Is your employer responsible for providing sunscreen?

Providing sunscreen to employees who work outdoors has become an increasingly important topic. Should employers provide it, or is sun protection a personal responsibility? Around the world, the answer differs. In this article, I’ll explain how different countries regulate sunscreen at work.

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Why sunscreen at work is becoming increasingly important

It’s no surprise that more people are asking whether employers should provide sunscreen. Summers are becoming hotter, and we know far more about the dangers of ultraviolet (UV) radiation than we did in the past.

UV radiation causes an estimated 80 to 90 percent of all skin cancer cases. As a result, people who work outdoors every day face a much greater risk than those who work indoors.

According to the UK’s Health and Safety Executive (HSE), occupational exposure to UV radiation causes around 60 deaths every year. It also leads to approximately 1,500 new cases of skin cancer annually.

Australia faces an even bigger challenge. Every year, occupational UV exposure contributes to around 200 cases of melanoma and approximately 34,000 cases of skin cancer. In the Netherlands, nearly 5,000 people develop skin cancer each year after being exposed to the sun at work.

 

Is providing sunscreen part of employer responsibility?

If you work outdoors and there is a risk of falling objects, your employer provides a safety helmet. If your feet are at risk, you wear safety footwear. If you need to stay visible, you wear high visibility clothing. Employers provide all of these items as personal protective equipment (PPE), and in many situations employees must wear them.

Working in the sun also exposes you to physical risks. It can cause sunburn and, in the worst cases, skin cancer. So should sunscreen also count as PPE?

At first glance, the answer seems obvious. Yet countries around the world still disagree. Some consider sunscreen a personal care product, making it the employee’s responsibility. Others argue that employers should provide sunscreen whenever employees have to work outdoors because protecting workers is part of their duty of care.

Employer responsibility for providing sunscreen

For many years, the Netherlands had no clear rules on sunscreen at work. However, several collective labour agreements (CAOs) now include sun protection.

For example, the Dutch roofing industry agreement states that employers must provide UV protective clothing, UV protective sunglasses, a cap with a neck flap and sunscreen.

The Dutch construction and infrastructure agreement requires sunscreen to be available on construction sites. Many companies have therefore introduced sunscreen stations, alongside providing shade and protective clothing. Similar provisions can also be found in agreements covering landscaping and green maintenance workers.

SPF is PPE

Several years ago, the British Trades Union Congress (TUC) launched the campaign “SPF is PPE.” The message was simple: sun protection should be considered part of personal protective equipment.

In the UK, occupational exposure to UV radiation is recognised as a workplace hazard. This extends beyond construction workers and roofers. Teachers and teaching assistants supervising children outdoors are often provided with sunscreen by their employer. In some cases, sunscreen is also made available to pupils. Employees of the London Underground who regularly work outside are also supplied with sunscreen.

Australia has taken a similar approach. Since 2002, employers have been able to claim tax deductions for providing sun protection to employees. The Australian government considers sunglasses, sunscreen and sun hats to be just as important as safety boots, helmets or protective gloves.

Why employers are not always responsible for providing sunscreen

Despite these developments, the UK and Australia remain exceptions.

In most countries, sunscreen is recommended, but employees are generally expected to purchase it themselves.

In the United States, for example, employers are not legally required to provide sunscreen. However, workers are advised to use sunscreen with a minimum SPF of 15.

Even in countries with extremely high temperatures, such as Saudi Arabia, Singapore and Japan, regulations mainly focus on providing drinking water, rest breaks and shade rather than sunscreen.

Providing sunscreen encourages its use

Although most countries consider sunscreen a personal responsibility, employers can make a real difference simply by providing it.

A Dutch study on construction sites found that 44.4 percent of workers never used sunscreen on their own. When employers made sunscreen available, that figure dropped to 35.3 percent.

Australia shows what a broader sun protection policy can achieve. Around 95 percent of outdoor workers use some form of sun protection. Half regularly apply sunscreen, while two in five wear a sun hat.

The UK shows a similar pattern. Around 70 percent of outdoor workers use sunscreen. Among those who do not, 16 percent say their employer does not provide it. Almost one quarter say they would use sunscreen more often if it were readily available at work.

Is your employer responsible for providing sunscreen?

Personally, I find it remarkable that occupational safety regulations often focus on protecting specific body parts while largely overlooking the skin, the body’s largest organ.

At the same time, I understand why many employers hesitate to provide sunscreen when the law does not require it. To protect yourself properly, you need to apply sunscreen every two hours and use a generous amount each time. A 200 ml bottle provides only around twelve applications for half of the body, assuming the other half is covered by clothing. For employers with large numbers of outdoor workers, those costs can add up quickly.

But the same principle applies to every form of PPE. In the long run, protecting employees costs less than dealing with occupational illnesses or injuries.

Best,

Aileen