UK personal protective equipment is governed by the Personal Protective Equipment at Work Regulations 1992 (as amended in 2022). Employers must provide suitable PPE free of charge to workers exposed to risks that cannot be controlled by other means. PPE is the last line of defence under the hierarchy of control — it should never be the first. Since the 2022 amendment, duties extend to "limb (b) workers" (casual workers, gig workers, those without traditional employment status). Employers must assess suitability, ensure correct fit, train workers in use, and replace PPE that becomes defective. PPE must always be provided free — charging workers is unlawful.
PPE is the safety equipment most people think of first — hard hats, hi-vis vests, safety boots, gloves, eye protection. The legal framework around it is more nuanced than it looks. Employers regularly fall into common traps: charging workers for PPE, treating PPE as the primary control rather than the last resort, or missing the 2022 update that extended duties to casual workers.
This guide covers what the regulations require, who they apply to, the hierarchy of control they sit within, and the common mistakes that catch employers out.
The headline UK regulation is the Personal Protective Equipment at Work Regulations 1992, significantly amended in 2022 to extend duties to "limb (b) workers" — casual workers and others outside traditional employment.
The regulations sit alongside several other instruments that affect PPE in specific contexts:
The 1992/2022 PPE at Work Regulations are the core workplace-duty regulations. The other instruments add specific requirements for specific hazards.
UK health and safety law expects employers to control risks using a hierarchy. PPE sits at the bottom — used only after higher-order controls have been considered:
| Order | Control measure | Example |
|---|---|---|
| 1 | Eliminate the hazard | Stop using the hazardous substance |
| 2 | Substitute with something safer | Use a less toxic chemical |
| 3 | Engineering controls — physical changes | Local exhaust ventilation, machine guards |
| 4 | Administrative controls — change how work is done | Work rotation, restricted access, training |
| 5 | PPE — last line of defence | Respirators, gloves, eye protection, hearing protection |
This isn't a preference — it's a legal expectation. Reaching for PPE first is a common mistake. The HSE expects employers to demonstrate that higher-order controls have been considered and either implemented or rejected with reasons before PPE is relied on.
The duty falls on the employer. Since the 2022 amendment, this includes:
The duty doesn't extend to genuinely self-employed contractors providing services to a business. But where someone is working under your direction without traditional employment status, you likely have PPE duties to them.
The duty also doesn't pass to workers themselves under any circumstances. PPE must be provided free — charging workers, deducting from wages, or making workers buy their own is unlawful.
Six core employer duties under the regulations:
Before providing PPE, the employer must assess whether it's suitable for the risk, the work and the worker. Assessment should consider:
PPE must be provided free. No charges. No deposits. No deductions from wages. No "buy your own and we'll reimburse" without genuine reimbursement guarantee. This applies to initial provision and replacement.
Particularly important for respiratory protection (which requires fit testing), but applies to all PPE. PPE that doesn't fit properly doesn't protect properly. Fit assessment and where necessary fit testing must be documented.
Workers must understand:
The employer must maintain PPE in efficient working order and replace it when damaged, defective or expired. Workers should be encouraged to report defects without fear, and replacement should be prompt.
PPE must be stored properly when not in use. Storage facilities should keep equipment clean, dry and secure. For respiratory PPE this matters significantly — contaminated or damp respirators can be more harmful than no PPE.
Workers also have duties under the regulations:
Wilfully refusing to use PPE can be a disciplinary matter — but only when the employer has properly fulfilled their own duties. An employer cannot expect workers to use PPE that doesn't fit, hasn't been trained on, or hasn't been properly maintained.
| PPE type | Protects against | Key considerations |
|---|---|---|
| Head protection (hard hats) | Falling objects, head impact | Replace after impact; check shell and harness regularly |
| Eye and face protection | Dust, splashes, sparks, radiation | Different lenses for different hazards; prescription compatibility |
| Hearing protection (ear plugs/muffs) | Noise above 80 dB action level | Calculate attenuation against actual noise levels; over-protection causes its own problems |
| Respiratory protection (RPE) | Dusts, fumes, vapours, oxygen-deficient atmospheres | Requires fit testing for tight-fitting masks; must match the specific hazard |
| Hand and arm protection (gloves) | Cuts, chemicals, vibration, heat, cold | Specific glove for specific hazard; chemical gloves have breakthrough times |
| Foot protection (safety footwear) | Crushing, penetration, slips, chemicals | Different ratings for different hazards; replace when soles or toecaps damaged |
| High-visibility clothing | Being seen by vehicle operators or others | Different classes for different traffic exposures |
| Body protection (overalls, aprons, chemical suits) | Splashes, contamination, heat, biological agents | Specific to hazard; sometimes single-use only |
| Fall protection (harnesses, lanyards) | Falls from height | Covered by Work at Height Regulations; requires inspection regime |
It's the last control measure. Reaching for PPE first — without considering elimination, substitution, engineering controls or administrative controls — fails the hierarchy of control test. HSE inspectors look for this specifically.
The employer must provide PPE free. Workers can use their own preferred items if those items meet the suitability assessment, but the employer's duty to provide doesn't disappear because the worker has their own.
Unlawful. PPE must be provided free. Deposits, deductions or "PPE bonds" are charges. The free-of-charge duty is absolute.
Handing PPE over isn't training. Workers must understand why the PPE is needed, how to use it, how to check it, how to clean and store it, and what to do if it fails. That requires structured training, documented and refreshed periodically.
Tight-fitting respiratory PPE requires fit testing on initial issue and at any point where face shape changes (significant weight gain or loss, dental work, scarring, beard growth). For most workers, fit testing every two years is reasonable; for higher-risk activities, more frequently.
Since the 2022 amendment, casual workers and limb (b) workers have explicit PPE rights too. The duty to provide doesn't depend on employment status — it depends on whether the worker is working under your direction.
Beyond the post-emergency phase, the principles remain: where work involves exposure to biological agents (healthcare, laboratories, certain cleaning operations), PPE selection must reflect the specific biological hazard, the route of transmission, and any guidance from the HSE or Public Health bodies. Standard surgical masks are not RPE and don't satisfy respiratory protection duties on their own.
For organisations with significant PPE responsibilities, structured training matters. Two relevant courses:
No. PPE must be provided free of charge. Charging, deducting from wages, or requiring deposits is unlawful under the Personal Protective Equipment at Work Regulations 1992.
The regulations apply to employees and (since 2022) limb (b) workers — those working under the employer's direction without traditional employment status. They do not extend to genuinely self-employed contractors providing services to a business — although those contractors typically have their own PPE duties under the same legislation as employers.
The 2022 amendment extended duties to "limb (b) workers" — casual workers, those on zero-hours contracts, gig workers, and others outside traditional employment but working under the employer's direction. Before the amendment, only employees were explicitly covered.
It depends on the type and use. Hard hats should be replaced after any impact and typically every 5 years. Respirators with disposable filters need filter changes per manufacturer guidance. Gloves should be replaced when damaged or contaminated. Safety footwear should be replaced when soles or toecaps are damaged or worn. Manufacturer guidance is the starting point; risk assessment dictates frequency in practice.
Yes — workers have a legal duty to use PPE in accordance with training and instructions. Refusing to use suitable PPE provided properly can be a disciplinary matter. But the worker's duty only triggers when the employer has fulfilled their own duties (suitable, free, fitted, trained, maintained).
No, not as a primary strategy. PPE is the last line of defence in the hierarchy of control. Substituting PPE for engineering controls without good reason fails the legal expectation that risks are controlled at source where reasonably practicable.
Defects in the equipment itself (rather than its use) are typically reported to the manufacturer, supplier, and the Office for Product Safety and Standards. Workplace incidents involving PPE failure may also be RIDDOR-reportable depending on the consequences. See our RIDDOR reporting guide.
If your organisation has significant PPE duties — particularly in construction, manufacturing, healthcare or laboratory work — the foundational training is the IOSH Managing Safely course for line managers, or the NEBOSH National General Certificate for safety officers and advisors.
KeyOstas is a NEBOSH Gold Learning Partner with 41 years of experience delivering health and safety training across the UK. Call us on +44 (0) 3300 569534 for advice on PPE-related training tailored to your sector and risk profile.
