PPE at Work: UK Regulations and Compliance Guide

Personal protective equipment (PPE) is one of the most visible aspects of workplace safety — hard hats on construction sites, gloves in kitchens, goggles in laboratories. Yet PPE is also one of the most commonly misunderstood. Many employers treat PPE as their primary safety measure, when the law is clear that it should be the last resort after all other control measures have been considered. Others fail to maintain it properly, train workers in its use, or keep the records needed to demonstrate compliance.

The regulations governing PPE in the UK changed significantly in 2022, extending duties to a wider group of workers. This guide covers the updated legal framework, employer and employee responsibilities, the PPE hierarchy, training requirements, record-keeping obligations, and the mistakes that most commonly lead to enforcement action.

What Is PPE?

The Personal Protective Equipment at Work Regulations 2022 define PPE as:

“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 the person against one or more risks to the person’s health or safety.”

This includes:

• Head protection — hard hats, bump caps, helmets
• Eye protection — safety glasses, goggles, face shields, visors
• Hearing protection — ear plugs, ear muffs, banded ear protectors
• Respiratory protection — disposable masks, half-face respirators, full-face respirators, powered air-purifying respirators
• Hand protection — gloves (chemical-resistant, cut-resistant, thermal, anti-vibration)
• Foot protection — safety boots, safety shoes, wellington boots with steel toe caps
• Body protection — high-visibility clothing, overalls, chemical-resistant suits, chainsaw trousers
• Fall protection — harnesses, lanyards, fall-arrest systems
• Skin protection — barrier creams, sun protection

Ordinary work clothes and uniforms that are not specifically designed to protect against a health and safety risk are not PPE under the regulations.

The Legal Framework

Personal Protective Equipment at Work Regulations 2022

The Personal Protective Equipment at Work Regulations 2022 came into force on 6 April 2022, replacing the Personal Protective Equipment at Work Regulations 1992. The most significant change was extending PPE duties to cover limb (b) workers — those who are not employees but who personally perform work under a contract (such as casual workers, some agency workers and some self-employed workers).

Under the 1992 regulations, only employees were covered. The 2022 update brought PPE law into line with a 2017 Supreme Court ruling and ensures that all workers who need PPE receive it, regardless of their employment status.

Key Duties Under the 2022 Regulations

Regulation 4 — Provision of PPE

Every employer must ensure that suitable PPE is provided to employees who may be exposed to a risk to their health or safety while at work, except where and to the extent that such risk has been adequately controlled by other means which are equally or more effective.

This is the critical principle: PPE is a last resort. It should only be relied upon when risks cannot be adequately controlled by elimination, substitution, engineering controls or administrative controls.

Regulation 5 — Compatibility

Where more than one item of PPE must be worn simultaneously, they must be compatible with each other. For example, a hard hat must be compatible with ear defenders, and safety goggles must fit properly over a half-face respirator. Incompatible PPE can reduce the protection provided by each item.

Regulation 6 — Assessment of PPE

Before choosing PPE, the employer must carry out an assessment to determine whether the PPE is suitable. This assessment must consider:

• The risks that have not been avoided by other means
• The characteristics of the PPE needed to be effective against those risks
• Any risks created by the PPE itself (e.g. reduced visibility, restricted movement, heat stress)
• Whether the PPE can be adjusted to fit the wearer correctly

Regulation 7 — Maintenance and replacement

PPE must be maintained in an efficient state, in efficient working order and in good repair. This includes cleaning, disinfection, inspection, repair and replacement as necessary.

Regulation 8 — Storage

Appropriate accommodation must be provided for PPE when it is not being used — clean, dry storage that prevents contamination, damage or loss.

Regulation 9 — Information, instruction and training

Employers must provide employees with adequate and appropriate information, instruction and training on:

• The risks the PPE is intended to protect against
• How to use the PPE correctly (including how to put it on, take it off, adjust it and store it)
• Any limitations of the PPE
• How to maintain and care for the PPE
• How to report defects or damage

Regulation 10 — Use of PPE

Every employer must take all reasonable steps to ensure PPE is used properly. Every employee must use PPE in accordance with training and instruction, return it to its storage after use, and report any defect or loss.

The Hierarchy of Control: PPE as Last Resort

The principle that PPE should be a last resort is not just guidance — it is embedded in the law. The Management of Health and Safety at Work Regulations 1999 and the Personal Protective Equipment at Work Regulations 2022 both require employers to follow the hierarchy of control:

1. Eliminate the hazard entirely — can you remove the dangerous substance, process or activity?
2. Substitute with something less hazardous — can you use a less toxic chemical, a quieter machine, a safer process?
3. Engineering controls — can you isolate people from the hazard using guards, enclosures, ventilation or barriers?
4. Administrative controls — can you change the way people work to reduce exposure (job rotation, limiting time in hazardous areas, safe working procedures)?
5. PPE — when all the above measures are insufficient, provide appropriate PPE to protect against the residual risk

An employer whose entire risk control strategy is “give them PPE” is almost certainly not compliant. PPE fails if it is not worn, does not fit, is damaged, or is the wrong type for the hazard. Higher-level controls protect everyone in the area, regardless of individual compliance.

Employer Duties in Detail

Selecting Suitable PPE

PPE must be:

• Suitable for the specific risks — Nitrile gloves protect against some chemicals but not others. An FFP2 mask protects against fine particles but not gases. Selecting the wrong PPE provides a false sense of security.
• Appropriate for the conditions — Consider temperature, humidity, duration of wear, and compatibility with other tasks. PPE that is too uncomfortable to wear for the required duration will not be used consistently.
• Correctly sized — PPE that does not fit properly provides reduced protection. This is particularly critical for respiratory protective equipment (RPE), which must be face-fit tested for each individual wearer. One size does not fit all.
• CE/UKCA marked — All PPE sold in Great Britain must carry the UKCA mark (or CE mark during the transition period) and comply with the relevant standards.

Providing PPE Free of Charge

Employers must provide PPE free of charge to employees and limb (b) workers. You cannot ask workers to buy their own PPE, deduct the cost from wages, or require a deposit. If PPE needs replacing due to wear, damage or loss (unless through negligence), the replacement must also be provided free.

Face-Fit Testing for Respiratory Protective Equipment

Tight-fitting respiratory protective equipment (RPE) — including disposable FFP masks, half-face respirators and full-face respirators — must be face-fit tested to ensure an adequate seal against the wearer’s face. There are two recognised methods:

• Qualitative fit testing — A pass/fail test using a taste agent (suitable for disposable masks and half-face respirators only)
• Quantitative fit testing — Uses a measuring instrument to determine the fit factor (suitable for all types of tight-fitting RPE)

Fit testing must be repeated when a worker’s facial characteristics change (e.g. significant weight change, dental work, facial scarring) or when a different make or model of RPE is issued.

Health Surveillance

For some types of PPE use, health surveillance may be required. For example:

• Workers who regularly use respiratory protective equipment should have lung function testing
• Workers exposed to noise despite hearing protection may require audiometry
• Workers exposed to skin hazards should have skin checks

Health surveillance requirements are typically set out in the relevant hazard-specific regulations (e.g. COSHH, Noise Regulations). For more on chemical safety requirements, see our guide to COSHH regulations.

Employee Duties

Employees also have legal duties under the PPE regulations:

• Use PPE in accordance with training and instruction
• Return PPE to its proper storage after use
• Report any loss, defect or damage to PPE immediately
• Not misuse or interfere with PPE
• Take reasonable care of PPE provided

Failure to wear required PPE is a disciplinary matter. However, before disciplining a worker, consider whether the PPE is genuinely suitable, comfortable, compatible with their tasks, and whether they have received adequate training. Non-compliance often stems from practical issues rather than wilful refusal.

PPE Record-Keeping

Maintain records of:

PPE Assessments

• The hazards assessed
• The PPE selected and the reasons for selection
• The date of assessment and the assessor
• When the assessment was last reviewed

Provision Records

• What PPE has been issued to each worker
• The date of issue
• Size and specification
• Any fitting or adjustment carried out

Face-Fit Testing

• The type of RPE tested
• The make and model
• The test method used (qualitative or quantitative)
• The result (pass or fail)
• The date and the tester
• The next test due date

Training Records

• What PPE training each worker has received
• The date of training
• The content covered
• When refresher training is due

Maintenance and Inspection

• Inspection dates and findings
• Maintenance carried out (cleaning, repair, replacement of parts)
• Equipment removed from service (and the reason)

Incident Records

• Any incidents involving PPE failure or non-use
• Investigation findings and corrective actions

Common PPE Mistakes

Using PPE as the first line of defence — The most fundamental and most common mistake. PPE should only be used when higher-level controls are insufficient. If your risk assessment jumps straight from hazard identification to PPE provision without considering elimination, substitution, engineering controls and administrative controls, it is not compliant.

One size fits all — Issuing the same size of gloves, respirators or ear defenders to everyone. PPE that does not fit properly does not protect properly. Individual sizing and fit testing are essential.

Not training workers — Handing out PPE without explaining how to wear it correctly, what it protects against, its limitations, and how to care for it. Untrained workers may wear PPE incorrectly, providing little or no protection while believing they are safe.

Failure to maintain — PPE that is damaged, dirty, worn out or past its expiry date does not provide the intended protection. Regular inspection and replacement are essential. Respirator filters expire. Safety boot soles wear down. Glove materials degrade with chemical exposure.

Ignoring comfort and practicality — PPE that is uncomfortable, restricts vision, impairs hearing, causes overheating, or makes tasks difficult to perform will not be worn consistently. Involve workers in the selection process — they are the ones who have to wear it.

Not replacing when needed — Some employers are reluctant to replace PPE frequently due to cost. This is a false economy. The cost of replacing a pair of safety boots is trivial compared to the cost of a foot injury, a compensation claim, and the associated lost working time.

Failing to update assessments — PPE assessments must be reviewed when risks change, new tasks are introduced, different PPE becomes available, or incidents occur. An assessment from three years ago may no longer reflect current working conditions.

Ignoring limb (b) workers — Since April 2022, the duty to provide PPE extends to limb (b) workers, not just employees. Employers who only provide PPE to direct employees may be in breach of the updated regulations.

Penalties for Non-Compliance

The PPE regulations are enforced by the HSE and local authorities. Non-compliance can result in:

• Improvement notices — requiring specific actions within a set timeframe
• Prohibition notices — stopping work activities until PPE compliance is achieved
• Prosecution — with unlimited fines in the Crown Court
• Civil liability — workers who suffer injury due to inadequate PPE provision may bring personal injury claims
• Corporate manslaughter charges — in the most serious cases where PPE failure contributes to a death

Digitise Your PPE Compliance

Managing PPE across an organisation — tracking what has been issued to whom, when it was last inspected, when face-fit tests are due, whether training is up to date, and maintaining the assessment records — is a significant administrative burden. On paper, it is virtually impossible to do consistently and reliably.

Digital tools allow you to maintain a complete PPE register, automate reminders for inspections, replacements and training renewals, record face-fit test results, and generate compliance reports instantly. When an HSE inspector asks to see your PPE records, everything is available at the touch of a button.

Explore how Assistant Manager can help you manage PPE compliance with our Digital Checklists feature for PPE inspection routines and issue tracking. For delivering and recording PPE training, see our Training & LMS feature.