Background

Due to the current situation with the Omicron variant of the virus, in more and more situations the use of FFP2 masks by the general public is required. This is not always a government decision, but also specific organisations/facilities require this for the public visiting (e.g. healthcare facilities, universities/schools, …).

Therefore, the European Safety Federation considers it necessary to repeat some concerns we already made a year ago, and also add a few following recent evolutions.

First of all, we want to refer to our paper dated 04/02/2021 (see attached as annex) as the vast majority of the points made at that moment are still valid. 

remark : download the full paper at the bottom of page

Since then, the Recommendation (EU)2020/403 is no longer applicable (see Commission Recommendation (EU)2021/1433 of 01/09/2021), which means only FFP masks fully in compliance with the PPE Regulation (EU)2016/425 can be placed on the market as of 01/10/2021. This has been possible as the shortages known in the beginning of the pandemic are no longer an issue due to huge increases of production capacity.

Additional concerns

In order to stop certain parties of applying excessive sales prices to the general public, maximum sales prices have been introduced by some authorities. While it makes sense to protect the general public from abuses by excessive prices, there are some important disadvantages, even risks to these limitations. If such limitations would be implemented, at least consultation of the concerned sector needs to be part of such an exercise, which was not always the case so far.

By limiting the sales prices to a fairly low level, those suppliers offering cheap, low quality and even non-compliant FFP masks are encouraged to continue or even expand their activities. We remind you of the important public investments encouraging and supporting EU production of, amongst others, FFP masks. Making it as good as impossible to sell masks produced in the EU disregards completely these efforts. Serious economic operators that offer only fully compliant masks are forced out of the market as they are unable to realise necessary margins. This means more non-compliant PPE on the market and while consumers have the impression they get correct protection, the reality is the contrary, so a false sense of protection.

Certainly consumers are buying products (including masks) more and more online. Looking at the online offers for ‘FFP masks’, it is clear that a huge variety of non-compliant PPE are being offered. But also, the sales price limitations are not applicable to online shops (certainly those based in different countries).

Without very strong market surveillance as well on compliance with the PPE Regulation as on sales price limitations, the decisions on limitations of sales price are completely ineffective and even could lead to an adverse effect : unsafe FFP masks for higher prices than intended. Looking at the number of notifications in the ‘Safe Gate’ system, this is very worrying for the evolution in the market for consumers.

 Another point that we need to stress is the lack of correct information to the general public. While the obligations/recommendations to use FFP masks for the general public are widely mentioned in the media, it is extremely rare to get at the same time information on the correct use of the FFP masks. Is the general public made aware that an FFP mask that is not properly fitting looses a good part of the protective properties ? Presence of facial hair is for instance not mentioned as an issue. Even after almost 2 years of pandemic, it is not uncommon to see in the media images of persons wearing FFP masks incorrectly.

Conclusion

While wearing FFP masks, even for the general public, has advantages for the protection of the individual, the efficacy of measures taken to encourage/oblige this is restricted by lack of market surveillance and proper training/information of the consumers by authorities and media.

Annex : ESF position paper dated 04/02/2021