Find out about shortages of personal protective equipment (PPE), requirements under health and safety legislation and what to do if stocks are running low in this briefing from NFU farm safety and transport adviser Tom Price.
Many activities in farming require the use of personal protective equipment (PPE) to protect the health and safety of workers. In the poultry sector there is a need to protect workers from health risks arising from poultry dust. Poultry dust is composed of a variety of airborne particles ranging from pure wood dust to a complex mixture of organic and inorganic particles. Across a wider range of food production sectors, it is estimated that there is a need for 200,000 FFP2 and FFP3 face masks each week. This is a business as usual requirement and is not connected in any way to protection from risks associated with the outbreak of COVID-19.
From 1st May until 31st July 2020, all PPE purchased by care homes, businesses and individuals to protect against COVID-19 will be free from VAT.
Is PPE in short supply?
Yes there is a shortage of PPE, not just in the UK but globally. Most PPE used in the UK is imported with the majority supplied by China. Much production in China is centred on Wuhan and Hubei. The response of the Chinese authorities to the COVID-19 outbreak and the lock down in China in January substantially reduced the amount of PPE entering the global supply chain causing a world shortage of PPE. In March, as COVID-19 spread across the world, several countries including France, Germany, Italy and the Czech Republic imposed export bans on PPE equipment further limiting supply to the UK. Demand for all types of PPE in the UK and in particular for FFP2 and FFP3 masks has massively increased as a result of COVID-19 and the need to protect front line workers in hospitals and other care settings.
The disruption to the global PPE supply chain has caused wide uncertainty over supply lead times. A number of the larger PPE distributors stopped taking orders from new customers in March or orders above a normal business as usual level in order to avoid stock piling and unfairness to other customers.
The government has taken significant action to ensure that PPE is used correctly where most needed and in sourcing supplies of PPE to the health service and other care providers by:
- Publishing guidance on the appropriate use of PPE in health care and other settings
- Establishing a dedicated logistics system to supply the health care sector
- Looking to secure future supply both from imports and the creation of a UK based manufacturing capability.
Requirements under health and safety legislation
Under the Control of Substances Hazardous to Heath Regulations 2002 (COSHH) employers have a duty to control substances that are hazardous to health. Wherever possible, risks to health should be removed but where this is not possible control measures including the use of PPE should be used.
It is important to note that, even though the current supply of PPE may be limited there is no relaxation to the COSHH regulations, and the requirement that PPE is provided and used where a risk of harm has been identified and it can not be removed through the use of other control measures.
The duty of employers to take reasonable steps to safeguard the health and safety of employees remains unchanged.
What can I do if stocks of PPE are running low?
Review risk assessments
The need to use PPE should only arise after a risk assessment has identified substances harmful to health and that steps to remove the risk completely are not possible. The level of PPE should be appropriate to the level of risk identified. A review of risk assessments may identify ways either to engineer out a particular risk or that a different level of PPE is more appropriate to manage the risk identified.
Steps to preserve available stocks include:
- Only providing PPE to workers who need it
- Issuing PPE specific to the level of risk e.g. only use FFP2 masks where the risk assessment has identified that FFP2 is required
- Maximising the use life of PPE by following manufacturer user checks, cleaning and storage instructions
- Reminding staff of the reasons why PPE is used, the need to use PPE appropriately and the need to treat equipment that is in short supply with respect
If possible, ensure you maintain a dialogue with your usual supplier, planning as to how long
your current stocks are expected to last and if required seek an alternative supplier. In March a number of larger PPE suppliers did stop accepting orders from new customers and limited
orders from existing customers. We have been informed that some suppliers are now accepting new customers but are reviewing orders and allocating stock firstly to the healthcare sector and then to priority sectors such as food production.
If you are looking for an alternative supplier you must be wary of online scams, purchasing
substandard products or products with false certifications.
- If a deal is too good to be true it is likely not true.
- Buy from a reputable supplier. A good way to find a reputable and trustworthy supplier is to check on the British Safety Industry Federation website for suppliers who are members of their accreditation scheme.
- Only buy equipment which is CE marked. All masks used as work equipment need to be CE marked. The CE mark on a mask tells you that it has met the minimum legal requirements for its design. The mark is composed of the letters ‘CE’ and then a four digit code which identifies the body that has checked the manufacturing quality. However, do not rely on the CE mark alone; CE marks have been forged by some unscrupulous scammers– always buy from a reputable dealer.
Is it ok to use homemade masks?
If a risk assessment has identified that a FFP 2 or FFP 3 mask is required to safeguard the
health and safety of workers and protect them from hazardous substances is it not ok to use a homemade mask. This is because a homemade mask will likely not meet the quality standards set out in the legally required standard. A copy of the legally required standard/specification is available here.
What is the NFU doing?
The NFU is working with other industry stakeholders to monitor the supply of PPE to the food sector. We are also working with other stakeholders in liaising with government, to prioritise the availability of PPE to essential roles in the food sector, while recognising the vital need to protect front line workers in the NHS first.
We also support activity by government and industry to create a UK based PPE manufacturing capability.
Where can I get information on my obligations as an employer to supply PPE?
- Information on the control of hazardous substances is available here.
- General information on PPE is available here.
- Information specific to the control of poultry dust is in HSE agriculture information sheet 39 available here.
NFU members can obtain further information and advice from CallFirst on 0370 845 8458.