a Legal Requirement?

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Yes, it is. Face fit testing is a legal requirement for anyone who wears a close-fitting mask at work. The law requires employers to prevent or control the exposure of employees to hazardous substances at work.

Considerable growth has been seen in the awareness of face fit testing since its introduction to the COSHH (Control of Substances Hazardous to Health) 2002 Regulations. COSHH covers chemicals, products containing chemicals, fumes dusts, vapours, mists and gases, and biological agents.

In July 2005, a European Standard was approved by the Comité European de Normalisation (CEN) which supersedes CR 529:1993. This required that all member countries must introduce the European Standard as a national standard without amendment.

If your employees wear a mask because of their job risk profile, then they need to be face fit tested. Tight fitting masks need to fit the wearer’s face to be effective. All faces are different making it unlikely that one size or shape of RPE (respiratory protective equipment) will fit everyone. Face fit testing ensures that the equipment selected will fit the wearer and provide the necessary protection.

Before considering providing RPE an employer should also control exposure to hazardous substances using other methods, like effective exhaust ventilation.

The Health and Safety Executive website provides excellent information about RPE and face fit testing.

When is respiratory protective equipment required?

In the UK, respiratory- related diseases and conditions now represent the third largest work related illness; those affected are typically unprotected labourers, metal plate workers, vehicle body builders, plumbers, gas fitters, carpenters and bakers.

Many work activities generate harmful dust, gas and fumes or where oxygen levels are low; for example, using a liquid in a laboratory that contains volatile solvents, or simply cutting materials such as concrete or wood with a power saw.

In these cases, and similar, the worker must be protected from potentially hazardous environments. To select the correct type of RPE for a particular job, the employer must understand the nature of the hazardous substance and the amount of it in the air, the form of the substance in the air, gas, particle or vapour, the type of work to be carried out and any other requirements specific to the wearer like the need to wear spectacles.

What is face fit testing?

Face fit testing is a quick and simple way of assessing whether tight fitting RPE does or doesn’t create an effective seal around the wearer’s face. If the seal is imperfect, it does not protect the wearer.

When RPE is deemed necessary for a particular job, this is the best time to carry out face fit testing. At this early stage, the wearer can be offered a choice that suits him or her. The employer must ensure that that the make, model, type and size of equipment which they wore during the testing, is made available for their use. If an employee is asked to wear more than one type of facepiece then each one should be fit tested.

Employers must be aware that CE (“Conformité Européene” or “European Conformity”) Marking on RPE does not automatically make it suitable for a job. Selecting the right RPE and face fit testing is still essential.

During the test, a series of short exercises are performed to simulate the wearer’s movements during a normal working day which allows the facepiece to be assessed under realistic conditions. Any other personal protective equipment that is worn at the same time as RPE, must also be worn during the testing to ensure that safety helmets, safety spectacles or visors or ear defenders do not interfere with the correct wearing of the facepiece.

A repeat face fit test should be carried out if the wearer loses or gains weight, undergoes any substantial dental work or develops any facial changes (scars, moles) around the area of the face where the seal fits. In the US annual retesting is mandatory and every other year in Canada.

Who does the testing?

The fitting of RPE and conducting the fit testing should be carried out by a fully qualified, competent and experienced person who has received the appropriate training. The British Safety Industry Federation (BSIF) runs a scheme for face fit testers and provides a lot of useful information for employers, testers and employees. The testing must be documented and records must be kept for at least five years. To be clear, it is the responsibility of employers to understand when RPE is necessary and to provide essential face fit testing by qualified testers.

Facial hair

Beards and stubble have become more and more popular in recent years and here we have a problem. Many masks rely on a good seal against the face so that when the wearer breathes in, the air passes through the filter where the air is cleaned. If there are gaps around the mask then “unclean” air will be breathed into the wearer’s lungs, negating the purpose of the mask.

The performance of tight-fitting masks depends on achieving a good contact between the wearers’ skin and the seal of the mask. A poor fit will significantly reduce the protection that the RPE can provide, resulting in the possibility of the wearer’s health suffering or their life being in danger.

It is judged therefore that the presence of stubble and beards prevent a good seal of the mask around the face. Those who are clean-shaven will be much more likely to have a good seal, preventing leakage of contaminated air.

Is face fit testing done?

It appears that there are many employers who do not comply with the current legislation.

Following multiple surveys of relevant organisations, the most fundamental problem was that a large number of businesses or individuals using tight fitting RPE, did not carry out fit testing; a significant proportion of those asked had not even heard of face fit testing or did not agree that it was relevant to their work activities.

These findings strongly indicate the need to improve awareness, understanding and implementation of face fit testing.


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