SGS Examines the Delivering of Safe PPE to Frontline Health Care Professionals

the world’s leading provider of testing and certification services, looks at
the changes that have been introduced during the COVID-19 pandemic to ensure
frontline health care professionals receive safe personal protective equipment

Responding to the pandemic has meant governments all over the world have
suddenly started ordering medical PPE at unprecedented rates. This has created
market conditions that allow counterfeit, poor-quality, out-of-date and unsafe
products to easy enter the supply chain.

To speed up the supply of medical PPE, governments have also tried variety
of alternative approaches. In the US, the US FDA introduced ‘conservation
strategies’ that allow the use of expired PPE and the reuse of single-use
PPE. It has also relaxed some medical PPE requirements through enforcement
policies and Emergency Use Authorizations. These are intended to increase the
availability of medical PPE by clarifying the policies that the FDA intends to
apply (and those it will not) for medical PPE items such as gowns, gloves,
masks, and respirators.

The Europe Commission has urged Notified Bodies to prioritize new
medical PPE when conducting conformity assessments against Regulation (EU)
2016/425. To create greater flexibility, it has also authorized Member States
to buy PPE that are not CE marked but which can demonstrate an adequate level
of health and safety efficacy. Market surveillance authorities have also been
instructed to focus on PPE compliance.

Europe defines medical PPE as either ‘medical device’ or ‘PPE’. The
classification then defines which legislation is enforced:

  • PPE – Regulation
    (EU) 2016/425
  • Medical device –
    Medical Device Directive 93/42/EEC (MDD) to be replaced by the Medical
    Device Regulation 2017/745 (now delayed until May 2021)

These establish a risk-based classification system that considers the
intended use hazard – greater risk equals higher class/category.

In terms of PPE, the classification can broadly be broken down into:

  • PPE items –
    disposable and re-usable face masks ensuring protection against particulate
    hazards, disposable and re-usable coveralls, gloves, and eyewear
    protection, which are used for prevention and protection against harmful
    biological agents such as viruses
  • Medical PPE –
    surgical masks, examination gloves and some types of gowns

Medical PPE items are classified by the US FDA using a risk-based
approach that depends on intend use setting and hazard mitigation. Generally, PPE
items that are intended to have a lower risk mitigation and/or are intended for
lower risk settings are deemed to be Class l medical devices. Medical PPE intended
for higher risk scenarios – e.g. surgical masks, surgical gowns, and surgical respirators
– are classified as Class II medical devices and have a greater regulatory

Surgical masks, as Class ll medical devices, must demonstrate to the
FDA, through design and/or testing, that they can mitigate certain risk hazards
associated with surgical settings. The FDA-recognized consensus standard for
surgical masks, ASTM F2100 – Standard Specification for Performance of
Materials Used in Medical Face Masks,
contains testing and requirements for
the materials used in the construction of these medical face masks.

Evaluations and methods within ASTM F2100 include:

  • Submicron Particle Filtration Efficiency (PFE) – ASTM F2299
  • Bacteria Filtration
    Efficiency (BFE) – ASTM F2101
  • Blood/Fluid
    Penetration Resistance – ASTM F1862
  • Breathability/Air
    Flow Resistance – EN 14683 Annex C
  • Flammability
    Resistance – 16 CFR 1610

Surgical N95 respirators, which are N95 respirator face masks cleared
for use in healthcare settings, must meet the typical FDA requirements of a
surgical mask as well as those requirements for a respirator approved by the
National Institute for Occupational Safety and Health (NIOSH) under 42 CFR Part
84. This requires the completion of a variety of performance tests, detailed in
Subpart K of 42 CFR Part 84, as well as the submission of drawings, packaging,
labels, user instructions, a product quality plan, and a quality assurance
manual for its manufacturing facility. Approved products are added to NIOSH’s
online Certified Equipment List.

Manufacturers and suppliers of medical PPE are advised to ensure their
products conform to the correct standards for their market to ensure the
products used by frontline health care staff are compliant, safe and effective.

SGS Medical PPE Services

SGS offers a comprehensive range of services to help manufacturers and
suppliers of medical PPE successfully access target markets around the world.
Utilizing our global network of testing facilities and experts, we offer a
one-stop shop for all PPE testing and certification requirements. Learn more
about SGS’s Medical
PPE Services

For more information, please contact:

Matthew McGarrity

Senior Technical Manager – Hardlines

SGS Consumer and Retail



About SGS

SGS is the world’s leading
inspection, verification, testing and certification company. SGS is recognized
as the global benchmark for quality and integrity. With more than 89,000
employees, SGS operates a network of over 2,600 offices and laboratories around
the world.

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