Understanding Respiratory Protective Equipment (RPE) in the Workplace: Compliance Under HSWA 2015
Respiratory protective equipment (RPE) protects workers from breathing in harmful dust, fumes, vapours and other airborne contaminants. The Health and Safety at Work Act 2015 (HSWA 2015) sets the overarching duty to manage risks to worker health, while the Health and Safety at Work (General Risk and Workplace Management) Regulations 2016 (GRWM) set out where personal protective equipment sits in the hierarchy of controls and what a PCBU must do when it relies on it.
Getting RPE selected, fitted and maintained properly matters wherever New Zealand workers are exposed to dust, fumes, vapours or other airborne hazards. A respirator that doesn't seal or is running on a spent filter gives the wearer a false sense of protection.
What Is RPE and Why Is It Necessary?
Respiratory protective equipment is a type of personal protective equipment (PPE) designed to stop workers inhaling hazardous substances. It's typically needed when higher-order controls such as elimination, substitution, isolation or engineering controls can't adequately manage the risk on their own.
Common airborne hazards include:
Dust from grinding, cutting or demolition.
Fumes from welding or soldering.
Vapours from paints, solvents or other chemicals.
Biological hazards such as mould spores or bacteria.
Under HSWA 2015, PCBUs (persons conducting a business or undertaking) must ensure the health and safety of workers so far as is reasonably practicable. That includes minimising exposure to airborne hazards using the hierarchy of controls. RPE isn't an administrative control though. Regulation 6 of the GRWM Regulations puts personal protective equipment on its own step below administrative controls, as the last measure for whatever risk remains.
Legal Responsibilities Under HSWA 2015 and GRWM Regulations
The HSWA 2015 and the GRWM Regulations (regulations 15 to 18 deal with PPE) set out these duties for PCBUs that rely on RPE:
Identifying and Managing Risks
PCBUs must identify airborne hazards and assess the risk. Where a risk can't be eliminated, it must be minimised with substitution, isolation or engineering controls first, then administrative controls, with RPE covering whatever risk remains.Providing Suitable RPE
RPE must suit the specific hazard and the work and meet the relevant AS/NZS standards. AS/NZS 1716:2012 covers the respirators themselves and AS/NZS 1715:2009 covers their selection, use and maintenance.
Selection should take in the wearer's face shape and size, the type of work, comfort and how long the RPE will be worn.
Ensuring Proper Fit and Fit-Testing
A fit test is essential for tight-fitting RPE to ensure an effective seal and protection for the wearer. This is particularly important for masks like:Disposable P2 respirators.
Half-face and full-face respirators.
Powered Air Purifying Respirators (PAPR) with facepieces.
Providing Training and Information
PCBUs must train workers on:How to properly use, wear, and adjust RPE.
How to maintain and clean RPE.
The limitations of the equipment.
Monitoring and Maintenance
RPE must be kept clean and in good working order, inspected regularly and repaired or replaced when it's worn or damaged. Store it somewhere clean so it isn't contaminated between uses.Consulting Workers
PCBUs must engage with workers when making decisions about PPE, including RPE. The people wearing it are the first to know whether it's practical for the job and whether it actually gets worn.
Types of RPE and When to Use Them
The right RPE depends on the hazard, the exposure level and the conditions at the workplace. Common types include:
Air-Purifying Respirators (APR)
Disposable respirators: For particles such as dust, fumes and fibres. They're designed for short-term or one-off use and don't protect against gases or vapours.
Half-face respirators: With replaceable filters for particles, gases or vapours, matched to the contaminant.
Full-face respirators: Offering greater protection, including for eyes.
Powered Air-Purifying Respirators (PAPR)
These use a battery-powered fan to push air through filters to the wearer, which reduces breathing resistance. Loose-fitting hoods and helmets are an option for workers with facial hair, while tight-fitting PAPR facepieces still need a fit test.Supplied-Air Respirators (SAR)
Used in environments with oxygen deficiency or highly toxic contaminants. These supply clean air from a tank or air line.
Best Practices for RPE Use
These practices line up with WorkSafe's advice for businesses on RPE:
Risk Assessments First
Always identify hazards and attempt to manage them using higher-order controls before relying on RPE.Select the Right Equipment
Match RPE to the specific hazard and make sure it meets the relevant standard. P2 filters protect against fine particles, while organic vapour filters are used for solvents.
WorkSafe's respirator selection tool is a good place to start.Ensure Proper Fit
Fit test tight-fitting RPE when it's first issued, then at least yearly or whenever the wearer's face changes significantly.
Facial hair and even one day's stubble can break the seal. Workers wearing tight-fitting RPE need to be clean-shaven where the mask seals, otherwise give them RPE that doesn't rely on a tight face fit.
Train and Supervise Workers
Provide comprehensive training on:RPE use and maintenance.
Identifying signs of wear or failure.
Cleaning and storing equipment properly.
Regularly Inspect and Replace RPE
Set up schedules for inspecting and replacing worn or defective equipment. Change filters on a schedule from the manufacturer or a competent person, not when the wearer starts to smell something. Disposable respirators are designed for short-term or one-off use and shouldn't be reused.Monitor Usage
The PCBU must ensure workers wear their RPE so far as is reasonably practicable. Supervisors are the people who see whether it stays on for the whole task.
Common Mistakes to Avoid
Even with good intentions, a few common mistakes undo the protection RPE is meant to give:
Using incorrect or inadequate RPE for the hazard.
Failing to fit-test workers for tight-fitting respirators.
Allowing damaged or dirty RPE to be used.
Relying solely on RPE without first addressing hazards through higher-level controls.
Final Thoughts
RPE is a genuine safeguard that should always be treated as the last line of defence in the hierarchy of controls. Under HSWA 2015 and the GRWM Regulations, PCBUs have clear responsibilities to identify hazards, put effective controls in place and make sure any RPE is suitable, fitted, maintained and actually worn.
Is Your Respiratory Protective Equipment Actually Working?
In Raise the Standard I describe every organisation as running four versions of itself, which I call the G.A.P.E. Governance is what leaders believe is happening, Assumptions is what the documents say, Practice is what people actually do and Evidence is what can be proven. Respiratory protective equipment is one of the clearest places to watch those four versions drift apart.
Picture how that plays out on a cutting job. The leadership team believes the crew are protected because there are masks in the store. The procedure says every tight-fitting respirator is fit tested once a year. In practice the newest worker on the saw has a week of stubble and a P2 that's been in his pocket since Monday. The fit test record with his name and the date on it is where you find out which version is true.
A full box of P2s in the store is reassuring, however assurance is not evidence. What counts is a current fit test, a filter changed on schedule and a supervisor who has watched the mask stay on for the whole task.
If you want to see where your own four versions have drifted apart, the free G.A.P.E. Self-Assessment walks you through Governance, Assumptions, Practice and Evidence one layer at a time.
Frequently Asked Questions About Respiratory Protective Equipment
How often does respiratory protective equipment need to be fit tested?
WorkSafe says tight-fitting RPE should be fit tested when it's first provided to a worker, then at least once a year. The test should also be repeated if there's a significant change in the wearer's facial characteristics. A competent person should run it in line with AS/NZS 1715:2009, using either a qualitative (taste or smell) or a quantitative method.
Can workers with a beard wear a respirator?
A tight-fitting respirator won't work properly over a beard. WorkSafe notes that facial hair and even one day's stubble make it almost impossible to get a good seal. Workers with beards need RPE that doesn't rely on a tight face fit, such as a powered air-purifying respirator with a loose-fitting hood or helmet.
Who pays for respiratory protective equipment in New Zealand?
The PCBU that directs the work must provide RPE under regulation 15 of the GRWM Regulations. WorkSafe's guidance is clear the cost can't be passed on to workers, in full or in part. A worker can supply their own RPE only if they genuinely and voluntarily choose to, as long as it's suitable for the work.
About the Author
Matt Jones is the founder of Advanced Safety and a HASANZ-registered health and safety consultant. He's a Professional Member of NZISM and holds a Graduate Diploma in Occupational Safety and Health.
He created Compliance Compass, the independent audit Advanced Safety uses to show leaders what's actually happening on site against what the documents say. The thinking behind it sits in his book Raise the Standard: Why Good Organisations Go Blind and How Leaders Restore Visibility, built on three frameworks: G.A.P.E.™ finds where visibility is lost, S.A.F.E.T.Y.™ designs the leadership architecture that closes the gap and F.E.E.D.™ keeps it closed.
He also hosts the Health & Safety Unplugged podcast.
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Latest update: 5 November 2026
