Directive 89 / 686 / EEC for Personal Protective Equipment

EU Product Directives, the basis for the free movement of goods

With the intention to avoid the trade barriers within the EU market, the European Commission has adopted more than 20 directives for product safety. These directives define and provide the essential requirements for health, safety and consumer protection. Only products that satisfy these basic requirements are allowed to be placed on the market.

Principle of presumption

If a product complies with requirements for safety as they are laid down in the relevant harmonized EU standards, it is assumed that the product meets the essential requirements of the relevant directive/s. A manufacturer may also prove to meet the safety requirements by using other technical solutions. But, a technically comparable level of safety must be demonstrated. Generally, the compliance with the essential requirements is established in a formal conformity assessment procedure.

The CE-mark

The CE-marking (CE expresses Conformité Européenne = compliance with EU Directives) is an official sign under EU law for any products relating to product safety. By attaching the CE marking, the manufacturer confirms that the product complies with any of the applicable and product specific European Directives. In summary, the CE-mark expresses:

• There is a European Directive / national law.
• The manufacturer knows this policy / this law.
• The manufacturer declares that the product placed in the market satisfies the essential requirements under consideration of policy.
• Herein, for eye- and face-protection devices, the CE mark expresses that the manufacturer and/or importer of the eye and face protection have applied for the testing, evaluation and certification of the product by an independent body (for example, at ECS).

After a passed CE certification process and the permission to affix the CE-mark, the product can be freely traded in the European Market.

Directive 89 / 686 / EEC for Personal Protective Equipment

The European Directive 89/686/EEC (PPE Directive) regulates the production and marketing of personal protective equipment in the European Common Market. It applies to "any device or means, which is intended to be worn or held by a person, and is intended to protect against one or more risks that endanger their health and their safety" (extract from article 1, paragraph 2 in 89 / 686/ EEC). Interchangeable PPE components which are essential for proper function are also included in the PPE Directive. Personal protective equipment should only be placed on the market in the European economic area, if they meet the essential requirements of the PPE Directive.

Conformity assessment

Any type of personal protective equipment must undergo a process for conformity assessment. This distinguishes between three categories. From Category II on, the compliance with the directive or the standards, respectively, must be confirmed by a third party, a notified body. (For products of eye and face protection, ECS GmbH offering this services since 2007, notified body 1883). The conformity with the PPE-Directive is confirmed sufficiently if the product meets the requirements as they are laid down in the European harmonized standards (EN-standards). For complex personal protective equipment (Category III), a type test and a production monitoring shall be carried out by a notified body. In this case, the contents of the certification procedure for obtaining the CE marking and the GS mark (see below) are comparable. Therefore, the GS mark is not used in this area.

PPE Directive and its transfer to national law

Each EEC / EC Directive must be conducted in all Member States into national law. In this process, the basic (minimal) requirements (essential requirements) are not allowed to be attenuated. The directive for personal protective equipment came into force on the 1st of July 1992. In Germany, it has been transposed into national law by the 8th provision to the Equipment and Product Safety Act (GPSG). On 1 December 2011, the GPSG was replaced by the Product Safety Act (Product Safety Act), which regulates the safety requirements of technical work equipment and consumer products in Germany. Thereby, the 8th provision of the GPSG was formally adapted to the ProdSG.

The GS mark (GS=geprüfte Sicherheit)

Using the sign for tested safety (GS mark = geprüfte Sicherheit), it is confirmed and certified that a product satisfies the requirements of the German Product Safety Act (ProdSG Produktsicherheitsgesetz). Again, these requirements are concretized in standards or other generally recognized rules of technology. Besides the CE marking, the GS mark is the only legally regulated mark assigned to product safety. During the GS-testing and certification procedures, it is checked whether the product meets the requirements of the Product Safety Act and other legislation for ensuring the safety and the health of persons at work. The requirements of the European Directives which are implemented within the Product Safety Act and its regulations are included. The GS mark implies that test labs and certification offices which have been authorized by the German government have tested the product and that a production monitoring and quality assurance measures are carried out.

Like for the CE-conformity assessment of eye protection devices, ECS has been authorized for granting the GS mark for eye and face protection products. According to the rules, ECS issues the GS mark only to manufacturers and only for complete, ready-to-use products, eg, for welding helmets with filters and cover lenses. Manufacturers agree on a regularly conducted / repetitive product testing and inspection of the manufacturing facility. Generally, manufacturers resort to the GS mark for quality assurance reasons. Towards the users and buyers, it is confirmed by a competent and experienced manufacturer-independent body that the product is safe in the sense of ProdSG.

Comparison with the CE marking

In contrast to the CE marking, the GS mark is used voluntarily. The CE mark regulates the free movement of goods in Europe and is fitted by the manufacturer's own responsibility. Manufacturers are required to affix a CE mark, confirming that their products conform to the applicable EC directives.

Voluntary marks

In addition to the mandatory CE conformity mark and the voluntarily used, but at least on the Product Safety Act (ProdSG) based GS mark, a series of "test and quality marks" for personal protective equipment, also for eye and face protection, are offered. Unfortunately and particularly towards Non-European manufactures, it is hawked that these "test and quality characters" offer and possess a higher status than the CE conformity or the GS mark. Obviously, this claim is wrong!

ECS has created its own testing and quality character, the ECStested mark. However, its applications is very strict, often restrictively coupled to the implementation of several quality assurance measures. These are:

• for any products for the eye and face protection, the ECStested mark is ALWAYS coupled to the GS mark. It is awarded only to complete and ready-to-use eye protection devices. It is only granted to manufacturers who agree to regularly repeated product testing and inspection of the manufacturing site. The inspection can also take place unannounced.
• for any products which are tested using comparable instruments to the eye and face protection devices. Foremost, screens for welding jobs and laser working places are named.
• for eye and face protection devices, which tested according to recognized technical rules and other standards, eg., ANSI, CSA, AS / NZS or similar.
• for laser protection products with a special individual approval according to GS-ET-30: Laser safety goggles and laser adjustment for special applications

Altogether, ECS aims to grant the ECStested mark in addition to the CE conformity and the GS mark only for very high quality, reliable and controlled products. The examination, the evaluation and the certification within the ECStested-program documents that the eye and face protection product conforms to specified requirements of highest quality. It helps the users to choose the best quality products.