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Health and Safety

PPE – Why is it the last resort, but first priority in industry?

Luke Pitt - Last Update: 22 Apr 2021

Contents

What are the regulations for PPE?

Hierarchy of Controls Management

How to assess risk in your workplace

Most of the courses I run start with the question “So, what does health and safety mean to you?”, and sadly some of the responses are just one phrase…PPE.

To some, it seems this one thing is going to solve the issues of unsafe working environments and practices and make the problem go away. So why do we make this last resort the very first thing we think about, and why don’t we make more of the hierarchy of control?

In this article, I want to debunk the sole use of PPE as the only solution to a hazard, and provide some food for thought as to why it is important to think things through before just issuing PPE, and ask ourselves “is this all we have?”.

Firstly, what are the regulations for PPE?

There are two elements of the PPE regulations which are described on the HSE’s website as follows:

“The current legislation which refers to the supply of personal protective equipment is the The Personal Protective Equipment Regulations 2016/425, which is enforced by the Personal Protective Equipment (Enforcement) Regulations 2018 . HSE are the enforcing authority for the supply of PPE that is designed for use at work.”
“The current legislation which relates to the use of personal protective equipment is the Personal Protective Equipment at Work Regulations 1992 . The latest details are available on  legislation.gov.uk . Other special regulations cover hazardous substances (including lead and asbestos), and also noise and radiation.

The 1992 regulations state that as an employer, we must provide PPE to our employees only where there is a health and safety risk that cannot be suitably controlled by other means, in other words, the last resort.

The regulations also state that the provision of the PPE should be:

  • Suitably assessed to make sure that it is fit for the purpose that it is intended for
  • Maintained and stored properly
  • The user is trained and provided with instructions on how to use the PPE/RPE safely
  • Used correctly by the employee

More information can be found at https://www.hse.gov.uk/pubns/indg174.pdf , which provides a user-friendly guide to assist with the initial assessment or indeed to validate the current PPE you use as fit for purpose.

So why with all this information available (FOR FREE), do we still use PPE as ONE of FIVE forms of hazard controls available to us?

Personally, I think it comes down to the fact that PPE is the easier, more obvious solution and saves us time wading through all options available to us. Why would we consider four other options if PPE “kind of” solves the problem of hazard control? 

If we go back to the concept of Health and Safety being a business argument as much as it is moral and legal, going through the four other options available IS the right way. Furthermore, if we do not spend the time to assess properly before making decisions (by undertaking a risk assessment), we may miss opportunities to streamline processes and make ourselves more competitive, safer, and productive.

Hierarchy of Controls Management

By using the hierarchy of controls when we assess risk, we can prioritise what controls we should consider and in what order. In doing this, we are naturally interrogating the process and finding the right solution to control the appropriate risks. Or we may find that in fact, we are using the appropriate measures

hierarchy of controls management graphic

 

I have no problem with the use of PPE, but it is important to bear in mind that by providing PPE you are not solving the issue of risk - it is just ONE way of safeguarding an individual.

PPE also has to be paid for, with potential additional training costs - and there is usually a need for health surveillance. PPE can also be quite uncomfortable, so is not it better to assess whether you actually need it first?

How to assess risk in your workplace

Start by looking at what you do and how you do it. Refer to your current risk assessments and see what you have in place already. Then, speak to everyone involved about the reality of the process - if it works and if the PPE provided is effective? From there you are in a better position to answer the following questions:

  • Are we doing enough to protect employees?
  • Do we need to do more?

Once these questions are answered, you can establish what options you have left - and then use the hierarchy of control to provide some priority.

Remember, it is your business, it is your decision.