The recent Coronavirus outbreak has led to discussion about how individuals can help to protect themselves from infection. What about the workplace? The basic function of any PPE is, of course, to provide protection to a worker, whatever their employment setting - from hard hats and boots on building sites; to face masks and gloves in healthcare.
The Health & Safety Executive (HSE) last week published its December 2019 report RR1147 - Evaluation of existing PPE worn by NHS staff for assessment of a patient with a suspected high consequence infectious diseaseon its website. The HSE website specifically advises that this research is NOT about Coronavirus and directs healthcare professionals to guidance on COVID-19 here. However, the report is a timely reminder of the importance of ensuring PPE is effective in a healthcare setting.
Research by HSE
The subject of the report is PPE used for suspected high consequence infectious diseases (HCID), such as Ebola. To address this, HSE and Sheffield Teaching Hospitals NHS Foundation Trust developed a tool known as Visualising Infection with Optimised Light for Education and Training (VIOLET), to test PPE and to train healthcare workers.
The research identified that PPE worn by healthcare workers to protect them from conditions such as Norovirus and Flu - including face masks, aprons and gloves - was not protective if worn when dealing with a patient with an HCID. In addition, a variety of existing PPE used when treating suspected HCID cases showed weaknesses or potential for contamination, either when wearing or removing the PPE.
The HSE group therefore developed a "HCID assessment PPE" model, considering the strengths of existing PPE, and procedures for applying and removing the equipment. It found the new model "would be protective if worn when assessing a patient with a suspected HCID, even with minimal training provided to the wearer". It was also noted that supervision was helpful for preventing contamination when PPE was removed, and that the VIOLET system was effective in training users in PPE.
What can we take from this report?
The report is a helpful reminder to the healthcare sector - and other industries - of the importance of ensuring PPE is appropriate and effective for all relevant risks. The Personal Protective Equipment at Work Regulations 1992 require employers to provide suitable personal protective equipment to employees. Protective equipment, while very effective in one context, may not be suitable or sufficient when dealing with a different risk.
PPE is required by the Regulations "except where and to the extent that such risk has been adequately controlled by other means which are equally or more effective". PPE is often an employee's first line of defence, and it is essential that it is used; but, from an employer's perspective, it is important to also consider more widely whether other measures could be put in place, to minimise the risks to employees as far as possible.
The Regulations specify that PPE should also be regularly assessed, maintained and replaced (Regs 6 & 7); stored appropriately when not in use (Reg 8); and, where multiple items of PPE are required, they should be compatible and continue to be effective against the risk (Reg 5). This is not always the case and it is important that employers are aware of the potential for overlap or conflict between items of equipment.
Finally, employees should be provided with suitable training to ensure they know how to use PPE properly (Reg 9). As highlighted by the HSE research report, it is not only important to provide employees with PPE, but also to provide effective training on how to use it, and wear it, to best protect themselves from risks in their workplace - wherever that may be.
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Practice Development Lawyer
