Quick answer: PPE compliance requires more than handing out hard hats. You must identify PPE needs from risk assessments, provide correctly rated and fitted PPE free of charge, train workers in its use, conduct RPE fit testing where required, inspect and replace PPE regularly, maintain a PPE register, and ensure PPE meets the relevant AS/NZS standard. Remember: PPE is the last resort in the hierarchy of controls, not the first response to a hazard.
Last reviewed: June 2026 by the BlueSafe Technical Team. Reflects current Model WHS Act and Regulations.
Personal protective equipment is the last line of defence between a worker and a hazard — and that is precisely why it attracts significant regulatory scrutiny. When every other control measure has been applied as far as is reasonably practicable, PPE is used to manage the residual risk. Using it as a substitute for higher-order controls — such as elimination, substitution, or engineering controls — is both legally problematic and practically dangerous.
For a full explanation of where PPE sits in the hierarchy, see our guide on the hierarchy of controls.
The checklist below covers every key element of a compliant PPE programme, from initial hazard identification through to ongoing record keeping. Work through each section and address any unchecked items.
1. PPE Needs Identified from Risk Assessments
Before any PPE is selected or issued, the need for it must be established through a documented risk assessment process.
- A formal hazard identification and risk assessment has been completed for all tasks and work areas.
- The risk assessment explicitly identifies where residual risk — after applying higher-order controls — requires PPE.
- The type of PPE required (e.g. eye protection, hearing protection, respiratory protective equipment, skin protection, head protection, foot protection) has been specified for each task or area.
- PPE selection is based on the nature and level of the hazard identified, not on convenience or habit.
- Risk assessments are reviewed and PPE requirements updated after any incident, near-miss, change in process, or change in the work environment.
2. Correct PPE Provided Free of Charge
- All PPE required for work tasks is provided by the business at no cost to the worker.
- Workers are not asked to purchase their own PPE or use personal PPE as a substitute for employer-provided equipment.
- The PPE provided meets the relevant Australian/New Zealand Standard (AS/NZS) for the hazard type (see Section 9 below).
- PPE is appropriate for the specific hazard — not generic or substituted with a lesser-rated item.
- Sufficient quantities of PPE are available so that workers are never without the required protection.
3. Fit and Sizing
Ill-fitting PPE can be as dangerous as no PPE at all. A hard hat that slips, safety glasses that gap at the sides, or a respirator that does not seal against the face provides minimal or no protection.
- Workers are individually fitted or sized for PPE before it is issued.
- Multiple sizes and styles are available where required to accommodate the range of workers on site.
- Comfort and fit have been considered in PPE selection — workers are less likely to wear PPE that is uncomfortable or poorly fitted.
- Workers with beards, facial hair, or other facial characteristics that may affect the seal of tight-fitting RPE have been identified and alternative RPE solutions provided (see Section 5).
- Female workers, younger workers, and workers with non-standard sizing requirements are provided with appropriately sized PPE — not a default "unisex" item that does not fit correctly.
4. Training on PPE Use
Providing PPE without instruction does not satisfy the duty of care. Workers must know how to use, adjust, and care for the equipment they have been issued.
- All workers who are required to use PPE have received documented training before using it in the workplace.
- Training covers: correct donning and doffing (putting on and taking off), adjustment for fit, limitations of the PPE, signs of wear or damage, and when to replace.
- Training is provided in a language and format the worker understands.
- Refresher training is provided when PPE is updated or when a worker's performance suggests they are not using it correctly.
- Training records are kept in the training register for each worker.
5. Respiratory Protective Equipment (RPE) Fit Testing
Tight-fitting RPE — including half-face respirators, full-face respirators, and powered air-purifying respirators with tight-fitting facepieces — requires a quantitative or qualitative fit test to confirm an adequate facial seal.
- All workers required to use tight-fitting RPE have undergone an initial fit test conducted by a competent person.
- Fit test records are kept on file, including the date, test result, tester's name, and the specific respirator make, model, and size tested.
- Fit testing is repeated when the worker's facial structure changes (e.g. significant weight loss, dental work, scarring) or when the respirator model is changed.
- Workers who cannot achieve an adequate fit with a tight-fitting respirator (e.g. due to facial hair) have been provided with an alternative — such as a loose-fitting powered air-purifying respirator (PAPR).
- Workers understand that facial hair between the facepiece seal and skin will prevent an adequate seal and invalidate the protection.
- The RPE selected is appropriate for the specific contaminant and concentration — cartridge type, filter rating, and assigned protection factor have all been verified.
6. Inspection, Maintenance, and Replacement
PPE degrades over time through use, UV exposure, contamination, and age. A PPE maintenance programme ensures the equipment continues to provide the protection it was designed to deliver.
- A documented PPE inspection schedule is in place, with inspection frequencies appropriate for the type of PPE and the intensity of use.
- Pre-use checks are conducted by workers before each use (workers have been trained to inspect their PPE).
- Periodic (e.g. monthly or quarterly) inspections are conducted by a competent person and results recorded.
- Damaged, degraded, or expired PPE is removed from service immediately and destroyed or disposed of so it cannot be re-used.
- Replacement PPE is available on-site so that damaged items can be exchanged promptly without workers being left unprotected.
- Manufacturer-specified service life and replacement schedules are followed — particularly for safety harnesses, hard hats, and chemical-resistant gloves, which have mandatory replacement timelines regardless of apparent condition.
- Maintenance and decontamination procedures are followed for reusable PPE (e.g. cleaning respirator facepieces, replacing filter cartridges on schedule).
7. Storage
- Designated, clean, and secure storage is provided for all PPE.
- Storage locations protect PPE from UV light, heat, chemical contamination, physical damage, and moisture — factors that degrade many types of PPE.
- PPE is not stored in locations where it could become contaminated (e.g. in the same bag or locker as chemical containers).
- Workers know where to find replacement PPE and how to access it.
- PPE that has been used in a contaminated environment is decontaminated before storage or is clearly segregated to prevent cross-contamination.
8. PPE Register
A PPE register provides the documentary evidence that PPE has been issued, is being maintained, and is fit for purpose. It is the foundation of your PPE compliance record.
- A PPE register is maintained and records: worker name, PPE type, make and model, size, relevant AS/NZS standard, date of issue, and inspection history.
- The register is kept up to date when PPE is replaced, returned, or upgraded.
- The register is accessible to supervisors, safety personnel, and inspectors on request.
- Disposal or retirement of PPE items is recorded in the register.
For a detailed overview of what a PPE register should contain, see our guide: What Is a PPE Register?
9. AS/NZS Standards
PPE sold and used in Australia must comply with the relevant Australian/New Zealand Standard. Using PPE that does not meet the required standard — even if it looks identical to compliant PPE — does not satisfy your legal obligations.
- All PPE in use has been verified as meeting the relevant AS/NZS standard for its type (see common standards below).
- PPE markings and certification documentation have been checked — not simply taken on faith from the supplier.
- Only PPE from reputable suppliers with verifiable certification is purchased.
Common AS/NZS standards for PPE:
| PPE type | Standard |
|---|---|
| Industrial safety helmets (hard hats) | AS/NZS 1801 |
| Eye and face protection (safety glasses, goggles, face shields) | AS/NZS 1337 series |
| Hearing protection (earmuffs, earplugs) | AS/NZS 1270 |
| Respiratory protective equipment | AS/NZS 1715 / AS/NZS 1716 |
| Safety footwear | AS/NZS 2210 series |
| High visibility garments | AS/NZS 4602.1 |
| Fall-arrest harnesses | AS/NZS 1891 series |
| Hand protection (gloves) | AS/NZS 2161 series |
| Sun protection clothing | AS/NZS 4399 |
Always confirm the applicable standard for the specific hazard and application with the manufacturer or a competent safety professional.
10. Worn Correctly and Supervised
Issuing PPE is not the end of the obligation. The WHS Regulations require that PPE is used correctly, and that the PCBU takes reasonable steps to ensure workers are actually wearing and using it as intended.
- Supervisors and managers enforce PPE use in all areas and tasks where it is required — PPE zones are clearly marked and communicated.
- Workers observed not wearing required PPE are corrected immediately and the situation is followed up appropriately.
- Site rules make it clear that failure to wear required PPE is a WHS breach — not simply a performance issue.
- Regular site inspections or walk-throughs include a check on PPE compliance.
- Workers are encouraged to raise concerns about PPE comfort, fit, or effectiveness without fear of negative consequences — poor fit is a compliance risk, not a complaint to be dismissed.
A note on the hierarchy of controls
PPE is the last and lowest control measure in the hierarchy of controls. It does not reduce or remove the hazard — it only reduces the severity of harm if exposure occurs. Before relying on PPE, you must be able to demonstrate that:
- Elimination of the hazard is not reasonably practicable.
- Substitution with a less hazardous material or process has been considered.
- Isolation or engineering controls have been applied as far as is reasonably practicable.
- Administrative controls (safe work procedures, job rotation, exposure limits) are in place.
PPE is then applied to manage the residual risk that remains. A SafeWork Inspector finding that a business has jumped straight to PPE without working through the higher-order controls may issue an improvement notice or find that the duty of care has not been met.
Related guides
- Hierarchy of Controls Explained
- What Is a PPE Register?
- WHS Compliance Checklist for Small Businesses
- What to Do When a SafeWork Inspector Visits Your Site
Frequently asked questions
Does an employer have to provide PPE free of charge?
Yes. Under the Model WHS Regulations (and equivalent state legislation), a PCBU must provide PPE at no cost to the worker. Workers cannot be asked to supply their own PPE or to pay for it as a condition of work.
What is RPE fit testing and who needs it?
RPE fit testing is a process that verifies a tight-fitting respirator forms an adequate seal against the wearer's face. It is required under the WHS Regulations for workers who use tight-fitting RPE when working with hazardous chemicals or in atmospheres requiring respiratory protection. A fit test must be conducted by a competent person and repeated when the worker's facial characteristics change or the respirator model changes.
What is a PPE register and is it legally required?
A PPE register is a record of the PPE issued to each worker, including the type, size, standard, issue date, and inspection history. While PPE registers are not explicitly named in the WHS Act, they are the standard tool for demonstrating compliance with the duty to provide, maintain, and replace PPE. Regulators and insurers expect to see one. See our guide to what is a PPE register for more detail.
When should PPE be replaced?
PPE should be replaced when it is worn, damaged, degraded, or has reached the end of its service life as specified by the manufacturer. Some PPE — such as hard hats and safety harnesses — has a mandatory replacement schedule regardless of visible condition. Check manufacturer specifications and relevant AS/NZS standards for the PPE type you are using. Do not wait for visible failure before replacing safety-critical PPE.
Get your PPE documentation in order
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This article is general information only and does not constitute legal advice. WHS laws vary between states and territories. Always confirm current requirements with your relevant state or territory WHS regulator or seek independent legal advice for your specific situation.