Image showing various items of PPE for workers

PPE Selection, Issue and Use at Work

PPE in Brief

PPE is the last line of defence under PPE at Work Regulations 1992 (amended 2022 to cover limb (b) workers). Selection, training, maintenance and supply records are what get checked.

Personal Protective Equipment (PPE) at Work

Personal protective equipment is anything worn or held by a worker to protect them from one or more health and safety risks. That includes safety helmets, gloves, eye protection, high-visibility clothing, safety footwear, respiratory protection, harnesses, and hearing protection.

PPE sits at the bottom of the hierarchy of control - it protects only the wearer, it relies on correct use, and it can fail. The first duty is always to eliminate or engineer out the hazard before falling back on PPE. Where PPE is the chosen control, the arrangements for providing, maintaining and training on it need to be as solid as any other safety control.

PPE and the 2022 Regulations Update

In the UK, the Personal Protective Equipment at Work Regulations 1992 were amended by the Personal Protective Equipment at Work (Amendment) Regulations 2022, which came into force on 6 April 2022. The amendment made one significant change - it extended PPE duties to cover all workers, not just employees.

The pre-2022 position covered only those with an employment contract. The 2022 amendment brought "limb (b) workers" into scope - casual workers, gig economy workers, agency workers, and others working under a contract personally to perform work. If someone is doing work for you and is exposed to risks that require PPE, you now have a duty to provide suitable PPE free of charge regardless of their employment status.

What the PPE Regulations Require

The core employer duties under the amended PPE at Work Regulations:

Carry out a suitability assessment before providing PPE, matching the equipment to the risk and to the worker.
Provide PPE free of charge to any worker who needs it.
Make sure PPE is maintained in efficient working order and good repair.
Provide appropriate storage for PPE when not in use.
Give workers information, instruction and training on the risks the PPE protects against and how to use it.
Have arrangements for reporting loss or defects.

Specific PPE types are covered by additional regulations - respiratory protective equipment falls under COSHH, hearing protection under the Control of Noise at Work Regulations, and PPE for construction work has its own requirements.

Assessing PPE Needs

PPE selection is only valid if the assessment that sits behind it is sound. The assessment needs to consider:

The hazard - what is the PPE protecting against? Impact, abrasion, cut, chemical splash, dust, vapour, noise, fall from height?
The risk level - how severe is the potential harm, and how likely?
The worker - fit, comfort, existing conditions, compatibility with other PPE, and compatibility with the task.
Multiple PPE compatibility - can the worker wear the hard hat, safety glasses, hearing protection and respirator together without one compromising another?
Standards compliance - the PPE must meet the relevant UK-designated standard (UKCA marking, or CE marking during the continued recognition period).

Managing PPE in Use

Providing PPE is only the start. Ongoing management includes:

Issue records - keep a record of what has been issued to whom, when, and what size. Required for some PPE types and useful as evidence of provision for all.
Fit testing - tight-fitting respirators must be face-fit tested for each user. Re-test when the user's face changes (significant weight change, dental work, facial hair growth).
Inspection and maintenance - routine checks before use by the wearer, plus scheduled servicing for items like harnesses and respirators.
Replacement - PPE has a working life. Gloves get abraded, filters expire, harnesses go out of certification. Have a replacement process rather than waiting for workers to ask.
Training - workers need to know why they are wearing it, how to wear it correctly, how to check it is still working, and when to replace it.

The 2022 amendment is the single biggest change in PPE law for thirty years, but I still meet organisations that are not aware of it. If you engage agency workers, contractors on a personal services basis, or anyone on a casual arrangement, they are now in scope. Your contracts and your PPE provision arrangements need to reflect that - not just employees any more.

On the shop floor, the thing that undermines PPE programmes more than anything is comfort. If the gloves do not fit, they come off. If the respirator pinches, it slips. If the glasses fog up, they get pushed up on the forehead. Comfort is not a luxury - it is the difference between a control that works and a control that does not. Bring workers into the selection process and pay attention to the feedback.

We switched from one glove supplier to a range of three after asking workers what they actually needed. Some hands are small, some are large, some jobs need grip, some need dexterity, some need cut resistance. One glove did not suit everyone. Compliance on glove-wearing went up the week we rolled out the choice.

On respirators, face-fit testing is the single most valuable session we run each year. We do it on-site, everyone gets their own model recorded on their personal file, and anyone who grows a beard knows they need to go on the powered air range instead.

For anyone working to ISO 45001, PPE is part of your operational control under Clause 8. The standard expects you to apply the hierarchy of control, which means PPE should appear as the last layer after elimination, substitution, engineering and administrative controls have been considered. Auditors will look for evidence that you have considered higher-order controls rather than jumping straight to issuing gloves and glasses.

The documented information auditors expect to see includes the PPE assessment, the issue records, the training records, and the evidence of maintenance and inspection where applicable. It does not all have to live in one place, but an auditor should be able to pull the thread for a given hazard and see the full picture.

Practical Compliance Guidance

Section 7 of the IMS1 Manual covers the operational H&S management requirements including PPE. It covers the assessment, provision, issue recording, training and maintenance of PPE as part of an integrated management system.

The alphaZ documents below give you the policy, procedural guidance, issue forms, and training material for running a compliant PPE arrangement aligned with the amended UK regulations.

alphaZ document	How to use it
ISO 9001 14001 45001 IMS Toolkit	The full integrated toolkit for ISO 9001, 14001 and 45001. Contains the procedural documents, forms and guidance needed to set up and run a compliant management system including PPE arrangements.
P71 PPE Policy	Sets out the organisation's commitment to providing and managing PPE. Issue to workers as part of the wider H&S policy set.
PP-7-01 Safe Use and Management of PPE Policy Procedure	The policy-procedure document covering PPE assessment, selection, provision, training and maintenance. Use as the written procedure for the management system.
PP-7-100 Health and Safety Policy Procedure	A single integrated H&S policy-procedure covering PPE alongside COSHH, manual handling, risk assessment and the other core H&S topics. Use as an alternative if you prefer one umbrella H&S procedure over separate topic-specific ones.
GG-7-01 Safe Use and Management of PPE	Plain-English guidance for line managers and workers. Covers what PPE is, when to use it, and how to care for it. Issue alongside training.
F-HS1 PPE Issuance Log	The organisation-wide record of PPE issued to each worker. Maintain for as long as the worker is employed and for a reasonable period afterwards.
F-HS2 Employee PPE Issue Sheet	Per-worker record of PPE issued, with signature to confirm receipt, training and instructions received. Key evidence for audit and for investigation if PPE fails.
TT-7-01 Safe Use and Management of PPE Toolbox Talk	Briefing material covering the key PPE points for workers. Deliver at team meetings and retain signed records as evidence of awareness training.

Note - all the above files can be downloaded with an alphaZ subscription.

Frequently Asked Questions

Can we charge workers for PPE?

No. Under the PPE at Work Regulations, PPE must be provided free of charge to any worker who needs it for the work they are doing. That includes replacement items when PPE is worn out or damaged through normal use. The 2022 amendment extended this duty to cover limb (b) workers as well as employees.

Who is a "limb (b) worker" under the 2022 amendment?

Limb (b) refers to section 230(3)(b) of the Employment Rights Act 1996. It covers people who work under a contract personally to perform work or services, but who are not in business on their own account dealing with a client. Common examples are agency workers, casual workers, and gig economy workers. The 2022 PPE amendment extended the employer's duty to provide PPE free of charge to this group.

Do we need to face-fit test disposable dust masks?

Yes, if they are tight-fitting (FFP2 or FFP3 disposable respirators relied on for respiratory protection). Face-fit testing is required for all tight-fitting respiratory protective equipment, disposable or reusable. Loose-fitting respirators (such as powered air hoods) do not require fit testing but still need the correct selection and training.

What about workers who wear their own PPE?

The employer's duty to provide suitable PPE free of charge cannot be discharged by accepting a worker's own equipment. If a worker wishes to use their own PPE (such as safety boots they are used to wearing), the employer must still check it is suitable and meets the required standard. In practice most employers require issued PPE for consistency and traceability.

UK Legislation

The following UK legislation is directly relevant to PPE. Organisations outside the UK should identify the equivalent legislation applicable in their jurisdiction.

Further Resources