Why PPE Should Be the Last Line of Defence, Not the Entire Safety Program

Why PPE Is Considered the Last Line of Defence

The hierarchy of controls is a recognized approach to selecting workplace hazard controls. It generally begins with elimination and substitution, followed by engineering controls, administrative controls, and PPE. CCOHS describes PPE as the least effective level because it controls exposure at the worker level rather than removing the hazard itself. (CCOHS)

PPE can be necessary and may also be specifically required by legislation. The problem begins when an employer treats PPE as the entire control strategy.

Consider a worker using a grinder. Safety glasses and a face shield may protect against flying particles, but they do not address whether the grinder is properly guarded, maintained, positioned, or suitable for the work. PPE matters, but it should sit within a larger control system.

Why PPE Alone Can Create a False Sense of Control

PPE depends heavily on human behaviour. The correct equipment must be selected, fitted, worn properly, inspected, maintained, stored, replaced when necessary, and used every time exposure occurs. If any part of that chain fails, protection may be reduced.

A worker may technically have PPE available while still being exposed because it does not fit, is damaged, is incompatible with other equipment, or is used incorrectly.

A related management problem appears when hazard assessments repeatedly say “wear gloves,” “wear safety glasses,” or “wear a hard hat” without considering higher-level controls. That may show that the hazard has been identified, but not that the risk has been fully evaluated.

Legislation and Provincial Differences

Canadian OH&S legislation is jurisdiction-specific, so employers should not assume that Alberta, British Columbia, and Saskatchewan use identical wording or requirements.

In Alberta, the OHS Code establishes a hazard-control sequence that requires employers to consider elimination and higher-order controls before relying on appropriate PPE where the hazard cannot otherwise be eliminated or controlled. (Search OHS Laws)

In British Columbia, WorkSafeBC directs employers to follow the hierarchy of controls, beginning with elimination or substitution and moving through engineering and administrative controls before PPE. WorkSafeBC also emphasizes documenting risk assessments and controls as part of demonstrating due diligence. (WorkSafeBC)

Saskatchewan’s Occupational Health and Safety Regulations, 2020 address PPE within a broader expectation that employers and contractors use design, work processes, suitable work practices, or administrative controls where reasonably practicable before relying on suitable PPE. (Publications Centre)

These are provincial legal frameworks, not interchangeable checklists. Requirements can also vary with the hazard, industry, equipment, work activity, workforce, and applicable standards.

Due Diligence Requires More Than Issuing PPE

Due diligence is better supported when an employer can show how hazards were identified, how risk was evaluated, why controls were selected, and whether those controls are working.

A purchase record showing that workers received safety glasses says little about whether the underlying hazard was adequately controlled. Stronger evidence may include current hazard assessments, inspections, maintenance records, safe work procedures, training, fit testing where applicable, corrective actions, supervisor observations, and records showing that controls were reviewed after changes or incidents.

A written safety manual may describe the hierarchy of controls perfectly, but if supervisors routinely tell workers to “just wear your PPE” around an uncontrolled hazard, the written program and field practice are not aligned. A customized workplace safety manual should reflect how controls are actually selected, implemented, and verified in your operations.

Common PPE-First Gaps in Real Workplaces

One common gap is treating mandatory site PPE as proof that hazards are controlled. Hard hats, safety glasses, high-visibility clothing, gloves, and safety footwear may be reasonable baseline requirements, but they do not replace task-specific controls.

Another gap appears when PPE is selected before the hazard assessment is complete. Providing hearing protection without assessing the noise source, for example, may overlook opportunities to isolate equipment, maintain worn components, install barriers, or change the process.

A third weakness is using “remind workers to wear PPE” as the main corrective action after an incident instead of asking why the hazard reached the worker in the first place.

What Employers Should Do Instead

Start with the hazard assessment. Identify the hazard, assess the level of risk, review the hierarchy of controls, select the strongest reasonably practicable controls, and then determine what residual risk remains. Well-documented workplace hazard assessments and control selection make it easier to show why PPE was chosen and what it is meant to protect against.

Supervisors should verify that controls actually exist in the field. Workers should understand the hazard and the purpose and limitations of the PPE they use. Practical workplace safety training and supervisor development helps both groups recognize when a stronger control is needed. Inspections should look beyond whether PPE is being worn and examine whether guards, barriers, ventilation, traffic separation, housekeeping, procedures, maintenance, and other controls remain effective.

Where PPE is required, employers should address selection, compatibility, fit, inspection, care, replacement, PPE training, and supervision. CCOHS notes that PPE does not remove the hazard and must be properly fitted, maintained, stored, and supported by worker education and training. (CCOHS)

COR, SECOR, and Best-Practice Considerations

COR and SECOR are not substitutes for legislation, and audit expectations can vary by certifying partner, jurisdiction, and audit instrument. However, a functioning safety-management system should show a logical connection between hazard identification, risk assessment, selected controls, training, inspections, supervision, and corrective action.

Industry best practice supports using the hierarchy of controls rather than defaulting to PPE. This also supports audit readiness because the employer can explain why controls were selected and how their effectiveness is monitored. Employers preparing for an audit can review our COR and SECOR safety program support.

Recommended safety-management practice also checks whether workers and supervisors understand the control strategy and apply it in the field.

Why This Matters for Your Business

Overreliance on PPE can increase workplace risk because the hazard remains present and protection depends on consistent human performance. If PPE fails, does not fit, or is not worn correctly, the worker may have little protection left.

For the business, that can affect regulatory exposure, incident frequency or severity, WCB or claims performance, productivity, operational interruptions, and corrective-action costs. Control quality can also influence contractor prequalification, client expectations, COR or SECOR performance, audit readiness, and the employer’s ability to demonstrate due diligence. Employers responding to inspection findings or orders may also benefit from OH&S regulatory and compliance support.

Final Thoughts

A strong safety program does not ask only whether workers are wearing PPE. It asks whether the hazard still needs to be there, whether exposure can be reduced, whether higher-level controls are working, and whether the remaining PPE requirements are appropriate.

Review your current hazard assessments and field practices with that question in mind. If PPE has become the default response to most hazards, identify where stronger controls may be reasonably practicable and update the supporting documentation, training, and supervision. Where professional support is required, Calgary Safety Consultants can help employers evaluate gaps and build a more practical, defensible safety-management approach.

About the author

John Duplessis, B.Sc., CRSP

President and Principal Health & Safety Consultant

John Duplessis is a Canadian Registered Safety Professional with more than 30 years of occupational health and safety experience in oil and gas, construction, green energy, midstream operations, and industrial project work.

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