WOW! The complaints from the field are overwhelming. The equipment that was purchased is wrong. An employee was injured. The equipment was substandard. How can NFPA 70E® allow such things? What is the subject of this discussion? Compliant PPE. NFPA 70E has a requirement that the employer provide the employee with appropriate PPE. How do you know what is appropriate? Appropriate is not only concerned with the claimed equipment rating but that the PPE has the ability to perform as needed to protect the employee. You are likely aware of PPE that is not only labeled incorrectly but also labeled as conforming to a standard when in fact the PPE does not conform. There are many pieces of PPE available that are counterfeit. How do you verify that the PPE really has been tested and conforms to the applicable standard? Even when something appears to be labeled correctly how do you know it is valid or that the standard stated is the correct one?
Past NFPA 70E editions had a requirement that the PPE conform to specific listed standards. The 2018 edition will still require that PPE conform to appropriate standards but will provide reference to several standards in informational form. Manufacturers of PPE have not been required by any NFPA 70E edition to evaluate their equipment to a standard. This means that YOUR ROLE IN SPECIFYING PPE HAS NOT CHANGED IN ANY WAY. Whether you realized it or not NFPA 70E has required that YOU verify conformance without telling you how to do it. YOU are still responsible for doing what you have done for several years. YOU are still the one who must make sure the appropriate standards for the specific PPE have been followed and that the PPE has been proven to meet the requirements. YOU are still the one responsible for providing PPE that will prevent the death of your employee when an incident occurs. YOU are still the one who must approve the PPE before you distribute it to your employees.
How do you do to determine that the PPE that you purchased complies with specific standards before being given to your employee as their last line of defense for limiting the severity of an injury. Are you even aware that there are standards addressing this? Did you purchase those standards to learn what they covered? Do you compare the PPE that you purchased to the standard to determine that it actually conforms? Do you just accept whatever the label states? Do you ask the manufacturer for something regarding compliance to any standard? Do you accept whatever the manufacturer sends without question? Do you know what is covered by the standard that the manufacturer claims compliance to? Do you conduct your own tests? This list could go on and on. But the point is regardless of what edition of NFPA 70E you use, YOU were and still are the authority having jurisdiction (AHJ) when it comes to approving PPE for your employees. YOU are the one who must decide what the appropriate PPE to purchase is and verify that the appropriate standard was used for the evaluation of that PPE. You do not have to accept anything that does not seem correct. No standard or code forces you to approve any specific piece of equipment even if it is listed by a third party.
Who verifies that PPE conforms to a standard? Does a claim equate to conformance? What does it all mean? In the past, NFPA 70E did not provide you with guidance on things to ask for. So what do YOU do now? The manufacturer may have provided a label on the PPE. They may have sent a letter stating that the PPE conforms to a standard. The manufacturer probably did not provide anything unless you specifically asked for it. Have YOU ever asked? The 2018 edition will require that the PPE manufacturer be able to provide you with one of three forms to address PPE conformity. YOU must ask for it. If a document is supplied, YOU must verify the truth behind that claim. Whatever method you use to verify the compliance, YOU are responsible for approving the PPE. This has been YOUR ROLE since PPE was first addressed in NFPA 70E. Regardless of the method you use for approving the purchase of PPE, the goal is to provide protection for the employee who is put a risk of injury when authorized to perform energized work. Your employee will trust that YOU have done all of this for them.
Next time: Do you mind getting a really bad sunburn.