Legal provisions for sale of personal protective equipment, with particular focus on safety footwear

This post is also available in: German

The following provisions must be fulfilled in order to sell personal protective equipment (PPE) in the European Union (EU).

At European level, the relevant legislative framework is established by EU Directive 89/686/EEC. This Directive has devolved into national legislation in the individual states through a series of country-specific laws. In Germany, these specifically include the Arbeitsschutzgesetz (German Employee Protection Act; ArbSG) and the Produktsicherheitsgesetz (Product Safety Act; ProdSG) as well as other laws and regulations.

The EU Directive was adopted in 1989, thereby setting down a standard legal provision applying to all members of the EU. One objective was to establish a European market for personal protective equipment. European norms were subsequently generated, which were harmonised through publication in the Official Journal of the European Union and then republished by national standards committees with identical content. At the same time, national standards that undermined the ideal of a single market were withdrawn.

European law classifies personal protective equipment into three different categories. Depending on the category, different conditions have to be met for the sale of a PPE product. Category I covers “simple design” PPE, “where the designer assumes the user can assess the level of protection provided against the minimal risks concerned”. For example, this includes gardening gloves. PPE products in Category III are “complex design”, “intended to protect against mortal danger or against dangers that may seriously and irreversibly harm health”. This includes respirators with filters or fall arrest equipment. All other PPE products are allocated to Category II, “intermediate design”, including the standard industrial use safety footwear in protection classes S1, S1 P, S2, S3, S4 and S5. Before they can be placed on the market, these products are subject to an EC-type examination by a Notified Body, a testing laboratory. EU member states designate and monitor these Notified Bodies, which must prove on a regular basis that they are suitable and have the necessary facilities (test equipment and competent personnel) for carrying out certification.

If the type examination, also known as certification, proves that the tested product has been assessed and examined against the harmonised standard, a presumption of conformity is issued declaring compliance with the requirements of the above EU Directive. Consequently, successful certification of a safety shoe model in accordance with EN ISO 20345:2011 grants the manufacturer permission to distribute the safety footwear in all EU countries on issue of a declaration of conformity based on the type examination certificate.

The following harmonised standards currently apply for footwear (extract):

EN ISO 20344:2011
Personal protective equipment — test methods for footwear

EN ISO 20345:2011
Personal Protective Equipment — Safety footwear

EN ISO 20347:2012
Personal protective equipment — occupational footwear

EN ISO 20349:2010
Personal protective equipment — footwear protecting against thermal risks and molten metal splashes as found in foundries and welding — requirements and test method

Every pair of safety shoes must be labelled according to applicable guidelines and supplied with user information. Safety footwear should be labelled as follows:

label_safety_footwear_en

The user information of safety footwear explains the labelling, use exceptions etc.

In general, a distinction is made between basic and additional requirements for safety footwearBasic requirements are obligatory for all safety footwear and specifically comprise qualitative guidelines for the materials being used, especially toe caps, the design and production technology.

A further requirement relates the the non-slip properties of safety footwear. The footwear must fulfil specific minimum requirements for the coefficient of friction based on a specified combination of floor surfaces and lubricants. Depending on the floor surface, the footwear is labelled as SRA, SRB or SRC.

safety_footwear_en

Additional requirements must be fulfilled if extra safety footwear features are necessary for an area of application in addition to the basic requirements. The current safety footwear norm defines 13 different additional features, which are each represented by a symbol in the aforementioned classification.

Labelling Description
P Penetration resistance
C Conductive footwear
A Antistatic footwear
HI Insulation against heat
CI Insulation against cold
E Energy absorption in the heel
WR Watertightness
M Extra protection of the middle part of the foot
AN Extra ankle protection
CR Cut resistance
WRU Upper material is resistant against penetration and absorption of water
HRO Sole is resistant against heat during contact
FO Fuel oil-resistance

 

As it can be relatively difficult to maintain an overview of the various symbols in the footwear labelling, the standard includes abbreviations that each represent a common combination of additional requirements. Alongside the SB abbreviation for the basic requirements, these are colloquially referred to as safety footwear protection classes S1, S2, S3, S4 and S5.

 

The following table shows the footwear properties for each abbreviation:

Abbreviation Description
For all footwear
SB Basic requirements for safety footwear
Footwear made of leather or other materials
S1 Basic requirements for safety footwear+ Fully enclosed heel area+ Antistatic properties (A)+ Energy absorption in the heel (E)+ Fuel oil-resistant outsole (FO)
S2 As S1, plus+ Upper material is resistant against penetration and absorption of water
S3 As S2, plus+ Penetration resistance (P)+ Cleated sole
For all-rubber or all-polymeric types
S4 Basic requirements for safety footwear+ Fully enclosed heel area+ Antistatic properties (A)+ Energy absorption in the heel (E)+ Fuel oil-resistant outsole (FO)
S5 As S4, plus+ Penetration resistance (P)+ Cleated sole
For hybrid footwear(This relates to polymeric footwear incorporating another material, such as leather, constituting the upper)
SBH Basic requirements for safety footwear

 

Additional requirements that are not covered by the abbreviations are otherwise identified through further symbols. For example, the S1 shoe that is also penetration-resistant resistant is labelled S1 P.

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