I sat down with our CE Technical Manager, Dominic Rumble, and BSiF’s Registered Safety Supplier Scheme Manager, Roy Wilders, to discuss how BSiF and Lakeland work together to achieve common objectives.
The task of ensuring and improving the protection of workers against workplace hazards is an ongoing and, let’s face it, never-ending process.
The development and design of plant changes with the recognition that the best approach to safety is, where possible, to remove the hazard and risk entirely (often in new facilities there's little need for PPE). However, as technology changes, so too do the demands of keeping people safe. As a result, safety requirements have become more complex, resulting in existing standards being changed and new ones developed. In other words, maintaining awareness of hazards and ensuring effective PPE is used at all required times is (and will always be) an "ongoing" task.
So where does the British Safety Industry Federation (BSiF) fit into this process, and how can manufacturers of premium PPE (like Lakeland) work with them to continue this process and, at the same time, benefit from it?
I sat down with Roy Wilders, BSiF’s Registered Safety Supplier Scheme Manager, and Dominic Rumble, Lakeland’s CE Technical Manager, to discuss this, and other issues
Q. What are the objectives of BSiF and Lakeland?
Roy Wilders (RW):
"BSiF’s mission is to support those who keep people safe and healthy at work to ensure that safety and health are positive forces for good.
We do this by helping to enhance the quality of PPE, Safety Equipment and Services in use. We also eliminate the use of unsafe or unsuitable PPE. It's a continuous process of improving awareness of hazards and how to effectively protect against them.
Our process includes improving the knowledge of those selling safety equipment in the UK (which we do through our Safe Supply Accreditation – a nationally recognised qualification in ‘Safe Supply’). To achieve this, we work on several different levels – including working with manufacturers such as Lakeland."
Dominic Rumble (DR):
"Lakeland’s key strapline is “Protect Your People”. We protect people against life-threatening hazards through chemical and heat protective clothing. That's what we do. So whilst we are a commercial manufacturing organisation (whose primary objective must be to generate income for our stakeholders) one of the ways we protect people – especially given the premium nature of many of our products – is by improving awareness of hazards and knowledge of standards, ensuring people use appropriate PPE. By doing this, we encourage users to understand that buying the cheapest is not always the best option, so they come to us for solutions to their protective requirements. In this sense, our objectives coincide quite nicely with BSiF’s."
Q. How do you go about achieving that?
"We focus our attention on three essential areas. The first is the Registered Safety Suppliers Scheme [RSSS]. This scheme involves us visiting the premises of our members annually and conducting a spot check audit. We will ensure that:
1) all CE related documentation such as Certificates and Technical Files are in order,
2) that the products are certified as claimed and
3) that all products continue to meet the requirements of the various CE standards.
This provides a recognised route for manufacturers to demonstrate compliance with due diligence and that they discharge their obligations as an economic operator in the marketplace under PPE Regulation (EU) 2016/425.”
Q. It sounds like just another layer of certification.... sort of “Certifying the certification”. Is it really necessary?
"I suppose that is true. It is certifying the certification, but even after more than 20 years of EU law requiring PPE to be certified, there are many users in the marketplace using counterfeit or uncertified products. These products may appear to be certified to the uninformed user, but they are often counterfeit or not actually certified; they just carry an apparent "CE mark" but have never been anywhere near a certification process. We see this not only in regions outside Europe, but also within Europe itself. It can be difficult to challenge it. So there's a clear benefit to this 'additional layer' of certification.
Also, given that the new PPE Regulation (replacing the old Directive) makes it mandatory for all in the supply chain, including distributors, to undertake due diligence to ensure product performance and certification are as they should be, this is an additional reassurance for our customers.
But the existence of counterfeit PPE also means that users are sometimes reluctant to simply accept a product is certified because the label says it is. There has been an increasing tendency for users to request copies of not only Declarations of Conformity, which we are legally obliged to provide, but also of the CE certificates and the myriad of test reports that are part of the certification process – which we are not obliged to provide. Our policy is to make certificates easily available along with Declarations of Conformity on our website. When test reports are requested however, sometimes we will acquiesce, but doing so can open up a can of worms as reports are not easy to interpret unless you understand what you are looking at. Sometimes test reports just confuse users further.
So the RSSS scheme, which does have an additional minimal cost on top of standard membership (though I do think it is worthwhile), provides further assurance for users that our products are properly certified. It allows us to add the BSiF RSSS shield onto all our literature, reassuring customers and making our lives a little easier in the process."
Q. You suggest that users are commonly unable to recognise whether PPE is certified or not? How widespread is that?
"You’d be surprised. Even in Europe there are plenty of users who are not entirely clear on what to look for on a label to confirm it is certified. Outside Europe it’s very common. This matters because, with the possible exception of North America, much of the rest of the world is increasingly specifying CE certified products. This is, of course, a good thing – but less so if people do not know how to differentiate certified and uncertified products!"
"In fact, a couple of years ago – before I joined BSiF – I know we worked on a joint piece of literature to address this very issue. Your Director of International Marketing had spent some time in India and had seen a number of products – sometimes from major manufacturers – which appeared to the uninitiated to be certified but were not. He spoke to several major end users, all of whom were shocked to discover that the products they were using were not actually certified when they were sure they were.
So, we worked together on a single piece of literature which was designed to explain how to recognise properly certified PPE, as well as how to follow and check the certification with the relevant authorities. We were happy to be involved; it was a good example of BSiF and Lakeland’s objectives coinciding, so working together on a project to address it made sense."
Q. So you mentioned there were three areas of work you focus on?
"Yes. The first was the RSSS scheme. The second is providing manufacturers with a market monitoring service – a system to help route out and address products in the marketplace that:
1) do not meet the requirements of product performance as laid down in standards or
2) where manufacturers are not discharging their responsibilities under the PPE regulation.
Where members find products in the market which they suspect have questionable certification, or where they believe a claim made in literature is not correct, they can forward the details to us and we'll contact the manufacturer. In the worst case, this might result in a product being removed from the market, but in the majority of cases it amounts to us drawing a manufacturer's attention to it and them putting it right by revising the claim or changing whatever needs to be changed."
Q. Does that actually happen? It’s a nice objective but what’s the reality?
"Indeed it does. In fact, I recently forwarded to Roy the details of a product one of our sales team came across that I had severe doubts about. I can’t go into details here, of course, but I know Roy’s team is addressing it – and if it proves our concern was correct, something will be done. It’s another benefit of BSiF membership – knowing that when we do come across product which might be a little “dodgy”, something can be done. “Dodgy” often means “cheap” – so in practical terms it helps us compete where otherwise it would be difficult to. In the past – before BSiF membership – that was always a real frustration.
It works both ways, of course. Roy recently brought to my attention an issue with a claim being made against our new Pyrolon CBFR coverall – the claim being that it does not provide the level of heat protection suggested in our literature. I was happy to be able to provide all the test and certification information to prove that what we say about the product is quite correct.
That mechanism in the market can only be a good thing; it allows users and manufacturers to question products they see and have doubts about, and for something to be done about it quietly and without fuss. As a manufacturer following the rules – or at least doing our best to – we have nothing to fear. For manufacturers not so willing to do the right thing, well… you have to say it’s good to know someone is there to do something about it."
- OK, so the RSSS, policing the market… what’s the third area of cooperation?
"Ah... now that’s the really interesting one. That would be taking part in the BSiF Special Interest Group meetings! What great fun that is!"
Q. Group Meetings?
"There are regular meetings of Special Interest Groups orientated around specific product types. The objective is to ensure that members are kept up to date regarding ongoing developments and upcoming changes in standards. Many of our members sit in the various working groups involved in the continuous process of reviewing and updating standards, so the group meetings are an opportunity not only for members to keep abreast of changes coming up, but also to make comments on planned changes which are then fed back to the various working group committees. This gives our members a valuable mouthpiece into the development of standards – an opportunity to send a message saying: “this is great – carry on” or if necessary: “you can’t do this! It simply won’t work because…” and so on."
"No sane person enjoys meetings. But these are actually useful and do make my job easier. Without them I’d spend half my time reading through web pages and journals. We deal with dozens of different CE standards, all of which might be in the process of being updated at any one time, so ensuring we are aware of upcoming changes that might affect us is quite a challenge. These meetings allow us not only to be aware of changes so we can anticipate rather than react – it also allows us an indirect voice into their development.
It can only be a good thing that manufacturers have a voice to ensure those writing the standards don’t include incorrect, excessive or unrealistic demands on product."
Q. I assume there is a cost to BSiF membership? Is it worth it?
"There is indeed. The cost is based on turnover."
"It's worth noting that as BSiF works on a non-profit basis, the funds paid are reinvested in activity."
"In that sense, the cost is an investment for us - yes - but I think it’s worth it. It’s difficult to quantify of course, but we get a number of advantages that probably reduce internal costs we would have otherwise. We also get to leverage expert knowledge we might not have internally, quick access to market surveillance, counterfeit product policing, an input into standard development through the meetings, prior warning of changes in standards, additional assurance for our customers in the form of the RSSS and so on.
Then there are the “soft” benefits: opportunities to network and find out more about best practice across the industry and the general benefits of being linked to an organisation like BSiF. It all helps to support our position of being the experts in chemical protective clothing. We like to say: “If you want to talk to the experts on chemical protection talk to Lakeland”. Being a BSiF member is just one of the things that enables us to say that with some justification.
And we can't forget the straightforward benefit of adding the RSSS shield to our literature. Some major end-users are now making that a requirement for suppliers, so whilst just a benefit now it could become vital in the future."
"From our point of view, by working with manufacturers in this way we gain access to specialist knowledge about specific products that we probably wouldn’t otherwise have. And there is, of course, no getting away from the fact that unless we work with manufacturers such as Lakeland, it would be far more difficult to achieve those basic objectives of enhancing safety and contributing to keeping people safe in the workplace. So one way of looking at it is not so much a question of what benefits we get out of it, but that we need good and effective partnerships with manufacturers such as Lakeland. The fact is... we can’t do without you!"
The British Safety Industry Federation and manufacturers like Lakeland working together can only be a good thing for the development of improved safety standards, increased safety awareness and the enhancement of Health and Safety at Work. If you would like to learn more, you can view a YouTube video presentation on the work of the BSiF here.