Certification of Personal Protective Technologies: Improving Worker Safety

1. Certification of Personal Protective Technologies: Improving Worker Safety NPPTL Briefing to ISEA Board of Trustees Les Boord, Director Maryann D’Alessandro, Associate Director for Science February 3, 2011

2. Objectives of Meeting • Discuss approaches to obtaining common ground between NIOSH and ISEA • Review the recommendations provided in the IOM Report • Describe strategy for addressing recommendations

3. Organizing and Operating Philosophy: “First, do no harm.” The committee recognizes that many conformity assessment processes already in place can fit this framework.” (p. 114, IOM report) “The expanded list of certified equipment could link to lists of certified equipments from accredited third-party organizations.” (p. 122-123, IOM Report)

4. National Academies Review of PPT Program (2008)Recommendation 1: Implement and Sustain a Comprehensive National PPT Program • Oversee, coordinate, and where appropriate, conduct research across all types of occupational PPT and across all relevant occupations and workplaces; • Participate in policy development and standards setting across all types of occupational PPT; • Oversee all PPT certification in order to ensure a minimum uniform standard of protection and wearability. The National Program should collaborate with other relevant government agencies, private-sector organizations, and not-for-profit organizations to conduct an assessment of the certification mechanisms needed to ensure the efficacy of all types of PPT; and • Promote the development, standards setting, and certification of effectively integrated PPT components and ensembles in which multiple types of PPT (e.g., eye protection, hearing protection, respirators) can be effectively and seamlessly worn together.

5. IOM Report: Certifying Personal Protective Technologies, 2010 • Recommendation 1 - Develop and Implement Risk-Based Conformity Assessment Processes for Non-Respirator PPT • Recommendation 2 - Enhance Research, Standards Development, and Communication • Recommendation 3 - Establish a PPT and Occupational Safety and Health Surveillance System

6. PPT Conformity AssessmentRisk Based Approach • PPT WITH A LOW DEGREE OF POTENTIAL IMPACT • Require first-party declaration by the manufacturer that the product meets the standard • Specify the standards to which the product must comply • PPT WITH A HIGH DEGREE OF POTENTIAL IMPACT • Provide oversight to any technical issue that may arise and assist the certifying organization in the enforcement of the conformity assessment process • Develop and implement a Tracking Labels system • PPT WITH A MEDIUM DEGREE OF POTENTIAL IMPACT • Require third-party testing and certification by accredited entities • Develop and maintain an online resource that provides access to lists of all certified products with Medium and High degrees of risk….Provide links to listings of certified products from third-party private-sector certifying organizations as well as to similar databases in other agencies

7. The status of conformity assessment in the US • US does not require that most PPE be independently tested and certified.   • Respirators require government testing and certification by NIOSH • Third-party certification is required in fire and emergency service standards from NFPA • Other workplace PPE such as safety glasses, hard hats and fall protection may be tested by manufacturer to show conformance to the standard

8. The status of conformity assessment in the US • Manufacturers develop products to meet consensus standards • Checks and balances in place through litigation • Current legal processes do not penalize for false claims

9. What is the challenge? • Need consensus regarding added assurances needed to demonstrate that products meet standards to which they are marked. • Is assurance beyond first party certification necessary? • What is the federal agency role in the process? • What are the barriers? • What is the user community willing to commit to support a different process?

10. A Draft Strategy to Address the Recommendations • Outline a plan • Review conformity assessment approaches • Define list of key stakeholders for individual meetings/briefings/partnerships • Conduct individual stakeholder meetings • Develop criteria to evaluate standards and conformity assessment processes • Post public request to participate to NIOSH docket • Determine strategy and prepare draft action plan

11. Recommendation 1 Actions • Define types of non-respiratory occupational PPT, with sub-categories as to specific user applications • Define tiered, risk-based conformity assessment methodology, incorporate other feasibility factors resulting in a classification system for Low, Medium, and High Risks • Apply the conformity assessment methodology to each type of PPT to determine its risk classification • Determine the existence and quality of conformity assessments for each type of PPT • Identify gaps for types of PPT with Medium and High risk classifications • Prioritize importance of gaps and develop strategy to address them • Implement strategy to address gaps

12. Recommendation 2 Actions • Document current standards development participation and identify and prioritize gaps • Expand participation in SDOs to address prioritized gaps • Initiate gathering of information to expand respirator trusted source page to include non-respiratory PPE links to current resources • Develop non-respirator PPT clearinghouse site • Develop a strategy to address PPE interface issues

13. Recommendation 3 Actions • Continue efforts to develop a Demonstration and Sentinel System for healthcare • Continue efforts in the Agriculture sector to identify needs for pesticide handlers • Explore existing surveillance systems • Explore partnerships with agencies such as CPSC, ITA, and FTC

14. Some near term actions • Begin discussions with stakeholders • Initiate strategy to expand Respirator Trusted Source site for non-respiratory PPE • Establish collaboration with CPSC

15. ISEA New Voluntary Standard for Conformity Assessment How can we learn more?

16. Questions

17. Quality Partnerships Enhance Worker Safety & Health Visit Us at: http://www.cdc.gov/niosh/npptl/ Disclaimer: The findings and conclusions in this presentation have not been formally disseminated by the National Institute for Occupational Safety and Health and should not be construed to represent any agency determination or policy. Thank you