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On March 16, 2006, the Commission decided that technical standard EN 143:2000 fails to ensure compliance with basic health and safety requirements of Directive 89/686/EEC with respect to electrostatic filters.
The issue at stake is very serious. Electrostatic filters are commonly used in different sectors (building industry, food industry, chemical industry, etc...including very small companies like bakeries or garages). They are used among others against asbestos and other types of dangerous dust. Electrostatic filters do not guarantee an adequate protection if they are used for more than a short time. The conclusions of the French Occupational Safety Resarch Institute INRS study are quite clear: "there are indeed two types of apparatus behaviours with respect to solid particles. Those which maintain or improve their filtration performance due to clogging phenomenon and those which lose it according to the load. Following the storage test, the majority of the electrostatic filtration equipment had lost their initial performance. From all the evidence, a disposable apparatus must be disposed of after a work shift, even if there is no sign of wear and tear".
"A simple visual inspection does not allow the real state of an apparatus to be ascertained. In view of the significant deterioration in the performance of electrostatic filters, the question of the level of protection they afford in the real work situation then arises. For INRS, these tests have highlighted the need to modify the mode of classification of filtering apparatus to one that takes into account the reality of the different behaviours of the materials".
For two years, the French Government has been asking insistently the European Commission to take action on this point. Such an initiative was supported by the TUTB and by the German KAN. It met the opposition of some PPE producers like the "3M" company. Unfortunately, the DG enterprise did not react promptly and a lot of time has been lost. On May 19-20, 2005, the representatives from the different member states in the administrative cooperation committee on Personal Protective Equipments had to adopt a special resolution to urge the Commission to take an initiative. In November 2005, the same committee expressed again its dissatisfaction for the passiveness of the Commission.
The recent decision of March 16, 2006 is certainly a positive step but the Commission did not organise any systematic information campaign on the risk of using electrostatic filters. There is a high risk that the decision could have no real influence on the practical situation if the trade unions do not intervene.
The next steps should be:
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the national authorities in charge of market inspection should remove from the market the equipments which do not guarantee an adequate protection; they should check the information notice taking into account the real performance of respiratory protective devices; they should contact the notified bodies in order to avoid the certification of devices which fail to comply with the basic health and safety requirements.
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at the workplace level, in cooperation with the labour inspection and the preventive services, the trade union safety representatives should impose a correct selection of respiratory devices taking into account the real performance level. It is important to explain that the present classification (P1, P2, P3) does not fully reflect the real performance of devices with electrostatic filtration.
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the CEN should review the present standard and accept that a more systematic trade union participation in the standardization process is required in order to avoid manipulation by the industry.
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