PPE and the law in Zambia

General information from Hanekom Innovations · Reading time about 5 minutes

The Occupational Health and Safety Act, 2010

Zambia's principal workplace safety legislation is the Occupational Health and Safety Act No. 36 of 2010. It establishes the general duty on employers to provide and maintain a working environment that is safe and without risk to the health of employees — a duty that includes the provision of suitable protective equipment where risks cannot be eliminated by other means.

The framing is important. The Act does not simply say “issue PPE”. It places the obligation on the employer to secure a safe workplace, of which protective equipment is one control among several. That is why a defensible safety programme starts with a risk assessment and works down the hierarchy of controls — eliminate, substitute, engineer, administer, and only then protect the individual.

What the duty means in practice

Providing PPE properly involves rather more than buying it:

• Assess the risk first. The specification follows from the identified hazard — the cut level, the filtration class, the EN standard, the attachment points. PPE bought without a risk assessment behind it is a guess.
• Provide it free of charge. PPE required for the work is the employer's cost, not the worker's.
• Make sure it fits. A respirator that does not seal, a harness that does not fit and a boot that is the wrong size all protect nobody. Fit testing and size ranges are part of provision, not an optional extra.
• Train people to use it. Correct donning, checking, limitations and when to replace it.
• Maintain and replace it. Set inspection routines and replacement intervals, and stock to them.
• Keep records. Issue records, inspection records, training records and product certification. When an inspector or a client audit asks, records are the answer.

ZABS and ZCSA: who does what

Two national bodies matter here and they are frequently confused:

• Zambia Bureau of Standards (ZABS) is the national standards body and Zambia's ISO member. It develops and publishes Zambian Standards (the ZS series) and provides certification and testing services. ZABS work is largely voluntary standardisation.
• Zambia Compulsory Standards Agency (ZCSA) administers compulsory standards — those made mandatory by statutory instrument. Where a standard is compulsory, meeting it is a legal requirement, not a quality choice.

Compulsory standards you should know about

Two entries on the compulsory standards list bear directly on PPE procurement:

In practice much of the PPE sold into Zambia is manufactured in South Africa and certified to the SANS adoption of the relevant ISO or EN standard, with NRCS approval where applicable. That is a legitimate route — but the certification belongs to the specific model, not to the brand as a whole. Ask for the specification sheet for the item being quoted.

What this means for procurement

• Write specifications, not shopping lists. “Safety boot, EN ISO 20345 S3, HRO outsole, sizes 6–12” can be compared across quotations. “Safety boots” cannot, and invites the cheapest compliant-in-name-only option.
• Ask for documentation at quotation stage, not after delivery. It costs nothing to ask and it changes who bids.
• Budget for replacement, not just issue. Worn PPE is non-compliant PPE. A programme that issues once a year and never replaces is a programme that spends most of the year out of compliance.
• Treat the cheapest quote sceptically on regulated items. On footwear and fall protection in particular, a price well below the market usually indicates a different specification, not a better deal.
• Keep the paperwork with the stock. Certificates filed away from the store room have a way of not existing when they are needed.

Where to read further

• Occupational Health and Safety Act No. 36 of 2010 — available through ZambiaLII
• Zambia Bureau of Standards
• Zambia Compulsory Standards Agency