The law does not say "women's PPE" anywhere — but it does say PPE must be a "suitable size and fit" and "reasonably comfortable", and that duty does not disappear because someone is a woman or smaller-stature. Ill-fitting gear is not a comfort issue; it is a safety failure. Here is the duty, the real risks, and the facilities side.
The "suitable size and fit" duty
The model WHS Regulations require a PCBU to provide PPE that is suitable for the work and the hazard, a suitable size and fit for the individual worker, and reasonably comfortable (Regulation 44). The language is gender-neutral — there is no explicit "female PPE" clause — but the duty applies to everyone, including women, pregnant workers and smaller-stature workers. And the PCBU keeps the duty even if the worker buys their own PPE with an allowance. Because standard stock is sized for the "average male", regulators and specialists increasingly read "suitable size and fit" as requiring women-specific or inclusive sizing, not "make do with oversize gear" — providing only male-cut PPE to a woman does not satisfy the duty.
(Enforcement note: recent prosecutions focus on broader failures — falls, plant, silica, psychosocial — rather than a stand-alone "ill-fitting women's PPE" case, but a serious injury linked to obviously unsuitable PPE could form part of a case.)
Why ill-fitting PPE is a safety failure
Ill-fitting gear forces workers to roll up sleeves, tape excess fabric, or skip items — creating secondary hazards:
- Harnesses designed for a male torso put chest straps across the breasts or neck, so they get loosened or mis-positioned — undermining fall-arrest performance — and webbing that will not shorten enough slips in a fall.
- Gloves that are too large cut grip strength, snag in rotating plant, and get removed for fine work, risking lacerations.
- Boots shaped for men cause heel lift and instability on ladders, trips on uneven ground, and blisters and fatigue that lead to slips.
- Hi-vis and clothing that is oversized snags on scaffold and plant, can be pulled into moving parts, and restricts movement on ladders.
A 2023 academic study found women in Australian construction still struggle to access properly-fitting PPE, relying on modifying men's gear or buying their own, with limited organisational support — a gap between what the market sells and what sites actually issue.
Welfare facilities
The WHS Act and Regulations require a PCBU to provide adequate welfare facilities — toilets, drinking water, washing and change areas — having regard to the work and site. Where both sexes are employed, the standard is separate or lockable facilities for privacy where reasonably practicable (separate female toilets, or unisex single-occupancy with locks and hygiene provision). Recent psychosocial-risk guidance is explicit that poor facilities, a lack of privacy, and unsafe access (poorly-lit paths to amenities) contribute to gender-based harm — so if women are on site, the PCBU must provide facilities that let them use the toilet, wash and change safely and privately. Decent amenities also signal that women are permanent workers, not "guests".
The market and the advocacy
Australian suppliers increasingly stock women's ranges — women's safety boots, narrower gloves, smaller eye protection, women's fall-arrest harnesses, and women's and maternity hi-vis — and the better brands design for women's body shapes rather than scaling down men's. NAWIC and allied groups advocate for women's PPE and better amenities to be treated as standard inventory, not a special order, and the federal WHS (Sexual and Gender-based Harassment) Code of Practice (2025) ties workplace design and facilities into gender safety. The bottom line: "suitable size and fit" plus the welfare-facility duty already give a clear hook — if a woman's PPE or her access to private, safe amenities is visibly compromised because only male-normed gear and facilities are provided, the PCBU is unlikely to be meeting its WHS duties, even though the law does not yet spell out "female PPE".
Common mistakes
- Treating ill-fitting PPE as a comfort gripe rather than a fall-arrest, grip or stability hazard.
- Issuing only male-cut PPE and expecting women to "make do".
- No private, lockable toilet or change facilities where women are on site.
- Treating women's PPE as a special-order afterthought instead of standard stock.
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