Use of personal fall-protection equipment (PFPE) in potentially-explosive atmospheres: Official view of BGRCI

On many occasions, SKYLOTEC has been asked about ATEX certification with regard to PFPE products by customers.
SKYLOTEC has for many years adopted the view that such certification is not possible.

This view coincides with the official view of BGRCI (German professional trade association for raw materials and the chemical industry), which made the following statement:
Directive 94/9/EC of 23 March 1994 is implemented by the Eleventh Regulation of the Product Safety Law (ordinance on protection against explosion). According to § 1, Par. 2, personal protective equipment is not covered by the scope of this regulation.

The requirements of the regulation led to misunderstandings, especially during the initial period. According to the conformity assessment procedures, non-electrical devices, with which sparks are generated when operated as intended, must now also be accompanied by a manufacturer’s declaration or a type-examination certificate. This explicitly does not apply to personal protective equipment (PPE). On the contrary, it is prohibited to test a device according to a directive, if this device is not covered by the scope of the directive.

For the PPE directive, the following requirements are included in Appendix II, Section 2.6:
PPE, which is intended for use in potentially-explosive atmospheres, must be designed and manufactured so that no arc or spark, which could cause an explosive mixture to ignite, can be generated by electrical, electrostatic or mechanical means.

This condition will be satisfied, if the PPE meets the following requirements:
Based on experience, individual mechanically-generated sparks rarely cause ignition, and are often not regarded as sources of ignition in zones 1 and 2, with the following exceptions:
1. Substances of explosion class IIC, such as hydrogen, acetylene, carbon disulphide and hydrogen sulphide, i.e. substances with very low ignition energy.
2. Sparks arising from the combination of aluminium and rust, with which a high-temperature reaction can occur, if they come into contact.

Consequently, the utilisation of iron fittings or iron carabiner hooks in zones 1 and 2 presents no risks, with the exception of the aforementioned IIC substances. The users should be informed of any risks associated with the use of these substances.

Concerning the normal usage of PFPE, electrically-generated sparks can be ruled out, unless electrically-driven winching devices are used. This is one of the rare cases, where the PFPE is covered by the scope of the ATEX directive. (See also the ATEX guidelines, page 39.)

There are also no ignition sources due to electrostatic charging. There is no risk of safety harnesses becoming charged while being worn. They must not be put on or taken off in an area within zones 0 or 1. For ropes made from textile materials, hazardous charging is only possible if their diameter exceeds 25 mm.

In summary, it can be concluded that there is no risk of ignition if iron-containing PFPE is used in zones 1 and 2, unless it is used in atmospheres with IIC substances.

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