PPE Requirements according to ADR
Under ADR law the only items of PPE required are eye protection, warning vest, protective gloves, and an emergency escape mask if toxic product is being carried. We frequently get questions about whether other protection should be supplied and what standards the PPE should meet so this blog is written to help provide some answers and points for consideration.
Is there a specification for PPE according to ADR?
The only item of mandatory ADR PPE which has a specification is the emergency escape mask, which is required for drivers of vehicles containing toxic product. The regulations specify that the escape mask should meet ABEK1(or2)P3. The Government guidance makes the following points regarding the suitability of PPE being carried:
- ‘Mandatory Items for all vehicles (Wheel chocks, warning signs, pocket lamp, high visibility jacket, gloves, eye protection). It is not the role of the enforcement officer (VOSA or Police) to judge suitability of equipment. Concerns should be reported to HSE’
- Use judgement. E.g. only one item missing may justify written report (RC3). Several types of gloves or eye protection may be seen. Doubts about condition or suitability should be recorded without reference to risk and referred to HSE with details.
- Classes 2.3 and 6.1 Emergency escape mask
This equipment may be in a vacuum sealed bag with a long ”shelf life” and should not be opened for routine checks
This puts the onus back onto the haulier to select suitable gloves, eye protection and any other supplementary (non-mandatory) PPE. Hazchem Safety recommends chemical gloves meeting EN374 type B as a minimum, indirect vent chemical goggles to EN 166 for the eye protection and a hi-vis waistcoat meeting EN20471 class 2.
Why Additional PPE?
The instructions in writing specify the following action in the event of an accident or emergency:
- Where appropriate and safe to do so, use on-board equipment to prevent leakages into the aquatic environment or the sewage system and to contain spillages;
- Move away from the vicinity of the accident or emergency, advise other persons to move away and follow the advice of the emergency services;
- Remove any contaminated clothing and used contaminated protective equipment and dispose of it safely
If the driver is to fulfil this responsibility a risk assessment may indicate the need for a chemical protective suit, boots and possibly a full-face covering. As a haulage company you will need to assess whether your drivers are expected to make reasonable and safe attempts to contain any spills which occur and in which case what suitable PPE should be worn. Or, whether you expressly state that they shouldn’t attempt to contain or clear-up spills, in which case only the mandatory PPE would need to be carried. Hazchem Safety have a range of ADR kits covering the basic minimum requirement in the bronze ADR kit through to the Gold ADR kit which enables drivers to safely contain spills of some of the most aggressive chemicals.
Drivers should only respond in these situations if trained and it is safe to do so. Hazchem Safety strongly recommends that all drivers attend a first-responder spill training which gives basic understanding of spill response, PPE requirements and environmental responsibilities.