Employers frequently have questions about the documents that confirm the compliance of PPE with the requirements of TR TS 019/2011 when included in the ETN issuance norms:
- Do all PPE items included in the ETN norms require certificates under TR TS 019/2011?
- If a product is not PPE but needs to be included in the ETN norms, what documents should confirm its protective properties?
You will find the answers to these questions in this article.
The term “personal protective equipment” (PPE) is defined in Article 209 of the Labor Code of the Russian Federation:
PPE are means used to prevent or reduce the impact on an employee of harmful and/or dangerous production factors, as well as to protect against contamination. Thus, PPE must have confirmed protective properties (otherwise, how can one understand whether the PPE can reduce or prevent the risk of harm to health)?
According to Order of the Ministry of Labor No. 766n, which sets requirements for PPE provision, the employer must purchase and operate only those PPE that have documents confirming conformity. Operation of PPE with expired conformity documents is not permitted. An exception is serially produced PPE placed on the market during the validity period of a conformity document (certificate or declaration) until the expiry of the product’s shelf life (calculated from the date of manufacture) or the normative service life of the PPE (calculated from the date of issue to the employee and recorded in the personal card).
Certificates or declarations of conformity for serially produced PPE, i.e. produced on an ongoing basis, are valid for 5 years; certificates for a batch of products are valid for no more than 1 year. A batch of PPE is already manufactured products delivered under a single contract, or produced by one manufacturer according to one technical document; the batch size is indicated in the certificate or declaration.
Is it possible to include products that are not PPE in the ETN norms?
Yes, there are such exceptions:
|
Products included in the Norms |
Conformity document |
Note |
|
Toilet soap |
TR TS 009/2011 declaration |
For children’s soap – a registration certificate |
|
Hosiery (socks) |
TR TS 017/2011 Certificate for first-layer items, e.g. cotton socks |
For woolen socks worn over cotton ones, a declaration is required |
|
Shower slippers |
TR TS 017/2011 declaration |
|
|
Bath towels |
TR TS 017/2011 certificate |
|
|
Special undergarments |
TR TS 017/2011 certificate |
For men: vest/long johns; for women: vest/pantalettes *A T‑shirt cannot be issued under the ETN as a stand‑alone item **A polo shirt is not an underwear item and cannot be included in the ETN norms: it is a second‑layer garment because it has a collar and fastener. |
TR TS 017/2011 “On the safety of light industry products”, approved by the decision of the Commission of the Customs Union dated December 9, 2011 No. 876.
What other non‑standard situations may arise when selecting PPE for inclusion in the ETN norms?
Appendices No. 1 and No. 2 to Order No. 767n list PPE that do not fall under TR TS 019/2011, since they are not included in Appendix No. 5 to the current edition of the technical regulation. These PPE must have confirmed protective properties, which means declarations for light industry products are not suitable for employers. What should be done in this case? Such PPE should have voluntary certificates in which, based on laboratory tests, the protective properties required by the employer are specified.
Examples of PPE from Section No. 1 of the ETN that are supplied with voluntary certificates:
|
Products included in the Norms |
Conformity document |
|
Headwear protecting against OPZ or mechanical impacts (abrasion and/or puncture and/or cut) |
Voluntary certificate |
|
Flight helmet liner: Winter/summer |
Voluntary certificate |
Also important to know:
-
Products from column 8 of Appendix No. 2 to Order No. 767n, “Items, mechanisms and devices that may be used as PPE and issued additionally based on the results of a professional risk assessment”, may be included in the Norms. Requirements for these products are not established in TR TS 019/2011; therefore, the protective properties listed on the marking must be confirmed by voluntary certificates of conformity.
-
The presence of voluntary certificates confirming the application scope and the necessary protective properties is required for other products included in column 8 of Appendix No. 2:
-
Items, including light industry products (knee pads, capes, headwear (except helmets, caps and heat‑resistant liners),
-
PPE for protection against low temperatures (special footwear, headwear and hand PPE), and protection for cool environments (mid‑season clothing),
-
Mechanisms, including exoskeletons, and devices that protect against cutting effects of a handheld chainsaw, which may be used as PPE and issued additionally based on the results of a professional risk assessment.
A refusal to carry out conformity confirmation to the requirements of the technical regulation (“refusal letter”) is not a document confirming the presence of protective properties.
Products not listed in column 8 of Appendix No. 2 to Order No. 767n should not be included in the Norms.
These provisions may be revised after the entry into force of Amendment No. 2 to TR TS 019/2011 (which provides for an expansion of the product nomenclature for which requirements will be established in TR TS 019/2011).