PPE at Work: Your Duties as an Employer

Last Resort, Not First Response

Personal protective equipment sits at the bottom of the hierarchy of control for a reason. It protects only the person wearing it, it does nothing to remove the hazard, and it fails the moment it is worn incorrectly, damaged or left in the van. The law reflects this: PPE should be used when risks cannot be adequately controlled by other means, not as a substitute for them. Handing out gloves is not a risk assessment.

That said, in many jobs PPE is genuinely essential, and when it is, the Personal Protective Equipment at Work Regulations 1992 set out exactly what employers must do. Since the 2022 amendment, those duties extend beyond employees to limb (b) workers, the casual and gig-style workers who work under a contract personally but are not full employees. If you engage casual labour, the PPE duties now cover them too.

The Core Duties

Provide it free of charge

Where PPE is required by the risk assessment, the employer provides it and cannot charge for it, or take deductions for it. That includes replacements when equipment wears out through normal use.

Make sure it is suitable

Suitable means appropriate for the actual risk, the conditions, the duration of the task and, crucially, the person. Consider:

• Does it protect against the specific hazard, at the level required? A dust mask rated for nuisance dust will not protect against silica.
• Does it fit? Faces, hands and bodies come in all shapes and sizes, including differences between men and women that one-size-fits-all kit ignores. Tight-fitting respirators legally require face fit testing for each wearer.
• Is it compatible with other PPE worn at the same time? Safety glasses that break a respirator's seal are making things worse.
• Can the person wear it comfortably for the duration of the work? Uncomfortable PPE gets removed, quietly, when nobody is watching.

Train people to use it

Workers need to know what the PPE protects them from, when to wear it, how to put it on and adjust it, how to spot damage, and how to store and clean it. A hard hat stored on the rear parcel shelf in sunlight, or a respirator kept loose in a toolbox full of dust, has been quietly ruined.

Maintain and replace it

PPE must be kept in good repair, with appropriate storage provided. Some items have service lives and expiry dates; helmets and respirator filters are common examples. Build checks into routine supervision rather than waiting for kit to fail.

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What Workers Must Do

Employees have duties too: use PPE as trained, look after it, store it properly and report loss or defects. Make the reporting easy. If getting replacement gloves takes three forms and a week, people will work with holes in the old ones.

Getting Buy-In

The difference between PPE that is worn and PPE that decorates a peg usually comes down to involvement. Let wearers trial options and have a say in what is chosen; comfort and dignity matter. Explain the why, enforce consistently from the top down, and lead by example. A site manager who walks the floor without ear defenders has just rewritten the rules for everyone watching.

Where to Start

Review your risk assessments first: is each item of PPE actually needed, and is anything needed that is missing? Then check fit, training, storage and replacement arrangements. Integral Safety can help with all of it, from consultancy support to accredited face fit testing for respirator wearers. Contact us to arrange a visit.