PPE Requirements in New Zealand: Supply, Fit and Use

Personal protective equipment protects a person from a workplace hazard that has not been adequately removed by other controls. It may include eye protection, gloves, protective clothing, hearing protection, respiratory protection or footwear. The right equipment depends on the task, the remaining exposure and the individual using it. A sign saying “PPE must be worn” does not show that the business has chosen suitable protection or controlled the source of harm.

New Zealand's Health and Safety at Work (General Risk and Workplace Management) Regulations 2016 set specific PPE duties in regulations 15 to 20. The Health and Safety at Work Act 2015 also sets primary risk-management duties. WorkSafe New Zealand's guide for businesses explains how provision, suitability and maintenance work in practice. This article covers the general framework; specialised work may have further rules and standards.

Begin with the risk, not the equipment list

Identify what could harm people and whether the work can be changed so the hazard disappears. If elimination is not reasonably practicable, consider substitution, isolation and engineering controls. Administrative controls can help with remaining exposure. PPE is a final layer for risk that remains. WorkSafe's guide calls it protection when other measures cannot adequately eliminate or minimise risk.

For risks to which the prescribed process applies, GRWM regulation 6 gives a hierarchy of controls. Regulation 4 defines when that process applies, so do not describe regulation 6 as mechanically governing every conceivable risk. The wider HSWA duty to manage risk still calls for effective measures. A respirator should not be the sole response to a dusty process if extraction or a different method can reasonably reduce exposure at source. A hard hat cannot make an unstable load safe. A glove cannot neutralise an uncontrolled chemical spill.

Document why PPE remains necessary and what it is expected to protect against. Review the underlying control when the task or material changes. The fact that a workforce has always worn a particular item is not enough to show it is still suitable.

Who must supply and pay for PPE?

Under GRWM regulation 15, the PCBU directing the work generally provides PPE needed to minimise risk, unless another PCBU has provided it. Regulation 16 permits a worker to choose genuinely and voluntarily to provide their own PPE, subject to suitability. The business cannot make that choice a condition of the job. WorkSafe's business guidance explains that costs cannot be passed on to the worker.

HSWA section 27 prohibits levying or charging a worker for something done or provided in relation to health and safety. That includes PPE provision where required. If a worker volunteers to use their own item, the PCBU must still check that it provides suitable protection, fits and is compatible with other equipment. The worker may change their mind, with reasonable time for the business to arrange an alternative. A purchased item cannot be treated as suitable merely because a worker prefers it.

Where a host business and contractor both have roles, agree who supplies an item and who checks it. A contract can organise supply but cannot leave a person exposed because each party expected the other to act. Explain the arrangement to the workers and check what arrives at the worksite.

Select equipment for the hazard and person

Choose the protective function first. What material, impact, noise, temperature or airborne contaminant remains? Then check whether the chosen item is designed for that exposure, is the correct size and fits the wearer. WorkSafe's guidance says PPE should suit the work and risks, be a suitable size and fit, be reasonably comfortable and work with other required PPE.

Compatibility matters. Eye protection may interfere with a respirator seal. A helmet can affect hearing protection. Gloves that resist one chemical may not resist another. Equipment that slips, fogs or prevents essential communication can create a new risk or be removed during the task. Ask workers to test fit in realistic conditions and investigate complaints rather than assuming non-use is simply a disciplinary issue.

Some PPE needs specialised fitting, testing or selection. Respiratory equipment for a hazardous atmosphere, for example, cannot be chosen by colour or a generic stock code. Get competent advice for the actual exposure and follow specific regulations and relevant standards. This page does not prescribe a respirator or glove for a particular job. Refer to manufacturer instructions and applicable technical standards without copying copyrighted standard text into the procedure.

Maintain, replace and store it

GRWM regulation 17 and WorkSafe require PPE to remain effective, including maintenance, repair and replacement. Decide who inspects reusable equipment, what makes it unfit for use, where replacements are kept and how contaminated items are cleaned or disposed of. Equipment exposed to a chemical, impact or extreme heat may require immediate replacement even if it looks intact. Follow the manufacturer's limits and the task assessment.

Storage can affect performance. A respirator left dusty or a harness kept in damaging conditions may not protect as expected. Workers need an easy way to report a fault and get a replacement before continuing affected work. Check whether spare equipment fits, rather than relying on one generic size.

An inventory or inspection record can help show what was checked and when, but it does not prove the wearer used the item correctly. Observe the work and ask whether PPE remains usable throughout the task.

Teach workers how and when to use it

The PCBU should provide information and training on correct use, wearing and maintenance. Explain the hazard, the role and limits of the item, how to put it on, how to recognise a poor fit, when to replace it and what to do if it is unavailable. WorkSafe's worker guide says workers must follow reasonable instructions and report problems with their PPE. That worker duty does not remove the business's responsibility to supply suitable protection and address the underlying risk.

Training must fit the complexity of the equipment. A brief induction may suffice for simple eye protection in one task, while specialised respiratory or fall-protection equipment demands more. Demonstrate use and check understanding. Revisit training when an item changes or an inspection shows it is used incorrectly.

Where PPE limits hearing, vision, movement or heat tolerance, assess the new risk. A worker who cannot hear a vehicle warning because of hearing protection needs an adjusted traffic or communication control. The solution is not simply to remove protection against noise while leaving both hazards uncontrolled.

Remember visitors and others

The GRWM Regulations, regulations 19 and 20, address PPE for other persons at a workplace and their use of it. A visitor entering a hazardous area may need suitable equipment and instructions even though they are not an employee. Plan how different sizes, prescription eyewear, mobility needs and short visits are handled. If an area cannot be entered safely with available protection, use another route or postpone the visit.

Do not issue an item merely to make the visitor look like a worker. Explain what hazard it addresses and any limits. Escorting may be necessary, but an escort does not replace effective control of the area.

Example: maintenance across two tasks

A maintenance worker moves from a workshop inspection to a dusty cutting job. The workshop's standard safety glasses may not address airborne exposure from cutting. The business checks whether a different method or extraction can control the dust, assesses the remaining risk and chooses any PPE accordingly. It verifies that eye and respiratory protection work together and that the worker understands when to use and replace them. If the cutting material changes, the old PPE decision is reviewed.

This is a decision sequence, not a specification for a particular material. Exposure assessment and competent advice may be needed. Keeping the risk and equipment decision linked to the task is more useful than one generic “PPE required” entry for the worker's job title.

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