Coordination of Notified Bodies for PPE
Considering the European Vertical Group 10, which deals with issues involving foot and leg protectors.
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The European Directive 89/686 for personal protective equipment (PPE) covers products designed to offer protection to the wearer’s feet, such as safety footwear. The primary purpose of the directive is to break down barriers to trade within the EU by harmonising safety standards. Prior to its introduction, manufacturers wanting to sell products in several European countries were required to test the product against each country’s national standard.
Since the inception of the PPE Directive and the single European market, these national standards have mostly been replaced by new pan-European standards that are created by European technical committees and then translated into the various European languages before being published. This has gone a long way towards standardising test and certification procedures, and allows a product tested and certified in one country to be sold throughout Europe.
The now familiar symbol is affixed by the manufacturer to declare conformity and, thereby, permit free movement of goods. However, there is still some way to go and, although all member states are now working to the same base documents (such as EN ISO 20345 in the case of safety footwear), these still include many ambiguities and have critical information missing.
As part of the European certification procedures that support CE marking to the PPE Directive, there is a requirement for Notified Bodies (see box 1) to coordinate their activities, so that where possible any differences in interpretations can be discussed and a common approach agreed. The main mechanism for the arrangement of this activity is through committees that are commonly referred to as ‘Vertical Groups’ (VGs). The role of these VGs is to promote communication and coordination between the various Notified Bodies that carry out test and certification activities throughout Europe, in an attempt to reduce inconsistencies that can occur.
|Box 1: Notified Bodies
|Notified Bodies (NBs) are EU-based organisations which, on the basis of their ability to carry out the examinations and tests required for CE marking of PPE, have been appointed by the government of that country and notified to the EU Commission. SATRA is a Notified Body for most types of PPE, including safety footwear.
There is a vertical group for each main product sector – for instance, VG1 covers head protection and VG10 covers foot and leg protection. These deal with issues specific to a particular product. Issues that relate to more than one product sector are discussed by a Horizontal Group, which coordinates the activities of the Vertical Groups.
In general, development of a recommended solution is a two-stage process that starts with the generation of a ‘proposal for enquiry sheet’. After a period of discussion and comment, this usually progresses to production of a ‘Recommendation for use sheet’ (RfU). If the question is felt to be unnecessary or no answer can be found, no RfU sheet will be produced. To date, VG10 has produced over 180 RfU sheets. As recommended solutions to a particular problem, the decisions made by the Vertical Groups are not binding, although there is some pressure on the Notified Bodies to treat them as such.
Each Notified Body is at liberty to decide whether or not it agrees with a particular recommended solution. Where appropriate, however, these recommended solutions are circulated to the relevant CEN technical committee so that they can be taken into consideration when the product standard is revised. Therefore, they provide a possible insight into future development of a product standard.
In order to make sure our knowledge and experience is always kept fully up-to-date, SATRA attends all such meetings covered by our Notified Body scope. SATRA delegate Peter Doughty currently chairs VG10, with the most recent meeting having been held in Helsinki during May. At this time, a total of 19 proposals for enquiry sheets were discussed, and this led to seven new RfU sheets being agreed. These RfUs covered topics such as clarification of slip resistance test procedures, marking requirements, overshoes, testing of foundry footwear and procedures for certification of orthopaedic footwear. The group also agreed to organise an interlaboratory trial on water absorption testing of insole materials. The next meeting of VG10 is planned for March 2014, where further questions will be discussed.
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This article was originally published on page 12 of the July/August 2013 issue of SATRA Bulletin.