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PPE should be a last resort
In many other chapters of this book, there are descriptions about the ways that employers should identify hazards, evaluate and assess risks with a view to reducing them. Compliance with the Management of Health and Safety at Work Regulations 1999 requires there to be a hierarchy of prevention and control measures where personal protective equipment should be used only as a last resort. Engineering controls and safe systems of work should be used wherever possible instead.
Unfortunately, some employers encourage employees to use PPE without ever considering the introduction of prevention and control measures that could eliminate the use of PPE. This leads to a number of problems:
- PPE protects only the person wearing it, whereas measures controlling the risk at source can protect everyone at the workplace.
- Theoretical maximum levels of protection are seldom achieved with PPE in practice, and the actual level of protection is difficult to assess.
- Protection is often ineffective because the PPE is not suitable, incorrectly fitted, not properly maintained, and may be used improperly.
- PPE is often designed for men, and for women workers this may introduce serious hazards and discomfort.
- PPE is also often designed without considering the reality that both male and female workers come in all shapes and sizes, that parts of the body to be protected vary considerably, that many workers wear spectacles, some have beards and stubble, and so the PPE may fail due to not fitting correctly.
- PPE may restrict the wearer by limiting mobility or vision, or by requiring additional weight to be carried, causing musculo-skeletal problems. As well as the health and safety problems that this may cause, it can also lead to a 'blame the worker' culture when the PPE is discarded because of the discomfort that it can cause.
Hazards affecting workers
Yet even where engineering controls and safe systems of work have been applied, it is possible that some hazards might remain. These hazards may lead to injuries to the:
- lungs, for example, from breathing in contaminated air
- head and feet, for example, from falling materials
- eyes, for example, from flying particles or splashes of corrosive liquids
- ears and hearing from noise
- skin, for example, from contact with corrosive materials or biological substances, or chemical substances that can be absorbed through the skin
- or hands, feet or head from extremes of heat or cold.
Sometimes, PPE is needed in these cases to reduce the risk.
In the 2014 TUC safety representatives' survey, many of these hazards were identified by safety representatives in their top five workplace hazards, broadly similar to 2012. For example:
- 17 per cent mentioned high temperature, up from 14 per cent in 2012.
- Nine per cent mentioned noise.
- Nine per cent mentioned chemicals or solvents.
- 10 per cent mentioned dusts.
- 11 per cent mentioned low temperatures.
A considerable number of laws and regulations of general application apply to PPE. Duties can be found in the other chapters of Hazards at Work:
- Chapter 11 – Management of Health and Safety at Work Regulations 1999 with the obligations placed upon employers to make suitable and sufficient assessments of risks to their employees and non-employees. The risks should be reduced using the principles of prevention outlined in Regulation 4 and Schedule 1, which make it clear that collective measures should be implemented in preference to individual measures
- a variety of specific regulations which include: Chapter 13 – the Control of Asbestos Regulations 2012; Chapter 17 – the Control of Substances Hazardous to Health Regulations 2002; Chapter 28 – the Ionising Radiations Regulations 1999; the Noise at Work Regulations 2005. These regulations take precedence over the PPE at Work Regulations. For example, a person working with asbestos would, where necessary, have to use respiratory protective equipment and protective clothing under the Control of Asbestos Regulations 2012. The Construction (Head Protection) Regulations 1989 have been revoked.
Also, Health and Safety at Work etc. Act 1974 – Section 9, no charge can be made to the worker for provision of PPE which is used only at work. Section 9 states:
"No employer shall levy or permit to be levied on any employee of his any charge in respect of anything done or provided in pursuance of any specific requirement of the relevant statutory provisions."
Safety representatives should check that their employer is observing their responsibilities under the Personal Protective Equipment at Work Regulations 1992.
Safety representatives can identify if there is a problem by:
- carrying out a survey with workers that may be affected
- using hazard and risk mapping with members
- doing a special inspection that concentrates on PPE, using the inspection checklist
- doing a special inspection that concentrates on the information provided and the health and safety training of workers who have to use PPE.
Safety representatives should report their concerns and those of their members to management in writing. Use Chapter 6 of Hazards at Work for ideas on how you can make sure that management gets things done.
Safety representatives should ask for copies of the risk assessments that the employer has done to ensure that they are preventing and controlling hazards without resorting to PPE as a first option. Where PPE is necessary, before choosing any PPE, the employer must make an assessment to determine whether the PPE they intend to provide is suitable for the hazard and for the workers using it. And the employer should consult them fully about this.
Safety representatives can also monitor the employer's safety policy regarding PPE, and check that:
- there are competent personnel that prevent or control hazards without resorting automatically to PPE
- there is consultation "in good time" about arrangements for the appointment of competent people, and training and information arrangements
- where there is any potential risk, that their employer has given all their workforce appropriate training and information
- PPE is suitable to be worn by women workers and all workers with special characteristics such as facial hair, spectacles or disabilities
- the introduction of PPE does not create new hazards such as the wearing of gloves in the health service causing latex allergy, or risk of causing a musculo-skeletal disorder.
(in alphabetical order)
Excellent news and resources on the Hazards web resource page.
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Trade union information
- Some unions provide guidance on PPE. The website addresses of all trade unions are in Britain's unions.
- Contact your union, or visit your union's website to find out what guidance is available.
Issued: 5 April, 2013