What we Look for

PPE or personal protective equipment including Swim Jackets and Float Vest type products are covered under regulation 2016/425 of the EU and EN13138-1:2021 is the latest iteration of the standard that applies to these products.

BAMRA recognises that thestandard is quite onerous and there will always be occasions where decisions
made by testing companies in regards to passing or failing may fall into being matters of opinion. Genuine designers and manufacturers who make every effort to meet the standard are looked on with empathy. Sadly however there are a very large number of companies who either through ignorance or worse wilfully do
what they can to avoid or subvert testing, resulting in unsafe, uncompliant and illegal product being used by babies and small children. There are enough of them to warrant the existence of BAMRA and its campaign for fair compliance (CAFCO)

The standard covers a great many elements of the products and aspect of consumer protection and ensuring the product is safe and fit for purpose. It should be noted that if a product doesn’t pass the tests and labelling observations then it cannot use the CE and UKCA mark and is illegal to sell a PPE without the CE and UKCA mark on it.

The latest version of EN13138-1: has added a number of additional tests and requirements including a much
stronger requirement for conspicuity/visibility, an amendment to the buoyancy testing procedure and updates on sizing and labelling.

Conspicuity

The CEN committee that has amended the standard to for 2021 have been very clear that they do not allow
muted, organic, natural colours to be used for Swim Jacket Float Vests. They have introduced a test featuring 4 common backgrounds, light blue, dark blue, grey and white tiled, simulating swimming pools and seawater with the intention of ensuring the wearer can be spotted in a busy swimming pool or in seawaters.

Consumers may wish or even demand softer cuter colours but to achieve a pass the Testing company must be sure that the colours used are bright and in contrast all four of the backgrounds stipulated by the standard.

If a Swim jacket Float vest isn’t bright and in contrast to the colours then it should not  have passed the clause and therefore should not be allowed on sale. Here are examples of both:

Compliant

Examles of seemingly Non-compliant

Buoyancy:

Fundamentally the authors of EN13138-1:2021 are looking to limit the use of Swim Jacket Float Vest type products by small children of under two years of age UNLESS the swim vest float jacket product has undergone and passed testing on a specific mannequin in laboratory conditions in a monitored pool. To date the three main testing houses ITS, SGS and BV have stated that they are not aware of any Swim Jacket Float Vests in this current form that have passed the test on the required mannequin II.

There are a great many Swim Jacket Float Vests being marketed in the age/weight categories 1-2 years 11-19
Kilos or even 1-3 years 11-19 kilos that make the claim of having passed the particular test but offer no evidence that they have.

Babies and small children have disproportionately heavier heads and so a Swim Jacket Float Vest that isn’t
configured correctly can be frightening and even dangerous especially for babies of 12-18 months.

These are only two elements that we look for but they are important, or the committee wouldn’t have included them in the standard. But they are easily sidestepped by manufacturers.  Many of these companies are deliberately evading their obligations and relying on UK and EU authorities not having the
capacity to spot their deceptions. They will test one style/type of product and then ship a number of different products quoting the same reference. No-one calls them out and the consumer ultimately pays the price.

So we continue to seek out products that don’t comply. We are only looking for examples of either unsafe
product and/or deliberate circumvention of the requirements that are necessary to apply the CE and UKCA mark and ensure the safety of the consumer.  We are in a conversation with government on how to approach the matter of fair compliance on a wider and national basis.

Contact Us

Please feel free to contact us on:

e: office@bamra.org

t: 07717 246900