PPE Toolbox Talk

The PPE that saves your life is the one nobody argues about

PPE is the last line, not the first. It protects one person, only while it is worn, and only if it actually fits.

The items people argue over are the visible ones: helmets, boots, hi-vis. The item that decides whether you are still well in thirty years is the one nobody checks. HSE attributes around 3,700 deaths a year to past exposure to carcinogens at work in construction, and construction accounts for over 40 per cent of all occupational cancer deaths and registrations. Asbestos causes roughly 70 per cent of those, silica around 17 per cent.

None of it shows up on the day

A dropped brick tells you immediately that the helmet was worth wearing. Silica dust tells you in twenty years. That gap is the whole problem with respiratory protection, and it is why a mask that has never been fit tested is so easy to live with.

What the law requires

PPE is governed by the Personal Protective Equipment at Work Regulations 1992, significantly amended in 2022. The core principle has not changed: PPE is what you use for the risk that is left after everything else has been done, not instead of doing it.

• Last resort. PPE must only be used where the risk cannot be adequately controlled by other means. Fix the hazard first. PPE at Work Regulations 1992, reg. 4.
• Free, suitable and compatible. It must be supplied free of charge, suitable for both the risk and the wearer, and compatible where more than one item is worn. No employer may charge for anything done to comply. Health and Safety at Work etc. Act 1974, s. 9.
• Wider scope since April 2022. Those duties now reach beyond employees to limb (b) workers, which covers most casual and short-term workers on site. PPE at Work (Amendment) Regulations 2022, in force 6 April 2022.
• Maintained and trained on. It must be maintained, stored properly and replaced, and everyone must have information, instruction and training on using it. PPE at Work Regulations 1992, regs. 7 to 10.

One change worth knowing about

Before April 2022 the duty to provide PPE free of charge applied to employees. The 2022 amendment extended it to limb (b) workers, the casual and short-term workers many sites rely on. If you have people on site who are not employees but are not running their own business either, they are almost certainly covered.

Source: HSE, Using PPE to control risks at work; PPE at Work Regulations 1992; PPE at Work (Amendment) Regulations 2022.

Why PPE fails on site

• Not worn for the quick job. One cut, one grind, one lift. Most overexposure happens in the tasks nobody bothered to plan.
• Wrong type for the hazard. A nuisance dust mask against silica, or safety glasses where a full face shield is needed.
• Facial hair on a tight-fitting mask. Even a day of stubble breaks the seal and the mask stops working. There is no way round this.
• Never fit tested. Two people, same mask, same size: one sealed, one not. Without a test you do not know which one you are.
• Damaged or past it. Scratched lenses, a cracked or heavily knocked helmet, perished gloves, boots with no tread.
• Wrong size. Gloves too big to feel with, a harness left loose, boots that stop you feeling the ground.
• Incompatible combinations. Ear defenders lifting the helmet off, glasses breaking the mask seal, hoods fouling hearing protection.
• Stored badly. Reusable masks in a dusty van footwell, harnesses in the sun, everything in the bottom of the bag.
• Filters never changed. A filter has a life. Once it is past it you are breathing through a false sense of security.
• Hearing protection taken out to talk, usually at the loudest moment of the day.
• Hi-vis that is no longer high visibility. Grey with dust, and invisible to a reversing dumper.

Controls to brief your crew on

• Deal with the hazard before reaching for PPE. On-tool extraction, water suppression, a quieter or lower-vibration tool, or cutting materials off site.
• Match the PPE to the actual hazard. Check the standard and the protection factor, not the picture on the box.
• Face fit test every tight-fitting mask, for the exact make, model and size that person will wear, and be clean-shaven at the seal every shift.
• Check it before you put it on. Straps, seals, lenses, shell, tread, stitching. Thirty seconds.
• Check the combination, not just the items. Helmet, glasses, mask and ear defenders have to work as a set on the same head.
• Get the right size. PPE that does not fit the person is not suitable PPE, and that is the employer’s problem to solve.
• Store it clean, dry and out of the sun. Reusable RPE gets cleaned after use, not when it looks bad.
• Change filters on schedule and record it. Do not wait until breathing gets hard.
• In a hearing protection zone, it stays on. Removing it for two minutes in a 100 dB area undoes most of the protection for that shift.
• Damaged kit gets replaced, free, same day.
• Say so if it does not fit or does not work. That is a report we want, not a complaint.

Source: HSE, PPE at work; HSE, Fit testing of RPE facepieces (INDG479); Control of Noise at Work Regulations 2005.

Who is competent to do this work

• Everyone issued with PPE must be trained in what it protects against, its limits, how to check it and how to store it. Handing someone a mask is not training.
• Fit testing must be done by a competent tester, ideally Fit2Fit accredited or equivalent, and repeated if the wearer’s face changes through weight loss, dental work or injury.
• Whoever selects the PPE needs to understand both the hazard and the standards, including protection factors for RPE and the right glove for the substance.
• Supervisors enforce it consistently. PPE rules applied to some people and not others stop being rules very quickly.

Paperwork that should be in place

• Risk assessments showing what has been done to control the hazard, with PPE identified as the residual control rather than the only one.
• PPE issue records, showing who has what, in what size, and when it was replaced.
• Face fit test records naming the person and the exact make, model and size of facepiece tested.
• COSHH assessments wherever RPE is being relied on, including the filter change schedule.
• Inspection records for harnesses and other lifesaving equipment, at the intervals the manufacturer requires.
• Training records covering use, limitations, checks and storage.

Five questions to get the crew talking

1. What PPE are you wearing today that you have never been fit tested for?
2. Which job on this site makes the most dust, and what is stopping it before it reaches the mask?
3. Has anyone got kit that is damaged or worn out and not replaced it yet? Why not?
4. Does your helmet, glasses and ear defender combination actually work together, or do you take something off?
5. When did you last change the filters on your mask?

How to run this toolbox talk

1. Read it first and add your site-specific detail.
2. Pick the moment. Start of shift, at the workface, ten minutes maximum.
3. Get the kit out. This talk works far better with a mask, a filter and a scratched pair of glasses in your hand.
4. Write down what came up. Notes and actions are on page 3 of the PDF.
5. Record who attended on the free toolbox talk sign-in sheet.
6. Close the actions out. Especially anything about kit that does not fit.

Frequently asked questions

Does an employer have to provide PPE free of charge?

Yes. Section 9 of the Health and Safety at Work etc. Act 1974 prevents an employer charging an employee for anything done to comply with a health and safety duty. That includes PPE, and it includes replacements for fair wear and tear.

Who is covered by the PPE regulations since the 2022 change?

From 6 April 2022 the duties extend from employees to limb (b) workers, broadly people who work personally for you under a contract but are not running their own business. Genuinely self-employed people are outside the 1992 Regulations, though duties under the Health and Safety at Work Act and CDM 2015 still apply, and site rules will normally require PPE regardless.

Do you need to be clean-shaven to wear a mask?

For any tight-fitting facepiece, yes, at the point where the seal meets the face. Stubble is enough to break the seal. Where someone cannot or will not shave, the answer is a loose-fitting powered hood rather than a mask that does not work.

How often should face fit testing be repeated?

There is no fixed statutory interval. HSE recommends repeating it if the wearer’s face changes, through significant weight change, dental work or facial injury, and many employers retest on a routine cycle. A new make, model or size of facepiece always needs a new test.

Is PPE the employer’s responsibility or the worker’s?

Both, in different ways. The employer assesses the risk, provides suitable PPE free, maintains and replaces it, and trains people. The worker uses it as instructed, checks it, and reports defects. Neither duty removes the other.