Inclusive PPE

Jim Shannon Excerpts

Tuesday 12th March 2024 Commons Chamber

[Emma Hardy (Kingston upon Hull West and Hessle) (Lab)]

There have been significant developments in both the design and use of personal protective equipment over the last few decades. UK workplaces are undoubtably safer as a result. The Personal Protective Equipment at Work Regulations 1992, now amended to the Personal Protective Equipment at Work Regulations (Amendment) 2022, were an important step forward. They placed a duty on every employer in Great Britain to ensure that suitable PPE is provided to employees who may be exposed to a risk to their health or safety while at work. Regulation 4(3) states that personal protective equipment shall not be suitable unless:

“(b) it takes account of ergonomic requirements and the state of health of the person or persons who may wear it;

(c) it is capable of fitting the wearer correctly, if necessary, after adjustments within the range for which it is designed”.

However, despite being revised seven times since coming into force, the regulations do not make specific mention of women, who I hardly need to remind the Minister comprise half the population, or to others with protected characteristics under the Equality Act 2010. That omission continues to have significant, real-world consequences.

The world is finally waking up to the fact that women are not just smaller men, whether that is in the design of crash test dummies or in the creation only three years ago of the first anatomically accurate female 3D physiological model for medical students. PPE needs to be designed with the female anatomy in mind. That also applies to the needs of others who are not catered for by a typical male body pattern.

[Jim Shannon (Strangford) (DUP)]

I commend the hon. Lady for raising this issue; I spoke to her about it before the debate. It is so important for everyone to have access to PPE that fits correctly depending on the industry in which they work, including the female construction workers who the hon. Lady has referred to. Back home, I have been contacted by constituents about the provision of PPE for pregnant women who are still working towards the end of their pregnancies. Should not more consideration be given to ensuring that they have correctly fitting PPE, as they are more at risk from hazards and other safety concerns in the workplace? Let us do it right for them.

[Emma Hardy]

I completely agree. That is exactly what the debate is about—ensuring that everyone is safe while at work.

In September last year, the National Association of Women in Construction Yorkshire published a research report on women’s PPE in the construction industry. I pay tribute to its author, Katy Robinson. Not only is she a resident of my area, but she inspired the speech that I am making tonight. She is also the campaign manager of NAWIC Yorkshire, a voluntary role that she undertakes outside work. She told me that most PPE distributors do stock women’s PPE, but the issue sometimes lies with employers, despite such PPE being readily available on the market. Her study found that 59.6% of employers did not provide women-specific PPE, which resulted in women wearing PPE designed for men and led to issues relating to ill-fitting PPE.

Ill-fitting PPE was found to cause a range of health and safety issues, including increased slips, trips and falls, an increased risk of entanglement, a limited range of motion, decreased dexterity from gloves, and impaired vision from safety glasses. Worryingly, 42% of women reported experiences relating to ill-fitting PPE which had had an impact on their careers. Long-term health problems included plantar fasciitis, Morton’s neuroma and tendinitis from poorly-fitting safety boots, and injury from suspension trauma and circulation damage as a result of ill-fitting harnesses.

According to other studies, 40% of women have reported experiencing an injury or incident that they identified as being related to PPE, 32% have had to make alterations or adjustments to PPE to make it fit, 77% have been exposed to dangers because of ill-fitting PPE, and 57% have found that their PPE sometimes or significantly hampered their work.

Every study reported that the majority of PPE is designed for men, and is based on outdated information and measurements. It could be argued that that is due to a historical lack of women in some sectors of industry and that those sectors just need some time to “catch up”, but there are also issues involving ill-fitting PPE in female-dominated industries such as healthcare, where it became a headline issue during the covid-19 pandemic.

Inclusive PPE is defined as personal protective equipment that takes into consideration the user’s protected characteristics, and momentum for change is building. Katy Robinson, who I mentioned earlier, founded the PPE Campaign with the aim of addressing

“the widespread inequalities in PPE provision and design among minority groups across the construction industry and beyond”.

The Chartered Institute of Building has launched a “PPE that fits” campaign to drive awareness of the way in which ill-fitting PPE is affecting health and safety on site while also hampering the industry’s ability to attract and retain a more diverse workforce. The Considerate Constructors Scheme, which helps the construction industry to raise its standards through construction site accreditation, has mandated the requirement of women-specific PPE. SHP is running a campaign called “Protection for everyone” to raise awareness of the issue, and locally, East Riding of Yorkshire Council voted to urge the UK Government to enforce inclusive PPE in industries involving science, technology, engineering and mathematics. Arco, which is based in my constituency and a leading UK provider of health and safety products and PPE, recognises the need for change and fully supports the campaign to improve inclusivity. I understand that this campaigning is indeed leading to change and that an increase in women’s PPE provision has been seen since it began, but workers deserve a guarantee that they will be protected.

The Minister may say that the issues I have highlighted are covered by the regulations, but there is overwhelming evidence that as they stand, the regulations are not effective in ensuring that large numbers of workers are receiving the protection they need. Reference to the Equality Act 2010 can be found in guidance surrounding the regulations, but it is not statutory. Well-fitting PPE should not be seen as best practice; it should be the minimum standard. An increasing number of manufacturers are creating products designed for women, including maternity PPE, and those that do typically sell them at the same cost point as men’s. Unfortunately, some manufacturers still only make men’s PPE, meaning that they can sell them at a cheaper cost point, as there is more demand for it and they make a loss on women’s PPE—hence the assumption that men’s PPE is cheaper than women’s. This gives a competitive advantage to companies that choose to ignore 50% of the population and all others with protected characteristics who suffer from the impact of ill-fitting PPE.

I believe that specific reference to the Equality Act 2010 is a significant omission from the regulations and should be addressed. I acknowledge that the regulations have been regularly revised since they were drafted, and I note that it was rightly seen fit in the Personal Protective Equipment at Work (Amendment) Regulations 2022 to change the pronouns from he/his to they/theirs to be more inclusive, but the regulations did not address the issue that is materially affecting thousands of people’s lives and careers. I urge the Minister to return to them and make the necessary changes.