Domestic Oven Gloves: PPE Updated
If you have read the previous edition, you will know that from 21 April 2018 domestic oven gloves and mitts will become Personal Protective Equipment (PPE). This is because under the new PPE Regulation (2106/425), oven gloves for domestic use have been included in the scope for the first time.
This has caused some confusion within the industry from manufacturers to retailers who have to be ready with CE Marked product in the supply chain for this transition. Few will have had previous experience of CE Marking and will be unfamiliar with the requirements for testing or the requirements for labelling, not to mention the creation of a Technical File which has to be submitted to a Notified Body for certification.
There is further complication because as this is a new Regulation – replacing the current Directive, the Notified Bodies themselves have to become approved to the new Regulation which takes time. Further to this, EN 407 - “Protective gloves against thermal risks” - is being reviewed at CEN level and will not be published and harmonised for a little while yet.
Clearly, manufacturers and sellers of such products must start the process of designing and testing their product before the deadline if a suitable product is to be ready in time. This means being familiar with the requirements of the Contact Heat test: ISO 12127-1, and the essential health and safety requirements for gloves including labelling.
So that Manufacturers and Specifiers have the latest information at their disposal, SGS has produced the following list of requirements which we predict will allow producers to design and fabricate products which will meet the new requirements for gloves which are safe for use in a domestic oven.
SGS UK Ltd suggests that using some of the clauses of BS 6526 is a good start adding to this, the new test method: ISO 12127-1 at a temperature of 250C as required by EN 407 for the palm area of the hand. SGS also suggests that in order to meet the “essential health and safety requirements” for PPE gloves, the back of the hand is also protected against hot contact. The details of how well protected this should be is still not clear but SGS is recommending that if it is as good as the palm, then this will satisfy the requirements.
Previously, such gloves would have been tested only in the new state, but under PPE rules, the protection level has to be maintained throughout its useful life, which means that if the glove is washable, then the number of washes it can withstand has to be known and stated in the literature accompanying the product. This adds a responsibility to the manufacturer to be able to demonstrate that after a specified number of washes, all properties including the Contact Heat requirement is maintained.
Our table below gives SGS’ considered opinion on what will be required from compliant domestic oven gloves under the new regulation.
Basic physical requirements for meeting the CE Mark standards for protection against Contact Heat.
- BS 6526:1998
- Clauses 4.2 Materials & 4.4 Dimensions
- Determination of pH (skin irritation)
- REACh, (specifically Azo Dyes)
- Contact Heat @ 250°C (ISO 12127-1)
- As new and;
- After multiple washes (ISO 6330)
The manufacturer/retailer will have to decide how many washes is reasonable for the useful life of the product based on their market knowledge. Currently SGS is suggesting 25 should meet this need.
It has been clarified that existing product already in the supply chain can continue to be sold after the April deadline, but any new product introduced in to the supply chain on or after the 21 April 2018 must be compliant with the new regulation and be CE Marked accordingly.
In order to achieve certification for the use of the CE Mark, a technical file has to be assembled and submitted to a Notified Body approved for the purpose, and this has to be reviewed against the essential health and safety requirements by the Notified Body before certification is granted.
Below is list of what is required in the Technical File.
- A complete description of the PPE and its intended use
- An assessment of the risks against which the PPE is intended to protect
- A list of the essential health and safety requirements that are applicable to the PPE
- Design and manufacturing drawings and schemes of the PPE and of its components, sub assemblies and circuits
- The descriptions and explanations necessary for the understanding of the drawings and schemes referred to in point d) and of the operation of the PPE
- The references of the harmonised standards referred to in Article 14 that have been applied for the design and manufacture of the PPE. In the event of partial application of harmonised standards, the documentation shall specify the parts which have been applied
- Where harmonised standards have not been applied, or have been only partially applied, descriptions of the other technical specifications that have been applied in order to satisfy the applicable essential health and safety requirements
- The results of the design calculations, inspections and examinations carried out to verify the conformity of the PPE with the applicable essential health and safety requirements
- Reports on the tests carried out to verify the conformity of the PPE with the applicable essential health and safety requirements and, where appropriate to establish the relevant protection class
- A description of the means used by the manufacturer during the production of the PPE to ensure the conformity of the PPE produced with the design specifications
- A copy of the manufacturer’s instructions and information set out in 1.4 of Annex II
Marking should be on the product itself or on labels attached to the product.
Under the PPE regulation the standard CE Mark shall be used, examples of which are shown below:
The Notified Body number should not be used as it is a Category II product.
It is not possible to use the pictogram for EN407 as the product cannot meet the requirements of the normative reference of EN 420.
However it shall include:
- Name, trademark or other means of identification of the manufacturer or his authorised representative
- Designation of the product type, commercial name or code
- Durable to the appropriate number of cleaning processes
If the manufacturer intends to indicate on the marking that the manufacturer’s instructions have to be consulted, then the following shall be used.
The manufacturer’s instructions for use shall meet the requirements of Clause 1.4 of Annex II of Regulation 2016/42.
In addition to the name and address of the manufacturer, the instructions that must be supplied with the PPE must contain all relevant information on:
- Instructions for storage, use, cleaning, maintenance, servicing and disinfection. Cleaning, maintenance or disinfectant products recommended by manufacturers must have no adverse effect on the PPE or the user when applied in accordance with the relevant instructions
- Performance as recorded during relevant technical tests to check the levels or classes of protection provided by the PPE
- Where applicable, accessories that may be used with the PPE and the characteristics of appropriate spare parts
- Where applicable, the classes of protection appropriate to different levels of risk and the corresponding limits of use
- Where applicable, the month and year or period of obsolescence of the PPE or of certain of its components
- Where applicable, the type of packaging suitable for transport
- The significance of any markings
- The risk against which the PPE is designed to protect
- The reference to this regulation and, where applicable, the references to other union harmonisation legislation
- The name, address and identification number of the notified body or bodies involved in the conformity assessment of the PPE
- References to the relevant harmonised standard(s) used, including the date of the standard(s), or references to the other technical specifications used
- The internet address where the EU declaration of conformity can be accessed
The information referred to in points (i), (j), (k) and (l) need not be contained in the instructions supplied by the manufacturer if the EU declaration of conformity accompanies the PPE.
For information about how to arrange testing, please contact the SGS Bradford Office:
SGS United Kingdom Limited
Units 41 & 43,
The Listerhills Park of Science and Commerce,
Campus Road, Bradford BD7 1HR
t: +44 (0)1274 303080
f: +44 (0)1274 303098
For information on certification contact the SGS Weston-super-Mare office:
SGS United Kingdom Limited
t: +44 (0)1934 522917 Option 4
f: +44 (0)1934 522137
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