Requirements for all personal protective equipment (PPE) are standardized, and one of these requirements is the application of marking on the item itself or its packaging containing a minimum set of required information.
PPE marking is important for correct selection and use, but first we need to understand what PPE actually is.
The term is given in the Labor Code of the Russian Federation:
Personal protective equipment (PPE) — means used to prevent or reduce the exposure of a worker to harmful and/or hazardous production factors, extreme temperature conditions, and to protect against contamination.
According to the Technical Regulation of the Customs Union "On the safety of personal protective equipment" (hereinafter — TR CU 019/2011), PPE includes:
- workwear;
- safety footwear;
- head protection (helmets; caps; heat-resistant under-helmets; headwear for cold conditions);
- hand PPE (gloves and mittens);
- eye and face PPE (goggles and face shields);
- PPE for protection against falls from height;
- respiratory PPE (half-masks; filtering or isolating masks);
- hearing PPE (earplugs and earmuffs);
- dermatological PPE.
PPE marking, like any marking, is necessary for product identification so the consumer can understand the field of application and operating rules of the product they hold.
In the case of PPE, marking has a special meaning because an incorrectly chosen protective item or improper use can lead to negative health consequences for the user or premature damage to the PPE, resulting in additional costs.
PPE marking under TR CU 019/2011
Safety requirements for PPE are formulated in TR CU 019/2011.
The regulation also sets out requirements for PPE marking, which, according to the technical regulation, contains three mandatory components.
Marking on PPE is applied based on the data contained in the manufacturer's documents and in conformity assessment documents. In our case these may be certificates of conformity or declarations of conformity. Indicating protective properties that the PPE does not possess according to the certificate or declaration is as much an error as failing to include protective properties that are listed in the conformity documents.
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Hard-to-remove marking. Applied directly to the PPE. It can be made by engraving on the PPE, by paint, on a sewn-in label or chevron, by embroidery — in any way that ensures the marking remains on the item throughout its service life for the worker. For most PPE this period equals 1 year. There are no strict limitations on the location of the marking, but the main requirement must be met — the information must remain legible throughout the service life and be accessible and understandable to the consumer.
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Packaging marking. Requirements for content are the same for individual and group packaging. Such marking should duplicate the information applied to the product itself and be supplemented with information concerning usage restrictions and shelf life. In some cases, individual packaging marking may omit part of the required information provided that the packaging is transparent (film, bag) and the marking on the PPE itself can be read through it.
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Operating instructions (or user manual). This document must include a detailed description of the PPE, its field of application, classification, including the PPE group according to Annex No. 1 to TR CU 019/2011, medical restrictions, age restrictions, warranty obligations of the manufacturer or importer of the PPE, and much other useful information for the consumer.
All three components of marking are mandatory, although the technical regulation contains caveats that, for example, marking on respiratory PPE (RPE) may not be applied if the information is available on the packaging.
TR CU 019/2011 clearly prescribes requirements for the content of applied marking on PPE, including the attributive composition of the marking. If additional information that may be critical for a particular type of PPE exists, it should also be included in the instructions. Such information may include warnings about use or preparation of the PPE for work.
PPE marking in accordance with TR CU 019/2011
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Characteristic |
Explanation |
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Attributes of PPE marking |
The list of mandatory marking components is the same for products manufactured in Russia and for foreign products |
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Language used |
Marking is applied in Russian (priority) and may be duplicated in other national languages. Product names, brands and manufacturer names may be written in Latin characters only |
|
Protective properties of the PPE |
May be specified in words, by letter designations adopted in the GOST for a specific type of PPE, or as pictograms |
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Protection classes or performance levels of PPE |
Indicated if the PPE can be classified by protection classes or performance levels. A single PPE may be assigned multiple protection classes or performance levels |
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Country of origin |
Information is mandatory to indicate. It should be noted that the country where the manufacturer is registered (its legal address) and the country where the product is manufactured may differ. For example, a Russian manufacturer may place garment production in Belarus. In this case the country of origin would be the Republic of Belarus |
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Document under which the product is manufactured |
For Russian products these may be TU, TO, STO or other documents adopted by the manufacturer. For foreign products, as a rule, these are European or international standards (EN, ISO, IEC) |
“Chestny Znak” marking
In addition to PPE marking under TR CU 019/2011, there is another type of marking — in the national product marking and traceability system "Chestny Znak". Such marking is presented on items, labels or packaging as a two-dimensional (2D) Data-Matrix barcode. It has the shape of a square or rectangle and consists of a set of dark and light (most often black and white) modules. This code guarantees the authenticity of the product and allows tracing its history, including the country of origin and when and by whom the product was removed from circulation.
You can check a specific marking code through the "Chestny Znak" app, which is installed on a mobile phone.
Currently, all safety footwear and part of workwear (jackets and raincoats made of textile materials) are marked with digital codes among PPE. However, an expansion of the list of products subject to marking in the "Chestny Znak" system has been announced, which will include:
- suits;
- trousers;
- bib overalls;
- coveralls.
It is expected that the list of marked products will be expanded by the end of 2023.
There is important information for companies that issue marked PPE free of charge to their personnel. To avoid registering in the system as a turnover participant, the end consumer must inform that the PPE is intended for use within the enterprise and will not be resold. In this case the seller will withdraw the marking codes from circulation immediately after the sale. In other words, the end consumer receives the product with “deactivated” marking codes.
If this is not done, the end consumer will have to report in the personal account of "Chestny Znak" within 3 calendar days that they have received the product and are its owner, and then write it off for their own needs by logging into the personal account again.
Considering that each item is assigned a unique code, the enterprise will need additional equipment to read the codes, special software to process the data, and an employee trained to work with the "Chestny Znak" system.
If the enterprise does not need to resell marked products, for example to contractors, it is better to simply instruct the supplier to withdraw the marking codes.
Marking of clothing and other light industry goods
Mandatory marking of clothing in accordance with current legislation started on January 1, 2021. As in other cases, the process is carried out using the functionality provided in the "Chestny Znak" system. Government Order No. 792-r and Government Resolution No. 1956 specify the categories subject to marking. Certain categories of individually manufactured clothing are not subject to marking.
The need to apply marking through the "Chestny Znak" system is determined by the HS code (TN VED EAEU) or OKPD2 code listed in Government Order No. 792-r. If at least one of the codes applies, the product falls under marking.
Options for placing the Data-Matrix code:
- on the product itself;
- on the product label;
- on the consumer packaging.
It is allowed to apply the code on tags or labels. The main condition is the use of appropriate equipment and consumables that prevent accidental or deliberate removal of the Data-Matrix code. When forming sets of several marked items, the identification means must be applied to each unit of the product and additionally on the common packaging.
Chestny Znak marking code
How to read PPE marking
Using a filtering half-mask as an example, we will examine what information is applied to the marking.
Consumers should be especially cautious when purchasing foreign products that claim to be manufactured according to GOST standards in force in the Russian Federation — the likelihood of such production is extremely low. Moreover, manufacturing products according to GOSTs under general technical conditions is practically impossible, and producing a product according to several GOSTs simultaneously is impossible in principle.
Decoding of the symbols placed in the marking should be contained in the PPE operating instructions, and if the information is absent, caution should be exercised when using such products.
Specifics of marking for certain types of PPE
In some cases, requirements are imposed for the placement of signs or symbols in the marking strictly in a certain order, as, for example, on eye and face PPE.
Eye PPE. Lens marking
In some cases, for example on workwear designed for protection against thermal risks of electric arc, the marking can be very complex and include letter designations, pictograms, as well as information on performance levels, protection classes and climatic zones.
On respiratory PPE (RPE), hearing PPE, and PPE for protection against falls from height, marking may not be applied provided that all information is on the individual packaging. Nevertheless, such a situation is not always convenient for consumers, so conscientious manufacturers generally do not use these caveats where possible, except for the marking of earplugs.
There is also a requirement to mark each glove in a pair, although many manufacturers often neglect this rule.
Conformity assessment of PPE
Documents confirming conformity with the requirements of TR CU 019/2011 are:
- certificate of conformity;
- declaration of conformity.
Forms of conformity assessment for different types of PPE are included in Annex No. 4 to TR CU 019/2011.
EAC marking
Marking applied to PPE cannot contradict the conformity documents, i.e. certificates or declarations. At the same time, the presence of excessive information in the marking about protective properties is as much an error as insufficient information about protection that is specified in the certificate or declaration.
Special attention should be paid to the information in certificates and declarations when selecting PPE during the transition from Typical Industry Norms (TIN) to ETN. In this situation, at the incoming inspection stage it is necessary to verify the end-to-end conformity of company norms, PPE marking and the certificate.
Optional PPE marking
In addition to mandatory marking, the manufacturer or importer has the right to apply any advertising information or information that enables the consumer to use, store and care for the PPE more efficiently and safely.
For example, pictograms indicating protective properties are applied in reflective materials on the URAN suit collection produced by Vostok-Service.
In addition, the manufacturer or importer may apply information about protective properties of PPE that are not included in TR CU 019/2011. For example, ETN includes headwear for protection against general industrial contamination or exoskeletons. Such PPE undergo conformity assessment in Voluntary Certification Systems. In this case preference should be given to systems that specialize specifically in PPE, since a Voluntary Certification System may specialize, for example, in electric kettles and therefore have a laboratory for testing low-voltage equipment. Therefore, if a certificate for heat-resistant PPE, for example for a metallurgist's hat, is issued by such a system, this should raise concern for the consumer.
Risks of using unmarked PPE
The use of unmarked PPE at an enterprise entails a number of risks, starting from purchasing unsafe products and ending with the results of inspections by supervisory authorities, which may interpret the use of unmarked PPE as failure to provide PPE to workers, a violation of the Labor Code of the Russian Federation with all resulting sanctions and fines.
It should be noted that each detected fact is recorded. Therefore, when purchasing ten units of PPE without marking, with incorrect marking or incorrectly certified, if an inspector detects one worker during an inspection, they only need to find the remaining nine.
Thus, the purchase of PPE without marking or with incorrect marking should be stopped by staff responsible for receipt of goods already at the incoming inspection stage. However, if such products do enter the enterprise, they must be identified and replaced with PPE that does not raise doubts both in terms of conformity assessment under TR CU 019/2011 and marking