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Compliance & Certification

PPE Rules for Trades — Who Pays and What You Must Provide (2026)

8 min read·12 Jun 2026

Personal protective equipment is the most visible part of site safety — hard hats, hi-vis, safety boots — but it's also the most misunderstood when it comes to who is responsible for it and who pays. If you employ anyone, run a labour-only gang, or work for yourself, you have legal duties around PPE that have changed in recent years. This guide sets out the law as it stands in 2026: what you must provide, who pays, what the 2022 amendment changed, and why PPE should always be your last line of defence rather than your first.

What Counts as PPE

PPE is any equipment worn or held by a person to protect them against one or more risks to their health or safety. On a typical trade site that means hard hats, safety boots, hi-vis clothing, gloves, eye protection, hearing protection, respiratory protective equipment (RPE) such as dust masks, and knee pads. It also covers things like harnesses for working at height and protective coveralls for handling hazardous substances.

The governing law in Great Britain is the Personal Protective Equipment at Work Regulations 1992, as amended by the Personal Protective Equipment at Work (Amendment) Regulations 2022. These sit alongside the broader duties in the Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999. The Health and Safety Executive (HSE) enforces all of them.

PPE Is the Last Resort — The Hierarchy of Control

This is the single most important principle, and the one most often skipped. The law requires PPE to be used only as a last resort — after every other reasonable way of controlling the risk has been considered. The hierarchy of control runs in this order:

  • Eliminate the hazard entirely — can the dangerous task be designed out or avoided?
  • Substitute it with something less dangerous — a less hazardous material or method.
  • Engineering controls — on-tool extraction, water suppression, guarding, local exhaust ventilation.
  • Administrative controls — safe systems of work, job rotation, training, signage, restricting access.
  • PPE — only what remains after all of the above.

A classic example is cutting concrete or stone. The first answer is not "wear a mask" — it is to use on-tool water suppression or extraction to stop the dust getting into the air at all. PPE then protects against whatever residual dust remains. Relying on a dust mask alone, with no extraction, is the kind of shortcut HSE inspectors pull operators up on, because PPE only protects the wearer and only when used correctly, every time.

Who Pays for PPE — The Employer, Always

Where PPE is needed, the employer must provide it free of charge. This is not negotiable and there is no exception for it. A worker must never be charged for PPE, and you cannot lawfully make deductions from wages to cover it, ask for a deposit, or charge for replacements caused by fair wear and tear.

This includes replacement items where PPE is lost or worn out through normal use. The only narrow situation where recovering a cost may be lawful is genuine, deliberate damage or repeated loss caused by the worker — and even then you should take advice before making any deduction, as the rules on wage deductions are strict. The safe default is simple: PPE is a business cost, you provide it, you pay for it.

The 2022 Amendment — Who Is Now Covered

Until 2022 the PPE at Work Regulations applied only to employees. The Personal Protective Equipment at Work (Amendment) Regulations 2022 came into force on 6 April 2022 and widened this significantly. The duties now also extend to a wider group commonly described as "limb (b) workers" — workers who carry out casual or short-term work and provide their services personally, but who are not employees under a contract of employment.

In plain terms, if you engage labour on a more casual or flexible basis than a standard employment contract, you can no longer assume the PPE duties don't apply. Where those people need PPE for the work you give them, you must provide and pay for it on the same basis as for an employee. The change was made precisely because so many people on site are not classic "employees" yet face the same hazards.

Genuinely self-employed people — those running their own business and responsible for their own health and safety — fall outside this extended duty and must sort out their own PPE (covered below). The line between a limb (b) worker and a genuinely self-employed contractor can be fine, so if you're unsure how someone is engaged, treat the safer assumption and provide the PPE.

Choosing the Right PPE

Providing PPE is not enough on its own — it has to be the right PPE, correctly selected and properly fitted. Before you buy, assess the actual hazard: what is the worker exposed to, at what level, and for how long? A nuisance dust mask is useless against fine silica; light gloves are useless against a chemical that needs a specific glove material.

  • Match the protection to the hazard — the correct standard and rating for the specific risk.
  • Fit matters — PPE that doesn't fit doesn't protect and won't be worn. Offer a range of sizes.
  • Compatibility — items worn together (glasses, ear defenders, dust mask, hard hat) must work together without one compromising another.
  • CE/UKCA marking — only supply PPE that is properly conformity-marked for the British market.

RPE and Face-Fit Testing

Respiratory protective equipment — dust masks and respirators — has its own extra requirement. Any tight-fitting mask (the type that seals against the skin, such as a disposable FFP3 or a half-mask respirator) only works if it makes a good seal on the individual's face. Because every face is a different shape, the law requires a face-fit test for each wearer on the specific make and model of mask they will use.

Two further points trip people up. First, the wearer must be clean-shaven around the seal area where a tight-fitting mask is used — even a day or two of stubble breaks the seal and lets contaminated air leak past the filter, making the mask close to worthless. If a worker won't or can't be clean-shaven, you need a loose-fitting alternative such as a powered hood. Second, fit testing should be repeated if the mask changes, if the wearer's face changes significantly, or periodically as part of good practice. Keep records of every fit test.

Training, Use and Information

PPE only protects when it's worn correctly. You must give workers the information, instruction and training they need to use it properly — how to put it on and take it off, how to check it, what it does and does not protect against, and when it must be worn. A dust mask worn under the chin, or eye protection pushed up onto a hard hat, offers no protection at all, and that's usually a training and supervision failure rather than a kit failure. Supervise to make sure PPE is actually being used.

Storage, Maintenance and Replacement

PPE must be kept in good, clean and efficient working order. That means somewhere to store it properly so it's not damaged, contaminated or left in the back of a dusty van between jobs. Reusable items such as respirators, ear defenders and eye protection need cleaning, inspecting and, where relevant, replacement filters and parts.

Disposable items — single-use dust masks, certain gloves — must be replaced, not stretched out across weeks. Damaged or worn PPE must be taken out of use and swapped for a working item immediately, at no cost to the worker. Build a simple replenishment routine into your business so that worn-out PPE is replaced before it becomes a hazard, and keep a basic stock on each vehicle.

If You're Self-Employed

If you are genuinely self-employed and in control of your own work, the duty to provide PPE falls on you. You are responsible for assessing the risks of your own work, choosing the right protection, paying for it, and keeping it maintained — exactly the same standards an employer would have to meet for staff. There is no one above you to supply it.

On larger or principal-contractor sites you may also find that the site's own rules require specified PPE before you set foot on it, and a principal contractor has duties to coordinate safety across everyone working there. But the cost and maintenance of your personal kit is your own. Treat it as a normal cost of trading, factor it into your rates, and don't cut corners on the items that protect your lungs, eyes and hearing — those are the injuries that end trade careers.

Quick Reference: Common Trade PPE

HazardPPE neededNote
Falling objects / head strikesHard hatReplace after any impact; check the date.
Foot injury / puncturesSafety bootsToe cap and midsole protection.
Being struck by vehicles / low visibilityHi-vis clothingKeep clean so it stays visible.
Cuts, abrasions, chemicalsGlovesMatch glove type to the specific risk.
Flying debris / sparksEye protectionGoggles for dust; visor for grinding.
Noise above action levelsHearing protectionEngineering controls first; correct rating.
Dust / fumes / silicaRPE (dust mask / respirator)Face-fit test; clean-shaven; extraction first.
Kneeling on hard surfacesKnee padsProtects against long-term joint damage.

The Bottom Line

PPE is your last line of defence, not your first. Control the hazard at source wherever you can, then use the right PPE to deal with what's left. If you employ or engage workers — including the wider group of limb (b) workers brought in by the 2022 amendment — you must provide that PPE free of charge, make sure it fits, fit-test tight-fitting masks, train people to use it, and keep it maintained and replaced. If you're self-employed, all of that falls to you. Get it right and it costs little; get it wrong and it can cost someone their health and you a prosecution.

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