We are metal fabricators and our staff work both in our workshop and onsite (mine and other sites). Are we required to provide all clothing, including work boots, in respect of PPE?
As an employer, you will have an obligation to provide personal protective equipment (PPE) to your workers where it is required to effectively reduce the risk of injury or harm in the workplace. This obligation extends to providing appropriate PPE to workers at the workshop, onsite, at the mine or at other sites which are not your own work premises.
Given that you operate a metal fabrication business involving elements of hazardous manual labour (including welding and grid blasting), certain kinds of PPE, including work boots, is likely to be required. However, PPE will generally not extend to all clothing, but instead relates primarily to safety helmets, eye protection, gloves and clothing specifically designed to protect against heat and/or toxic chemicals.
To determine what PPE to provide at each site, you will first need to identify the risks, including by way of a risk assessment. In Western Australia, Regulation 3.32 of the Occupational Safety and Health Regulations 1996 (the Regulations) provides that an employer must first consider whether the identifiable risks in the workplace may be eliminated by means other than the provision of PPE. If the risks cannot be practicably reduced through other means, appropriate PPE that would reduce the identified risks will need to be provided in accordance with Australian Safety Standards (the titles of which are included at Regulation 3.33).
It is important to remember that the use of PPE should always complement, and not replace, other risk control measures. For completeness, you will also need to ensure that the award or agreement that binds you and your workers does not make express provision for PPE. If it does, you will need to ensure that you comply with those requirements in addition to your statutory obligations.