HSE Inspectors now asking for Evidence of Fit Testing Competency

In the middle of June, 2010 the HSE's Operational Circular 282/28 was updated. Paragraph 4 in the introduction now states that "RPE fit testing should be conducted by a competent person. Competence can be demonstrated through achieving accreditation under the ‘Fit2Fit RPE Fit Test Providers Accreditation Scheme’. This Scheme has been developed by the British Safety Industry Federation (BSIF) together with industry stakeholders and is supported by HSE. The scheme is not compulsory and employers are free to take other action to comply with the law. One way employers can demonstrate good practice is by ensuring that the fit tester is appropriately accredited, for the type of service they offer, by the Fit2Fit scheme. Further details on the scheme can be found at the web site: http://www.fit2fit.org"

Operational Circulars are distributed to all HSE Inspectors and support staff and are in effect instruction sheets and checklists against which they conduct inspection visits and interviews. So what does this mean for people wearing respirators and for Health and Safety Managers?

For some time now there has been concern over the level of respiratory protection actually achieved by workers, even as part of well managed Respiratory Protection Management Plans. Argument has flowed back and to regarding how respiratory protection is, and should be, determined: The EU has developed regulations and standards defining the testing of new masks during development and there is a comprehensive CE Marking Strategy that allows managers to define the type of RPE they need to issue and the correct canisters that need to be fitted to protect against various industrial pollutants. All well and good, but such type approval testing is done on EU standard head forms and under rigorously controlled testing conditions. For years now (literally) experts have debated how the levels of protection defined by such testing relate to the real world conditions found in say a bakery, a paint spray shop, a nuclear power plant, a woodworking factory, or a pharmaceutical manufacturing site. Biological studies were done that traced the levels of pollutants in test subjects' blood or urine. These studies pretty well all showed that the theory was not being borne out by the practice- people were continuing to be exposed at levels far higher than was acceptable, or expected, from type approval testing results.

Then Fit Testing came along; first qualitative then quantitative fit testing. We started to realise that although developments in mask manufacture and materials have created highly effective masks, they were only so effective if they were on the right sized face and had been donned carefully. In the USA fit testing as a training tool has been in place for decades and several studies (the most detailed by was done by 3M over 20 years ago) that compared WorkPlace Protection Factors (the actual reduction in pollutant when comparing inhaled air and that outside the mask in the workplace) of workers who had been trained and Fit Tested to comparable groups of workers who had not been so trained and tested have all shown that Fit Testing as part of a training programme significantly increased the level of protection that workers achieved - from the same masks!

Fit Testing has been specified in UK Health and Safety Guidance and ACOPS(Approved Codes of Practice) for several years now but sadly, the initial effect may have been to actually lower some workers protection levels. The Fit Testing was sometimes not done properly, the results were not fully understood or their significance was not fully appreciated by those carrying out the testing. HSE Inspectors and Senior Researchers became concerned, along with others in the industry, that things needed to be done better and, along with the British Safety Industry Federation, developed the FIT2FIT Accreditation Scheme for RPE Fit Testers. The Scheme launched late last year (2009) and was endorsed by HSL Buxton's Topic Specialists. Steps were taken to close the loop by making evidence of competency mandatory and by editing OC282/28 to place a duty on visiting inspectors to ask for evidence of competency in Fit Testing.

So the loop is complete - Good respiratory protection can only be adequately delivered as part of a good training programme, which is validated by Fit Testing, which should only be delivered by competent Fit Test Specialists, who will have demonstrated their competency via the FIT2FIT scheme, which the HSE will want to see proof of- in order to ensure that employers are delivering good respiratory protection. Now, ask yourself, are you in the loop - or out of it? If you are out of it, you need to get onboard and soon. Apply for accreditation as a Competent Fit Test Specialist, then get yourself some refresher training - from a FIT2FIT Accredited Training Provider.

Does Your Fit Test Specialist have one of these? If not, make him get one or use someone who has