Employers often ask, “What exactly do we need to do to be compliant when staff wear masks or respirators at work?” In the UK, Respiratory Protective Equipment (RPE) is not just something you purchase and hand out. It is a managed control measure that must be selected correctly, fitted (where required), maintained, and supported with training and records.
This guide explains the key legal duties and the practical steps to run an effective, compliant RPE programme.
📋 Key Takeaways
- RPE is a last line of defence, it must be used alongside, or after, higher-level controls like extraction and process changes.
- A risk assessment (often under COSHH) must justify the type of RPE, including the correct protection factor and filter type.
- Tight-fitting respirators require face fit testing for each wearer, and retesting is needed when changes occur.
- Employers must provide training, maintenance, storage, and replacement, plus keep suitable records.
- Higher-risk work (for example asbestos) can require higher protection, stricter controls, and additional competence.
The main UK laws and guidance that drive RPE duties
Your responsibilities typically come from several overlapping pieces of legislation, depending on the hazard:
- Health and Safety at Work etc. Act 1974 (HSWA): the overarching duty to protect employees and others.
- Management of Health and Safety at Work Regulations 1999 (MHSWR): risk assessment, competent arrangements, training.
- Control of Substances Hazardous to Health Regulations 2002 (COSHH): the most common legal basis for RPE in workplaces with dusts, fumes, vapours, bioaerosols, and chemicals.
- Personal Protective Equipment at Work Regulations 1992 (as amended): PPE must be suitable, maintained, and provided with instruction and training.
- Control of Asbestos Regulations 2012 (CAR): specific, strict requirements for asbestos work (including RPE and face fit testing).
For practical application, HSE guidance is widely used, including HSG53 (RPE at work) and COSHH essentials. You can find these via the HSE website.
Start with the hierarchy of control, not the mask
RPE should not be the only control unless there is no reasonably practicable alternative. Employers should consider, in order:
- Elimination (stop the task or substance)
- Substitution (use a safer product or process)
- Engineering controls (LEV, enclosures, automation)
- Administrative controls (reduced exposure time, segregation)
- RPE (and other PPE)
If you rely on RPE because extraction is “not working well”, that is usually a sign the engineering control needs attention. HSE typically expects engineering controls to be optimised first, then RPE used as additional protection where needed.
Employer duties, step by step
Benefits (of a structured RPE programme)
- Clear compliance route under COSHH and PPE regulations
- Better real-world protection, fewer exposure incidents
- Consistent selection across teams and sites
- Reduced downtime from incorrect kit, poor fit, or missing parts
1) Assess the respiratory hazard (risk assessment)
Your assessment should identify:
- What is in the air: dust, fibres, welding fume, solvent vapour, spray mist, biological agents.
- How much exposure is likely: concentration, task duration, frequency.
- Who is exposed: employees, contractors, visitors, public.
- Work conditions: heat, humidity, facial hair policies, other PPE conflicts (eye protection, welding helmets, hearing protection).
- Workplace Exposure Limits (WELs) where applicable.
Under COSHH, you must prevent or adequately control exposure. If RPE is part of the control strategy, you need to specify it properly and manage it.
2) Select suitable RPE (type, class, and filter)
RPE selection should match the hazard and the workplace conditions. Key decisions include:
- Disposable filtering facepiece (FFP): typically for particulates (dusts, mists, fumes).
- Reusable half mask / full face mask: can take particulate filters and gas/vapour filters.
- Powered air (PAPR): can reduce breathing resistance, improve comfort, and support longer wear times, often used in welding, grinding, and higher-dust environments.
- Supplied air systems: for oxygen-deficient atmospheres or very high-risk contaminants where filters may not be suitable.
📊 Mask Comparison
| Feature | FFP2 | FFP3 |
|---|---|---|
| Typical use | Nuisance to moderate dusts and aerosols (task dependent) | Higher hazard dusts, fumes, and fine particulates (task dependent) |
| Minimum filtration (EN 149) | 94% | 99% |
| Maximum total inward leakage (EN 149) | 8% | 2% |
| Common workplace examples | Some construction dust tasks, general particulate control | Silica-related tasks, welding fume support, higher dust loads |
RPE selection must consider Assigned Protection Factor (APF) and filter type (P, A, B, E, K, combination). A high filtration particulate mask does not protect against solvent vapours, and the wrong choice can create a false sense of safety. For complex mixed hazards, get competent advice.
3) Ensure correct fit, face fit testing (tight-fitting RPE)
If you use tight-fitting RPE (most disposable FFP masks, half masks, full-face masks), employers must ensure it fits the individual wearer correctly.
This normally means:
- Face fit testing for each wearer on the make, model, and size they will use.
- Retesting when there are changes that could affect fit, such as:
- weight change
- dental work or facial surgery
- new eyewear that interferes with the seal
- switching to a different mask model or size
Common fit testing methods include qualitative (taste-based) and quantitative testing.
A “fit check” (user seal check) is good practice each time a mask is worn, but it is not a substitute for formal face fit testing.
4) Provide information, instruction, and training
You must train employees on:
- why RPE is needed and what it protects against
- how to wear it correctly, donning and doffing
- limitations (for example, breakthrough for gas filters, filter loading for particulates)
- how to do a user seal check (where applicable)
- cleaning and storage requirements
- what to do if they feel unwell, smell vapours, or notice damage
Training should be refreshed periodically and when changes occur.
5) Maintenance, examination, and replacement
Employers must ensure RPE remains effective:
- disposable masks must be replaced at suitable intervals, and not reused beyond intended use
- reusable masks need cleaning, disinfection where appropriate, and periodic checks
- filters must be replaced according to:
- manufacturer guidance
- usage time and contaminant load
- hygiene requirements
- damage or breathing resistance (particulate filters)
You should also plan for:
- spare parts availability
- recordkeeping of inspections for reusable RPE
- hygienic issue and shared equipment controls (if sharing cannot be avoided)
6) Storage and issue control
RPE must be stored:
- clean and dry
- protected from dust, sunlight, chemicals, and physical damage
- so that the face seal is not distorted
This is especially important for reusable facepieces and powered systems.
7) Health surveillance (when needed)
Under COSHH, health surveillance may be required where:
- there is a reasonable likelihood of identifiable disease or adverse health effect
- exposure control relies on RPE
- the disease is linked to the work and can be detected early
This can apply to sensitising agents, certain dust exposures, and other regulated hazards.
8) Keep records and demonstrate control
Good records help prove you are managing RPE properly:
- RPE risk assessments and rationale for selection
- face fit test records
- training records
- maintenance and inspection logs (especially for reusable and powered systems)
- filter change schedules or triggers
Special case: Asbestos and other high-risk work
Asbestos work is tightly regulated under the Control of Asbestos Regulations 2012. RPE is only one part of the required controls and must be selected and managed by competent persons, alongside the correct methods, licensing (where required), decontamination, and air monitoring. If asbestos is suspected, stop and seek competent support.
Practical employer checklist (quick audit)
Use this as a simple internal check:
- ✅ We have a COSHH (or equivalent) risk assessment identifying airborne hazards
- ✅ RPE is specified by type, class, and filter, not “any FFP3”
- ✅ Tight-fitting RPE users have current face fit tests for the exact mask model
- ✅ Staff are trained and supervised, and know the limitations
- ✅ We have storage, cleaning, inspection, and replacement arrangements
- ✅ We keep records and review after changes, incidents, or complaints
Recommended products from The Face Mask Store UK
Below are practical items that support compliance and day-to-day control, especially around fit testing and higher-grade RPE selection.
Alpha Solway Face Fit Test Bitter QLTK1
A qualitative (bitter) face fit testing kit to support employer duties for tight-fitting respirators, helping you verify a proper seal for each wearer.
Trident FFP3 Valved Disposable Face Mask
A straightforward FFP3 disposable option for higher-level particulate protection needs (task and risk assessment dependent), useful for employers standardising a single-use RPE option.
3M Versaflo M-407 Respiratory Helmet with TR-619UK Powered Air Turbo PAPR Kit
A powered air respirator kit that can improve comfort for longer wear and reduce breathing resistance. Often considered where disposable RPE is poorly tolerated, or where a higher level of managed respiratory protection is needed (subject to assessment).
