The PPE list is one of the few occupational health and safety documents that the law explicitly requires from every employer — and yet in most companies it comes together backwards. A supplier’s sales rep sends over a catalogue, the company orders gloves, vests, and a few pairs of boots, and the “list” gets written up after the fact to match the invoice. But the Labour Code calls for a company’s own list, drawn up from a risk assessment and the actual conditions of the work. The gap shows up on the inspector’s first question: why these items, and why for this particular role?
We’ll go through exactly what Section 104 of the Labour Code requires, how to build a PPE list by role and activity, what belongs in the policy, and how to keep issuance records that still hold up as evidence years later.
What Section 104 of the Labour Code Actually Requires
Personal protective equipment isn’t the first layer of protection — it’s the last. Under Section 104(1) of the Labour Code (Act No. 262/2006 Coll.), an employer must provide it only when risks can’t be eliminated or sufficiently reduced through collective protection measures or work organisation. That order has a practical consequence: a missing guardrail on a loading ramp doesn’t get solved by issuing every warehouse worker a harness — it gets solved with a guardrail. PPE only comes into play once technical and organisational measures aren’t enough.
Section 104 itself then sets out four obligations that form the backbone of the whole agenda:
- provide PPE free of charge, based on the employer’s own list drawn up from a risk assessment and the actual conditions of the work,
- not substitute a cash payment for providing PPE — a flat “boot allowance” added to payroll doesn’t satisfy the obligation,
- keep the equipment in usable condition and check that it’s actually being used,
- provide washing, cleaning, and disinfecting agents in proportion to how dirty skin and clothing get, and, where the conditions apply, protective drinks as well.
The equipment itself must protect the employee against the relevant risks, must not endanger their health, and must not get in the way of doing the job. In environments where clothing or footwear wears out or gets dirty at an unusual rate, or where it serves a protective function, work clothing or footwear counts as PPE too — typical examples are coveralls in a paint shop or insulated clothing in a chilled warehouse.
The detailed conditions for providing PPE are set out in an implementing government regulation; general requirements for workplaces and work organisation are added by Act No. 309/2006 Coll., as amended by Act No. 318/2025 Coll., effective from 1 November 2025. The other side of the relationship is covered by Section 106 of the Labour Code: employees are required to use the equipment they’re issued. But checking that it’s actually used stays the employer’s job — and that’s exactly the record that’s most often missing from the binder.
Why a List Copied from a Supplier’s Catalogue Won’t Hold Up
A supplier’s catalogue answers the question of what’s in stock. A PPE list is supposed to answer the question of what actually threatens the people in your company. Every item on the list should trace back to an identifiable risk that justifies issuing it — and every risk that couldn’t be resolved some other way should have a matching item on the list.
We covered how to base a risk assessment on real activities in detail in our article on workplace OHS risk assessment. The PPE list is its direct continuation: whatever’s left over after technical and organisational measures ends up as a line item on the list.
A mismatch shows up in both directions. A list that assigns safety goggles to a role that never grinds anything or handles chemicals points straight to a copied template. And the reverse: a maintenance worker who actually cuts with an angle grinder but whose list entry shows only gloves is an uncovered gap — and after an accident, that’s exactly what gets examined: what should have been assigned for that specific activity.
How to Build Your Own PPE List, Step by Step
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Start from activities, not job titles. One position usually covers several activities with different risks — a warehouse worker receiving goods faces different risks than the same worker restocking shelves in an aisle where forklifts operate. The starting point is the risk assessment and a walk-through of the operation.
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Match each remaining risk to a type of protection. Head, eye, hearing, respiratory, hand, foot, body protection, fall protection. At this stage you’re not choosing brands yet — just working out what needs protecting.
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Specify the equipment’s parameters, not a catalogue number. “Safety footwear with a protective toe cap,” “gloves resistant to the specific substance in use, per its safety data sheet,” “hearing protection rated for the workplace’s noise level.” The specific model can then change without having to rewrite the list.
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Set replacement intervals and checks. Service life depends on wear and the manufacturer’s data; for equipment with a limited lifespan — helmets, filters, fall-protection gear — track those deadlines separately.
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Discuss the draft with the people who actually wear the equipment. Gear that can’t be worn through a full shift ends up in the locker room, protecting no one. Feedback from the floor is cheaper than findings after an accident.
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Approve, date, and update the list whenever activities, technology, or chemicals change — just like the risk assessment it’s based on.
The result might look something like this:
| Role / activity | Assessed risk | Assigned PPE | Replacement |
|---|---|---|---|
| Warehouse worker — handling goods, moving through forklift aisles | load falling on foot, collision with forklift | safety footwear with toe cap, hi-vis vest | per wear; vest when visibility fades |
| Maintenance worker — grinding, drilling | flying particles, noise | safety goggles, ear-muff hearing protectors | goggles when scratched; protectors per manufacturer |
| Cleaning — diluting cleaning agents | chemical burns, skin irritation | gloves per safety data sheet, eye protection while diluting | gloves on an ongoing basis, per type |
| Office staff — occasional access to the warehouse | collision with forklift | hi-vis vest at the entrance | when damaged |
This table illustrates the logic — it’s not a template to copy. The specific parameters come from the risk assessment, manufacturers’ instructions, and, for chemicals, the safety data sheet for each product.
What Belongs in a PPE Policy
The list says who gets what. The policy says how the whole system works. In practice, it’s worth covering:
- who draws up and approves the list, and when it gets reviewed,
- how initial issuance works and how damaged or worn equipment gets replaced,
- rules for maintenance, cleaning, and storage — including who’s responsible for laundering protective clothing,
- the procedure for lost or deliberately damaged equipment,
- who checks that equipment is being used and how, and what happens when an employee doesn’t use it,
- the provision of washing, cleaning, and disinfecting agents, and protective drinks where applicable,
- the link to training: employees need to know what the equipment protects them against, how to use it, and when it gets replaced — which is why PPE also feeds into the content of occupational health and safety training for employees.
Keep the scope proportionate to the operation: a company with a few dozen employees usually needs no more than a few pages plus the list as an appendix. The PPE policy is one piece of the broader documentation package — our overview of OHS documentation for a small company shows where it fits alongside the risk assessment, job categorisation, and training records.
Issuance Records: A PPE Card That Actually Proves Something
The third document is the simplest one — and the one most often missing. The record sheet, or PPE card, documents that a specific person actually received a specific item of equipment.
| Field on the card | What it’s for |
|---|---|
| Name and job role | links to the corresponding line on the PPE list |
| Assigned equipment (type, spec) | exactly what was issued |
| Date of issue and employee’s signature | proof of receipt |
| Expected replacement date | tracking service life |
| Date of replacement or return | a history, not just the latest status |
| Notes | damage, loss, reason for an out-of-cycle replacement |
The format doesn’t matter much — a paper card in a personnel file works just as well as a shared spreadsheet. What matters is that the record gets created at the moment of issue, not written up retroactively the night before an inspection. Without signatures, there’s no way after the fact to tell what was actually issued, what’s still sitting in storage, and what people bought for themselves.
Common Mistakes That Show Up First During an Inspection
- a cash allowance instead of actual equipment — the Labour Code explicitly does not allow substituting a cash payment,
- one “universal” type of glove used for both mechanical work and chemicals,
- a list copied from another company, with no link to the company’s own risk assessment,
- no replacement cycle — footwear gets worn “until it falls apart,”
- issuance with no signature and no date,
- no record of checking that equipment is actually used,
- equipment that can’t be combined — hearing protectors that don’t fit with the helmet,
- forgotten PPE for temporary workers, visitors, and contractors entering the operation.
What the Labour Inspectorate Actually Checks
An inspection typically walks the whole chain: risk assessment → PPE list → issuance card → actual conditions on the shop floor. A mismatch between any two of these shows up during a single walk-through — the list promises safety footwear, but people in the hall are wearing sneakers; the card claims respirators were issued, but nobody knows where they are. We describe what a labour inspection actually checks and how it unfolds in our article on labour inspectorate checks.
But the toughest test doesn’t come during an inspection — it comes after an accident. The first questions target what equipment was designated for the activity in question, whether it was actually issued, and whether its use was checked — and the answers get traced back to exactly the list, the cards, and the records. We’ve covered what the first steps after a workplace accident look like separately; the PPE records are one of the pieces of documentation used as evidence for the incident.
Who Can Draw Up Your List and Policy
A company with a single type of operation and a properly done risk assessment can put together its own PPE list in-house, following the steps above. For operations spanning multiple roles, chemical products, or machinery, it’s worth bringing in a qualified risk-prevention specialist — the links between safety data sheets, manufacturers’ instructions, and equipment specs are exactly where templates fall apart. But bringing in a specialist doesn’t transfer responsibility: the employer remains responsible for health and safety at work, and OHS stays part of the job duties of managers and supervisors.
If you’d rather have it handled in one go, send us a no-obligation inquiry: we’ll walk through your operation, connect the PPE list to your risk assessment, and prepare both the policy and the record cards so the documents line up with each other — standalone, or as part of your overall OHS documentation.
Sources
- Workplace OHS Risk Assessment – the risk assessment process that the PPE list directly builds on.
- OHS Documentation for a Small Company – where the PPE policy fits within the overall documentation package.
- Labour Inspectorate Checks – what an inspector reviews and what documentation to have ready.
- Act No. 262/2006 Coll. – the Labour Code; Section 104 governs the provision of PPE and washing, cleaning, and disinfecting agents and protective drinks, Section 106 covers employee obligations.
- Act No. 309/2006 Coll. – further occupational health and safety requirements; workplace requirements and professional competence in risk prevention. Used as amended by Act No. 318/2025 Coll. (effective from 1 November 2025), which, among other things, revised the professional competence requirements for risk prevention.
The legal status was verified as of 30 July 2026. The Labour Code is used as effective from 1 January 2026 (Section 104 was left unchanged by the most recent amendment); Act No. 309/2006 Coll. as effective from 1 November 2025. The detailed conditions for providing PPE are set out in an implementing government regulation under Section 104(6) of the Labour Code.
This text is provided for informational purposes and does not substitute for legal advice. The specific scope and parameters of PPE need to be set according to the actual operation, the risk assessment, manufacturers’ instructions, and the actual conditions of the work.
Is your PPE list copied from a catalogue, with issuance cards nobody’s seen in years? We’ll build you a PPE policy based on your actual operation — from the walk-through through a list organised by role to record cards that hold up during an inspection or after an accident. Send us a no-obligation inquiry or write to info@sohe.cz, and we’ll scope it to your operation.