Compliance · PPE at Work Regulations
The 2022 amendment to the PPE at Work Regulations made one change with wide ripples: the duty to provide protective equipment no longer stops at employees. If your workforce includes casual or gig-style workers, the rules very likely now include them.
The change
The original 1992 regulations placed PPE duties on employers toward their employees. The 2022 amendment extended those same duties to "limb (b)" workers — people with casual, irregular or gig-style arrangements who work under a contract personally and aren't running their own business. Zero-hours bar staff, casual warehouse labour, some couriers: if the risk assessment says the job needs PPE, they're now owed it on the same terms as employees.
The duties themselves didn't change, they just cover more people: assess the risk, provide suitable PPE free of charge where the risk requires it, maintain and replace it, store it properly, train workers in its use — and workers must use it as trained.
Checklist
| Duty | In practice |
|---|---|
| Risk-assess first | PPE is the last resort after other controls — the assessment names what's needed |
| Provide free of charge | No charges, no deposits, no wage deductions for required PPE |
| Suitable means suitable | Correct spec for the hazard AND a fit for the wearer — including maternity fit |
| Maintain & replace | Worn-out PPE replaced at employer cost — the care hub covers what 'worn out' looks like |
| Include casual workers | Limb (b) workers are inside the duty since April 2022 |
| Train and record | Workers shown how to use, wear and store it — and expected to comply |
Questions
They extended employers' PPE duties beyond employees to 'limb (b)' workers — casual and gig-style workers under a personal work contract. Where a risk assessment requires PPE, those workers must now receive it free, maintained and with training, on the same basis as employees.
No — PPE required by the risk assessment must be provided free of charge, and that includes replacements when kit wears out. Charging, deposits or wage deductions for required PPE aren't permitted.
Broadly: someone who contracts to do work personally, isn't an employee, but also isn't genuinely running their own business toward your organisation as a client. Status questions can be genuinely tricky — where it matters, check HSE guidance or take advice rather than guessing.
Whatever the risk assessment says the team needs, it's stocked, certified and priced for volume.