Fill the Gap of National Standards and Provide Basis for Allocation，Law Enforcement and Supervision

——lnterpretation of GB 39800.1-2020 Specification for Personal Protective Equipment Part1 ：General Provisions

【Abstract】This paper analyzes and explains the general situation， revision background and revision content of GB
39800.1-2020 specification for the allocation of personal protective equipment Part 1:generalprovisions.
【Keywords】individual protection ； Equipment； standard；unscramble

1.Background of the standard development
China has the largest working population in the world, with 775 million people employed nationwide in 2019, and most workers have careers that exceed one half of their life .One-half of the life cycle. At present, China is in the stage of rapid development of industrialization and urbanization, the safety production and occupational disease prevention and control problems accumulated in the previous decades of rough development gradually emerged, will face many new problems and new challenges. First, the number of reported cases of occupational diseases remains high, and by the end of 2020, the cumulative number of reported occupational diseases nationwide has reached nearly one million cases. Due to the low coverage of occupational health inspection and imperfect employment system, the actual number of cases is much higher than the number of reported cases. Second, the current situation of production safety is still in a period of climbing over the hurdles. 34,000 production safety accidents occurred in China in 2020, and more than 27,400 people lost their lives. In addition, with the development of technology, new hazards continue to emerge, a variety of new safety and health issues have caused widespread concern among workers and all sectors of society, old and new problems and conflicts intertwined, work safety and occupational health face multiple pressures.

Personal Protective Equipment (PPE) is an important industrial product to ensure labor safety and is the last line of defense to protect the lives and health of hundreds of millions of workers. Huang Yifu and other researchers found that 15% of production casualties occurred when workers did not wear PPE or did not wear PPE correctly. Yang Ying randomly selected nine manufacturing enterprises in Beijing and found that only one enterprise met the PPE requirements. Zhang Qunfang surveyed 159 small and micro enterprises in Shenzhen and found that the rate of setting up the PPE management system was only 57%. In addition, the rate of individual protective equipment is also very low, such as 43% for gas masks and 21% for protective glasses, which reveals that there is a big problem in the management of individual protective equipment in China. How to solve the problem of individual protective equipment in the employer’s equipment, so that individual protective equipment such as “life-saving” equipment really equipped to the hands of each operator who needs protection, so that it really plays the role of “last line of defense”, is to solve the current safety in China One of the important means to solve the serious situation of production and occupational disease prevention and control, and the key to solving the problem of equipping is the development of mandatory equipment standards”. Compared with European and American countries, before December 2020, China lacks a standard for the systematic regulation of the management of individual protective equipment. As soon as possible to develop individual protective equipment and management standards, to fill the national mandatory standards in individual protective equipment management gaps in our country, for the majority of practitioners of individual protective equipment and management to provide equipment, law enforcement and supervision of the basis, and for our production enterprises to provide individual protective equipment with guidance and equipment constraints, become individual protective equipment management urgent problem.
In such a background, the National Technical Committee of Individual Protection Standardization organized Beijing Institute of Labor Protection Science and other units drafted GB 39800.1-2020 “Individual protective equipment equipment specification part 1: general rules”. The standard was promulgated on December 24, 2020, and will be implemented on January 1, 2022. In order to help the majority of readers to better understand the standard, the author is now interpreting it.

Interpretation of the content of the standard
1.1 Scope of application
GB39800.1-2020 “Individual protective equipment specification Part 1: General” applies to the provision and management of individual protective equipment for each user unit, not for each user unit with individual protective equipment for firefighting and management, the applicable user unit, refers to the enterprises, institutions and individual economic organizations and other units in China, which is consistent with the People’s Republic of China Occupational New Prevention and Control Law” (People’s Republic of China Service Act) and other laws into the object of application is consistent, due to the field of firefighting XF621-2006 “firefighters personal protective equipment equipped with standards” this mandatory industry standard, in order to avoid the standard cross-repeat, clear that the standard does not apply to fire products equipped.
1.2 Terminology and definitions
The standard has developed four terms, including individual protective equipment, occupational hazard factors, tracking the source of the lake, paragraph number. Among them, in order to facilitate the understanding of front-line employees and increase the convergence of the standard, GB/T12903 – 2008 “individual protective equipment terminology” 3.1 “individual protective equipment” definition, adding the “labor protective equipment The definition of “labor protective equipment” has been added. The definition of “occupational hazards” combines the “risk factors” of the “Law of the People’s Republic of China on Work Safety” and the “harmful factors” of the “Law of the People’s Republic of China on Prevention and Control of Occupational Diseases”. On the basis of the “Occupational Safety and Health Terminology” of GB/T15236-2008, the definition of “Occupational Hazard Factors” has been changed to “Hazardous Factors”, which covers a more comprehensive scope. The definition of “tracing lake source” is based on the “General Office of the State Council on accelerating the construction of important product tracing system” (Guo Ban Fa (2015) No. 95) in the definition of the construction of the tracing system, to modify the development.
1.3 Principles of individual protective equipment equipment
The standard specifies the basic requirements of the employer for individual protective equipment, summarized in the following six principles: First, the principle of compliance. When there are occupational hazards and risks in the workplace, the employer should be equipped with individual protective equipment, which is clearly stipulated in the Labor Law of the People’s Republic of China, the Occupational Disease Prevention and Control Law of the People’s Republic of China, the Work Safety Law of the People’s Republic of China and other laws and regulations, and is also equipped with the most basic requirements. Article 54 of the Labor Law of the People’s Republic of China stipulates that: the employer must provide workers with labor safety and health conditions in accordance with national regulations and necessary labor protective equipment, and workers engaged in occupational hazards should undergo regular health checks. Occupational Disease Prevention Law of the People’s Republic of China, Article 22: The employer must adopt effective protective facilities for occupational diseases, and provide workers with personal use of protective equipment for occupational diseases. Employers provide workers with personal protective equipment for occupational diseases must meet the requirements of the prevention and control of occupational diseases; does not meet the requirements, shall not be used. Article 45 of the Work Safety Law of the People’s Republic of China stipulates that production and operation units must provide employees with labor protective equipment that meets national standards or industry standards, and supervise and educate employees to wear and use them in accordance with the rules of use.
In addition, the individual protective equipment must meet the requirements of national standards or industry standards, that is, the equipment purchased by the employer should be qualified products. This is the minimum requirement to ensure that the product has the basic protective performance.
Second is the principle of effectiveness. Operators in wearing individual protective equipment, people, equipment, the environment that constitutes a microsystem, which Equipment is the central link to resist environmental harm to people. To ensure that the protection of the equipment is effective, there are three requirements: first, to adapt to the external environment, that is, to adapt to the environmental conditions of the workplace, operating conditions, the presence of hazardous factors and the degree of harm. There is another layer of meaning here, do not over-protection, such as when you can be equipped with protective masks, it is not necessary to be equipped with air respirators. Secondly, it should be suitable for the operator, such as respirator fitting mask to fit the wearer’s face, protective clothing to “fit”, protective shoes to “fit”, protective gloves to ensure that the wearer’s hands have a certain degree of flexibility. Finally, the individual protective equipment itself should not lead to other additional risks, such as the material or structure of the equipment can not cause harm to the human body.
Third, the principle of comfort. Individual protective equipment should not only be “prevented” but also “wearable”. Personal protective equipment as workers wear the necessities of daily work, its comfort performance is very important. In the daily inspection and research process, front-line workers often reflect the comfort of individual protective equipment is not good, poor operability, coupled with the harsh working environment and heavy workload, greatly increased the body load. Many workers reflect that although some individual protective equipment has a good protective function but wear after the uncomfortable, inconvenient, affecting the normal work, and sometimes bring other aspects of safety risks. Such as some labor protection shoes wear not only feel bulky, but also gnawing feet, due to poor breathability leads to rotten feet, etc.. Some dust masks due to resistance, workers are difficult to wear for a long time in high-intensity work, etc.. Therefore, the standard especially proposed in the premise of effective protection, pay attention to the principle of comfort.
Fourth, the principle of compatibility. Workplace hazards are often not a single, but a variety of hazards coexist, which then requires a variety of individual protective equipment to cooperate with the use. In the process of equipping, consider the compatibility and functional substitution between equipment, such as helmets and earmuffs, myopic eye competition or protective glasses and full face shield, full-body protective clothing and air exhaler, etc.
Fifth, the principle of coverage. The standard provides that the employer is not only responsible for the outfitting of the unit’s regular employees, but also to cover its use of labor assigned to create workers, temporary employment and the admission of interns. The Law of the People’s Republic of China on Work Safety stipulates that production and operation units that use dispatched workers should include the dispatched workers in the unified management of the unit’s employees: if they receive internships for secondary vocational schools and higher education students, they should provide the internship students with appropriate education and training on work safety and the necessary labor protection supplies. For other outsiders allowed to enter the workplace, including visitors, inspectors and other personnel, should also be included in the scope of management of individual protective equipment equipped.
Sixth is the principle of articulation. Individual protective equipment standards are a series of standards, including a general rule and a series of sub-standards. The general rules are mainly from the overall provisions of the “how to match” and “how to manage” the problem. Each sub-rule is based on the characteristics of each industry, focusing on the “how to match” the problem of regulations. In the standard Appendix A, according to GB/T4754-2017 “National Economic Classification” and the characteristics of China’s national economic industry individual protection needs, the planning of electric power, electronics and other 10 industries of individual protective equipment sub-rules equipped with standards, including petrochemical natural gas, gold non-ferrous, non-coal mining 3 industries with national standards (standard number are 39800.2-2020, GB39800.3 – 2020, GB39800.4-2020) has been promulgated on December 29, 2020, and synchronized with the implementation of the general rules. The standard 3.6 provisions of the standard and the national standards for the equipment of individual protective equipment in various industries for the interface, the provisions of the use of units should be based on the standard combined with the industry’s individual protective equipment with national standards for the equipment and management of individual protective equipment: no industry individual protective equipment with national standards, should be in accordance with the requirements of the standard for individual protective equipment and management.

1.4 Individual protective equipment (PPE) equipment procedures
The standard’s PPE equipment procedures section specifies how to equip PPE, including three parts: equipment process, workplace hazard identification and assessment, and PPE selection.
1.4.1 Equipping process
The flow chart of individual protective equipment in this standard is based on the labor protective equipment selection procedure in the former State Administration of Safety Supervision “Labor protective equipment management specification for employers”, and combined with the actual situation and development trend of China’s individual protective equipment management, including 14 procedures: determine the scope of identification, and the identification and assessment of hazard factors: determine whether to cause harm to the human body and its hazard degree; determine to take engineering or management measures and confirm whether they can be completely eliminated; whether the need for individual protective equipment: according to the results of the hazard assessment to select the appropriate individual protective equipment: determine the manufacturer or distributor: verify the product information and national tracking tide source system information is consistent: the acquisition of individual protective equipment; individual protective equipment acceptance, to determine whether it meets the national or industry standards: individual protective equipment Storage and archiving: Issuance of PPE: Training on wearing, use and maintenance of PPE: Correct wearing of PPE: Preservation, maintenance, inspection and disposal of equipped PPE.
In this procedure, the following three principles are reflected: First, the identification of hazard factors and hazard assessment is the premise and basis for the correct provision of individual protective equipment: Second, when there are hazard factors in the workplace, the first consideration is to take engineering or management measures to eliminate occupational hazards in the workplace, individual protective equipment is the last means of consideration: Third, individual protective equipment can not eliminate the risk, only It is the last line of defense against risk, but not the bottom line of defense, because each individual protective equipment has its own white protective limit. When the results of the hazard assessment exceeds its protective limits, other measures should be taken, such as stopping operations.
1.4.2 Identification and evaluation of workplace hazards
The identification of hazard factors is the premise and basis of the correct equipment equipped with individual protection, effective and adequate identification of hazard factors, can be targeted to develop preventive measures to achieve the prior control of the risk of hazards, in order to eliminate or reduce the degree of harm.
1) Identification principles
The standard puts forward two basic principles of workplace hazard identification.
First, it should be based on adequate. First, based on existing national laws, regulations, standards, followed by professional knowledge, and finally, based on the actual situation, including different workplaces, production processes, operating environments, etc.. The combination of laws and regulations, theory and practice, in order to be based on adequate.
Secondly, it is necessary to consider comprehensively. Should be all kinds of factors in production and operation activities, including personnel, equipment and facilities, the use of materials, process methods, environmental conditions, management systems and other systematic analysis. Not only to analyze the normal production operation of the hazards, but also to analyze the technology, materials, processes and other changes, equipment failure or failure, personnel operating errors and other circumstances that may produce the hazards.
2) Identification methods
First, the basic method. The standard proposes that on-site investigation, measurement, access to relevant records, inquiries and communication can be used to analyze the hazard factors in the operating environment. At the same time, the standard also gives two optional methods: one is based on the type of work engaged in the identification of hazard factors. Appendix B of the standard gives the common categories of work and may cause accidents or injuries. The standard in accordance with the working conditions in the operating environment and may cause accidents or injuries listed 35 major categories of work, the Division gives a description of the categories of work, and may cause accidents or injuries, the employer can combine the standard in Table B.1, according to the type of work performed by the operator, to determine the possible accidents or injuries. At the same time, if the actual work involves a number of operational features, that is, comprehensive operations. The standard points out that in the comprehensive operation, the employer can be equipped with multiple or multifunctional individual protective equipment for the operator according to the characteristics of the operation. Second, the employer directly identify the hazards according to the work of the staff. Appendix C of the standard lists the possible hazards and harmful factors of the production process. The appendix is quoted from GB/T13861-2009 “Production Process Hazardous and Harmful Factors Classification and Code”, the scope of application of the standard clearly states that “applicable to all industries in the planning, design and organization of production In the scope of application of the standard, it is clearly stated that “applicable to all industries in the planning, design and organization of production, the prediction of dangerous and harmful factors, prevention The identification and analysis of the causes of casualties, also applies to occupational safety and health information processing and exchange. It is also applicable to the processing and exchange of occupational safety and health information”. Therefore, it can be used as a reference for the identification of workplace
Therefore, it can be used as a reference for the identification of hazard factors in the workplace.
Second, the analysis approach. The standard proposed in the identification of hazard factors, can be analyzed from the following aspects: a) normal working conditions: b) abnormal working conditions: c) personnel work activities: d) equipment procurement, storage and transport, and operation, repair and maintenance of equipment and facilities; e) raw and auxiliary materials, intermediate and final products: f) production, construction processes: g) environmental conditions: h) management system: i other auxiliary activities and contingencies, this article is actually a further gate to the standard 4.2.1.1b) clause.
3) Hazard assessment
Hazard assessment is to identify the degree of harm of harmful factors to assess the analysis, as a basis for the selection of individual protective equipment protection function and protection level. Hazard assessment is a more complex system, there are a variety of assessment methods, in the standard only put forward some normative requirements, the specific operation can refer to GB/T27921-2011 “risk management risk assessment techniques” and other literature.
1.4.3 Individual protective equipment selection
Based on the identification of workplace hazards and the results of hazard assessment, the standard requires that the individual protective equipment should be combined with the protection parts, protection functions, the scope of application and protective equipment.
Based on the identification of workplace hazards and hazard assessment results, the standard requires the selection of appropriate individual protective equipment, taking into account the protective parts, protective functions, scope of application and suitability of the protective equipment for the operating environment and users. The standard on the current commonly used PPE is divided into nine categories, including head protection, eye and face protection, hearing protection, respiratory protection, protective clothing, hand protection, foot protection, fall protection and other protection, and the nine categories of 49 kinds of PPE product standards, protective functions and reference scope of application, so as to facilitate the selection of PPE when equipped.

1.5.PPE equipment management
After the individual protective equipment is equipped, it is the problem of how to manage. The management of individual protective equipment is an essential part of individual protective equipment. If the individual protective equipment is equipped with “hardware”, then the management is “software”, this clause includes the basic requirements, tracking and measuring sources, the degree of judgment and replacement, training and use of four parts.
1.5.1 Basic requirements
The basic requirements section of the standard includes three articles. In the whole procedure of individual protective equipment, there must be a sound management system, so as to ensure that the individual protective equipment equipped with a complete range, qualified performance, reasonable distribution, management standards. Therefore, the basic requirements of the standard section of the first article provides that a sound system and distribution files should be established. These systems should at least include procurement, acceptance, storage, selection, issuance, use, obsolescence, training and so on. The second article provides for the receipt and acceptance of incoming storage and periodic inspection of state regulations. The employer should be equipped with individual protective equipment in accordance with national or industry standards, which is clearly stipulated in the “Law of the People’s Republic of China on Safety Production”, “Law of the People’s Republic of China on Prevention and Control of Occupational Diseases”, “Labor Law of the People’s Republic of China” and other regulations, and the incoming inspection is the last procedure to ensure the quality of products, so the standard makes it clear that the employer should conduct incoming inspection of individual protective equipment before it is put into storage. In addition, China for some products in its mandatory standards clearly specified in the regular inspection matters, such as GB21148 – 2020 “foot protection safety shoes” 9.2.3 provides that for electrically insulated shoes, in order to ensure safety, should be set to test the electrical properties, while it is recommended that every six months; for shoes stored for more than 24 months (calculated from the date of production), need to be tested one by one, and only meet the standard requirements before they can be sold and used. The third article mainly focuses on the response to changes in workplace hazards after being equipped with individual protective equipment. In the process of operation found that there are other hazards, the existing individual protective equipment can not meet the operational safety requirements, the need for additional with each, should immediately stop the relevant operations, in accordance with the requirements of this part with the appropriate individual protective equipment before continuing operations.

1.5.2 Traceability
Traceability system construction is the collection and recording of individual protective equipment in the production, circulation, consumption and other aspects of information, to achieve the source can be traced, the destination can be traced and other goals, to strengthen the whole process of quality and safety management and risk control of effective measures. Traceability system into individual protective equipment equipped with management, but also to implement the “General Office of the State Council on speeding up the construction of important products traceability system” (State Office issued [2015] No. 95) “around the people’s lives and property safety and public safety has a significant impact on the product, the overall planning of the national important product traceability system construction “An important initiative of the guidance.
The standard traceability section includes five articles, the first of which is the basic requirements, the fundamental provisions for the implementation of the traceability system, stipulating that the employer should purchase individual protective equipment with traceability markings on the minimum labeled packaging and transport packaging.
The second article is the requirements for manufacturers in the tracking and tracing system. The standard requires manufacturers to enter three types of information in the national tracking and tracing system before each batch of products is sold, namely: first, the manufacturer’s own information; second, the information of the products sold; and third, the information of the inspection and testing report of the product model. Among them, the inspection report provided should be noted that it is the inspection report of the product model, and not necessarily the inspection report of the batch of products. In addition, for the national tracking and tracing system, here refers to the system that can achieve the function of tracking tide source in the whole country.
The third article is the requirements for the distributors in the tracking tide source system. Because sales information is often more sensitive, therefore, the standard stipulates that dealers Before the product is sold only to enter the necessary sales information, the specific information requirements by the tracking lake source system to ensure the realization of its tracking lake source function at its own discretion.
The fourth is the requirements for tracking the source of the lake system in the inspection and testing agencies. The standard stipulates that inspection and testing agencies should be in the national tracking and tracingsystem to enter the inspection and testing report information.
Article V specifies how the employer uses the tracking and tracing system. The standard stipulates that when purchasing individual protective equipment, employers can verify the physical product information and product inspection and testing report information through the traceability mark of the product and the inspection and testing report.

1.5.3 Disposal and replacement
Judgment and replacement is an important link in the management of the whole individual protective equipment. In order to avoid the existence of certain enterprises “overdue use” of protective equipment
“continue to use after the failure of the function” and other situations, the standard provides that one of the following situations must be replaced: a) individual protective equipment is judged to be unqualified by inspection or examination: b) individual protective equipment exceeds the expiration date: c) individual protective equipment function has been invalidated: d individual protective equipment in the manual of other condemnation or replacement conditions. or replacement conditions. The standard also stipulates that the PPE that has been judged to be obsolete or replaced shall not be used again.
1.5.4 Training and Use
The training and correct use of workers is the prerequisite to ensure the correct wearing and effective protection of PPE. Relevant regulations in China attach great importance to the training of workers. For example, the “People’s Republic of China Production Safety Law” Article 28 clearly stipulates that production and operation units should educate and train employees on production safety to ensure that employees have the necessary knowledge of production safety. Without production safety education and training qualified employees, shall not be allowed to work. Occupational Disease Prevention and Control Law of the People’s Republic of China” Article 34 clearly stipulates that the employer shall provide pre-employment occupational health training and regular occupational health training during employment, popularize occupational health knowledge, urge workers to comply with occupational disease prevention and control laws, regulations, rules and operating procedures, and guide workers in the proper use of occupational disease prevention The training and use section of the standard consists of 6 parts. The training and use part of the standard includes six articles, the first of which stipulates that the use of units should develop training and assessment plans, and keep the corresponding records: the second article provides for the training period and training content of knowledge related to the equipment of individual protection: the third article is to solve the problem of some enterprises individual protective equipment “with but not wearing”, the standard provides that the wear and use of occupational health equipment is not in accordance with the provisions. Article 4 stipulates that workers should be proficient in the correct wearing and use of PPE and have the use of units to supervise the use of PPE; Article 5 stipulates the inspection of PPE before use (such as appearance inspection, suitability inspection, etc.); Article 6 stipulates how to conduct daily inspection and maintenance of PPE. Article 6 stipulates how to carry out daily inspection and maintenance of individual protective equipment, which should be in accordance with the relevant content and requirements of the product manual, instruct and supervise individual protective equipment users to carry out correct daily maintenance and pre-use inspection of individual protective equipment in use, and to designate trained and qualified personnel to be responsible for daily inspection and maintenance for those who must be in charge.
Conclusion
GB39800.1-2020 “Individual protective equipment with each specification Part 1: General Provisions” is an important technical support for China’s safety production and occupational disease prevention and control.
Technical support, is to implement the “Work Safety Law of the People’s Republic of China”, “Labor Law of the People’s Republic of China” and “Occupational Disease Prevention and Control Law of the People’s Republic of China” on individual protective equipment related requirements of the important standards, but also the follow-up of individual protective equipment and supervision and management of the important law enforcement basis, belong to the top-level standards of the individual protective equipment standard system. The development and release of the “Individual Protective Equipment Equipment Specification” series of national standards to fill the gaps in our national standards for the management of individual protective equipment, will provide the majority of practitioners with individual protective equipment management, law enforcement and supervision of the basis for our production enterprises to provide individual protective equipment guidance and equipment constraints, to protect the lives and health safety of our employees. Promote the benign development of China’s individual protective equipment industry and industry.