Royal Mail Group/CWU Joint Statement And New Personal Protective Equipment (PPE) Safety Standard:
The Law:
Employers have duties concerning the provision and use of personal protective equipment (PPE) at work. Basically, Employers must provide PPE and workers must use it. The Regulations covering PPE are the Personal Protective Equipment at Work Regulations 2002 and 1992 (as amended). Remember workers have a right not to put themselves in danger.
Personal protective equipment (PPE) Examples:
Personal Protective Equipment (PPE) is all equipment (including clothing affording protection against the weather) which is intended to be worn or held by a person at work and which protects them against one or more risks to his/her health or safety. Examples for PPE are safety helmets, gloves, eye protection, high-visibility clothing, safety footwear, weatherproof clothing and safety harnesses or other garments or equipment designed to protect the wearer’s body from injury or infection etc. The hazards addressed by protective equipment can include physical, electrical, heat, cold, wet, chemicals, biohazards, and airborne particulate matter.
Main Requirements of the PPE Regulations:
The main requirement of the Personal Protective Equipment at Work Regulations is that personal protective equipment is to be supplied and used at work wherever there are risks to health and safety that cannot be adequately controlled in other ways. The Regulations also require that PPE:
• is properly assessed before use to ensure it is suitable
• is maintained and stored properly
• is provided with instructions on how to use it safely
• is used correctly.
• is provided free of charge.
• This includes agency workers.
Information, Instruction & Training:
Anyone using PPE needs to be aware of why it is needed, when it is to be used, repaired or replaced and its limitations. It is essential that workers are Trained and instructed into how to use PPE properly and make sure they are doing this. Because PPE is the last resort after other methods of protection have been considered, it is important that users wear it all the time they are exposed to the risk. Employers must never allow exemptions for those jobs which take ‘just a few minutes’. Employers should regularly check that PPE is being used and investigate any reasons why it is not. Safety signs can be useful reminders to wear PPE.
RMG New PPE Standard
Royal Mail Group and the CWU have jointly reviewed the existing standards of PPE, following the HSE risk assessment process with PPE considered as a last resort. The covering ‘joint statement’ attached confirms that Royal Mail Group, the CWU and Unite/CMA value the workforce and view their personal safety as paramount. The ‘joint statement’ confirms the belief that the workforce have the right to undertake their duties with the correct standard of protection and that the Unions have and will continue to be involved with the ongoing monitoring and review of the PPE process and all parties fully support the deployment of the new PPE standards as outlined on the attached documents which are:
➢ RMG/CWU PPE Standard Joint Statement
➢ RMG PPE Standard 6.5 Flowchart – Appendix 1
➢ RMG PPE Standard 6.5 Guidance – Appendix 2
➢ PPE Work Area Matrix – Appendix 3
➢ RMG Job Types Matrix – Appendix 4
➢ RM Engineering Matrix – Appendix 5
➢ RM Fleet Matrix – Appendix 6
➢ PPE Issue & Instruction Record – Appendix 7
➢ RMG PPE – WTLL on the new Standard to share with all affected personnel
It is imperative that supplies of the correct PPE are ready for issue and that these new standards of PPE are then communicated to all staff by using the WTLL brief attached.
Strong employee engagement at this stage will mean better understanding of the standards and the reasons for the control of common workplace risks such as slips and trips. It is the legal responsibility of every employee at work to take reasonable care for the health and safety of themselves and others who may be affected by their acts or omissions. It is crucial that Royal Mail Group, CWU and Unite/CMA continue to work together to ensure these new PPE standards work in practice, locally and nationally, reviewing them as necessary, periodically to protect all staff. In particular Royal Mail will encourage and provide support both locally and nationally to staff to enable them to understand the PPE standard and any changes to past arrangements and how this new standard may affect their work area or individual job role. Promoting positive engagements, using the materials produced and working together to ensure compliance is key to the success of this initiative.
Deployment Process and Communications:
The PPE Standard has been jointly approved following extensive consultation and input and suggested changes are welcome from CWU Reps for consideration at the next review. The deployment began in October and, along with the Standard and Materials, the communications will include the following:
• Joint Statement
• Joint WTLL
• Ops Bulletin Article
• SHE Community internal communications
• RMG Plasma Screens
• RMTV
• Operational PPE Matrices will be expected to be displayed on Noticeboards.
Key messages:
• Safety is Royal Mail Group’s number one priority – and RMG will manage this by encouraging everyone to look at risks indoors and outdoors. Any work performed has to be risk assessed for potential risk(s).
• If any staff member has concerns in their office, or see any unsafe practices, a number of potential controls are available to apply. Members can speak to their Manager or CWU Safety Rep.
• Royal Mail is committed to keeping PPE up to date and appropriate to protect staff in their work activities.
• Royal Mail will provide appropriate PPE (and instructions of use), and staff must wear the appropriate items (as required by law and RMG rules).
Accidents due to people not wearing the correct PPE:
Royal Mail Group states that a high proportion of our accidents take place due to people not wearing the correct PPE. The top risks areas are:
1. Inappropriate footwear or safety footwear not being worn;
2. Not wearing high Vis PPE when required;
3. Hi-risk activities (e.g. Maintenance tasks);
Non Compliance:
Extensive discussions took place in respect of this aspect of the application of the PPE safety standard. Royal Mail’s original position was that any individual found not wearing or using the appropriate PPE would be taken down the RMG/CWU agreed ‘Conduct Code’. However I’m pleased to report that agreement has been reached that a three stage joint compliance process will apply, so ensuring a fair and reasonable approach to encouraging and ensuring members understand the need to comply with PPE requirements without immediately being confronted with a heavy handed approach which fails to inform the individual why the requirement is mandatory. The agreed process is as follows:-
If someone is found not wearing or using PPE for identified job types or work areas:-
➢ First time: stop the individual working therefore reducing the risk of incident, giving time for the issue to be rectified. The member of staff will be required to wear the PPE before continuing with the designated task.
➢ Second time: the unit manager and area safety representative (or designated appointee/ASR substitute) will speak to the individual, making sure they understand the need to wear the required PPE.
➢ Third time: as the PPE requirements have already been explained to the individual and they form part of our safety procedures, as long as it can be demonstrated that the individual has received and understood the appropriate training information and instruction, it is reasonably practicable for Royal Mail to expect staff to comply and as a last resort, failure to use the appropriate PPE may be dealt with through use of the correct and ‘progressive’ application of the conduct code.
Joint Working – Monitoring and Reviewing Standards
Managers, CWU Safety Reps and all employees must review the On Site Work Area Matrix and the relevant Job Type/Task Matrix and ensure they are understood and followed at all times. PPE is a mandatory requirement.
WTLL Sessions
• Once the content of the WTLL brief has been communicated, the Matrix will be issued to staff with time allowed to read it and ask questions.
• If possible, the CWU Safety Rep will be involved in delivering the message (the PPE Standard has national CWU and CMA approval).
• Staff will be asked if they have any issues to be raised as soon as possible and employees will then be informed that the new Standard is to be introduced and enforced immediately.
• Staff will be informed that a signature will be required recording that they have received the WTLL communication.
• Managers will then identify and issue any required PPE not identified on the Group Matrices as required.
Roll Out and Review
There is a joint commitment between Royal Mail and the CWU on PPE. RMG have developed and updated PPE standards, and discussed how they’ll roll out across the business. This includes consulting with the Local Safety Teams and CWU Area Safety Representatives taking into account their input, ensuring Risk Assessments are reviewed on an annual basis, but where RMG install equipment and/or make other significant changes, they must be reviewed more regularly – dependent on what’s happening in your office.
High Risk Activities
Individual Safe Systems of Work for high risk activities and Risk Assessments may increase the standard of PPE required.
Posting Peg
The Posting Peg appears on the RMG PPE Standard Matrix for the first time. To clarify its use, it appears in the section entitled ‘Other’ – As per risk assessment for specific tasks or work area and it states ‘Posting Peg’ (delivery points where risk exists). To explain: The Posting Peg is not compulsory PPE for all delivery points. Firstly, it will only be compulsory for any address that has had a risk assessment and is recorded on WRAP as requiring a Posting Peg to be used at that particular address. Secondly, the Postman/Postwoman undertakes a ‘dynamic’ risk assessment whilst on their delivery round if there is the risk of a dog behind the door, then the individual will use it. Both RM and CWU encourage members to use the Posting Peg wherever necessary.
Conclusion
Make sure you know your members’ responsibilities and they are kept up to date. The Safety Policy and RMG ‘Your Responsibilities’ leaflets are available on the RMG intranet.
Yours sincerely
Dave Joyce
National Health, Safety & Environment Officer
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