PPE and Outdoor Working
Exposure to the sun can cause skin damage such as blistering and in extreme cases, even skin cancer, which has become the most common form of cancer in the UK.
Workers may also be in danger of becoming overheated due to working in high temperatures while wearing Personal Protective Equipment (PPE), but taking off their PPE while working is not an option.
Legislation
Although there is no legal obligation for employers to provide suncream or sunglasses for outdoor workers, they should consider providing sun protection advice as part of the health and safety training.
Under Regulation 4 of the Personal Protective Equipment at Work Regulations 1992, employees must be provided with ‘suitable’ PPE which is appropriate for conditions in the workplace. In terms of suitability, the code of practice suggests that consideration be given to environmental factors such as the weather, if working outside.
Regulation 11 of the Workplace (Health, Safety and Welfare) Regulations 1992 provides that all outdoor workstations should, so far as is reasonably practicable, provide protection from adverse weather conditions.
Other applicable legislation:
- Health & Safety at Work etc. Act 1974
- Management of Health and Safety at Work Regulations 1999
Although all workers should take steps to protect themselves, employers are under a duty to consider implementing measures, outdoors or indoors, such as:
- Shading employees from direct sunlight
- The provision of fans or air-cooling equipment
- Ensuring hats and other suitable clothing is worn
- Suitable rest breaks
- Scheduling work during a cooler time of day or year
- Additional supplies of drinking water
- Educating workers
PPE considerations
Waterproof and weatherproof clothing only falls within the PPE Regulations if it is necessary to protect the wearer from health and safety risks due to adverse climatic conditions.
Specialised personal protective clothing may incorporate, for example; personal cooling systems or breathable fabrics which can help protect workers in certain hot environments.
However, protective clothing or respiratory protective equipment is often required when there will be exposure to some other hazard at work, which may increase the risk of heat stress.
If this is the case, the HSE advises that:
- Because PPE is the last resort after other methods of protection have been considered, it is important that users wear it at all times, no matter what the conditions
- If PPE must be worn, make sure that workers are not wearing more PPE than is required for their protection
- Employers can encourage workers to remove personal protective equipment when resting to help encourage heat loss
- Employers should check regularly to ensure PPE is being used
- Safety signs can be useful reminders to wear PPE
Further information
http://www.hse.gov.uk/temperature/thermal/controlling.htm
HSE – Sun protection: advice for employers of outdoor workers:
www.hse.gov.uk/pubns/indg337.pdf
A Short Guide to the Personal Protective Equipment at Work Regulations 1992 – Rev 1 can be downloaded at:
www.hse.gov.uk/pubns/indg174.pdf
Case Study
Three road workers were sacked for taking off their personal protective equipment. The three men, who had been working on a railing at the side of the road, took off their hard hats and jackets when temperatures rose to 27°C (80°F). They were photographed by a health and safety officer and subsequently sacked by employers, Amey Lafarge, for gross misconduct.