This guide is a plain summary, not legal advice. For your own business, check HSE guidance or take professional advice.
PPE is the last line of defence
PPE should only be relied on once other ways of controlling a risk have been considered. Removing the hazard, guarding machinery, changing the process or separating people from traffic all come first. PPE protects only the person wearing it, and only when it fits and is worn correctly.
Your risk assessment should show where PPE is still needed after those other steps.
What employers must do
Where the risk assessment shows PPE is needed, the main duties include:
- Provide suitable PPE, without charging workers for it
- Assess that it suits the risk, the job and the person
- Make sure it fits, including for women and people of different builds
- Maintain, replace and store it properly
- Give information, instruction and training on its use
The 2022 change: limb (b) workers
From 6 April 2022, the Personal Protective Equipment at Work (Amendment) Regulations 2022 extended these duties beyond employees to limb (b) workers. These are people who work under a looser arrangement, such as some casual, agency or zero-hours staff.
In practice, if you provide PPE to employees for a task, you now need to provide it on the same basis to limb (b) workers doing that task. Those workers also have a duty to use it properly. HSE has been reviewing the regulations, so check its website for any later changes.
Uniform is not always PPE
A branded polo or softshell is uniform: it shows who you are but does not protect against a specific risk. Hi-vis on a site, safety boots in a warehouse or FR coveralls on a plant are PPE when the risk assessment calls for them. The difference matters because the legal duties apply to PPE, while uniform is a matter for your own policy.
Getting the right standard
PPE should be marked to the relevant standard for the risk, such as EN ISO 20471 for hi-vis, EN ISO 20345 for safety footwear, EN 388 for mechanical risks to hands, or EN ISO 11612 for heat and flame. Check the marking on the garment or its user information rather than relying on a product name.
Where to put your logo
Branding PPE is common and useful, as it shows who is on site, but it must never reduce the protection. On hi-vis, logos go on the fluorescent fabric only, never over reflective tape, and large logos can reduce the compliant area. On FR clothing, the logo method and materials must suit the garment. Supplying PPE alongside branded uniform in one order keeps each person's kit together and makes starter kits simpler.
