What does the Labor Inspectorate check regarding PPE?

Personal protective equipment (PPE) serves as a crucial last line of defense against injuries and occupational diseases in many sectors. Precisely because PPE is only used when risks have not been (sufficiently) eliminated at the source or through collective measures, the Dutch Labor Inspectorate closely scrutinizes the justification, selection, availability, training, and actual use of PPE. An inspection therefore rarely focuses solely on “do we have a helmet on hand,” but rather on the entire safety assurance process: from the Risk Inventory and Evaluation (RI&E) and Action Plan to monitoring, maintenance, and demonstrable compliance.

In this article, you’ll learn what the Labor Inspectorate actually checks regarding PPE, which documents you must have in order, and which shortcomings are most frequently identified—with references to official sources so you can immediately assess your policy.

What is the role of the Labor Inspectorate?

The Dutch Labor Inspectorate (under the Ministry of Social Affairs and Employment) monitors compliance with labor conditions legislation and enforces it where necessary. In doing so, the Inspectorate looks not only at incidents but also takes a preventive approach: Is your organization structured in such a way that employees can work safely and healthily?

When it comes to PPE, this role broadly translates into three pillars:

• Supervision and assessment: verifying whether employers comply with obligations under, among others, the Working Conditions Act and the Working Conditions Decree, including the selection and use of appropriate PPE.

• Enforcement: ranging from warnings and requirements to fines, shutdowns, or other measures if risks are serious or if there is a systemic failure to comply. A practical explanation of how the Labor Inspectorate enforces regulations can be found on the Labor Inspectorate’s website.

• Promoting compliance: through explanations during inspections and via public information.

When does the Labor Inspectorate inspect PPE?

PPE inspections take place in various situations. These include thematic inspections (e.g., working at heights, hazardous substances, noise, welding fumes), site visits following reports or accidents, or sector-specific campaigns. PPE may also be explicitly included during inspections of machinery, tools, and protective equipment.

Important: The inspection typically assesses the big picture. PPE cannot be considered in isolation from your risk assessment, work methods, supervision, and safety culture in the workplace.

What PPE-related issues are inspected?

The Labor Inspectorate generally examines four interrelated questions. If you can answer these logically by referring to policy, practice, and evidence, you’ll be in a strong position during an inspection.

1. Is the choice of PPE well-founded based on the RI&E?

The starting point is your RI&E and Action Plan. The inspector wants to see that risks have been identified and that you are applying the occupational health strategy: first address the source of the risk, then implement collective measures, followed by organizational measures, and only then use PPE as a last resort or as supplemental protection.

In practical terms, this means you can demonstrate:

• what risks exist for each task or workstation (e.g., grinding, working with solvents, fall hazards, noise);

• what measures you have already taken without PPE (barriers, exhaust ventilation, substitution, work procedures);

• why PPE is necessary and what level of protection is required (e.g., cut resistance, filter class, SNR value, fall protection configuration).

If PPE is distributed “as standard” without being linked to specific risks, that is a well-known red flag.

2. Are the PPE items suitable, appropriate, and of the right quality?

Not every PPE is automatically suitable. The inspection assesses whether the equipment is appropriate for the risk and the work situation, and whether it is practical to wear in real-world conditions so that employees actually use it.

• Suitability: A dust mask without the correct filter class offers no protection. Neither does hearing protection with insufficient attenuation. For fall protection, the entire system must be correct: harness, lanyard, anchor point, and fall distance.

• Fit and sizing: PPE must fit the user properly. Consider respiratory protection (where relevant: fit check/fit test) and proper sizing for gloves and safety shoes.

• Compatibility: PPE must be compatible for simultaneous use. A face shield that interferes with a helmet, or hearing protection that does not seal properly due to eyeglass arms, creates a false sense of security.

• CE marking and product requirements: The Labor Inspectorate may also verify (especially during inspections of “protective equipment” under the Commodities Act) whether the PPE, as a product, complies with European regulations.

• Condition: Damaged helmets, worn-out gloves, dirty filters, or fall protection equipment that has not undergone (periodic) inspection are immediate areas of concern.

Practical tip: Specify for each task which PPE combination is permitted and why. This prevents disputes on the job site and creates a verifiable framework.

3. Are PPE items available, on time, and in the right place?

Availability sounds simple, but it’s often put into concrete terms during inspections: Are PPE items actually present where the work is taking place, in sufficient quantities, and in a style that fits the users? A box of gloves in a warehouse isn’t helpful if employees are working on a construction floor and “just” start working without them.

The inspector may ask about:

• distribution processes (who gets what, when, and based on what criteria);

• replacement policies (when is something replaced, who decides that, and how quickly);

• hygiene and storage (for example, clean storage of respiratory protection, separated from contaminated areas).

4. Are PPE items actually being worn and used correctly?

This is often the decisive part of an inspection: what actually happens on the job site. The Labor Inspectorate observes and asks questions. Are safety glasses worn in the splash zone? Is the helmet’s chin strap fastened? Is a mask put on and taken off correctly? Is fall protection actually attached to a suitable anchor point?

This applies not only to the employee but also to the employer, who must ensure:

• clear instructions and understandable work procedures for each task;

• education and training, including refresher courses and onboarding for new employees, temporary workers, and contractors;

• supervision and enforcement: managers who correct mistakes, set a good example, and are consistent.

A common misconception is that a signed checklist is sufficient. The inspectorate wants to see that employees can actually apply the procedures and that compliance is being monitored.

Documentation and record-keeping: what do you need to be able to show?

An inspection is not just a walk-through but also a review of your records. Proper documentation helps you demonstrate that your PPE policy is systematically implemented. Consider the following components:

• Risk Inventory and Evaluation (RI&E) and Action Plan with a clear breakdown of PPE requirements for each risk and task. 

• PPE matrix or task-risk-PPE overview: which tasks, which hazards, which PPE, which standard or performance requirement (e.g., EN standards listed on the manufacturer’s product or documentation).

• Instruction and training: training plans, attendance lists, test results, toolbox meetings, and verifiable instruction for specific PPE (e.g., respiratory protection, fall protection).

• Issuance and Replacement Records: who received which PPE, when, and when replacements are scheduled.

• Maintenance and inspections: inspection and testing records for reusable PPE, particularly fall protection and respiratory protection equipment where applicable. Also document how you handle damage or incidents.

• Incidents and near-misses: records of incidents in which PPE played a role, and the corrective actions taken in response.

The more extensive your operation, the more important consistency becomes: the same rules, the same definitions, and a single source of truth in your documents and on the job site.

Common Shortcomings Identified During Inspections

In practice, the Labor Inspectorate regularly observes the same patterns. The points below are typical “gaps” between policy and implementation.

• PPE without proper justification: PPE is distributed, but no one can explain why this specific type, with these performance requirements, was chosen for this task.

• Insufficient or outdated training: Employees may have received a toolbox session at some point, but new colleagues, temporary workers, or non-native speakers have not been properly included.

• No or weak supervision: PPE is mandatory on paper, but supervisors do not correct violations or consistently set a good example themselves.

• Improper use: for example, a half-face respirator worn with a beard, hearing protection hanging loosely around the neck, or a safety harness that isn’t properly adjusted.

• Maintenance not ensured: filters used for too long, damaged helmets that are not replaced, or the lack of a record of fall protection inspections.

• Incompatible PPE combinations: goggles, a mask, and hearing protection that interfere with each other, thereby reducing overall protection.

For additional practical knowledge and industry-specific information, a trade association or specialized knowledge base can be helpful.

What are the consequences of violations?

If the Labor Inspectorate identifies deficiencies, the follow-up depends on the severity and the immediate risk. In the event of an acute hazard, operations may be halted immediately or immediate corrective actions may be required. Additionally, fines may be imposed for violations of occupational safety and health obligations, particularly in cases of repeat violations, serious risks, or an incident resulting in injury.

It’s important to realize that, in the event of an accident, the demonstrable duty of care is scrutinized afterward. Without a thorough Risk Inventory and Evaluation (RI&E), proper instruction, supervision, and the right resources, your position as an employer is legally vulnerable.

How to Prepare for an Inspection: A Practical Checklist

Proper preparation isn’t something you do “on the fly” when you’re expecting an inspection; it’s an ongoing routine. Still, a concise checklist can help you fine-tune your PPE compliance.

Step 1: Clearly identify tasks and risks for each workstation

• Update the Risk Assessment and Link it to Specific Work Activities.

• Verify that you have demonstrably considered source-based and collective measures (occupational hygiene strategy).

Step 2: Make PPE requirements specific and unambiguous

• Create a PPE matrix that includes the task, risk, required PPE, performance requirements, and any combination rules.

• Specify which PPE is not permitted in specific situations (if relevant to your industry).

• When purchasing PPE, verify that it meets product requirements and bears a valid CE marking.

Step 3: Organize instruction, training, and refresher sessions

• Make instruction task-oriented and practical: demonstrate, have employees practice, and check their understanding.

• Ensure proper onboarding for new employees, temporary workers, and contractors.

• Repeat the training periodically, especially for high-risk PPE such as respiratory protection and fall protection.

Step 4: Ensure supervision and exemplary behavior

• Make it clear who is responsible for supervision and what the escalation procedure is in the event of a violation.

• Ensure that managers follow the exact same rules as the rest of the team. Inconsistencies are quickly identified during inspections.

Step 5: Maintain verifiable records of maintenance, inspections, and replacements

• Establish fixed inspection routines for reusable PPE.

• Record issuance, replacement, damage, and incidents. Ensure that records are traceable.

Assess your PPE management in 30 minutes

Want to quickly see where you stand before an inspection takes place? Grab your RI&E, your PPE matrix, and 2–3 workstations, and go through the four check questions from this article. Compare your approach with the official guidance on the Arboportaal and immediately document any discrepancies in your Action Plan.

PPE as the Final Piece, Not a Check-Off List

The Labor Inspectorate does not inspect PPE as a standalone item, but as part of your overall safety management system. The key question is always: Have you properly assessed the risks (RI&E), selected the correct equipment (suitable + CE-marked), properly instructed your employees, and ensured that work is carried out safely in practice through active supervision and routine maintenance?

If you approach PPE as the essential final piece of your control measures and demonstrably embed this in policy and behavior, you not only reduce the risk of enforcement action but, more importantly, the risk of injury and absenteeism. This restores PPE to what it should be: reliable protection when it really matters.