The Importance of EPI Records in Prevention and Defense in Labor Actions

INTRODUCTION

Personal protective equipment (PPE) represents an important protection measure for workers when occupational risks cannot be eliminated or sufficiently controlled by collective and administrative protection measures.

However, in the context of Occupational Safety and Health, it is not enough to simply acquire and make available the equipment. The organization must demonstrate that the PPE has been correctly selected for the existing risk, provided to the worker, properly used, replaced when necessary and accompanied by the relevant guidelines and training.

In this context, PPE supply and control records are of particular importance. In addition to integrating the preventive management of the company, they constitute relevant technical and documentary elements in audits and, mainly, in judicial expertise arising from labor actions involving unsanitary conditions and other occupational risks.

WHAT THE NR-6 ESTABLISHES

The Norma Regulamentadora No. 6 – Personal Protective Equipment (PPE) establishes the responsibilities related to the selection, supply, use and control of such equipment.

It is the responsibility of the organization, among other obligations:

acquire only PPE approved by the competent body;

provide risk-appropriate equipment free of charge;

guide and train the worker;

register the supply of the PPE;

require its use;

take responsibility for periodic hygiene and maintenance, where applicable;

Replace equipment when damaged or lost.

The registration of the supply can be carried out through books, tokens or electronic system, including through biometric system.

Therefore, the PPE file should not be understood only as an administrative document. It integrates the Occupational Safety and Health management system and constitutes objective evidence of the measures adopted by the organization to protect its workers.

Providing is not the same as proving

A situation often observed during labor expertise occurs when the company informs that it has always provided the necessary equipment, but does not have sufficient documentation to demonstrate that supply.

It is common to find claims such as:

“the worker has always used ear protector”;

“The gloves were available in the sector.”

“Everyone got respirators.”

“When the equipment was broken, it was replaced.”

Although this information may represent the operational reality of the company, the absence of records makes it difficult to provide technical proof of the protection measures adopted.

In an expert evaluation, it is necessary to objectively verify elements such as type of PPE, number of Certificate of Approval – CA, date of supply, period of use, frequency of replacement, suitability for the occupational agent and training carried out.

Without this information, it may not be technically possible to establish whether the equipment used was capable of reducing or neutralizing certain exposures throughout the period discussed in the action.

CERTIFICATE OF APPROVAL – CA

Another key element is the Certificate of Approval – CA.

The equipment may only be marketed or used as PPE when it has the indication of the respective CA issued by the competent body.

The CA number allows to identify, among other information, which equipment was supplied and for which occupational risks that product was approved.

This aspect is especially important because it is not enough to demonstrate that the worker has received “a glove”, “a mask” or “an ear protector”. It is necessary to verify that that equipment was technically adequate to the risk actually existing in the workplace.

For example, a hearing protector should be analyzed considering its attenuation characteristics and noise exposure conditions. In the same way, protective gloves should be compatible with the existing chemical agent or risk, and respiratory protective equipment should be selected according to the contaminant and the conditions of exposure.

Thus, PPE inadequate to the risk cannot have its efficacy presumed just because it was delivered to the worker.

The Importance of Replacement Periodicity

One of the points often analyzed in judicial expert examinations is the periodicity of equipment replacement.

Every PPE has its own characteristics of use, conservation and useful life. Certain equipment may lose its protective capacity due to wear, contamination, deformation, mechanical damage or inadequate conservation conditions.

Therefore, a token containing only one delivery over several years of contract may be insufficient to demonstrate effective protection over the entire period.

The control should allow you to establish a chronological line, for example:

Date

PPE provided

CA

Quantity

Signature

10 January 2026

Hearing Protector

xxxxxxxxx

UCLA

Joao

In this way, it is possible to verify if there was continuity of protection during the period of occupational exposure.

THE PPE SHEET SHOULD CONTAIN RELIABLE INFORMATION

In order to have greater technical and documentary consistency, it is recommended that the supply control allows you to clearly identify:

(a) the name and identification of the employee;

(b) function and, where relevant, sector of work;

(c) identification of the PPE;

d) number of the Certificate of Approval – CA;

(e) the date of supply;

(f) quantity supplied;

(g) records of substitutions;

h) proof of receipt by the worker;

(i) information or records of the applicable training; and

(j) sufficient history to demonstrate the continuity of protection.

Electronic systems can also be used. The important thing is that the records are complete, traceable and available for consultation and presentation when necessary.

TRAINING AND GUIDELINES ALSO NEED TO BE DEMONSTRED

Another misconception is to consider that the simple signature of the delivery form is sufficient to demonstrate the entire management of the PPE.

The protection only achieves its purpose when the equipment is used correctly.

Therefore, information should be provided regarding the purpose of the equipment, the risk against which it offers protection, limitations, the correct form of placement and adjustment, conservation, sanitation, maintenance and replacement.

Depending on the characteristics of the PPE and the activity, training should also be carried out.

In practice, therefore, the company must be able to demonstrate a logical sequence:

RISK IDENTIFYED → SELECTED EPI → AS APPROPRIATE → SUPPLY → TRAINING/GUIDELINES → USE → MONITORING → MAINTENANCE REGION → REPLACEMENT →

This documentary chain presents much more consistency than a simple file containing signatures.

THE IMPORTANCE OF REGISTRATION IN A LABOUR EXPERIENCE

In labor actions involving additional insalubrity, the Judicial Expert usually analyzes the activities effectively exercised, the existing agents, the intensity or nature of the exposure, the measures of collective control and the protective equipment used.

At this point, OSH documents play a key role.

Imagine a company in which the worker has been exposed to noise for five years. The organization claims to have provided hearing protectors throughout the period.

During the expertise, they can be analyzed, among other elements:

levels of occupational exposure to noise;

model of hearing protector;

Corresponding CA;

applicable mitigation;

Dates of delivery;

periodicity of substitutions;

guidance and training;

monitoring of use;

Compatibility of PPE with working conditions.

If the company presents documentation that is consistent and chronologically compatible with the period worked, there will be technical elements to analyze the effectiveness of the protection.

On the other hand, the simple statement that the worker used PPE does not replace the objective elements necessary for the technical evaluation.

Documentation should not be produced solely for the purpose of judicial defence.

The best document management is that performed during the employment relationship, and not only when a labor complaint arises.

Reconstruct years later what equipment was used, what their ACs were, when they were replaced, and what trainings were carried out can be extremely difficult.

Therefore, the registration should be part of the preventive routine of the organization.

Efficient management must maintain consistency between:

PGR → risk inventory → exposure assessment → control measures → PPE selection → delivery form → training → supervision → replacement.

When these documents present information compatible with each other, a consistent technical set is formed, capable of demonstrating the management of occupational risks carried out by the organization.

EPI DOES NOT SUBSTITUTE COLLECTIVE PROTECTION MEASURES

It is important to note that the use of PPE should not be treated as the first or only risk control measure.

The management of OSH should observe the hierarchy of prevention measures, prioritizing the elimination of hazards and collective protection measures where technically applicable.

The PPE integrates this prevention system and should be selected considering the risks that remain after the adoption of other control measures.

Thus, documenting the PPE does not only mean obtaining a signature from the worker, but also technically demonstrating that there has been an adequate process of managing occupational exposure.

CONCLUSION

The records of Personal Protective Equipment have an importance that goes beyond the simple fulfillment of an administrative obligation.

Adequate management must demonstrate which PPE has been provided, for which risk, with which Certificate of Approval, at what date, for how long, when it was replaced, what guidance has been provided and how its use has been followed by the organization.

In a labor complaint, especially in discussions related to insalubrity, the absence of these elements can significantly hinder the technical demonstration of the effectiveness of the protection measures adopted.

On the other hand, complete, coherent and traceable records allow to reconstruct the protection conditions existing during the employment contract and provide objective elements for expert evaluation.

Therefore, the management of PPE should be understood as an integral part of Occupational Risk Management, and not just as filling out forms.

Uncontrolled PPE is just equipment. Correctly selected, supplied, used, monitored, replaced and documented PPE is a true preventive measure.

Maintaining adequate records means protecting the worker, strengthening the management of Occupational Safety and Health and providing greater technical and documentary security to the organization in the face of inspections, expertise and labor demands.

Thank you for reading and until the next article.

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Also read: https://bntonline.com.br/brasil-discute-veto-da-ue-carne-em-reuniao-nos-usa/