Brad is on the roll of solicitors of England & Wales but does not hold a practising certificate and does not provide legal advice.
Updated June 2026 · England & Wales
Keeping people safe at work is not a box-ticking exercise. It is one of the core legal duties that comes with running a business in the UK, and it sits at the heart of how workplaces are judged by regulators, insurers and staff alike.
Two of the most practical pieces of that duty are Personal Protective Equipment (PPE) and the Control of Substances Hazardous to Health (COSHH) regime. Between them, they cover a huge slice of everyday workplace risk, from chemicals and dust through to falling objects, noise and contact with machinery.
This guide walks through what those duties mean in practice, what employers are expected to put in place, and the kinds of questions that tend to come up when you are trying to get your paperwork and policies in order.
Overview
PPE is the kit an employer provides to protect workers from risks that cannot be removed or sufficiently reduced by other means. Think hard hats on a construction site, gloves in a kitchen handling chemicals, ear defenders in a noisy workshop, goggles in a lab, or high-visibility jackets on a warehouse floor.
It is a last line of defence, used once risks have been reduced as far as reasonably practicable through better processes, guarding, ventilation or substitution. COSHH, by contrast, is the framework for managing substances that can damage health, whether they are cleaning products, solvents, welding fumes, flour dust or biological agents.
A COSHH assessment looks at what is being used or generated, who might be exposed, how exposure could happen, and what needs to change so the risk is brought down to a level that is as low as reasonably practicable. Together, PPE and COSHH form a large part of any serious workplace health and safety system in the UK.
Key steps
Map the hazards in your workplace. Before you can decide what PPE or COSHH controls you need, walk the site and list every activity that could cause harm. Talk to the people doing the work, because they often spot risks managers miss. Record machinery, substances, noise, dust, manual handling and working at height, so nothing is left off.
Carry out and record your risk assessments. Each hazard needs a written assessment that sets out who might be harmed, how serious the harm could be, and what you are doing to control it. For hazardous substances this becomes a COSHH assessment. Keep the documents accessible, review them when things change, and date every version so you can show progress over time.
Reduce risk at source before relying on PPE. The law expects you to eliminate or engineer out risk where you can. That might mean swapping a harmful chemical for a safer one, installing local exhaust ventilation, guarding machinery, or changing how a task is done. PPE should come in only when those higher-level controls cannot fully deal with the remaining risk.
Select, issue and maintain suitable PPE. Once PPE is needed, choose kit that actually fits the task, the environment and the individual wearing it. Issue it free of charge, make sure it is compatible when several items are worn together, and put arrangements in place for cleaning, inspection, storage and replacement. Keep a simple record of what has been issued and when.
Train people and keep checking. Equipment and policies only work if staff understand them. Train workers on why controls exist, how to use PPE correctly, how to spot defects, and what to do if something goes wrong. Supervise, audit and refresh that training regularly, and update your assessments whenever processes, products or people change.
Under UK health and safety law, employers must provide PPE free of charge where it is needed to control a workplace risk. That includes replacements when kit is worn out or damaged through normal use. Employers cannot pass the cost on to staff through wage deductions or charges. If an item is lost or deliberately damaged, separate rules on deductions may apply, but the starting point is that safety equipment is the employer's cost.
Q Do small businesses need a written COSHH assessment?
If you have five or more employees, significant health and safety findings must be recorded in writing, and that usually includes your COSHH assessments. Even smaller businesses benefit from writing things down, because it shows inspectors, insurers and staff that risks have been thought through. A COSHH assessment does not have to be long, but it does need to be specific to the substances and tasks involved in your workplace.
Q What counts as a substance hazardous to health?
COSHH covers a wide range of materials, including chemicals, cleaning products, solvents, paints, adhesives, dusts such as flour or wood dust, fumes from welding or cooking, biological agents like bacteria, and some nanomaterials. If a substance carries a hazard label, is generated by a process, or could cause ill health through inhalation, skin contact or ingestion, it is worth assessing under COSHH even if you are not sure at first whether it qualifies.
Q How often should PPE and COSHH assessments be reviewed?
There is no fixed review interval in the legislation. The expectation is that assessments are reviewed whenever there is reason to believe they are no longer valid, for example after a change in process, a new substance, a near miss, an injury, or new information about a hazard. Many employers build in an annual review as a matter of good housekeeping, with faster reviews triggered by significant changes.
Q Can employees refuse to wear PPE?
Workers have their own legal duty to cooperate with health and safety measures and to use PPE provided by the employer. If someone repeatedly refuses, it becomes a disciplinary and safety issue rather than a matter of personal preference. Before taking action, employers should check that the PPE is suitable, fits properly and does not create other problems, and should listen to any practical concerns the worker raises.
Q Does PPE include things like sun cream or warm clothing?
The position can be nuanced. Ordinary weather-related clothing is not usually classed as PPE under the regulations, but where sun exposure or cold is a specific work hazard, employers are still expected to manage that risk. That might mean providing suitable outdoor gear, scheduling work to avoid the worst conditions, or offering training on skin protection. The test is whether the risk comes from the work itself.
Q What records should I keep for PPE and COSHH?
At a minimum, keep your written risk and COSHH assessments, details of the control measures in place, training records, maintenance and inspection logs for equipment such as respiratory protection, and records of PPE issued to individuals. For some exposures, health surveillance records may also be required. Good records protect your workers, support your defence if something goes wrong, and make audits and insurance renewals much smoother.
Health and safety duties shift depending on the work you do, the substances involved, and the size of your team. An experienced legal adviser can help you think through where your obligations sit, based on what you describe on the call.
✓Plain-English answers to your specific questions about PPE and COSHH duties
✓Practical perspective on where your main risks are likely to sit based on what you describe
✓Help thinking through what to put in your policies and assessments
✓Clarity on what to watch out for in your specific situation
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Written & reviewed by
Brad Askew Solicitor (non-practising)
Brad is on the roll of solicitors of England & Wales but does not hold a practising certificate and does not provide legal advice. LegalDocuments.co.uk is not a law firm and does not provide regulated legal advice.
This article is for general information only. It is a tool to help you find your way — not legal advice, and not a substitute for speaking to a qualified adviser about your situation.