Give jargon the boot

In the BSIF Guide 2023 we looked in detail at the changes made from the harmonised standard EN ISO 20345:2011 to the new EN ISO 20345:2022. In order to support this work BSIF Safety footwear Special Interest Group (SIG) have issued a new addition to the Jargon Buster to incorporate the new categories of protection and the changes to product markings. This new document can be downloaded¹ and should be read in conjunction with the original Jargon buster². This document is aimed at distributors, customer facing staff, duty holders and end users to help all to better understand the changes and the new categories of protection that have now been created. 

Please do look at the “Jargon Busters” as they are simple to understand tools designed to help you navigate the safety footwear standards.

Electrical shock protection of footwear

The European harmonised standard for footwear offering electrical shock protection is EN 50321-1:2018. This standard does not differentiate between footwear types, and all footwear can be tested by this method. The method is designed to assess the electrical safety of footwear in typical and in the most unfavourable foreseeable conditions of use. 

The test method uses water as both the inner and outer electrode, simulating live electrical working in wet outdoor conditions. It has been evidenced that most, if not all leather and fabric upper footwear will fail these requirements. The uppers of leather/fabric upper footwear generally become electrically conductive in the presence of water. The test is very challenging to the footwear but for very good reasons. In use, the environment is rarely controllable and rarely dry, so the method provides for realistic and worst-case scenario. 

In recent years there has been a steadily growing trend to supply footwear items “classification I” with leather and/or canvas uppers with electrical insulation properties of the sole. Many, if not all of these products use test methods developed outside of the CEN/ISO scheme. Most use the American standard ASTM F2413-18 “Electrical Hazard” or the Canadian standard CSA Z195 “Electrical shock protection” to support claim of electrical shock protection. These products have raised significant concerns in industry as these methods do not significantly challenge the footwear or simulate normal working conditions. 

For the EU and UK market, compliance with the regulation (EU) 2016/425 as amended and applied in GB is a mandatory requirement for all items of PPE. The regulation is clear that a claim of electrical shock protection is a category III “complex design” claim – where the hazard presents a risk of significant injury or death if a product fails to perform. Such products require Cat III certification along with ongoing independent quality assurance checks under the regulations Module C2 or D. 

There is a significant concern that products of this type are currently being supplied to the EU/UK markets without the necessary Cat III certification for the electrical insulation claims being made.

The BSIF Footwear Special Interest Group members, together with electrical industry experts and with the support of the BSIF Test and Certification Association and the Health and Safety Executive have worked extensively to provide footwear manufacturers with a mechanism to correctly certify these products. 

The Regulation requires the electrical risk to be assessed in the most unfavourable foreseen conditions of use. Where this is not fully satisfied by a test method, it is essential to identify the limitation of use associated with the test method. These methods can clearly be used to assess the performance of a product of this type, but the usage of the product must be limited to the appropriate conditions to ensure wearer safety.

The ASTM and CSA electrical test method only includes a single type of test in laboratory conditions. The method measures the current flow through the SOLE (not the upper), tested in the DRY state, on a RIGID base plate, with no PEFRFORATION of the sole, in a LOW POWER (high voltage) AC circuit. The method is such that the end uses are therefore limited, to:

• Use in Dry conditions only (footwear must be entirely dry and therefore no accompanying claims of WRU/WPA/WR/Waterproof are permitted)

• On hard ground surfaces (No usage in soft and lose ground)

• Suitable for accidental exposure to voltages not exceeding 600V AC*

• No Live electrical working

• No usage in areas where the outsole may be perforated or contaminated by sharps (therefore no accompanying claims of perforation resistance - P/PS/PL/PR)

• No usage where accidental exposure may be to DC voltages.

* The test voltage of 18 000 V AC is widely known in industry. Some products claim this is the usage voltage, such claims are extremely dangerous. In the USA, OSHA 3151:2023 dictates that “EH” footwear may only be safely used up to 600V AC. In all electrical insulation test methods (including EN 50321-1:2018) there is a large margin of safety built in, a differential between the test voltage and the usage voltage. The usage voltage is not only dictated by the test voltage, but also limited by the power of the system. The CSA/ASTM test method is a very low power system which severely limits the safe usage voltages of these products. 

In addition to the limitations of use, the document also identifies mandatory and recommended markings for the footwear and gives guidance as to suitable wording for user instructions including appropriate warnings.

The BSIF Test and Certification group involved with this work includes the UK Approved Bodies, Chairs of all the BSIF Special Interest Groups, representatives of the appropriate government agencies and the market surveillance authorities and I am pleased to say that we have been able to agree all aspects of this document. UK Approved Bodies are prepared to work with this procedure to achieve a Cat III certification for products of this type. UK Authorities also accept this route to market. These documents will now be presented to the appropriate CEN vertical group for their consideration in addressing the situation in the EU. Once this process is complete the framework will be in place to give a mechanism for certification within both the EU and UK. Manufacturers may begin working with these protocols immediately. 

References
1 https://tinyurl.com/5x3z4bvh
2 https://tinyurl.com/yadsyb9d

Lloyd Preston is technical manager at Tripal Group. For more information, visit www.tripal.global