Whilst the PPE Directive [PPED] works reasonably well, it could benefit from some tidying-up to correct a number of translational variances. It will be reviewed in time once the "blueprint" for New Approach Directives, of which the PPED is one, is finalised. This "blueprint" originally contained the facility for any standard to be harmonised and, at the same time, list in this Annex ZA areas where the basic health and safety requirements had not been met. Also, products could comply with a harmonised standard and gain a presumption of conformity with the Directive - a situation which would create a "half-pregnant" situation leading to many disputes between manufacturers and notified bodies on how to satisfy the requirement of the PPED. This would then likely create much confusion with users seeking to access suitable protection.

The New Approach "blueprint" now clearly states that for a harmonised standard to provide a presumption of conformity it needs to have been published in the EU's Official Journal. This means that the EU Commission is now taking responsibility for the judgement as to whether specific health and safety requirements are [or are not] essential and ensures that everyone can now be comfortable that any item of PPE is correctly described by the standard it claims to meet.

Whilst the UK government department [BERR] has been supportive of the BSIF's position, the fact that there are now twenty-seven member states and qualified majority voting operates in this area created the real possibility that this matter would not be resolved through diplomatic channels. Despite the inertia of the ESF and the lack of interest within the Horizontal Group, the BSIF has successfully lobbied the EU Commission with the assistance of BERR to bring about these changes. The BSIF now hopes that the previously anticipated confusion will be prevented.
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