Tougher regulation for chainsaw boots

How EU controls on producers and suppliers of chainsaw footwear will be tightened in 2018.

by John Hooker

Accident rates in the forestry and arboriculture industry are higher than in construction. The three main hazards are falls from height, being struck by moving trees or branches and direct contact with chainsaws. In the USA alone, there are over 25,000 chainsaw injuries each year, with 45 per cent of these being to feet and legs. Even minor chainsaw injuries can be complex with long recovery times, and can result in permanent damage.

It is virtually impossible to eliminate all chainsaw risks to the user. Therefore, the use of appropriate personal protective equipment (PPE), including footwear for protection against chainsaws, is paramount.

Current EU legislation

The European Union (EU) has comprehensive PPE legislation (including for chainsaw boots), which is currently enshrined in the PPE Directive 89/686/EEC. Since 1995, PPE suppliers have been required to follow defined approval procedures (figure 1) before placing their product on the European market.  The relevant procedure depends on if the product is categorised as ‘simple’, ‘intermediate’ or ‘complex’ design PPE.

Footwear for protection against chainsaws is currently categorised as ‘intermediate’ design (category 2). The manufacturer must assemble the supporting technical documentation and apply to a Notified Body such as SATRA for an ‘EC type-examination’ to be conducted on the product. This involves independent third-party product testing to relevant European standards or technical specifications, and assessment of the supporting technical documentation. After receipt of an EC type-examination certificate (but before the product is placed on the market), the manufacturer must complete an ‘EC Declaration of Conformity’. All product placed on the market must be marked with the ‘CE mark’ – the manufacturer’s declaration that the product is compliant with all relevant European regulations.

New PPE Regulation (EU) 2016/425

After more than 20 years, the PPE Directive is to be repealed and a new PPE Regulation (EU) 2016/425 comes into effect on 21st April 2018. The implications of this on the supply of footwear for protection against chainsaws are very significant, because the risk of injuries from chainsaws has been upgraded. PPE designed to protect against risks of injuries from chainsaws will be subject to the same controls as PPE designed to protect against other life threatening risks, such as falls from height. There are some important changes relevant to suppliers of footwear for protection against chainsaws:

Ongoing production conformity: This will be similar to that for complex design PPE (category 3) under the current directive. Manufacturers will be subject to the strictest conformity procedures, including EU type-examination in accordance with ‘Module B’ of the regulation, plus monitoring of ongoing production conformity in accordance with either ‘Module C2’ or ‘Module D’ of the regulation as described below.

Under Module C2, the manufacturer must implement internal production controls that will ensure homogeneity of production and conformity of the PPE with the type described in the EU type-examination certificate, and with applicable regulation requirements. This must be supported by a programme of product checks at random intervals, supervised at least once a year by a Notified Body.

Module D requires the manufacturer to use a quality system to ensure that the PPE conforms to the type described in the EU type-examination certificate and with applicable requirements of the Regulation. The quality system must be assessed by a Notified Body against the requirements of the Regulation. Regular follow-up surveillance visits must be carried out at least once a year.

Under both Module C2 and Module D, the Notified Body will take appropriate measures if non-conformance is found. This could lead to withdrawal of the type-examination certificate.

Importers and distributors: The regulation clearly defines the obligations and responsibilities of manufacturers, authorised representatives, importers and distributors of PPE. In addition, importers or distributors who place product on the market under their own name or trademark will have the same obligations as a manufacturer.

Declaration of conformity: Manufacturers will need to ensure that when chainsaw footwear is supplied to an end-user, it is accompanied by either a full hard copy of the declaration or the internet/website address where the declaration can be accessed.

Five-year certificate validity: To ensure that this type of footwear is examined on the basis of it being state-of-the-art, time-limited EU type-examination certificates have been introduced. These will be valid for a maximum of five years, after which they will need to undergo a revalidation procedure in order to be extended. A simplified renewal procedure is applied where there has been no change to the products, the harmonised standards or associated guidance.

Testing standards: A variety of products for protection against injury from chainsaws is available, including footwear, leg protectors, upper body protectors, gaiters and hand protectors (gloves and mittens). EN ISO 17249:2013/AC:2014 – ‘Safety footwear with resistance to chainsaw cutting’ lays down the requirements for footwear and refers to EN 381-3:1996 – ‘Protective clothing for users of hand-held chainsaws – Test methods for footwear’. Test reports based on these standards will be required for an EC type-examination to be conducted.

The relevant standards for footwear in the USA are ASTM F1458-04 – ‘Standard test method for measurement of cut resistance to chainsaw of foot protective devices’ and ASTM F1818-13 – ‘Standard specification for foot protection for chainsaw users’. The European and US standards effectively assess the same properties, using a highly specified chainsaw, but differ substantially in how the test machine is designed and operated.

The only way to assess the cut resistance of chainsaw-protective footwear is to have it properly tested (see figure 2). The EN standard outlines three levels of cut resistance performance – ‘Level 1’ being the lowest and ‘Level 3’ the highest. These relate to the speed of the chainsaw during the test. To meet these levels, the footwear must resist cut-through in all tests and in each of the specified areas. If the chain penetrates the final inner layer of the lining and any hole created is greater than 10mm in length, the footwear fails.

Leather-uppered footwear that meets the requirements for cut resistance usually contains several layers of a cut-resistant textile – for instance, a para-aramid yarn. Woven and knitted construction textiles have proved successful, as have felted and certain rubber and polymeric materials. Chain-jamming fabrics may also be used, but with some limitations. The size of footwear uppers makes it difficult to insert such textiles into the upper in a way that the yarns are adequately released when the boot is cut. The leather itself must be tough and approximately 2.5mm to 3mm thick. In addition, the ISO/EN standard demands that the footwear must also comply with the general protective requirements in EN ISO 20345.

Irrespective of performance levels, EN ISO 17249 stipulates that the cut protection area must be continuous and to the same level over the vamp, tongue and toe cap area. The coverage must also include the front and sides of the leg section. The height of the protection up the leg depends on the size of the footwear. For instance, this height must be a minimum of 162mm for sizes up to EUR 36, and 192mm for EUR 45 and above. No gaps are permitted in the coverage area, except for in the case of performance levels one and two, when a gap of up to 10mm is allowed between the lower edge of the protection and the featherline of the sole/upper.

The use of non-steel toe caps is acceptable. In this case, however, the toe cap area must be cut tested – whether aluminium or non-metallic toe caps are used. The other three test areas are on the vamp (15mm behind the rear edge of the toe cap), at the throat and on the front of the leg, 150mm above the level of the upper surface of the insole.

Publishing Data

This article was originally published on page 38 of the July/August 2017 issue of SATRA Bulletin.

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