Posted By Eric Burt HSE are currently consulting on how effective the PPE Regs 92 have been in implementing the EC Directive 89/656/EEC Their questionnaire is available to download form : www.hse.gov.uk/spd.pdf/question.pdf This might be an opportunity to push for the introduction of specific Regulations (or the amendment of the existing ones) in relation to the provision of safety boots/shoes which seems to cause many H&S Practitioners problems. We have seen contributions on this forum from colleagues who seem to be at a loss as to who supplies them, who pays for them, when they should be replaced, etc etc. Any thoughts....?? Eric

Posted By Sean Fraser The discussions on this subject have often revolved around the definition of "employer" and it hasn't been restricted to PPE since provision of work equipment has had similar problems. The difficulty appears to be where there is a heavy use of contracted parties, often utilising casual labour which is either employed via an agency or taken on as self-employed personnel. I do not believe that legislation would help here - the requirements are clear. It is the interpretation of who is repsonsible that muddies the waters. Often contracts state that contractors are responsible for meeting the necessary legislative requirements but it doesn't give much in the way of detail, and the only time it is challenged is when there is a dispute or worse, an accident. Perhaps a more appropriate approach would be for contracting companies to take a closer look at their bidding requirements and guidance so that potential contractors are in no doubt as to who would be taking responsibility for what, especially the provision of PPE and work equipment and co-ordination with the contractee. As an aside, I just tried to pull up that questionnaire and it wouldn't link, nor is it in the HSE Website under "Current consultations and Discussions". I've had problems with similar links in the past - is it me? Is there a different section I should be referencing? Just my thoughts on the subject.