PPE register and PPE inspection checklist

What a PPE register is

A PPE register is a list. Each line is an item of protective equipment or, for cheap items handed out in bulk, a type of item. Against each line you record when it came into use, who has it or where it is kept, when it was last checked and when it should be replaced.

It does two jobs. It tells you what needs checking or replacing this month. And when an inspector, an insurer or a customer's auditor asks how you look after PPE, it is your evidence.

Is a PPE register a legal requirement?

No, not by name. Regulation 7 of the Personal Protective Equipment at Work Regulations 1992 requires every employer to see that PPE provided to workers is "maintained (including replaced or cleaned as appropriate) in an efficient state, in efficient working order and in good repair". It does not mention a register.

HSE's guidance on the regulations (L25) fills the gap. It says the responsibility for maintenance, the procedures to follow and how often they are done should be put down in writing, and that records of tests and examinations should be kept where appropriate. It gives the two ends of the scale: mechanical fall arrestors need a planned programme of examination, testing and record keeping, while abrasion-resistant gloves only need periodic inspection by the user.

For two kinds of equipment a record is required by law:

• Harnesses, lanyards and other personal fall protection. Regulation 12 of the Work at Height Regulations 2005 requires inspections of this equipment to be recorded, and the record kept until the next inspection is recorded.
• Respirators that are not disposable, where they are used to control exposure to hazardous substances. Regulation 9 of the COSHH Regulations 2002 requires a record of each thorough examination and test, kept available for at least 5 years.

The wider duties on choosing, providing and paying for PPE are in our guide to the PPE regulations.

What to record

You do not need a line for every pair of disposable gloves or every box of earplugs. For consumables, record the type, where it is kept and how many you hold. Keep item-by-item lines for PPE that is personal to one wearer, expensive or inspected individually. Our guide to health and safety documents covers how long to keep records like these.

How often PPE should be inspected

For most PPE the law sets no interval. Regulation 7 says "maintained", and how often you check is for you to decide from the manufacturer's instructions, how hard the item is used and where. In practice there are two levels of check.

• Before use, by the wearer. A quick look for damage each time the item is put on. The regulations require you to train wearers in what they must do to keep their PPE in good order, and HSE's guidance says that training should include practice in inspecting it before use.
• A periodic check by a named person. Someone who knows what to look for goes through the PPE in use and in the stores at an interval you set, and writes down what they find. Monthly suits most small firms for general PPE, and it can be done as part of a regular workplace inspection. The monthly figure is our suggestion and is not taken from the law.

Fall arrest equipment is the one type with its own inspection regime, set out in HSE's leaflet on inspecting fall arrest equipment made from webbing or rope. The leaflet is written about energy-absorbing lanyards and says the same principles can be applied to harnesses. Its examples of arduous conditions include demolition, steel erection and scaffolding. The leaflet says the person inspecting must be independent enough to make an objective decision and must have real authority to discard a defective lanyard. Where harnesses and ropes are used to lift or lower people, as in rope access, the lifting equipment regulations (LOLER) also require a thorough examination by a competent person at least every 6 months or in line with an examination scheme.

PPE inspection checklist

Use the sections that match what you issue. Each line is written so that "yes" means the item is fit to use. The points for head, eye, hand and foot protection and hi-vis follow HSE's guidance on the PPE regulations, those for hearing protection follow HSE's noise guidance, and those for fall arrest follow HSE's leaflet. Add anything the manufacturer's instructions ask for.

Head protection

• The shell has no cracks, dents or deep scratches (shallow scratches and grazes are acceptable)
• The internal harness is not damaged or deformed and still adjusts to fit
• The helmet has not taken a significant impact since it was last checked
• The helmet is within the life stated by the manufacturer, counted from the date of manufacture marked on it
• The helmet has not been drilled, painted, marked or covered with stickers
• The inside and the sweatband are clean
• The chinstrap, where one is fitted, is present and fastens

Eye and face protection

• Lenses are clear, with no deep scratches or wear that reduce vision
• The frame, headband or harness is not bent or deformed
• The item fits the wearer and does not slip off
• The lenses, frame and headband are clean
• The item is kept in a protective case when not in use

Hearing protection

• The protectors are in good, clean condition
• Earmuff seals are undamaged
• Headband tension has not weakened
• Nothing has been modified by the wearer
• Compressible earplugs are soft, pliable and clean

Respiratory protective equipment

• The facepiece, straps and valves are clean and undamaged
• Filters are the right type for the hazard and within the manufacturer's replacement period and shelf life
• Each wearer of a tight-fitting mask has passed a fit test for that make, model, type and size
• Reusable respirators are stored as the manufacturer instructs, away from dirt, solvents and sunlight
• The record of thorough examination for each reusable respirator is up to date
• Disposable masks in the stores are in their packaging and within any date marked on them

Gloves and hand protection

• Gloves are free of holes, cuts and debris
• Gloves have kept their shape and are not worn or deteriorated
• The glove type matches the hazard, and chemical gloves are used within the manufacturer's breakthrough time
• Each wearer has the right size, with no gap between glove and sleeve where chemicals are handled
• The inside of reusable gloves is clean and dry

Safety footwear

• Uppers and seams are sound, with no splits and no toecap showing through
• Soles are firmly attached and the tread is not worn smooth
• Nothing is lodged in the tread
• Laces or fastenings are intact
• The footwear is the type the job needs, for example with a penetration-resistant midsole where there are nails underfoot

High-visibility clothing

• The garment is clean enough for the fluorescent colour and the reflective bands to show clearly
• Reflective bands are complete, not cracked, peeling or worn through
• Seams are sound and there are no tears
• Fastenings work, so the garment can be worn closed
• The class of garment matches the work, as set out in your risk assessment

Fall arrest harnesses and lanyards

• The item carries a unique identification mark that can still be read
• A detailed inspection by a competent person has been recorded within the interval you have set (HSE recommends at least every 6 months)
• Webbing has no cuts, including small cuts at the edges, and no abrasion
• Stitching is complete, with no cut or worn threads
• There are no knots other than any the manufacturer intended
• Webbing shows no glazing, hard patches, flaking or change of colour from heat, chemicals or sunlight
• Webbing is free of paint, dirt and grit
• The energy absorber has not started to deploy and its cover is in place
• Karabiners, hooks and connectors are not bent or damaged, and their gates close and lock
• The item has never been used to arrest a fall

Storage and stock

• PPE is stored clean and dry, away from sunlight, heat and chemicals
• Replacement stock of each item in use is on the shelf
• Shared PPE is cleaned and disinfected before the next person uses it
• The manufacturer's instructions for each type of PPE are kept where they can be found
• PPE for visitors is available in a range of sizes

How long PPE lasts

There are no legal lives for PPE. The regulations say "replaced as appropriate", and HSE's guidance says PPE should be replaced when it exceeds its shelf life or is too badly damaged to repair. The manufacturer sets the shelf life, so the instructions that come with the item are the place to look.

The figure most often quoted is for hard hats. It comes from HSE's guidance on the regulations (L25), which says that as a general guide industrial safety helmets should be replaced three years after manufacture, "but always check with the manufacturer". Two things are worth noticing. It is a general guide, and your helmet's own instructions take priority. And it runs from the date of manufacture, so a helmet that sat in the stores for a year has two years left by that guide.

Some items are finished regardless of age:

• A helmet that has taken a significant impact, or whose shell is deeply scratched, worn or deformed.
• A lanyard that has arrested a fall. HSE's leaflet says it should never be reused.
• Eye protection with lenses so scratched that vision is reduced, or a deformed frame.
• Gloves that are worn or have deteriorated, and chemical gloves past the manufacturer's breakthrough time.

What to do when PPE fails a check

1. Take it out of use straight away. Bin it, cut it up or tag it so that it cannot drift back into the stores.
2. Replace it before the work carries on. HSE's guidance is to keep replacement PPE available, which is the reason for holding stock.
3. Repair only what can properly be repaired. HSE's guidance is that a trained wearer can do simple repairs such as replacing a bootlace, that anything more intricate needs someone with the skill and technical knowledge, and that only the manufacturer's recommended spare parts should be used.
4. Write it in the register. Record what failed, when and what replaced it.
5. Look for a pattern. If the same item keeps failing, it may be the wrong item for the job, and the regulations require the suitability assessment to be reviewed when there is reason to think it is no longer valid.

Workers have a legal duty to report any loss of or obvious defect in their PPE to you straight away. Make that easy. People stop reporting if a replacement is slow to arrive or comes with a telling-off.

Keeping it in SafetyPro360

SafetyPro360 keeps a stock list of PPE items. Each item has the number in stock, a minimum and a reorder level, and shows as low stock when the count is at or below the reorder level, or the minimum if that is higher, and as out of stock at zero. Stock adjustments are recorded with a reason. It does not record which item was issued to which person, so keep that part of your register separately. The inspection checklist on this page can be set up as a checklist in the product and run on a phone, with each completed check kept with its date, who did it and its score.

Questions people ask