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OHS requirements for workwear and protective equipment: a guide for employers

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OHS requirements for workwear and protective equipment: a guide for employers

Jobb og Fritid-redaksjonen14 August 20267 min read

Who is responsible for workwear, what does the regulations say about protection classes, and what should a clothing list include? A guide for those with OHS or procurement responsibility — from the specialist shop that has been clothing the working people of Northern Norway since 1988.

Workwear is not merely clothing — for many roles it is personal protective equipment backed by legal requirements. Even so, the rules are spread across legislation and several regulations, and it is not always obvious what actually applies to your particular workplace.

This guide brings together the essentials: who bears responsibility, what requirements apply to the equipment, what the protection classes mean in practice — and a checklist you can use when drawing up the clothing list.

What the regulations actually require

The starting point is the Working Environment Act, section 3-2: the employer must ensure that the necessary personal protective equipment is made available to employees. What is 'necessary' is not a matter of opinion, but is determined by the risk assessment — which is the very hub of OHS work.

The details are set out in the regulations. The Regulations on Organisation, Management and Participation, Chapter 15, govern the use of personal protective equipment in the workplace, and the Regulations on the Performance of Work set requirements for the activities the equipment must protect against. Employees, for their part, are obliged to use the equipment that has been prescribed — this follows from the Working Environment Act, section 2-3.

In practice, this means: map the hazards per role — not per department — and let the requirements drive procurement. A carpenter, a driver and a warehouse worker within the same company may have entirely different requirements for footwear, visibility and clothing.

Who pays — and what must accompany the equipment

The rule is straightforward: the employer makes the protective equipment available, and employees must not pay for it. This also applies to maintenance and replacement — equipment that is worn, damaged or has lost its protective capability must be replaced at the employer's expense.

Equipment purchased must be CE marked, have instructions in Norwegian and be accompanied by a declaration of conformity. It is the manufacturer's and supplier's responsibility to provide these — but the employer's responsibility to verify that they are in place. When purchasing from a specialist retailer, this should be a matter of course.

Do not forget the training: employees must know when the equipment is to be used, how to use it correctly, and how to recognise when it is time to replace it.

High-visibility clothing: class 1, 2 and 3 (EN ISO 20471)

High-visibility clothing is certified to EN ISO 20471, which divides garments into three classes according to the area of fluorescent background material and reflective tape they carry. The higher the class, the more visible — and the stricter the requirements.

  • Class 1: the lowest level — typically harnesses or individual garments with a limited area. Appropriate where risk and speed are low.
  • Class 2: intermediate level — vests and T-shirts. The common minimum on construction sites and in warehouses with vehicle traffic.
  • Class 3: the highest level — jackets and suits with coverage requirements extending to the sleeves as well. Required in practice for work on and alongside public roads, and generally wherever high-speed traffic forms part of the risk picture.

Two things many people get wrong: the class can be achieved by combining garments — a certified jacket and trousers together can give class 3 even if the individual garments are class 2 — and visibility has a limited lifespan. Fluorescence fades and reflective tape wears with washing and use, so garments must be replaced before they fall below the requirement, not when they merely look 'worn enough'. The maximum number of wash cycles is stated in the garment's instructions.

Safety footwear: the S classes explained (EN ISO 20345)

Protective footwear is certified to EN ISO 20345. All classes have toe protection rated at 200 joules — the difference lies in what the shoe protects against beyond that.

  • SB: the basic requirement — toe protection.
  • S1: toe protection plus closed heel, antistatic properties, energy absorption in the heel and fuel-resistant sole. For indoor and dry environments.
  • S1P: S1 plus penetration-resistant midsole. A common choice in light industry and warehousing.
  • S2: S1 plus water-resistant upper. For outdoor work and damp environments.
  • S3: S2 plus penetration-resistant midsole and cleated sole. The standard choice on construction sites.

The 2022 revision of the standard also introduced S6 and S7 — essentially S2 and S3 with the requirement that the entire shoe is waterproof. In the wet conditions of Northern Norway, this is worth looking for. Penetration-resistant midsoles are available in both steel and metal-free versions — metal-free midsoles are lighter and provide better insulation against cold.

Choose the class based on your risk assessment, not out of habit: a construction site normally requires S3, a workshop or warehouse can often manage with S1P, and in wet outdoor conditions S7 or safety boots are the right choice. And a safety shoe that does not fit will end up sitting in the locker room — fit and trying on are part of health and safety too.

Weather and cold are health and safety matters too

The Working Environment Act requires a fully satisfactory working environment with regard to climate as well. For outdoor work in Northern Norway, this is no formality: cold, wind and precipitation affect both safety, concentration and sickness absence.

Rainwear is certified to EN 343 (water resistance and breathability), and cold-weather clothing to EN 342. But just as important as the certificates is the system: layer upon layer with wool next to the skin, insulation in the middle, and a wind- and waterproof outer layer. Cotton next to the skin is the classic mistake — wet cotton against the body in sub-zero temperatures is a hypothermia risk, not merely uncomfortable.

We have been clothing workers in Northern Norwegian weather since 1988, and this is perhaps the area where sound expertise makes the greatest difference to both health and safety and wellbeing.

Checklist for those with health and safety responsibility

  1. Carry out a risk assessment per role — what hazards apply, what requirements follow.
  2. Draw up a clothing list per role with specific protection classes (for example S3 footwear and class 3 visibility for road work).
  3. Check CE marking, Norwegian instructions for use and declaration of conformity on everything purchased.
  4. Ensure training in correct use — and document it.
  5. Establish a routine for maintenance and replacement, including high-visibility clothing that has lost its effectiveness.
  6. Involve the safety representative in the selection and evaluation of equipment.
  7. Document assessments, choices and routines in the internal control system.

Are you setting up or updating your clothing list? We help companies throughout the country to translate health and safety requirements into specific garments per role — with a corporate agreement, agreed prices and a dedicated contact person. Request a no-obligation quote — or call us on 77 68 64 85.

Frequently asked questions

Must the employer pay for workwear and protective equipment?

Personal protective equipment must be made available by the employer, and the cost cannot be passed on to the employees. This also covers maintenance and replacement. For ordinary workwear without a protective function, greater contractual freedom applies — but where the clothing is an OHS measure, it is the employer's responsibility.

Which safety footwear class do we need?

This is determined by the risk assessment. General rule of thumb: S3 on construction sites and outdoor civil engineering work, S1P in workshops and warehouses, S7 or safety boots in wet environments. All classes have toe protection rated at 200 joules.

When is high-visibility clothing class 3 required?

For work on and alongside public roads, class 3 is in practice required, and generally wherever employees move among fast-moving vehicles. The class can be achieved by combining certified garments — for example, a jacket and trousers together.

How often must high-visibility clothing be replaced?

When the garment no longer meets the class requirement. Fluorescent colour fades and reflective tape wears away through washing and use — the manufacturer states the maximum number of wash cycles in the instructions, and garments that have faded or have damaged reflective tape should be replaced regardless of that number.

What does the CE marking on protective equipment mean?

That the manufacturer guarantees the equipment meets the requirements of the regulations on personal protective equipment. The equipment must also be accompanied by instructions in Norwegian and a declaration of conformity. If any of this is missing, the equipment must not be put into use.

Can employees use their own footwear or clothing at work?

Not where the risk assessment requires protective equipment — in that case the employer must provide the correct equipment, and employees are obliged to use it. Privately owned equipment provides no guarantee of the correct protection class or proper maintenance.

For more general questions and answers, see our FAQ page.