Introduction 

The nursing workforce is predominantly female and richly diverse, encompassing a wide range of ethnicities, religious beliefs, and individuals living with disabilities. It is essential that personal protective equipment (PPE) provided to nursing staff reflects and respects this diversity, ensuring both safety and dignity in the workplace

The RCN believes that PPE must be designed and supplied with inclusivity at its core. This includes accommodating different facial structures, body types, religious dress requirements or beliefs, and health and accessibility needs. Ill-fitting, or non-inclusive PPE not only compromises safety but can also lead to exclusion, discomfort, and reduced confidence among staff. Within this position statement we define PPE as that required to protect users from health and safety risks, including respiratory protective equipment (RPE), gloves, eye protection and radiation protection, as opposed to equipment used only to protect others (referred to as source control) e.g. fluid repellent surgical masks to prevent the wearer from spreading infection. However, the same principles of user comfort and useability from an equity, diversity and inclusion (EDI) perspective should still apply.  Uniforms, not classed as PPE, are outside of the scope of this position statement, but we expect employers to consider EDI requirements within their uniform policies and relevant infection prevention and control of infections and related guidance.

Whilst the RCN recognises there may have been a need for pragmatism during a global pandemic causing shortages of PPE supplies in the UK, we do not believe that the safety of nursing staff should be compromised due to poorly designed or poorly fitting PPE.   Furthermore, many nursing staff are currently wearing PPE daily, for example, when caring for patients with high consequence infectious diseases or working with ionising radiation.  We cannot wait for another pandemic to ensure equity of protection.  PPE should fit the nursing workforce rather than the nursing workforce having to fit the PPE. 

 

Legal Requirements

Health and Safety Legislation 

Under the respective personal protective equipment regulations, which cover Great Britain and Northern Ireland, every employer shall ensure that suitable PPE is provided to their employees who may be exposed to a risk to their health and safety while at work.  The exception to this is where and the extent that such risks are adequately control by other means which are equally or more effective.  Suitable PPE is defined as: 

• Appropriate for the risk or risks involved and the conditions at the place where the risk occurs.
• Takes into account ergonomic requirements and the state of health of the person who may wear it 
• Is capable of fitting the wearer correctly
• Must comply with relevant manufacturing standards and should, as far as is reasonably practicable prevent or control the risk without increasing the overall risk. 

There is also a legal duty under the Safety Representatives and Safety Committee Regulations to consult health and safety representatives on the introduction of new technology or anything that could substantially affect the safety of members.  This should include consultation on the risk assessment to determine the type of PPE required specific to the hazard, alongside the selection of required PPE. 

In organisations where trade unions are not recognised, under the Health and Safety (Consultation of Employees) Regulations, the employer still has a duty to consult workers or an elected representative of the workforce. 

Equality Legislation 

In addition to health and safety legislation, employers need to comply with relevant equality legislation. 

Although Great Britain and Northern Ireland have separate legislation on equality in relation to suitable PPE, both share the principle that it is unlawful for employers to treat workers less favourably due to protected characteristics (race, gender, age, disability, religion). Employers must take reasonable steps to remove or reduce disadvantages, including providing alternative PPE. 

Reasonableness is not limited to cost but to meeting legal requirements that PPE adequately protects against identified risks where other controls are insufficient. Failure to consider protected characteristics and provide suitable alternatives may amount to direct or indirect discrimination. 

Issues Impacting the Nursing Workforce 

A literature search (Lynch, 2025) identified key issues with the provision of inclusive PPE for a diverse nursing workforce. These were reiterated by speaking to RCN members with lived experience of using PPE and RCN representatives who supported members throughout the Covid pandemic. The report on Module 3 of the Covid Inquiry also picked up on issues relating to PPE and EDI which are included below (UK Covid Inquiry 2026). 

Gender and Ethnicity Bias¹

The literature suggests that the majority of PPE is designed around white men anthropometrics, leading to poor fit for women workers and black and minority ethnic group workers. This was recognised in the report on Module 3 of the Covid Inquiry, highlighting that a lack of access to FFP3 masks that were designed to fit their facial shapes, women and ethnic minority healthcare workers were more likely to be left inadequately protected (UK Covid Inquiry 2026). Women and non-white ethnic groups also have lower fit test success rates compared to their male white counterparts.  Poor fitting PPE impacts on its effectiveness and trust in safety measures.

Many radiation protection garments (lead aprons) are designed without protection for female breast tissue (Appendix 1). 

There is little research on transgender and non-binary workers experiences of PPE provision, but the principles of choice (including gender neutral options) and good fit would apply.

Religious and Cultural Considerations 

PPE policies such as clean shaven for RPE, may conflict with religious dress codes and requirements, affecting acceptance in healthcare. The report on Module 3 of the Covid Inquiry highlighted the Health and Safety Executive’s guidance that if a worker could not be clean shaven for religious reasons, the employer should make alternative arrangements to either prevent or adequately control the risk e.g. through the provision of loose fitting powered respirator hoods or not deploying the healthcare worker to a high incidence area.  The Inquiry heard evidence that this did not always happen (UK Covid Inquiry, 2026). Culturally sensitive PPE policies that reconcile religious requirements and the safety of workers enhance diversity, inclusion and acceptance by staff. 

Health, Disability and Psychological Impact 

Ill-fitting PPE can cause a number of health issues from headaches to skin irritation or exacerbate issues for people with pre-existing conditions such as respiratory problems or heart conditions, reinforced in the report on Module 3 of the Covid Inquiry (UK Covid Inquiry, 2026) Wearing PPE for long periods can also exacerbate health risks especially when combined with hot working environments. Workers with hearing, speech or sight impairment and those who are neurodiverse may also have challenges with the suitability of PPE and compatibility with medical devices. Women experiencing symptoms of the menopause may also have debilitating symptoms which can be exacerbated by PPE. 

Some workers with underlying health conditions may not be able to tolerate or respond to qualitative or quantitative fit testing for tight fitting RPE e.g. eye conditions affected by ocular pressure or those with a loss of taste. 

There may be increased stress, depression and anxiety from workers who wear ill-fitting or unsuitable PPE at work.

The report on Module 3 of the Covid Inquiry highlighted the benefit to healthcare workers with hearing impairment or who relied on lip reading for communication of transparent masks that offer equivalent protection to FFP3 masks (UK Covid Inquiry 2026). 

Workplace Cultures 

Training for managers on the importance of inclusive PPE for a diverse workforce can increase staff confidence, create supportive cultures and prevent bullying.   

Equally staff should be supported to raise concerns about unsuitable or ill-fitting PPE and such concerns must be acted on.  RCN research during the pandemic found that 34% of nursing staff felt under pressure to care for patients with inadequate PPE.  This rose to 56% in Black, Asian and Minority Ethnic nursing staff highlighting a disproportionate experience in the workplace. The report on Module 3 of the Covid Inquiry also highlighted issues with bullying and microaggressions towards ethnic minority groups regarding PPE availability (UK Covid Inquiry, 2026). 

Organisational or professional pressure to pass fit tests may lead to some staff fearing the consequences of a failed test.  This may be greater in nursing staff concerned about their immigration status. The report on Module 3 of the Covid inquiry makes specific mention to fit testing and better record keeping both within and between organisations so there is better understanding on the types and numbers of masks to be obtained (UK Covid Inquiry, 2026).

Internationally educated nursing staff may come to the UK with different experiences of PPE provision including re-use of single use items.  They may be reluctant to raise concerns and feel pressured to accept unsuitable PPE.  Policies on selection and use of PPE should be culturally sensitive and encourage and actively support staff to raise concerns. 

Organisational Barriers and Policy Gaps 

The report on Module 3 of the Covid inquiry highlighted that shortages in PPE disproportionately affected black and ethnic minority staff.  Meaning that inclusive access to PPE is a business continuity and pandemic planning issue (UK Covid Inquiry 2026). 

Many workplace PPE policies lack equity considerations, leading to a one size fits all approach.  Inclusive policies as well as compliance with health and safety requirements to risk assess, identifying who can be harmed and how, will help address the gap. 

Impact of Professional Identity and Morale 

Marginalisation of workers, due to ill-fitting PPE erodes confidence and reduces workforce cohesion and retention.

 

RCN Position 

The RCN commits to working with the following organisations and relevant representative bodies to drive forward the following calls for action:

Manufacturers 

Manufacturers should invest in inclusive design and testing processes that reflect the diversity of the healthcare workforce. This includes expanding sizing ranges, offering culturally sensitive options, and ensuring compatibility with assistive devices. As stated in the Module 3 Covid Inquiry report the four nations need to work with PPE manufacturers need to innovate in terms of the needs of the nursing workforce and the delivery of patient care e.g. clear masks, communication in air fed hoods.

Suppliers and Procurers

We recognise that supply and procurement vary in devolved nations and within Independent Health and Social Care organisations (e.g. direct procurement, procurement hub or via local authorities) however we call on all organisations who supply or procurer PPE to health and social care organisations to:

• Work collaboratively with health and care organisations, including nursing representatives to understand the needs of their workforce. 
• Act on intelligence from health and care organisations on the suitability of PPE. 
• Ensure nursing staff are at the centre of procurement decisions, be that direct or through a shared service, and be cognisant to the needs of a diverse nursing workforce. 
• Where bulk procurement is carried out e.g. across a nation, ensure that expert nursing infection prevention and control and health and safety staff are involved in procurement decisions.  

Employers 

Employers should engage with staff to understand their PPE needs, ensure procurement and PPE policies reflect diversity and inclusion, and provide alternative options where standard PPE may not be suitable. They must uphold legal obligations under both health and safety and equity law and foster a culture where staff concerns are welcomed and addressed.  Employers should pay due attention to British Standard 30417, Guidance on the Provision of Inclusive Personal Protective Equipment (BSI, 2025) and Article 16 of International Labour Organisation (ILO) Convention 192 on Biological Hazards in the Working Environment (ILO, 2025) in relation to gender and use of the precautionary principle. 

Specifically, for the nursing workforce employers should: 

• Ensure that policies on the selection and use of PPE are culturally sensitive and inclusive and include a thorough equality impact assessment. 
• Meet their legal duty to consult with workers and their health and safety representatives on risk assessment and the selection and provision of PPE to ensure it meets the need of a diverse workforce.  Where they exist, we would also expect employers to engage with various staff equality networks to identify any issues or concerns. 
• Ensure all staff are aware of and able to raise concerns about the suitability of PPE and that concerns are acted on. 
• Ensure that any training on PPE is culturally sensitive e.g. recognises different practices on single use PPE 
• Ensure that EDI is considered as part of the risk assessment process when selecting suitable PPE i.e. considering who can be harmed and how. 
• As part of their RPE programme, ensure they have a rolling programme of fit testing, in place based on current and future demands for testing and keep accurate, auditable records of mask fit, training and review dates. 
• Ensure that the importance of fit testing is clearly communicated to staff and that they are not put under pressure to pass a qualitative fit test  
• Fit testing procedures must take into consideration the health status or existing disabilities of the person to be tested.  Occupational health advice should be sought where necessary e.g. ocular pressure, or the ability to taste Bitrex solution.  Reasonable adjustments should be made where necessary.  
• There must be clear routes of escalating and reporting concerns on the failure of PPE internally and to the supplier and the regulator. 
• Organisations should invest in sufficient numbers of expert staff to support policies on PPE and EDI including occupational health, infection prevention and control, health and safety and, for large organisations, specialist clinical procurement staff.   

Health and Care Regulators

• To ensure organisations are considering equity and inclusion in their approach to the selection of PPE.   

Workforce Safety Regulator (Health and Safety Executive/ Health and Safety Executive Northern Ireland) 

• Provide a statement and guidance to employers on the importance of inclusive PPE aligning health and safety requirements with employers' duties under respective equality legislation.
• Monitor evolving research into the suitability and effectiveness of PPE, including radiation protection, for all workers and amend guidance accordingly. 

By taking these steps, we can all ensure that all nursing staff, regardless of background or identity are protected, respected, and empowered to deliver care safely and confidently. 

Appendix 1  

Radiation Protection  

The International Agency for Research on Cancer (IARC) have defined ionising radiation as having sufficient and convincing evidence as a breast cancer risk.  Whilst the current risk of breast cancer in female nursing staff exposed to ionising radiation is unknown, radiation PPE may not be sufficient to cover breast tissue which in females extends into the upper outer quadrant of the breast and the axilla.²

For nursing staff who are required to wear radiation protection at work for part or all of their shift, the RCN supports following the guidelines from the British Orthopaedic Association. Nursing staff may be exposed to lower doses than operating surgeons due to proximity to the radiation source, but in the absence of conclusive evidence on the risk to nursing staff working with ionising radiation, we call for implementation of the precautionary principle. 

Specifically, the RCN calls for: 

• Compliance with legal requirements to limit exposure as low as reasonably achievable by firstly minimising exposure through reducing duration of exposure and increasing distance from the sources and shielding. 
• Where PPE is required: 
  • Vest tops should be well-fitted to the individual and as close to the axilla as possible. 
  • Different body shapes and sizes require trialling different options to find the best fit. 
  • Adapted lead apron protection to include capped sleeves and axillary wings that can be worn under standard gowns to protect the upper outer quadrant of the breast. Detachable sleeves are not recommended. 
  • Alternative aprons with capped sleeves are currently available in the UK  
  • Detachable axillary wings and bolero style lead sleeves (worn under existing apron) are also available  
  • Increased coverage results in reduction in dose, 
  • Minimum lead thickness should be 0.25mm 

Design Features that need to be considered include: 

Anatomical design: Custom-fit radiation apparel must account for women’s distinct anatomical features. The design should provide optimal coverage and shielding.  

Breast protection: Radiation blocking for sensitive breast tissue during medical procedures should avoid flattening the breasts or gaping at the armholes.  

Flexibility and comfort: Radiation protection apparel should ensure a snug fit without compromising comfort. Weight should be minimised and flexibility maximised, permitting ease of movement and a full range of motion without fatigue.  

Adaptable components: Adjustable elasticated inserts, straps, and closures incorporated into the design accommodate body size and shape variations. The garment can be customised for each individual, enhancing comfort and functionality.  

Lightweight, lead-free options: Women are generally smaller than and unable to carry as much weight as their male counterparts. Alternative core materials may maintain the same level of protection while significantly reducing weight and avoiding lead exposure.  This should also be a consideration as a reasonable adjustment for nursing staff who are required to wear radiation protection rand have a disability or a long term condition which is exacerbated by wearing a heavy lead apron for long periods of time.  

Footnote

¹The RCN recognises and embraces our gender diverse society and encourages this position to be used by and/or applied to people who identify as non-binary, transgender or gender fluid. 

The RCN also recognises that not all those born female or male will identify with the same gender nouns, but for ease of reading use the term woman/man and where appropriate acknowledge non-binary terms.

²The term female is used in this context to refer to biological sex, in line with the scientific literature relating to breast cancer.

 

References  

British Orthopaedic Association (n.d.) Breast cancer risk. Available at: https://www.boa.ac.uk/standards-guidance/radiation-exposure-in-theatre/breast-cancer-risk.html (Accessed: 9 February 2026).

British Standards Institution (2025) BS 30417:2025 Provision of inclusive personal protective equipment (PPE) – Guide. London: BSI. Available at: https://www.bsigroup.com/en-GB/insights-and-media/insights/brochures/bs-30417-provision-of-inclusive-personal-protective-equipment-ppe-guide/ 

International Agency for Research on Cancer (IARC) (2012) IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. Volume 100D: Radiation. Lyon: IARC. Available at: https://monographs.iarc.who.int/agents-classified-by-the-iarc/ (Accessed: 9 February 2026).  

Kydd, A. (2021) ‘Menopause and personal protective equipment: how does this meet acceptable working conditions?’, Case Reports in Women’s Health, 32, e00356. Available at: https://rgu-repository.worktribe.com/OutputFile/1447294 (Accessed: 9 February 2026) 

Lynch C (2025) Literature search: Personal protective equipment (PPE)/respiratory protective equipment (RPE) at work and suitability relation to equality, diversity and inclusion in nurses. Date of search: 20/8/25. London: RCN Library and Museum.   

Royal College of Nursing (2020) RCN Survey on PPE Access and Safety During COVID‑19. Survey findings reported in Nursing in Practice, 28 May. Available at: https://www.nursinginpractice.com/latest-news/bame-staff-have-less-access-to-ppe-survey-finds/

UK Covid‑19 Inquiry (2026) Module 3 Report: Impact of Covid‑19 pandemic on healthcare systems in the four nations of the United Kingdom. Cabinet Office. Published 19 March 2026. Available at: https://www.gov.uk/government/publications/uk-covid-19-inquiry-impact-of-covid-19-pandemic-on-healthcare-systems-in-the-four-nations-of-the-united-kingdom-module-3-report 

 

Related Health and Safety legislation 

England, Scotland and Wales  

Health and Safety at Work etc Act 1974  

Management of Health and Safety at Work Regulations 1999 

Control of Substances Hazardous to Health Regulations 2002  

Personal Protective Equipment at Work Regulations 1992 (as amended)  

Personal Protective Equipment Regulations 2002 

Ionising Radiations Regulations 2017  

Personal Protective Equipment (Enforcement) Regulations 2018 

Safety Representatives and Safety Committee Regulations 1977 

Health and Safety (Consultation of Employees) Regulations 1996 

Northern Ireland  

Health and Safety at Work (Northern Ireland) Order 1978 

Management of Health and Safety at Work Regulations (Northern Ireland) 2000 

Control of Substances Hazardous to Health Regulations (Northern Ireland) 2003 

The Personal Protective Equipment at Work Regulations (Northern Ireland) 1993 

Personal Protective Equipment (Enforcement) Regulations 2018 

Safety Representatives and Safety Committee Regulations (Northern Ireland) 1979 

Health and Safety (Consultation of Employees) Regulations (Northern Ireland) 2016 

 

Equality legislation 

England, Scotland and Wales  

The Equality Act 2010

Northern Ireland 

The Sex Discrimination (Northern Ireland) Order 1976 

The Disability Discrimination Act 1995 

The Race Relations (Northern Ireland) Order 1997 

The Northern Ireland Act 1998 (Section 75) 

The Fair Employment and Treatment (Northern Ireland) Order 1998 

The Employment Equality (Age) Regulations (Northern Ireland) 2006 

The Windsor Framework (Implementation) Regulations 2024