We do not assess the PPE as an individual document.

Like yourself we assess the hazard identify and implement controls.

When we have no options left except the PPE then we consider what is required and document that as an additional control e.g. when deciding upon hearing protection we list the required SNR rather than just blanket stating Hearing Protection.

This is possibly where your client is coming from avoiding the template Risk Assessment - Hi-Vis (what class?), Safety Footwear (impact, puncture, chemical, mid-sole?), RPE (filter type?). Gloves (resistance to, penetration time?)

There is a legal requirement to carry out an assessment relating to PPE.  It's in the PPE Regs if I remember correctly.  As you correctly identify, this is not a risk assessment of PPE (although PPE does in fact carry risks in itself, for example hearing protection might prevent alarms from being heard).  It is an assessment of what PPE is needed and the suitability of PPE.  So I would rebrand it a "PPE assessment".  Of course it might already be fully covered in the activity risk assessments, but then again, it might not be.

Hi Waz

This is one of those cases where the general rule that "What the Client wants, the Client gets" needs to be diplomatically dealt with!

"A client is asking for a PPE Risk Assessment under R6 of the PPE Regs 1992.  I have stated that we don't risk assess control measures, but what we do do is assess the risks against the activities undertaken.  Then, under the hierarchy of control, if we cant fully mitigate the risk, then we will adopt further controls in forms of PPE, which is specified e.g. Safety Glasses EN166 Class 1, or EN388 Gloves Cut Resistance 5 / C.

Subsequently, an activity risk assessment identifies the risk, the relevant control measure (when PPE) and the standard required.  This is formal enough."

There are two parts to what you wrote:

1. The first sentence.

2. Your response.

What you haven't told us is how the Client has responded (if they have) to your response.

Nor who it is in the Client's organisation who has asked the Q and who may or may not have answered your response.

So, it might be a case of getting others in the Client organisation involved (IFF the Client doesn't accept your logical position).

Otherwise you end up adding a caveat to your risk assessment documentation to explain that your risk assessment deals with a multitude of different legislation all of which says "Thou shall do an assessment".

...and this is just unhelpful bureaucracy that adds no value for anyone INCLUDING your Client.

Adding that caveat takes time and next time you do a job for this client you put up the price!