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The scope of the UK's PPE requirements was extended in 2022, to include not just employees but "limb (b)" workers, such as casual staff, contractors and gig workers who perform work personally.
In 2026, are your PPE arrangements still reflecting that extended scope, and still aligned with current HSE guidance?
The Scope Extension: Who are limb (b) workers?
The Personal Protective Equipment at Work (Amendment) Regulations 2022 (PPER) extended existing PPE duties beyond traditional employees, with the changes coming into force on 6 April 2022.
A limb (b) worker is someone who performs work personally for an organisation but isn't working under a traditional employment contract. In practice, this covers:
- Casual staff.
- Contractors.
- Gig economy workers.
- Agency (and other flexible workers who fall within this definition).
Since 2022, these workers have had the same legal right as traditional employees to free, suitable protective equipment. That means employers can't treat PPE as something reserved for permanent staff on the payroll.
If a limb (b) worker is carrying out work personally for your organisation and faces a risk that PPE would control, the duty to provide, maintain and support the use of that PPE applies to them too.
This is not a new 2026 regulation. Rather, 2026 is a useful opportunity to check that this extended scope has been properly embedded in your organisation's PPE arrangements, and that those arrangements remain aligned with HSE's current guidance, updated in 2026.
So, the question for 2026 is simple:
Does your PPE provision reflect the full scope of workers it's legally required to cover?
Why the Extended Scope Still Catches Organisations Out
The duties themselves weren't rewritten in 2022; their scope was extended. That distinction matters, because it's easy for an organisation's PPE processes, built around a traditional employee headcount, to simply not "see" the wider workforce.
Common gaps include:
- PPE policies that reference "employees" without accounting for limb (b) workers
- Risk assessments that don't extend to contractors or gig workers doing the same tasks as employees
- Onboarding processes for casual or agency staff that skip PPE issue and training
- Unclear responsibility between your organisation and labour providers or agencies over who supplies and maintains PPE
For organisations using agency workers, contractors or other flexible labour, PPE arrangements need to explicitly account for this wider workforce, not assume it's covered by default.
Your 2026 Compliance Check
If your organisation implemented changes in 2022, 2026 is a good time to check those arrangements are still working in practice. Ask:
- Are all relevant limb (b) workers correctly identified?
- Do risk assessments cover the work they undertake, not just work done by employees?
- Do PPE procedures explicitly apply to limb (b) workers?
- Is suitable PPE provided to them free of charge, exactly as it would be for an employee?
- Are they receiving appropriate information, instruction and training on that PPE?
- Are responsibilities between your organisation and any labour providers clear?
- Can you demonstrate that PPE issued to limb (b) workers is being properly maintained and replaced?
The important point is that the 2022 extension should now be embedded in normal PPE management, not treated as a new 2026 requirement or an afterthought for non-employee workers.
What Does HSE's 2026 Guidance Mean for You?
While the legislative extension took effect in 2022, HSE's current guidance remains central to reviewing your arrangements in 2026. The fundamentals haven't changed: PPE should be selected according to the risks identified, be suitable for the wearer and task, fit correctly, work effectively alongside other PPE, and be properly maintained, and this applies equally whether the wearer is an employee or a limb (b) worker.
For HSE managers, 2026 is an opportunity to review whether policies, risk assessments and working practices explicitly reflect the extended scope.
For buyers, it's an opportunity to review whether procurement processes account for the full range of people who need PPE, including those outside the traditional employee headcount.
A Practical PPE Health Check
Rather than asking whether your organisation has implemented a new set of 2026 PPE rules, ask whether your existing arrangements reflect the full, extended scope of who's covered.
Review your workforce. Have you correctly identified everyone covered by your PPE arrangements, including limb (b) workers such as casual staff, contractors and gig workers?
Review your risk assessments. Do current assessments accurately reflect the hazards, tasks and working environments for the full workforce, not just direct employees?
Review your PPE specifications. Are products still suitable for the risks and the people who use them, whatever their employment status?
Review product compliance. Can you obtain the relevant conformity assessment information and product documentation?
Review compatibility. Where several items are worn together, have you checked they work effectively as a complete PPE system?
Review training and use. Do limb (b) workers understand when PPE is required, how to use it correctly, and its limitations, just as employees do?
Review maintenance. Are inspection, cleaning, storage, maintenance and replacement arrangements effective for PPE issued to everyone in scope?
Review your supply chain. Are responsibilities clear between your organisation, PPE suppliers, manufacturers, importers and labour providers where limb (b) workers are engaged through agencies?
The 2026 Takeaway
There's an important distinction to make:
- 2022 was when PPE duties were extended in scope, giving limb (b) workers the same legal right to free, suitable protective equipment as employees.
- 2026 is the opportunity to check that extended scope is embedded, understood and being applied, and that your organisation remains aligned with current HSE guidance.
For HSE managers, that means reviewing policies, risk assessments, training and workforce coverage with the full, extended scope in mind. For PPE buyers, it means checking that procurement decisions support suitable, compliant and effective PPE for every worker who's legally entitled to it, not just those on the traditional payroll.
The question isn't "What's the new PPE law for 2026?"
It's "Does our PPE provision reflect everyone the law requires us to cover?"
That's the more useful question for any organisation reviewing its PPE arrangements in 2026.
Sources and Further Guidance
