COSHH 2002 and INDG479, UK wide
Face Fit Testing and RPE Programmes
A tight fitting mask that does not seal against the individual face wearing it is not protective equipment. It is a false sense of security with a purchase order behind it. AL23 Safety arranges and manages face fit testing to INDG479 revision 2 and builds the wider respiratory protection programme around it, for clients UK wide.
What is face fit testing?
Proving the seal on the individual face that will wear the mask
Face fit testing checks that a specific make, model and size of tight fitting facepiece forms an adequate seal on a specific person. Faces vary in width, depth, nose bridge and chin profile far more than mask sizing allows for. The test is carried out on the person rather than on the mask.
The operative guidance is INDG479 revision 2, "Guidance on respiratory protective equipment fit testing", published by HSE in October 2025. It is a new revision and it is the version to work to in 2026. The change introduced in revision 2 is a clarification that testing may be carried out using either a flush or an extended port on the facepiece.
There are two families of test. Qualitative testing is a pass or fail based on the wearer's own detection of a bitter or sweet test aerosol inside a hood. Quantitative testing produces a numerical fit factor, either by ambient particle counting or by controlled negative pressure. Fit testing is one component of a programme. The COSHH assessment has to establish that respiratory protection is the right control before any of it makes sense.
Who needs one
Every wearer, every mask, every time the variables change
- Anyone issued a tight fitting facepiece where control of exposure relies on it, disposable, reusable half mask or full face
- New starters, before they are allowed to carry out the exposed task rather than at the next convenient training day
- Any change of respiratory protection type, size, model or material, a switch of manufacturer at the same nominal size included
- Significant weight change, dental work, facial surgery, scarring or new piercings in the seal region
- Wearers who have started using other head worn equipment that interferes with the seal, including eye protection, hearing protection and helmets
- Licensed and notifiable non-licensed asbestos work, confined space entry, lead work and work with ionising radiations, where the supporting Approved Codes of Practice require fit testing
Loose fitting powered equipment such as hoods, visors and blouses needs no fit test because it does not rely on a face seal. That is the working answer for anyone who cannot be clean shaven.
The regulations that apply
Your legal framework, in plain terms
There is no regulation called the fit testing regulations. The duty is constructed from the requirement that respiratory protection be suitable, which appears in the Control of Substances Hazardous to Health Regulations 2002 and in the parallel regimes covering lead, asbestos, confined spaces and ionising radiations. INDG479 revision 2 confirms that it is the Approved Codes of Practice supporting those five regimes that require fit testing. Below the whole structure sits the Health and Safety at Work etc. Act 1974.
COSHH 2002, regulation 7
Where control of exposure requires respiratory protection, that equipment must be suitable. A tight fitting facepiece that does not seal on the wearer is not suitable, which is where the fit test comes from. The Approved Code of Practice L5 makes this explicit.
Control of Asbestos Regulations 2012, Control of Lead at Work Regulations 2002, Confined Spaces Regulations 1997 and Ionising Radiations Regulations 2017
The same construction applies under each, through their supporting Approved Codes of Practice.
Personal Protective Equipment at Work Regulations 1992
Regulation 4 provision of suitable equipment, regulation 6 assessment, regulation 7 maintenance and replacement, regulation 9 information, instruction and training, regulation 10 use. Where COSHH applies it takes precedence over these regulations for respiratory protection.
HSG53, fourth edition, 2013
The practical guide to respiratory protection at work. It carries the adequate and suitable distinction that a defensible programme is built on.
COSHH regulation 9(4)
Maintenance, examination and test records for non-disposable respiratory protection must be kept for 5 years. INDG479 requires fit test reports to be kept for a minimum of 5 years and accessible to employees and enforcing authorities.
What the service covers
Testing, selection and the programme around it
- Qualitative testing of disposable and reusable half masks using bitter denatonium benzoate or sweet saccharin aerosol, preceded by a taste threshold screening on every candidate
- Quantitative testing by ambient particle counting or controlled negative pressure, covering half masks, full face masks and powered respirators
- The full exercise sequence, a minimum of seven exercises each lasting at least one minute, from normal breathing through head turning, talking and bending and back to normal breathing
- Pass criteria applied without softening. Disposable and reusable half masks must reach a fit factor of 100. Full face masks must reach 2,000.
- A check against the ambient particle counting limitation, since FFP1 and FFP2 disposables can only be PortaCount tested where N95 technology is employed
- Verification that the wearer is clean shaven in the seal region, with the test refused where there is any hair growth between the skin and the sealing surface
- Selection advice for wearers who cannot be clean shaven, built on loose fitting powered equipment rather than a larger mask
- Selection matched to measured or assessed exposure by assigned protection factor, informed by exposure monitoring where the exposure is not already quantified
- Pre-use check routines for wearers, plus a maintenance and examination regime for reusable equipment
Our process
From exposure data to a valid register
- 01
Programme review
We start with the exposure and the assessment. Where extraction should be doing the work that masks are currently doing, we say so before testing anybody.
- 02
Selection
We match equipment to the hazard by assigned protection factor and to the job by wear duration, communication, visibility and compatibility with other equipment.
- 03
Testing
Tests run on site during normal working, with taste screening ahead of qualitative tests and calibration checks ahead of quantitative ones. A wearer who fails is refitted with a different size or model and retested.
- 04
Reporting
Each wearer receives a report to the Annex 1 content standard. You receive a register showing who passed and on which model and size, plus who has no valid pass.
- 05
Programme and review
We write the policy, set the review triggers and agree a repeat testing system built on your risk rather than a calendar habit.
What you get
A report per wearer and a live register
- An individual fit test report for every wearer, naming the make, model, size, method, exercises and result
- A site register of valid passes, cross-referenced to the tasks each wearer is authorised to carry out
- A written respiratory protection programme covering selection, fit testing, clean shaven policy, pre-use checks, maintenance and supervision
- A review system for repeat testing, with the reasoning recorded rather than an arbitrary date
What we need from you
The exposure basis and who wears what
- The exposure data or assessment that led to respiratory protection being selected
- The makes, models and sizes currently issued, plus confirmation of what is available to swap to
- A list of wearers by task, with advance notice of the clean shaven requirement given to each
Why AL23 Safety
A failed test is reported as failed
Accountable
A failed test is reported as a failed test. We do not repeat a test until it passes and call that a pass.
Honest about intervals
HSE sets no retest frequency. We will tell you that, then help you build a defensible review system instead of selling you an annual cycle as though it were the law.
The programme, not just the test
We scope the work, appoint the right specialist, interpret the results and turn them into an action plan you can actually deliver.
UK wide
We arrange and manage fit testing for clients across the UK from our Manchester base, on construction sites, in factories, laboratories and healthcare settings.
Talk to us about your RPE programme
A straight read on whether your masks are doing anything
If you have a drawer of fit test certificates and no idea whether any of them are still valid, describe the situation on a call. No obligation.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usThis is the question the market answers badly. INDG479 revision 2 sets no fixed interval. It requires a system for reviewing when a repeat test is needed, plus a retest whenever the equipment type, size, model or material changes or the wearer's circumstances change. Annual testing for high hazard work and a two yearly cycle for stable lower risk work are industry convention. They are defensible as a review system. They are not guidance and not law.
Price is driven by the number of wearers, the test method, the number of models and sizes you issue and whether a full group can be tested in one visit. Quantitative testing costs more per head than qualitative because of the equipment and the time involved. Tell us the headcount and the shift structure and we will scope it.
No. INDG479 is unambiguous that a fit test must not be conducted where there is any hair growth between the skin and the sealing surface. Wearers must be clean shaven in the seal region whenever they wear a tight fitting facepiece at work. Stubble defeats the seal as effectively as a full beard. Where facial hair is worn for religious or other justified reasons the correct answer is loose fitting powered equipment, which needs no fit test at all.
No. The claim is repeated often enough to be worth correcting. Qualitative testing is not permitted for full face masks, which is categorical. For disposable FFP3 and reusable half masks it remains permitted by INDG479. Many high hazard sectors, licensed asbestos work and healthcare among them, require quantitative testing by policy or contract because a numerical fit factor is auditable and a taste test is not.
Disposable half masks and reusable half masks require a minimum fit factor of 100. Full face masks require 2,000. An older figure of 500 for full face masks still circulates from legacy HSE inspector guidance. INDG479 revision 2 states 2,000. That is the number we work to. Be aware also that some published fit testing companion guidance still refers to the April 2019 version of INDG479 rather than to revision 2.
The legal requirement is that testing is carried out by a competent person. Fit2Fit, run by the British Safety Industry Federation, is a voluntary scheme and it is the route HSE inspectors are pointed at to identify competent testers. HSE's own formulation is that following the scheme is not compulsory and that employers are free to take other action to comply.
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