PPE Is Not a Safety System

The Hierarchy of Controls Explained

Here’s how a competent safety system should be designed—from most effective to least:

1. Elimination

Remove the hazard completely from the site or process.

This is the most effective control measure—removing the need for the hazardous task entirely.

Example: Instead of requiring workers to manually cut bricks on scaffolding at height (which poses risks of falling, dust inhalation, and hand injuries), all bricks are measured, marked, and cut at ground level in a designated cutting zone before being lifted to the working platform. This eliminates multiple hazards by changing how and where the task is performed.

2. Substitution

Replace a hazardous task, substance, or tool with something less dangerous.

This control involves changing out materials, equipment, or methods for safer options—without compromising the task.

Example: Instead of using angle grinders to cut rebar on site (which creates sparks, noise, and flying debris), substitute with pre-cut, pre-bent rebar delivered directly from the supplier. This reduces the need for high-risk hot work and manual cutting on site.

3. Engineering Controls

Redesign the work environment or process to separate people from hazards.

This control focuses on physically altering the environment to remove or reduce exposure to the hazard—without relying on human behaviour.

Example: Instead of relying on workers to wear harnesses near open edges, install temporary edge protection or fixed guardrails around the perimeter of slabs and elevated work areas. This provides a passive safety solution that prevents falls, regardless of worker actions.

4. Administrative Controls

Implement procedures or work practices to reduce exposure to hazards.

This control focuses on managing how tasks are performed through planning, training, and supervision.

Example: Establishing a permit-to-work system for high-risk activities like hot work or confined space entry. This ensures that only trained, competent workers perform the task, under controlled conditions, with proper pre-task checks, supervision, and emergency procedures in place.

5. PPE (Personal Protective Equipment)

Use protective gear as the last line of defence—only when more effective controls cannot fully eliminate the risk.

PPE does not remove the hazard; it merely reduces the impact on the individual. It should always be used in conjunction with other controls, not as a standalone solution.

Example: When jackhammering concrete on-site, even after implementing noise-reducing attachments and rotating shifts (administrative controls), workers must still wear hearing protection, safety goggles, and v gloves to protect themselves from residual risks.

PPE: The Last Resort, Not the First Response

Let’s be clear, PPE is important. But it's only effective if all other control measures have been exhausted and a task still poses residual risk. PPE does not eliminate the hazard; it only protects the worker temporarily. And even then, its effectiveness depends on proper selection, maintenance, use, and training.

Issuing PPE without documented risk assessments, training, and system-level planning is not compliance. It’s negligence.

Legal Requirements You Cannot Ignore

Several legal provisions make it clear that PPE is only one element in a broader safety system:

• OHS Act Section 8(2)(b): Requires employers to eliminate or mitigate hazards through control measures before resorting to PPE.

“taking such steps as may be reasonably practicable to eliminate or mitigate any hazard or potential hazard to the safety or health of employees, before resorting to personal protective equipment;”

This clause directly reinforces the legal obligation to implement higher-order control measures before issuing PPE. PPE is not a standalone solution but a last resort when elimination, substitution, and engineering or administrative controls are not reasonably practicable.

• Construction Regulation 9: Requires the employer or contractor to conduct hazard identification and develop risk-based procedures—before PPE is considered.

(a) “A contractor must… cause a hazard identification to be performed by a competent person… before the commencement of any work…”

(c) “A contractor must… develop a documented risk assessment and safe work procedures to mitigate, reduce or control the risks identified.”

These provisions place a legal obligation on contractors to take proactive steps, before work begins, to identify hazards and implement documented, risk-based controls.

Importantly, subregulation (c) clarifies that safe work procedures must be designed to control or reduce risk, not simply default to issuing PPE. Personal protective equipment should only be considered after all reasonably practicable controls (such as elimination, substitution, engineering, and administrative controls) have been applied and are proven to be insufficient.

In essence, CR 9(1)(a) and (c) confirm that PPE is not a substitute for proper planning, risk assessments, or procedural controls. It is the final layer, not the foundation, of your safety system.

• General Safety Regulation 2: Requires written safe work procedures and risk-based control, of which PPE is the final step.

GSR 2(1) – “Every employer shall provide and maintain, as far as is reasonably practicable, a working environment that is safe and without risk to the health of his employees.”

GSR 2(2) – “An employer shall ensure that the precautionary measures required for the protection of the health and safety of persons… are adhered to by every person to whom they apply and that no person intentionally or recklessly interferes with or misuses anything provided in the interest of health or safety.”

While GSR 2 doesn’t explicitly list PPE, it emphasizes the employer’s duty to implement precautionary measures, which by legal interpretation and practice must follow the hierarchy of controls. This means employers must apply elimination, substitution, engineering, and administrative controls first, as far as reasonably practicable, before issuing PPE.

Further, the requirement to ensure that “precautionary measures are adhered to” places responsibility on employers to develop documented, enforceable safe work procedures that prioritise more effective risk controls than PPE alone.

This regulation reinforces that PPE is not the safety system—it’s one small part of it, and only acceptable after stronger, systemic controls have been evaluated and implemented.

If you can’t show how you’ve moved through the full hierarchy of controls and documented it in your safety file, you're not legally compliant.

What a Properly Structured Safety System Looks Like

At Zenith Safety Consultants, we don’t stop at issuing PPE. We:

• Conduct comprehensive, site-specific hazard identification and risk assessments
• Develop documented safe work procedures aligned with Construction Regulation 9
• Apply the hierarchy of controls in all health and safety planning
• Ensure PPE is issued when residual risk remains, never as a shortcut
• Train workers on correct PPE use, care, limitations, and legal responsibilities
• Monitor, audit, and continuously improve your site safety systems

The Bottom Line

PPE is important, but it’s not a substitute for a safety system. If your health and safety program begins and ends with issuing gloves and hard hats, you're exposed. Not only to physical risk, but also to non-compliance penalties, reputational damage, and potential prosecution under the OHS Act.

Don’t gamble with safety. Let ZSC help you build a system that protects your people before the gloves go on.

For more information on how Zenith Safety Consultants can help your business, please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it. or call 021 010 0209.