Personal protective equipment (PPE) policy

1 Introduction

There is a statutory requirement under the Personal Protective Equipment at Work Regulations 1992 (as amended 2022) for personal protective equipment (PPE) to be supplied and used at work wherever there are risks to health and safety that cannot be adequately controlled in other ways. PPE must be considered in addition to all other control  measures and should not be relied on as the only means of protection.

PPE is “all equipment (including clothing affording protection against the weather) which is intended to be worn or held by a person at work and which protects individuals against one or more risks to their health or safety”. Regulation 2, PPE regulations.

2 Purpose

The purpose of this policy is to set out the requirements for the selection, use and maintenance of PPE, including respiratory protective equipment. It provides information and advice on the different types of PPE available as well as establishing procedures to minimise the risk to colleagues of latex allergy and dermatitis through the selection and use of gloves.

Core standard 68 of the NHS England core standards for emergency planning, resilience and response (EPRR) requires organisations to “have access to and are trained to use FFP3 mask protection (or equivalent)” for “colleagues who may come into contact with confirmed infectious respiratory viruses”. The arrangements in the policy detail the trust arrangements to comply with this requirement.

FFP3 masks are face masks that protect the user by preventing the inhalation of hazardous substances including liquid aerosols.

3 Scope

The policy applies to all employees, colleagues and workers (more casual workers such as bank colleagues, sometimes referred to as limb (b) workers) employed by the trust, including apprentices, bank colleagues and volunteers carrying out work on behalf of the trust in compliance with the requirements of the Personal Protective Equipment at Work (Amendment) Regulations 2022.

It should be noted that some PPE is not covered by the Personal Protective Equipment Regulations. Ear protection is covered under the Control of Noise at Work Regulations 2005 and respiratory protection is covered under the COSHH Regulations 2002 and Confined Spaces Regulations 1997. However, the advice given in this policy is still applicable, as the general principles of selecting and maintaining suitable PPE and training colleagues in its use are common to all regulations that refer to PPE.

The trust has a number of clinical policies that deal with PPE selection and use from an infection prevention and control perspective. These can be found in the infection prevention and control manual. Some of the precautions associated with these other policies overlap with this policy. The primary objective of this policy is to ensure that the legal requirements for the provision of PPE are outlined in more general terms.

4 Responsibilities, accountabilities and duties

4.1 Chief executive

The chief executive has specific accountability to ensure that responsibilities for health and safety, including the provision of suitable PPE is effectively assigned, accepted and managed at all levels in the trust consistent with good practice. This duty is delegated to others within the trust.

4.2 Executive directors

Executive directors have delegated responsibility for the management of health and safety, including ensuring that there are suitable and sufficient arrangements and resources for PPE and to ensure this policy is implemented throughout the trust. This is further delegated to managers and supervisors.

Health and safety lead

The health and safety lead will:

• provide information and advice on PPE
• follow up on any reported PPE and ill health related incidents
• report on any hazards, associated with any particular PPE, coming to light during use

4.3 Managers

Managers will, if required, seek advice from a suitably competent person to ensure any requirements related to PPE are implemented and:

• conduct a workplace risk assessment to identify all workplace hazards which are of significant risk and review the possibilities of reducing the risks by means other than PPE usage
• identify the need for PPE
• research manufacturers and suppliers literature and in conjunction and co-operation with users, select suitable and appropriate equipment
• provide a suitable quantity with an appropriate stock level being maintained
• provide appropriate PPE cleaning arrangements and regimes where applicable
• provide all colleagues with instruction and training in correct usage, identification of wear and tear, and any known faults together with any maintenance that may be required
• make provision so that users have suitable storage facilities for PPE
• audit and inspect PPE on a periodic basis and record the findings
• maintain records of issue and receipt for PPE and use PPE personal equipment signature (PES) form for the colleague to sign for the receipt of any issued PPE. See appendix A
• as appropriate, ensure signage is posted in those areas where wearing of PPE is compulsory. For example, noise zones
• monitor any new PPE coming to the market, which may offer improved protection or acceptance to wear
• ensure that colleagues in areas where glove use is required are aware of and comply with the trust’s requirements for glove use through local induction, information, instruction and training, supervision and audit
• maintain adequate supplies of the type of gloves required which are appropriate to the tasks being carried out identified through risk assessment. See appendix B
• ensure colleagues are aware of the hazards of latex sensitisation based on the information contained within this policy and glove use. See section 5, PPE storage
• in clinical services, identify colleagues who may undertake aerosol generating procedures (AGPs) where a patient is known or suspected to have an infection spread via the aerosol route and ensure that they undergo face fit testing for the use of filtering face piece class 3 (FFP3) respirators. Further details about AGPs can be found in the infection prevention and control manual

4.4 Procurement and purchase ledger

The Department is responsible for putting a block on any orders for latex gloves and for notifying the relevant department of any orders which have been raised for latex gloves.

Procurement is responsible for ensuring that minimal supplies of a range of FFP3 respirators in different sizes are kept in stock within the trust.

4.5 Employees and colleagues

All trust colleagues will:

• co-operate with managers in any PPE selection process
• undertake face fit testing if their role requires the use of a FFP3 face mask
• sign for any issued PPE. See appendix A
• wear and use the PPE correctly
• carry out PPE maintenance and cleaning where necessary
• store the PPE correctly
• check all PPE for damage before use
• report any defects or wear and tear
• obtain a replacement for lost or damaged equipment
• not misuse any PPE issued to them
• inform managers if they suffer an adverse reaction or sensitivity when using PPE so that advice can be sought from occupational health and the colleague’s GP
• report any reactions and incidents related to PPE use via the trust Safeguard IR1 incident reporting system

5 Procedure and implementation

5.1 What types of PPE are available?

PPE should be regarded as a last line of defence in terms of protecting against risks to health and safety. Although a risk assessment may identify PPE as being necessary, other means of control should be given preference, and wherever possible, PPE must not be relied upon as the sole means of protection.

PPE includes the following when they are worn for the protection of health and safety.

Protective clothing, such as:

• aprons
• clothing for adverse weather conditions like coats and waterproof trousers
• gloves, see appendix B
• safety footwear for example, with protective toe caps or for electrical hazards
• safety helmets
• high visibility vests

Protective equipment, such as:

• eye protection like safety glasses or goggles
• respiratory protective equipment (RPE), ranging from dust masks to breathing apparatus
• hearing protection like ear muffs and ear plugs
• safety harnesses

There may be various types of hazards identified in the risk assessments indicating why PPE is required to be worn, such as:

• impact, fixed objects, ejection hazards, sharp objects, puncture and penetration hazards
• falls from height, falling and flying objects
• chemical, radiation and contamination hazards
• noise, vibration and electrical hazards
• visibility, extreme temperatures, weather hazards and oxygen deficient hazards

5.2 PPE selection

PPE should be used if the risk assessment identifies it as an appropriate means of controlling exposure to risks, or if local rules stipulate its use. It must be suitable for its intended use.

The assessment must take into account:

• the hazard it is intended to protect against
• the task to be undertaken. For example, whether the length of time or physical effort whilst wearing the PPE will be an issue
• fit requirements for the individual worker
• its compatibility with any other item of PPE to be worn at the same time
• whether the health of the person who will be wearing it has been taken into account. For example, asthmatics

Whether wearing PPE increases the risk or creates new risks like making communication more difficult. All PPE must conform to an approved standard. Compliance with the standard is identified in the UK by marking items with the CE kite mark, in accordance with the Personal Protective Equipment Regulations 2002. Only BS EN standard equipment that is marked in this way is approved for use by colleagues.

PPE selection checklist:

• suitable. Check BS EN standard
• fit for the purpose designed for
• effective and appropriate for the risks and conditions involved

5.3 PPE and disability

It is recognised that many deaf and hearing impaired people rely on lip reading and facial expressions for clear communication, something that is not possible when opaque face masks are being worn. Clear face masks do exist, but have previously not offered the same level of protection as type IIR fluid resistant surgical masks that were required for use during the COVID-19 pandemic in health and social care organisations.

If colleagues are required to wear masks due to national, NHS or trust guidance it may be possible to wear a clear face mask if treating a deaf patient. However, use of a clear mask must be considered on a case-by-case basis, carefully considering the risks and ensuring that the mask must provide the same level of protection as a type IIR surgical face mask. Three clear face masks equivalent to the type IIR mask are available. They are not yet on the NHS supply chain, but they are available for purchase and use by NHS trusts immediately.

When assessing whether PPE is suitable, risk assessors will need to specify on the risk assessment, what type of PPE should be worn. For example, nitrile rubber gloves BS EN 374, eye protection to EN 166 34B, not just gloves and goggles.

5.4 PPE limitations

• Effective protection is only achieved by using PPE that is suitable for the hazard which it is supposed to protect against. It must be correctly fitted, maintained and properly used.
• PPE protects only the person wearing it, whereas measures controlling the risks at source can protect everyone in the workplace.
• PPE may restrict the wearer to some extent by limiting mobility, visibility or by requiring additional weight to be carried.
• Some items of PPE have limited life-spans such as respiratory protection and hard hats and therefore these should be recorded as part of the PPE inspection. Expired PPE must be replaced. Information on life spans can be obtained from the manufacturer’s guidance which accompanies the PPE.
• Latex gloves can cause skin allergies in some users. Such gloves must not be used in the trust.

5.5 PPE storage

PPE must be stored in a location that does not put the equipment at risk of being damaged or contaminated by damp, sunlight or harmful substances such as solvents.

If PPE becomes contaminated it should be stored separately from ordinary clothing and where necessary be labelled. It should be cleaned if it can be cleaned without affecting to level of protection it offers to the user. If this is not possible it should be disposed of.

5.6 Latex allergy and dermatitis

The health and safety executive (HSE) consider that work related dermatitis is a significant cause of work related ill health, particularly in healthcare working environments. This can include irritant dermatitis due to known sensitiser hazards (substances that may cause an allergy) such as latex.

Latex is a natural product obtained from the rubber tree (hevea brasiliensis) that is used in the manufacture of many medical products commonly used in healthcare settings, including gloves. It is recognised as a sensitiser and a substance hazardous to health as defined by the Control of Substances Hazardous to Health 2002 (COSHH) Regulations.

Associated health problems include:

• type 1 latex allergy, an immediate hypersensitivity reaction characterised by rash, conjunctivitis, rhinitis, asthma and occasionally difficulty in breathing and life-threatening anaphylaxis
• type 4 latex allergy, rash often developing hours after exposure. It may be due to latex proteins or chemical residues added in latex processing. This reaction predisposes individuals to developing Type 1 allergy

As a result of knowledge and developments connected with the use of latex gloves and in consultation with the trust’s infection prevention and control team into the type and range of trust activities where glove use occurs a decision was made to cease the use of latex gloves in the trust. Purchasing and purchase ledger will therefore place a block to prevent the ordering of any supplies of latex gloves. A range of gloves made from alternative materials is available, some of which are unsuitable for use in clinical environments. See appendix B for details.

Any skin allergies to PPE resulting in dermatitis should be reported using the trust safeguard IR1 incident reporting system and reported to the health and safety executive (HSE) under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR). Occupational dermatitis is a reportable disease under RIDDOR. Colleagues reporting skin reactions should be referred to occupational health.

6 Training implications

Suitable training and information should be provided to colleagues about the correct use and storage of PPE. Records should be kept of PPE issued to colleagues including training in the correct use of the specific PPE issued. Training should be provided by line managers or supervisors (where they are competent to do so) when any new equipment is issued, except where equipment is replaced with an identical product.

7 Monitoring arrangements

7.1 PPE risk assessments

• How: During health and safety workplace inspections.
• Who by: Managers and Safety team.
• Reported to: In accordance with the inspection regime.
• Frequency: Health, safety and security forum.

7.2 Wearing and non-wearing of PPE

• How: Random checks.
• Who by: Managers.
• Reported to: Random.
• Frequency: Health, safety and security forum.

7.3 The correct use of gloves

• How: Observation and audit.
• Who by: All designated managers and Infection Prevention and Control team.
• Reported to: Trust Infection Prevention and Control team.
• Frequency: Random and as directed by the trust Infection Prevention and Control team.

7.4 Non latex glove purchasing

• How: Monitoring of orders.
• Who by: Procurement and purchase ledger.
• Reported to: All designated managers and heads of departments.
• Frequency: On receipt of latex gloves orders.

7.5 FFP3 face fit testing

• How: Monitoring test dates on ESR.
• Who by: Safety team.
• Reported to: Annually.
• Frequency:  Health, safety and security forum.

8 Equality impact assessment screening

The completed equality impact assessment (EIA) for this policy has been published.

Read the PPE policy EIA.

8.1 Privacy, dignity and respect

The NHS constitution states that all patients should feel that their privacy and dignity are respected while they are in hospital. High Quality Care for All (2008), Lord Darzi’s review of the NHS, identifies the need to organise care around the individual, “not just clinically but in terms of dignity and respect”.

As a consequence the trust is required to articulate its intent to deliver care with privacy and dignity that treats all service users with respect. Therefore, all procedural documents will be considered, if relevant, to reflect the requirement to treat everyone with privacy, dignity and respect. When appropriate this should also include how same sex accommodation is provided.

8.1.1 How this will be met

No issues have been identified in relation to this policy.

8.2 Mental Capacity Act 2005

Central to any aspect of care delivered to adults and young people aged 16 years or over will be the consideration of the individuals capacity to participate in the decision making process. Consequently, no intervention should be carried out without either the individual’s informed consent, or the powers included in a legal framework, or by order of the court.

Therefore, the trust is required to make sure that all colleagues working with individuals who use our service are familiar with the provisions within the Mental Capacity Act (2005).

For this reason all procedural documents will be considered, if relevant to reflect the provisions of the Mental Capacity Act (2005)to ensure that the rights of individual are protected and they are supported to make their own decisions where possible and that any decisions made on their behalf when they lack capacity are made in their best interests and least restrictive of their rights and freedoms.

8.2.1 How this will be met

All individuals involved in the implementation of this policy should do so in accordance with the Principles of the Mental Capacity Act (2005).

9. Links to associated documents

This policy should be read and implemented in association with the following trust policies:

• Infection prevention and control manual
• Medical devices management policy
• Incident management policy
• Requisitioning, ordering and receipt of goods procedure
• Uniform and appearance at work and dress code policy

10 References

• Control of Substances Hazardous to Health Regulations 2002 (opens in new window).
• Control of Noise at Work Regulations 2005 (opens in new window).
• The Personal Protective Equipment at Work Regulations 1992 (opens in new window).
• The Personal Protective Equipment Regulations 2002 (opens in new window).
• Personal Protective Equipment at Work (Amendment) Regulations 2022 (opens in new window).
• Confined Spaces Regulations 1997 (opens in new window).
• The Reporting of Injuries Diseases and Dangerous Occurrences Regulations 2013 (opens in new window).
• Guidance on respiratory protective equipment (RPE) fit testing (opens in new window).
• Latex allergies in health and social care (opens in new window).
• Natural rubber latex sensitisation in health and social care (opens in new window).
• National infection prevention and control manual for England (opens in new window).
• Latex Allergy, Occupational aspects of management 2008 (opens in new window).
• Guidance Note MS24, Medical aspects of occupational skin disease (opens in new window).

11 Appendices

11.1 Appendix A PPE personal equipment signature (PES) form

• Appendix A PPE personal equipment signature (PES) form

11.2 Appendix B Glove materials and selection

11.2.1  Glove materials

All examination gloves are single use only and as such must be discarded after use.

Examination gloves must not be washed between use as damage may go undetected.

Some gloves, usually used outside of clinical settings, are designed to be re-used. For example, more robust rubber gloves used for domestic or catering activities or leather or textile gloves used in maintenance or gardening activities.

Rubber gloves should be checked before use for discolouration, cracking or damage and disposed of if damaged or contaminated on the inside. These types of rubber gloves should be washed after use to remove contamination. Alcohol hand gel or rub must not be used to decontaminate rubber or gloves.

All gloves have a use by date and this must be checked prior to the use of gloves. Gloves that have gone beyond their use by date must be disposed of and not used.

The glove of first choice in the Trust will be non-latex.

11.2.1.1 Synthetic rubber

The most commonly used type is nitrile. Nitrile is the accepted material choice for gloves used in healthcare due to the strength barrier properties. A concern for many years has been the risk of impaired dexterity due to muscle fatigue where gloves are worn for a prolonged period of time, but the stretch ability of these gloves has continued to be improved by manufacturers.

Residual accelerants in nitrile or other synthetic rubbers may also cause Type IV allergic response in some wearers, although accelerator free gloves are now available. Accelerators are the chemicals used in the glove manufacturing process to help make gloves more durable and elastic. Unfortunately, chemical accelerators are also some of the most common causes of allergic reactions.

11.2.1.2 Latex

Only to be used in the trust in exceptional circumstances.

Natural rubber latex (NRL) provides excellent protection against blood borne viruses, which for many years has made it the material of choice for gloves when dealing with blood and blood stained body fluids.

The use of latex gloves in healthcare and therefore colleagues’ exposure to NRL has increased since the mid 1980’s. Although allergy to natural NRL remains rare it can produce reactions ranging from non-allergenic irritation to allergy which is a key disadvantage.

There will be areas of healthcare where it continues to be appropriate to use NRL gloves, mainly where invasive surgery takes place. In such circumstances a risk assessment would be required to indicate the choice of glove.

11.2.1.3 Vinyl

Vinyl gloves are looser fitting than either Nitrile or NRL but due to degradation with use they have a higher leakage rate and therefore a greater risk of skin contamination. It should also be noted disposal of vinyl gloves by incineration can lead to pollution through release of toxins.

11.2.1.4 Polythene

Only used in catering.

11.2.2 Glove selection

Glove selection is to be decided based on a risk assessment of the activities to be undertaken.

Five areas should be considered (HSE, 2018):

1. substances being handled
2. other hand hazards like risk of puncture wounds or cuts
3. type and duration of contact. For example: Worn for long periods or intermittently?
4. the wearer in terms of size and comfort
5. the task and how robust the glove needs to be

Manufacturers should be able to provide guidance on the best glove for use with a particular hazards.

Glove selection in general clinical settings:

• vinyl examination gloves should not be used in a clinical setting.
• non-sterile synthetic rubber. For example, nitrile gloves should be worn for procedures where there is risk of exposure to blood or body fluids
• sterile synthetic rubber. For example, nitrile gloves should be used for procedures where a sterile field and high barrier protection is required

11.3 Appendix C Filtering facepiece disposable respirators

11.3.1 Filtering facepiece (FFP) disposable respirators

FFP respirators are a form of respiratory protective equipment that provide a higher level of respiratory protection than surgical face masks. They are available in three protection levels, FFP1, FFP2 and FFP3. The higher the number, the more efficiently the mask filters particles such as dust or airborne liquid particles from the air. For this reason, FFP3 respiratory masks may be used against more harmful substances and at higher concentrations than FFP1 and FFP2 masks.

Disposable FFP3 masks are used in the trust and must be worn by colleagues carrying out aerosol generating processes (AGPs), when working with covid-positive patients or where a patient is known or suspected to have an infection spread via the aerosol route.

Examples of AGPs include tracheostomy procedures (insertion or removal) and respiratory tract suctioning. Appendices of the trust infection prevention and control manual provides more examples. Colleagues can continue to wear a higher level of PPE for CPR if they feel this is necessary, providing they have been fit tested with an FFP3 mask in the last 2 years and that the donning of the PPE does not compromise patient care.

11.3.2 Face fit testing

Each model of FFP3 respirator is slightly different in its fit and one type of mask may not fit everyone due to individual face dimensions. In order to protect the user, masks must be a tight fit around the user’s face so that contaminated air cannot enter and be breathed in, potentially causing illness or harm. A face fit test will identify whether a mask is suitable for use by a particular wearer or advise if alternative masks need to be tried. Each user must be fit tested for each type of mask used.

In order to ensure resilience should there be a shortage or discontinuation of a particular model of masks, the user must be tested so that they are able to use at least two models of mask. Fit testing should be carried out every two years or whenever there is a change in the circumstances of the wearer that could alter the fit of the mask. For example, facial changes, such as weight loss or gain, piercing, rhinoplasty, fillers (cheeks and lips) etc. Additionally, users should check that there is a good fit every time a respirator is used.

Facial hair, such as a beard or stubble does not allow a tight seal around the face so individuals must be clean shaven or alternative protection such as a hood must be used.

Fit testing must be carried out by a competent person who has been trained to carry out testing.

11.3.3 Trust arrangements and procedure

The trust uses a variety of makes of mask:

• Kolmi and Medicom, small and medium
• Drager 1730
• Handany HY9330
• GVS F31000
• Alpha Solway HX3

Minimum stocks of these are kept in stores at a number of trust sites and in grab bags that are used in an emergency. The masks are disposable and for single use.

Many colleagues underwent face fit testing for disposable FFP3 disposable masks during Covid 19. This was carried out by a national face fitting team employed by the NHS. There are also a number of suitably trained colleagues in each care group able to carry out face fit testing.

All new colleagues who may be required to carry out AGPs should be identified by their line manager and undergo face fit testing. This must be recorded on ESR and refreshed every 2 years unless there is a change in circumstances of the individual as mentioned in the previous section.

The process for donning and doffing a face mask is detailed on the following page. Masks should be put on with clean hands to avoid contamination of the mask and disposed of as clinical waste after use.

Once a mask has been put on it is important that the user carries out a pre-use check to ensure there is a good seal between the face and the mask. This should be done each time a fit-tested facepiece is worn and before entering the hazardous environment. Note, however, that a pre-use wearer-seal check is not a substitute for fit testing.

To carry out a pre-use check the user should breathe out sharply after placing their hands around the mask.

• If air is felt, then there is not an adequate seal. Tighten the headbands if there is airflow around the edges of the mask or adjust the nose piece if air is leaking here.
• If there is no leakage, then there is a good seal.
• If a seal cannot be achieved, refit the mask and repeat the process to achieve a good seal.
• If a seal cannot be obtained, then the hazardous area should not be entered as the user may be exposed to contaminated air.

Provided the seal remains intact, masks can be worn comfortably for at least two hours but are effective for longer unless compromised. For example, splashed with body fluids or damp with respiration. Ensure that respiratory masks are changed after an aerosol generating procedure or after a session.

11.4 Appendix D How to put on and fit check an FFP3 respirator poster

• Appendix D How to put on and fit check an FFP3 respirator poster