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TR CU 019/2011: documents for workwear and other PPE

A formal attitude to PPE documents ends not with a fine but with an accident. Gloves for working with chemicals and gloves for cleaning are legally different goods, even if they look the same.

Personal protective equipment is the category where a formal attitude to documents ends not with a fine but with an accident. This is why the requirements here are stricter than for ordinary clothing: gloves for working with chemicals and gloves for cleaning are legally different goods, even if they look the same.

What counts as PPE

TR CU 019/2011 applies to personal protective equipment. These are products intended to prevent or reduce the effect of harmful and dangerous factors on a person.

The line is drawn by the claimed protection An ordinary work jacket without claimed protective properties falls under TR CU 017/2011 as a light industry product. As soon as you write “abrasion protection” or “high visibility”, the product becomes PPE, with all the resulting requirements. The wording in the product card decides which regulation you will be checked against.

Certification or declaration

The regulation divides PPE into two classes by the degree of risk, and the class directly decides the form of conformity assessment.

Class 1Class 2
Nature of the riskSimple designs, reversible injuriesProtection against irreversible injuries and death
Form of conformity assessmentDeclarationMandatory certification
ExamplesGeneral-purpose gloves against mechanical impacts, simple workwear with basic protectionProtection against chemicals, electric arc and falls from a height; respiratory protection, hard hats

The practical conclusion: most serious PPE is certified, which means tests in an accredited laboratory and, for serial production, inspection control. With regular deliveries, a batch scheme quickly becomes more expensive than a serial one. The schemes are explained in a separate article.

What the tests confirm

The laboratory does not test the product “in general”. It tests the specific protective properties that you claim. Each claimed property is a separate indicator and a separate cost.

You claimWhat will be checked
Protection against abrasion and puncturesResistance of the material to mechanical impacts
Protection against low temperaturesThermal insulation for a given climate zone
Limited flame spreadBehaviour of the material in contact with fire
Protection against electric arcResistance to the thermal effect of the arc
Protection against chemicalsResistance to specific substances, not to “chemicals in general”
High-visibility propertiesArea and brightness of the retroreflective elements
Protective toe cap of footwearImpact load and resistance to compression

The key point: protection against chemicals is always specific. Gloves tested for resistance to acids are not confirmed for solvents. The claim “chemical resistant” without naming the substances is not a characteristic. It is a reason for a complaint.

Marking of PPE

Here the marking carries more meaning than for any other product: the worker uses it to understand what the product protects against and for how long.

The instructions are mandatory and must contain the procedure for checking before use, the limits and the signs by which the product must be replaced. For fall protection systems this is literally a matter of life, and it is checked seriously.

Service life is not a formality For many PPE it is limited whatever the product looks like: a hard hat ages from ultraviolet light, respirator filters have a shelf life, and lanyards lose strength. Stating the service life is a mandatory part of the marking, and without it the company cannot control the replacement.

Who buys this and why they check strictly

The main buyer of PPE is the employer, who must provide it for the workers. The employer needs the documents not as a formality: after an accident, the investigators will check what the worker was given and whether it matched the working conditions.

From this come the features of sales in this niche:

So careless documents here cost not a blocked product card but the loss of a corporate customer.

Importing PPE

Typical mistakes

MistakeConsequence
A document under 017 for a product with claimed protectionThe wrong regulation; there is no conformity assessment
A declaration instead of a certificate for class 2Wrong form of conformity assessment
“Chemical resistant” without naming the substancesThe property is not confirmed
A protection class is claimed that is higher than the one confirmed by testsMisleading, with a risk to life
No instructions and no service life statedIncomplete accompanying information
The material or the fittings were changedThe protective properties may have changed, and new tests are needed

The fourth row is the most dangerous. If you overstate the protection class to win a tender, a person will be less well protected at a critical moment than they expected. This is no longer a question of administrative liability.

Action plan

If you do not claim protective properties, the product goes back to light industry, and then the starting point is the analysis of TR CU 017/2011. How inspection control works is explained in a separate article.

Check your product Describe the product and what it must protect against. The system will determine whether you fall under the PPE regulation and will show the form of conformity assessment. Start the check.
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