PPE
Also known as: Personal protective equipment
PPE is equipment worn to protect against risks that could not be removed by other means. It is the last control in the hierarchy, not the first.
- Equipment worn by a person to protect against a residual risk.
- The employer must supply it free, and make sure it fits and is maintained.
- It is the last resort after the hazard itself has been tackled.
PPE is personal protective equipment: the hard hats, boots, gloves, eye protection, hearing protection, respiratory protection and harnesses worn to protect against a risk that could not be removed by other means.
The legal position is easy to state and often misread. PPE is a last resort. It sits at the bottom of the hierarchy of control because it does the least of any control available: it protects one person, only while it is being worn, only if it fits, and only if it has been looked after. Every option above it protects everyone in the area whether or not they remember to do something.
What the employer has to do
Provide it free of charge. Since the 2022 amendment to the regulations, that duty extends beyond employees to limb workers, which on a construction site brings in a large share of the labour that used to sit outside it.
Make sure it is right for the risk, and compatible where more than one item is worn together. Eye protection that breaks the seal on a mask, or a hard hat that stops ear defenders sitting properly, creates a new problem while solving the first.
Make sure it fits. For tight-fitting respiratory protection this means face-fit testing to the individual, and repeating it if their face changes. A beard at the seal defeats the mask regardless of its rating, which is why clean-shaven policies exist on sites with a silica or fume risk.
Maintain, store and replace it, and train people to use it. Then check that it is actually being worn, because provision without supervision is where most of the enforcement action lands.
Where it goes wrong
The recurring failure is PPE standing in for a control plan. A risk assessment that lists dust masks against a silica hazard and stops there has skipped elimination, substitution, on-tool extraction and water suppression, all of which are more effective. Where a COSHH assessment reaches respiratory protection, it should show what was tried above it.
The second failure is the record. Face-fit certificates, training and issue records tend to live in a folder in the site office rather than against the person. Keeping them on the individual’s record, with the expiry visible, is what makes them producible when an audit or an incident calls for them. That is what Sync’s credential management does.
Common questions
Can an employer charge for PPE?
No. PPE required to control a risk at work must be provided free of charge, and the cost cannot be recovered through deductions from wages. Since the 2022 amendment this extends to limb workers as well as employees, which brings much of the self-employed labour on a typical site within scope.
Does PPE need to be fitted?
Respiratory protection does, and it is the most commonly missed duty on site. A tight-fitting mask has to be face-fit tested to the individual wearing it, and the test is invalidated by beard growth at the seal. Harnesses, footwear and eye protection also need to fit properly to work at all.
Is a hard hat always required?
On most construction sites, yes, as a site rule. In law the requirement comes from the risk assessment rather than a blanket rule, but the practical answer on a live site is that head protection is mandatory unless there is a specific, assessed reason it is not.
Who maintains it?
The employer is responsible for making sure PPE is maintained, stored properly and replaced when it is damaged or past its life. The wearer is responsible for using it as trained and reporting defects.
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