This is an excerpt from the TUC book "Hazards at Work: Organising for safe and healthy workplaces", the best-selling guide to health and safety at work.
Buy a copy of the book (if you are a safety representative on a TUC training course, please speak to your tutor about getting a discounted copy).
At the time of writing, the use of PPE is headline news as the country battles the respiratory virus Covid-19. The government has struggled to provide enough equipment for NHS and other frontline workers, and supplies of varying quality are being hastily manufactured here and abroad.
The information below is based on its use in more normal circumstances.
Even where engineering controls and safe systems of work have been applied, it is possible that residual hazards may remain a threat. These may lead to injuries to the:
Sometimes, PPE is needed in these cases to reduce the residual risk.
In the 2018 TUC safety reps’ survey, many of these hazards were identified by safety reps in their top five workplace hazards, broadly similar to 2016. For example:
14 per cent mentioned high temperature, similar to 16 per cent in 2016.
11 per cent mentioned noise, same as 2016; five per cent mentioned chemicals or solvents.
10 per cent mentioned dusts; 14 per cent mentioned low temperatures and 7 per cent mentioned infections.
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:
A range of legislation includes PPE and there is coverage in several other chapters of this book. The Management of Health and Safety at Work Regulations 1999 put obligations on 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.
Other regulations include:
Definition of PPE (Regulation 2)
Personal protective equipment means all equipment (including clothing affording protection against the weather) which is intended to be worn or held by a person at work and which protects them against one or more risks to their health and safety, and any addition or accessory designed to meet that objective.
In practice, however, these regulations will not apply to ear protectors, most respiratory protective equipment and some other types of PPE used at work. These types of PPE are specifically excluded from the PPE at Work Regulations because they are covered by existing Regulations such as the Noise at Work Regulations. However, even if the PPE at Work Regulations do not apply, the Regulations and Guidance may still be applicable, as the general principles of selecting and maintaining suitable PPE and training people in its use are common in all Regulations which refer to PPE
Provision of Personal Protective Equipment (Regulation 4)
When health and safety risks cannot be adequately controlled by other means, employers must provide employees with suitable PPE. Self-employed persons have a similar duty to themselves. Suitable PPE means:
Employers should ensure that PPE is provided for personal use to ensure hygiene and health.
Compatibility of PPE (Regulation 5)
Where there is more than one risk, employers must ensure that different items of PPE that have to be worn together by employees are both compatible and effective.
Assessment of PPE (Regulation 6)
Before choosing any PPE, the employer must make an assessment to determine whether the PPE they intend to provide is suitable. The assessment required should include:
The assessment must be reviewed if:
Maintenance and replacement of PPE (Regulation 7)
Every employer must ensure that any PPE provided is:
Accommodation for PPE (Regulation 8)
Appropriate accommodation must be provided for PPE when it is not in use.
Information, instruction and training (Regulation 9)
Employers must provide employees with information, instruction and training that is adequate, appropriate and that they understand. This will ensure that employees know:
Information must be kept available, and at suitable intervals demonstrations in the wearing of PPE should be organised.
Use of PPE by employees (Regulation 10)
Employers must take all reasonable steps to ensure that employees properly use the equipment provided.
Reporting loss or defect (Regulation 11)
Employees must report to their employers any loss of or obvious defect in the PPE provided for them.
The self-employed also have a duty to obtain and use the appropriate PPE wherever there is a risk to their health and safety that cannot be adequately controlled by alternative measures.
Safety reps should check that their employer is observing their responsibilities under the Personal Protective Equipment at Work Regulations 1992.
Safety reps can involve workers in identifying if there is a problem by:
Safety reps 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 reps 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. Reps should check that they are being consulted on the purchase of PPE to ensure the employer makes an assessment to determine that the PPE is appropriate for the hazard and for the workers using it.
Safety reps can also monitor the employer's safety policy regarding PPE, and check that:
(in alphabetical order)
Excellent news and resources on the Hazards web resource page.
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Many 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.
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