PPE Questions — CSCS Practice

Personal Protective Equipment in Construction

Personal Protective Equipment (PPE) is the last line of defence against workplace hazards. While the hierarchy of control prioritises eliminating or reducing risks at source, PPE remains essential on construction sites where residual risks cannot be fully controlled by other means. Every construction worker must understand what PPE is required, when to wear it, how to use it correctly, and what to do when it becomes damaged or defective.

The Personal Protective Equipment at Work Regulations 2022 replaced the previous 1992 Regulations and extended PPE duties to cover limb (b) workers — including agency workers, casual workers, and some self-employed individuals — for the first time. Under these Regulations, employers must provide PPE free of charge where risks cannot be adequately controlled by other means, ensure it is suitable for the hazards present, and provide training on its correct use.

The Hierarchy of Control and PPE

PPE should never be the first choice for managing workplace risks. The hierarchy of control, as set out in the Management of Health and Safety at Work Regulations 1999, requires employers to consider control measures in the following order:

1. Elimination — remove the hazard entirely
2. Substitution — replace with something less hazardous
3. Engineering controls — isolate people from the hazard (guards, barriers, LEV)
4. Administrative controls — change the way people work (training, signage, safe systems)
5. PPE — protect the individual worker as a last resort

PPE is ranked last because it only protects the individual wearer, it relies on correct use, and it can be uncomfortable which may lead to non-compliance. However, on a busy construction site, PPE is often essential alongside other control measures.

Minimum PPE Requirements on Construction Sites

While the specific PPE required depends on the risk assessment for each task, most UK construction sites require the following as a minimum standard for all persons entering the site:

• Safety helmet (hard hat) — complying with EN 397 or EN 14052, protecting against falling objects and head impacts
• High-visibility clothing — typically a hi-vis vest or jacket, Class 2 minimum for general site work, Class 3 for areas with moving vehicles
• Safety footwear — steel or composite toe cap boots, typically S3 rated (toe protection, penetration resistance, water resistance, energy absorption at heel)

Additional PPE is required based on the specific task being performed. This may include safety glasses or goggles, hearing protection, respiratory protective equipment (RPE), gloves, and fall protection equipment such as harnesses.

Hard Hat Standards and Replacement

Safety helmets must comply with EN 397 (industrial safety helmets) and carry the CE or UKCA mark. Workers must inspect their hard hat before every use and replace it if it shows signs of damage such as cracks, dents, or fading. Most manufacturers recommend replacing hard hats every 3 to 5 years from the date of manufacture, regardless of visible condition, because UV exposure and weathering degrade the plastic over time.

Hard hats should never be painted, drilled, or modified in any way, as this can compromise their structural integrity. Stickers are generally acceptable provided they do not cover damage. The internal harness must be checked for wear, and the hat must fit correctly — neither too tight nor too loose.

Respiratory Protective Equipment (RPE)

Construction generates significant airborne hazards including silica dust from cutting concrete and stone, wood dust from carpentry, asbestos fibres during refurbishment of older buildings, welding fumes, and solvent vapours from paints and adhesives. RPE is classified into two main types:

• Tight-fitting RPE (disposable masks, half-face masks, full-face masks) — relies on a seal against the face and requires face-fit testing to ensure proper protection
• Loose-fitting RPE (powered air-purifying respirators, air-fed hoods) — does not rely on a face seal and is suitable for workers who cannot achieve a good face seal due to facial hair or facial shape

The most common disposable masks are rated FFP1 (filters 80% of particles), FFP2 (filters 94%), and FFP3 (filters 99%). For hazardous dusts such as silica and asbestos, FFP3 is the minimum standard. Workers with facial hair that passes through the seal line of a tight-fitting mask must not use that type of RPE — they must either shave or use a loose-fitting alternative.

Hearing Protection

The Control of Noise at Work Regulations 2005 set two key action levels for noise exposure:

• Lower exposure action value: 80 dB(A) — employers must make hearing protection available and provide information on noise risks
• Upper exposure action value: 85 dB(A) — employers must enforce the wearing of hearing protection and create mandatory hearing protection zones

Common construction activities that exceed 85 dB(A) include disc cutting, using breakers and pneumatic drills, operating circular saws, and working near piling operations. Two main types of hearing protection are used: ear plugs (inserted into the ear canal, disposable or reusable) and ear defenders (cups that cover the entire ear). Both types must be appropriately rated for the noise levels present.

CE and UKCA Marking

All PPE sold in the United Kingdom must carry the UKCA (UK Conformity Assessed) mark or the CE mark. These marks confirm that the PPE has been tested to the relevant European or UK standard and provides the level of protection claimed by the manufacturer. PPE without these marks must not be used on construction sites, as there is no assurance that it meets the required performance standards.