Any person performing the testing must be a ‘Competent Person’ as per the minimum requirements detailed by the HSE in their Operational Circular OC282/28. The testing must be documented and records kept for at least five years.

Approved Codes of Practice (ACoPs) and HSE Operational Circular 282/28 ‘Fit Testing of Respiratory Protective Equipment Facepieces’ have been issued outlining the options for compliance and recommending how Face Fit Testing should be performed. ACoPs have ‘special’ legal status within the UK in that, if a prosecution takes place and it is proved that these recommendations were not followed, it would then need to be proven by the employer that compliance with the COSHH requirements had been achieved in some other way. Recent discussions with the HSE indicate that the OC 282/28 may be upgraded to an AcoP - giving it the same legal status as the current COSHH ACoPs.

The requirement for Face Fit Testing is also covered in the Control of Asbestos at Work Regulations (2002) and the Control of Lead at Work Regulations (2002).

European Standards - EN 529:2005
In July 2005, a European Standard was approved by the Comité Européen de Normalisation (CEN) which supersedes CR 529:1993. This requires that all member countries must introduce the European Standard as a national standard without amendment. In the UK it is known as BS EN 529:2005 Respiratory protective
devices - Recommendations for selection, use, care and maintenance - Guidance document’.

Introduction of this standard into CEN Member Countries was required by March 2006. It provides guidance on establishing and implementing a suitable respiratory protective device programme to provide a European-wide baseline for the selection, use, care and maintenance of respiratory protective devices. It is not intended to be exhaustive, but highlights important aspects to which attention should be given. These recommendations will help organisations comply with the national legislation of CEN Member Countries - where such legislation exists - or with European Legislation.
Importantly, the guidance helps to ensure that RPE is suited to:

The substances of potential exposure
The individual wearer
The task to be performed
The environment in which the RPE is to be used

With particular reference to the wearer, Section 9: Adequacy and Suitability, sub-section 9.3.4 Assessing suitability for the wearer, requires that both the ‘facial characteristics of the wearer including facial hair’ and the ‘physical characteristics of the wearer’ be considered when selecting RPE. In particular, Annex D defines the requirement to be clean-shaven if tight-fitting RPE is selected and even defines the term ‘clean-shaven’. Annex E >
60     Health & Safety International | April 2008