In brief
The legislation does not impose a specific issue form, but you can only show that you issue PPE free of charge, deliver the right product to the right person and renew worn equipment through records kept per employee. A good record states the product type and protection class, size, delivery date and the criterion for the next replacement. The business itself sets the replacement interval according to the level of risk and conditions of use.
What is a PPE issue record for?
At inspection, the answer to "Do you issue PPE?" is given by records, not words. The Regulation on the Use of PPE in Workplaces gives the employer five concrete obligations; a PPE issue record is the most practical way to document each of them:
- PPE is provided free of charge by the employer; its maintenance, repair and the replacement of necessary parts are also the employer's responsibility (Art. 6/1-e).
- The conditions of use and in particular the duration of use are determined according to the level of risk, frequency of exposure, characteristics of the workstation and performance of the PPE (Art. 6/1-c).
- PPE is kept in places easily accessible to employees and in sufficient quantity (Art. 6/1-h).
- Practical training in its use is given (Art. 6/1-g).
- Faulty PPE is not used until the fault is remedied; where necessary it is replaced with new equipment and checked before each use (Art. 8/3).
The regulation does not use the word "issue". The issue record here is proof of delivery; it does not place any debt on the employee. Art. 4 of Law No. 6331 also states that the cost of OHS measures cannot be passed on to employees. Do not write a clause such as "the cost of lost or worn PPE will be deducted from wages" in the record; this both breaches the legislation and leads employees to hold on to worn equipment.
We explain which PPE is selected for which job and to which standard in our article on PPE selection, and the regulation as a whole in our article on the Regulation on the Use of PPE. This article covers the work after selection: delivery, replacement and tracking.
How to fill in a PPE delivery record
Writing "PPE has been delivered" on a collective signature list and having employees sign it falls short at inspection. It must be clear what was given, to whom, in what size, when, and when the next replacement is due. The following fields are sufficient:
| Field | What is written? | Common mistake |
|---|---|---|
| Employee and task | Full name, department, task (e.g. MIG welder) | Writing only the department name |
| PPE and type | Product name, brand/model or stock code | Writing "gloves" without specifying the type |
| Standard and protection class | E.g. TS EN 388 level, FFP2, S3 | Leaving it blank; at inspection it is unclear whether the right product was issued |
| Size | Glove size, shoe size | Buying one size and counting PPE that does not fit as "issued" |
| Quantity and delivery date | Day, month, year | Writing only the month instead of the date |
| Next replacement | Date or criterion (damage, manufacturer's service life, incident) | Not having the column at all |
| Information and training | Instructions for use shown, practical training given | Not linking the training to a separate record |
| Signatures | Receiving employee and person delivering | Missing signature of the person delivering |
Add two practical rules. First, make the first delivery on the same day as induction training; putting on and checking PPE is demonstrated in the practical part of that training. Second, for foreign employees or those with reading difficulties, also explain the content of the record verbally. The regulation requires instructions to be understandable to employees (Art. 6/2).
Free template: per-employee PPE issue card
You can copy the table below into a spreadsheet and use it as a separate sheet (card) for each employee. The sample rows have been filled in for a welder's task, common in metalworking workshops in Bursa.
| No | Date | PPE (type, standard, class) | Size | Quantity | Reason issued | Next replacement / criterion | Employee signature | Delivered by |
|---|---|---|---|---|---|---|---|---|
| 1 | 05.01.2027 | Welding gloves, TS EN 12477 | 10 | 2 pairs | First issue | Hole, hardening or 4 weeks at the latest | ||
| 2 | 05.01.2027 | Auto-darkening welding mask, TS EN 175 / TS EN 379 | – | 1 | First issue | Cover lens replaced when scratched | ||
| 3 | 05.01.2027 | Safety shoes S3 | 43 | 1 pair | First issue | Toe cap damage, sole wear | ||
| 4 | 05.01.2027 | Earplugs, TS EN 352-2 | – | 1 box | First issue | Single use; new pair at start of each shift | ||
| 5 | 28.01.2027 | Welding gloves | 10 | 1 pair | Wear (hole) | Same criterion |
The "reason issued" column matters. When first issue, wear, fault, loss, size change and task change are recorded separately, you can see from the record which product wears out faster than expected and in which task losses are increasing. Add the PPE for the new task to the card of an employee who changes task; the PPE matrix in the risk assessment is also the source for this card.
How to set the PPE replacement interval
The legislation does not set fixed periods such as "gloves are changed once a month". The business sets the period and writes down its justification. Define at least one of three triggers for each item of PPE; whichever comes first triggers replacement:
- Time: The maximum period set according to intensity of use. If the manufacturer's instructions give a service life or expiry date, the business rule cannot exceed it.
- Condition: Visible damage, deformation, increased filter resistance, replacement indicators in the instructions.
- Incident: A helmet that has taken an impact, a fall arrest system that has stopped a fall, gloves exposed to a chemical splash. These are not reused until assessed according to the manufacturer's instructions.
| PPE | Typical replacement trigger | Who checks? |
|---|---|---|
| Cut-resistant gloves | Hole, cut, coating peeling | Employee before each use |
| Safety helmet | Manufacturer's service life, crack, impact | Employee; department supervisor monthly |
| Filtering half mask / filter | Breathing difficulty, odour, manufacturer's instructions | Employee; workplace physician during fit check |
| Safety shoes | Toe cap exposed, sole wear | Employee; department supervisor |
| Full-body harness | Service life in instructions, stitching damage, after a fall | Recorded inspection by a competent person |
Set the replacement interval based on observation in the first year, then adjust it based on the records. Writing a "4 weeks" rule for gloves that wear through in 2 weeks in the welding section forces employees to work with holed gloves. Conversely, there is no need to throw away a product that has not worn at all just because the date has come; the criterion should be "time or condition, whichever comes first". For class selection of dust and gas masks, see our article on dust masks FFP1, FFP2, FFP3, and for gloves, our article on work glove selection.
PPE issue list and stock tracking
Individual cards show who received what; the PPE issue list shows total consumption by department. If you keep both, stock planning follows naturally. The regulation's requirement to keep "sufficient quantity" means that the right sizes must not run out in the store.
A simple minimum stock calculation:
Minimum stock = average monthly consumption × (lead time, months) + safety stock
Example: in a sheet metal section with 40 operators, cut-resistant gloves are consumed at an average of 1 pair per week.
- Monthly consumption ≈ 40 × 52 / 12 ≈ 173 pairs
- The supplier delivers orders in 2 weeks (≈ 0.5 months) → 173 × 0.5 ≈ 87 pairs
- 25% safety stock for unexpected increases → 87 × 1.25 ≈ 109 pairs
When stock falls to this level, an order is placed. Do not forget to distribute the calculation across sizes: if all 109 pairs are size 9, an employee who wears size 10 is still left without gloves. Count sizes from the individual cards.
Once a month, compare the total consumption in the issue list with the number of employees in each department. If consumption per employee in one department is twice that of others, either the product is not suitable for the job or there is a condition that accelerates wear (sharp burrs, oil, hot parts). This finding may indicate a risk that can be solved by collective measures before PPE and should be fed back into the risk assessment.
In stock tracking, also check: the shelf life given by the manufacturer for filters and helmets on the shelf, whether the Turkish instructions and conformity documents for the products are on file, and hygiene measures where PPE intended for one person is shared (Art. 6/1-ç).
Common issue record mistakes found at inspection
- A one-page collective signature list. No product type, size or date; it is unclear who received what.
- Only the first issue recorded. Because reissued PPE is not written down, it looks as though no replacement is taking place.
- Subcontractors and temporary workers forgotten. It must be clear from whom and how the PPE of everyone working on the same site is provided.
- Records do not match the risk assessment. FFP3 is written in the risk assessment while FFP1 is recorded as delivered.
- A cost deduction clause. Every deduction statement written in the record becomes evidence that PPE was not issued free of charge.
- Old cards thrown away. The cards of employees who have left must also be kept in the OHS file; for file organisation, see our article on OHS file contents.
Setting up issue cards and the PPE matrix together with the risk assessment is a routine part of our OHS specialist service. For PPE needs specific to metalworking sections, see our metal and machinery page.
Frequently Asked Questions
Is a PPE issue record mandatory?
The regulation does not name a specific form. However, you must be able to prove that you issue PPE free of charge, provide practical training and replace worn equipment. A dated, signed delivery record per employee is the most reliable way to do this.
What happens if an employee loses their PPE?
A replacement is issued without delay; work does not start without PPE. The loss is written in the "reason issued" column of the card. If losses recur frequently, investigate causes such as the storage location, size fit or discomfort of the product.
Who sets the PPE replacement interval?
The employer sets it together with the risk assessment team. The regulation links the period to the level of risk, frequency of exposure, characteristics of the workstation and performance of the PPE. If the manufacturer gives a service life, this period is not exceeded.
Should issue records be kept on paper or digitally?
Either is fine. What matters is that the record is per employee, dated and shows the recipient's confirmation. In a digital system, you must be able to show how you obtain the employee's confirmation and that records are stored in a way that cannot be altered.
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Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.