When is PPE required?

Personal protective equipment (PPE) is part of everyday practice in many industries: safety shoes in the warehouse, hearing protection in production, a face shield during grinding work, or respiratory protection against dust and fumes. Yet this often sparks debate: when is PPE truly mandatory, and when can you do without it?

In this article, we explain this in practical terms based on the Working Conditions Act, the Working Conditions Decree, and the RI&E (including the Action Plan). We also show how the Dutch Labor Inspectorate enforces these regulations and which (EN) standards and CE marking are relevant in practice.

What does the Working Conditions Act say about PPE?

PPE as the final step in the occupational health and safety strategy

The law is based on the occupational health and safety strategy: first address risks at the source, then implement collective safeguards, and only use PPE if those measures are insufficient. PPE is therefore not a substitute for a safe work environment or proper work procedures, but a supplement when residual risks remain.

Practical example: When dust is generated in a workshop, addressing the source (exhaust ventilation at the machine) is usually the first step. If exposure can still occur despite exhaust ventilation, respiratory protection may be necessary for specific tasks or situations.

Legal Basis: the Working Conditions Act and the Working Conditions Decree

The employer’s general duty of care is set forth in the Working Conditions Act: work must be organized in such a way that employees do not suffer harm. The obligations regarding PPE are further elaborated in the Working Conditions Decree (including making PPE available, ensuring it is appropriate for the risk, providing it free of charge, ensuring the correct sizing, and providing instruction and supervision).

PPE and Product Requirements: CE Marking and EU Regulations

PPE must meet product requirements. In practice, this means that PPE must generally bear the CE marking and comply with European PPE regulations. 

Please note: CE marking alone is not sufficient. The PPE must also be suitable for the specific risk and circumstances and must be used correctly.

When is PPE required?

PPE becomes mandatory as soon as the Risk Inventory and Evaluation (RI&E) reveals that there are risks that cannot be sufficiently eliminated or controlled through source measures, technical measures, or organizational measures. It is therefore not a matter of “gut feeling,” but of a substantiated risk analysis and appropriate control measures.

Important: Mandating PPE is more than just saying “just put on some safety glasses.” The employer must also ensure that PPE actually works in practice: the correct type, the correct fit, compatibility with other PPE, maintenance, replacement, and clear work instructions. 

When is wearing PPE mandatory?

Wearing PPE is mandatory if this is specified in the Action Plan, the work instructions, or a task risk analysis (TRA) based on the RI&E, and if the risk is not sufficiently controlled without PPE.

Common situations:

• Hazardous substances: gloves, chemical-resistant clothing, safety goggles or face shields, and sometimes respiratory protection. The selection must be based on the Safety Data Sheet (SDS) and the route of exposure (skin, eyes, inhalation). 

• Risk of falling or flying objects: safety helmet and eye protection, for example on construction sites, during lifting operations, assembly, and demolition.

• Fall hazard: fall arrest harness with suitable anchor points and fall arrest devices, for example, when working at heights where collective measures (edge protection, scaffolding) are insufficient. 

• High noise levels: hearing protection when technical noise reduction is insufficient. 

• Cutting, impact, and collision risks: cut-resistant gloves, arm protection, and safety shoes with the appropriate safety rating.

• Traffic and internal transport: high-visibility clothing in warehouses, distribution centers, and outdoor areas where forklifts and freight vehicles operate.

Important distinction: “mandatory” also means “enforced.” The employer must organize supervision and hold employees accountable. If PPE is specified in procedures but not worn in practice, compliance is insufficient.

Relevant standards in practice: what should you look for?

The law generally does not prescribe a single specific EN standard for each task, but in practice, EN standards are an important way to demonstrate that PPE provides the appropriate level of protection. Some commonly used examples:

• Safety shoes: EN ISO 20345 (safety footwear with toe protection).

• Eye and face protection: EN 166 (personal eye protection).

• Hearing protection: e.g., EN 352 (hearing protectors).

• Respiratory protection: including EN 149 (dust masks/FFP), EN 140/EN 143/EN 14387 (filters and half-masks/full-face masks, depending on type).

• Hard hats: EN 397 (industrial safety helmets).

• Fall protection: including EN 361 (safety harnesses) and related standards for lanyards/fall arresters.

Tip for your policy/procurement: In your RI&E/TRA, specify not only that “PPE is mandatory,” but also the specific type and level of protection (e.g., safety class of footwear, filter type for respiratory protection, etc.).

When is PPE not mandatory?

PPE is not mandatory if the RI&E shows that the risk is absent or sufficiently controlled by other measures (for example, an office environment without specific risks). PPE may also not be required (or may even be undesirable) for tasks where wearing it poses an additional hazard, such as near rotating parts where gloves could get caught. In such cases, the control measure should be different: guarding of moving parts, lockout/tagout, work methods, and training.

Note: “not mandatory” does not automatically mean “prohibited” or “unnecessary.” Sometimes companies still opt for PPE as an additional layer of protection, but this should never mask the absence of source-based or collective measures. The rationale for this should be included in the Risk Assessment and Evaluation (RI&E) and work instructions.

Who is responsible for PPE under the law?

Employer: ultimately responsible for safe working conditions. Specifically, this means, among other things:

• Identifying risks (Risk Inventory and Evaluation) and documenting measures in an Action Plan.

• Selecting the appropriate PPE based on risk, exposure, and duration of use.

• Providing PPE free of charge, ensuring it fits properly, and replacing it in a timely manner.

• Providing instruction and training, including verifiable information sessions.

• Monitoring proper use and taking action in the event of violations.

Employee: must use PPE correctly, in accordance with instructions, and for the purpose for which it was provided. The employee must also report any defects or unsuitability.

What happens if PPE is not used or is used incorrectly?

Improper use immediately increases the risk of injury, occupational diseases, and incidents. Examples include hearing damage from putting on ear muffs too late, eye injuries from safety glasses that are not properly secured, or skin irritation from using the wrong type of gloves.

In addition, it can lead to liability and enforcement actions. If an accident occurs and it turns out that the employer failed to adequately provide appropriate PPE, instruction, or supervision, this can be a major factor in determining fines and follow-up measures.

How does the Dutch Labor Inspectorate monitor PPE use?

The Dutch Labor Inspectorate does not merely check whether PPE is available, but primarily whether the policy is correct and being followed. During inspections, you can expect, among other things:

• Review of the Risk Inventory and Evaluation (RI&E) and Action Plan: Is PPE correctly included as a measure?

• Assessment of workstations and processes: Do PPE and risks align?

• Instructions and training: Have employees been instructed, and can this be demonstrated?

• Supervision and compliance: Is PPE actually being worn in designated zones and during specific tasks?

• Maintenance and replacement: Are filters, face shields, helmets, and footwear still within their service life and in good condition?

Practical examples of PPE in the workplace

Example: Construction site

On construction sites, safety shoes and helmets are often standard, supplemented by eye protection when sawing, drilling, or grinding, and hearing protection in noisy environments. When working at heights, fall protection may be mandatory if collective measures are lacking or insufficient. It’s important to take a task-specific approach: a carpenter, demolition worker, and installer often face different risks and therefore require different PPE combinations.

Example: Warehouse or Logistics

In logistics, the main concerns are the risk of being struck by objects, falling loads, and foot injuries. Common PPE includes safety shoes, high-visibility clothing, and sometimes gloves for handling materials. In some environments, hearing protection is also relevant, for example, during prolonged use of rolling stock or in loading and unloading zones with peak noise levels.

Example: Production Environment

In manufacturing, risks are wide-ranging: mechanical hazards, noise, splashes, dust, and chemicals. PPE may include cut-resistant gloves, hearing protection, safety glasses or face shields, and respiratory protection. Pay special attention to compatibility issues here: safety glasses that do not fit properly with a half-face respirator, or hearing protection that does not provide sufficient attenuation due to an improper fit.

Selecting PPE Based on the RI&E and Task Risk Analysis

The RI&E identifies the risks, but the application to the workplace is often determined on a task-by-task basis using a task risk analysis (TRA). This helps you avoid off-the-shelf packages that don’t fit. When making your selection, consider:

• Level of protection: standards/performance appropriate to the risk (e.g., EN standards; filter type for respiratory protection).

• Fit and comfort: essential for compliance, especially during prolonged use.

• Compatibility: safety glasses, helmets, hearing protection, and respiratory protection must work together.

• Maintenance: cleaning, storage, inspection, and replacement intervals.

• Field testing: Have users test the equipment and gather feedback before a large-scale rollout.

Common Mistakes in PPE Policy

In practice, we see that many organizations do provide PPE, but the policy behind it isn’t airtight. Minor shortcomings in justification, selection, instruction, or supervision can have major consequences for workplace safety. Below are the most common mistakes in PPE policies:

• Using PPE as the first line of defense instead of addressing the source of the hazard or implementing collective safeguards (contrary to the occupational health and safety strategy).

• Lack of justification: PPE not linked to the Risk Inventory and Evaluation (RI&E)/Risk Assessment (TRA) or workplace instruction card.

• One-size-fits-all approach: no sizing options, no women’s models where needed, no fit testing.

• Insufficient instruction: failure to explain when, how, and why PPE is required.

• Lack of supervision: rules exist on paper but not on the job site.

• Replacement too late: worn-out shoes, damaged helmets, old filters, or scratched visors.

Mini-checklist: Is PPE properly managed at your workplace?

You can use this mini-checklist to verify whether PPE is being used correctly in your work environment:

• Does the RI&E/TRA describe the residual risk for each task or zone?

• Is it documented which PPE (type/standard/level of protection) is required?

• Is there training and refresher training, and is this documented?

• Is there supervision (by supervisors/workplace rounds), and are deviations followed up on?

• Is there a replacement and maintenance process (filters, helmets, shoes, face shields)?

PPE is mandatory if residual risk remains

PPE is mandatory as soon as the Risk Inventory and Evaluation (RI&E) shows that risks cannot be adequately controlled by other measures. This requires a practical approach: clearly describe risks, select PPE correctly (including the appropriate level of protection and standards), train employees, and ensure compliance.

Do you want to be sure that your PPE policy complies with the Occupational Safety and Health Act and works on the job site? Then start with a brief audit:

• Review the current RI&E and verify that PPE is properly justified for each risk/task;

• For each PPE item, verify that the CE marking and specifications match the risk;

• Organize a trial run with users and document the selections in work instructions.

Do you work in a specific industry or perform specific tasks (e.g., welding, wood dust, spray painting, demolition)? If so, I can also refine the text with industry-specific examples and the most relevant PPE types and standards for each task.