CE marking on workwear prompts questions20-04-2010
Is CE marking on workwear justified or can we speak of misleading information here?
This would appear to be a question to which only a nuanced answer is possible. Clearmark has done a search and put its findings down on paper.
CE mark required by law
CE marking on protective clothing is required by law because protective clothing is regarded as part of personal protective equipment (PPE). For the definition of PPE see box.
On these grounds protective clothing must conform to Directive 89/686/EG and to national legislation of the same type. If a piece of PPE – therefore protective clothing – satisfies the requirements of Directive 89/686/EC then it has to carry the CE mark.
It does not matter whether the product has been approved by a notified body. If it can be said that a so-called Category 1 PPE is involved, an approval process of this kind (an EG type approval procedure) does not apply, whereas this is the case for category 2 and 3 products. .
Grey area ensures an inflation of the CE mark
At first sight, working clothes would seem to have a function different from that of protective clothing and do not usually serve to afford protection against a clear and specific risk, and yet there would seem to be on the market a great many working garments that carry the CE mark.
It is possible to reason that workwear carrying the CE mark are seen by their manufacturers as protective clothing and are put on the EU market with that in view. We can, for instance, think of clothing that offers protection against contact with dust and dirt.
And thus by applying the CE mark the manufacturer is in conformity with the requirements that flow from – in this case – Directive 89/686/EC, which is seen as applying here.
This therefore means that just like other PPE workwear is not only fitted with the CE mark but must also conform to current standards such as EN 340 (general requirements for protective clothing).
And if the working garment offers protection from a risk that does not fall under category 1, there is also the obligation to submit it to an EC type approval procedure. What does fall under category 1, for example, is protection against mechanical factors that only cause surface damage (gardening gloves, thimbles etc.). Workwear should also fall under this category.
A further requirement is that CE marked workwear must be provided with user instructions in at least the official language of the EU country in which it is sold (EN 340, paragraph 8).
In practice this is not consistently done and often, for example, there is no user instruction.
CE marking on workwear is therefore a ‘grey area’ in the PPE field because manufacturers do not follow all the requirements of the directives and thus contribute to the inflation of the CE mark.
It would be a good deal better if manufacturers clearly indicated why their clothing is fitted with a CE mark and also ensured that all requirements involved in CE marking have been met.
For the purposes of this Directive, PPE shall mean any device or appliance designed to be worn or held by an individual for protection against one or more health and safety hazards.
PPE shall also cover:
(a) a unit constituted by several devices or appliances which have been integrally combined by the manufacturer for the protection of an individual against one or more potentially simultaneous risks;
(b) a protective device or appliance combined, separably or inseparably, with personal non-protective equipment
worn or held by an individual for the execution of a specific activity;
(c) interchangeable PPE components which are essential to its satisfactory functioning and used exclusively for such equipment.
Any system placed on the market in conjunction with PPE for its connection to another external, additional device shall be regarded as an integral part of that equipment even if the system is not intended to be worn or held permanently by the user for the entire period of risk exposure.
This Directive does not apply to:
- PPE covered by another directive designed to achieve the same objectives as this Directive with regard to placing on the market, free movement of goods and safety,
- the PPE classes specified in the list of excluded products in Annex I, independently of the reason for exclusion mentioned in the first indent.
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