Poland: PAPR rules for welding — Kodeks pracy, NDS limits and CIOP-PIB guidance

In Poland, respiratory protection for welders sits on three legal layers: the Labour Code (Kodeks pracy) and the 1997 general OSH regulation, which oblige employers to assess and document occupational risk, prefer collective controls over individual protection, and supply CE-marked PPE free of charge; the NDS occupational exposure limit system (regulation of 12 June 2018, most recently amended by Dz.U. 2026 poz. 447), which sets substance-by-substance limits for welding-fume components such as manganese, chromium(VI) and nickel; and the EU PPE Regulation 2016/425, under which powered air-purifying respirators are Category III products — with CIOP-PIB acting as Poland’s notified body No. 1437 and publishing non-binding selection and protection-factor guidance for employers. Standards-wise, PKN has replaced PN-EN 12941:2002 and PN-EN 12942:2002 with PN-EN 12941:2024-06 and PN-EN 12942:2024-06 (adopting EN 12941:2023 / EN 12942:2023). Current as of July 2026.

Which rules apply

Polish respiratory-protection duties for welding flow from the Labour Code (Kodeks pracy, Act of 26 June 1974). Article 237(6) obliges the employer to provide, free of charge, personal protective equipment against dangerous and harmful workplace factors, and Article 228 § 3 is the legal basis for the NDS exposure-limit regulation. Below the Code sit the general OSH regulation of the Minister of Labour of 26 September 1997 (consolidated text Dz.U. 2003 No 169, item 1650, as amended, notably by Dz.U. 2007 Nr 49 poz. 330) and a welding-specific regulation of the Minister of Economy of 27 April 2000 on OSH in welding work (Dz.U. 2000 No 40, item 470). The general regulation requires the employer to assess the occupational risk of the work performed (§ 39a) and to document that assessment and the preventive measures applied (§ 39a ust. 3); § 39 ust. 2 sets the general prevention principles the employer must follow, including eliminating hazards at their source and giving priority to collective protective measures over individual ones; § 39c requires the employer to inform workers of the hazards against which personal protective equipment will protect them and points to Annex 2 for the detailed rules on selecting and using that equipment. The welding regulation covers welding, surfacing, brazing/soldering, resistance welding (zgrzewanie) and thermal cutting. Exposure limits are set by the NDS regulation of 12 June 2018 (Dz.U. 2018, item 1286, as amended), carcinogen duties by the Minister of Health regulation of 26 July 2024 (Dz.U. 2024, item 1126), and measurement duties by the Minister of Health regulation of 2 February 2011 (consolidated text Dz.U. 2025, item 949). The Państwowa Inspekcja Pracy (National Labour Inspectorate) enforces these labour-law provisions.

Approval and certification of PAPR

PAPR sold in Poland is regulated directly by Regulation (EU) 2016/425 on personal protective equipment, applicable since 21 April 2018 — there is no separate national approval scheme. Respiratory protective equipment is Category III (protection against the most serious risks), so a device must pass EU type-examination (module B) plus ongoing conformity checks (module C2 supervised product checks or module D production quality assurance), and must carry the CE mark followed by the identification number of the notified body overseeing production. The Labour Code requires that PPE given to workers meets these conformity-assessment requirements. Poland’s own notified body for PPE is CIOP-PIB (Central Institute for Labour Protection – National Research Institute), notified body No. 1437, whose certification centre issues EU type-examination certificates and publishes a public list of them. The relevant product standards are PN-EN 12941 (powered air-purifying devices with loose-fitting facepieces — the category covering welding-helmet PAPR) and PN-EN 12942 (powered devices with tight-fitting masks), both published by the Polish Committee for Standardization (PKN) as identical adoptions of the European EN standards.

Employer and programme duties

Under the Labour Code the employer supplies PPE free of charge, informs workers how to use it, and may not admit an employee to work without the required PPE. The 1997 general OSH regulation sets out the prevention hierarchy in § 39 ust. 2: the employer must act on the general principles for preventing accidents and occupational disease, in particular eliminating hazards at their source and giving priority to collective protective measures over individual protective equipment. Separately, § 39a requires the employer to assess the occupational risk arising from the work performed — including from the chemical, biological, carcinogenic or mutagenic substances used and from changes in work organisation — and § 39a ust. 3 requires that assessment, and the preventive measures applied as a result, to be documented. Where individual protection is still needed after collective measures, § 39c requires the employer to inform workers of the hazards concerned and directs to Annex 2 for the detailed rules on selecting and using PPE. Employers must also measure harmful agents: under the 2011 measurements regulation (consolidated 2025 text, § 4), ordinary chemical agents and dusts are re-measured at least every two years when the last result was between 0.1 and 0.5 of the NDS and at least annually above 0.5 NDS; under § 6, for carcinogens, mutagens and reprotoxic substances the frequencies tighten to at least every six months (0.1–0.5 NDS) and every three months (above 0.5 NDS), using accredited laboratories (§ 5 sets a separate continuous-measurement duty that applies only to substances with a ceiling value, NDSP). Where carcinogens such as chromium(VI) or nickel compounds are present, the 26 July 2024 Minister of Health regulation additionally requires a register of the work and a register of exposed workers.

Welding fume: exposure limits (NDS)

Poland has no single NDS for “welding fume” — the current NDS annex (as replaced by Dz.U. 2026 poz. 447) contains no welding-fume entry, so exposure is assessed against the limits for the fume’s component substances. Key current values: manganese and its inorganic compounds 0.2 mg/m³ (inhalable fraction) and 0.05 mg/m³ (respirable); iron oxides (as Fe) 5 mg/m³ inhalable and 2.5 mg/m³ respirable; chromium(VI) compounds 0.005 mg/m³; nickel compounds 0.05 mg/m³ inhalable and 0.01 mg/m³ respirable (in force since 18 January 2025 under Dz.U. 2024 poz. 1017, implementing Directive (EU) 2022/431); nitrogen dioxide 0.7 mg/m³ (NDSCh short-term 1.5); ozone 0.15 mg/m³; carbon monoxide 23 mg/m³ (NDSCh 117). Chromium(VI) and many nickel compounds are category 1A/1B carcinogens, which pulls stainless-steel welding into the stricter carcinogen regime, although welding itself is not one of the technological processes listed in Annex 1 of the 2024 carcinogen regulation. The welding OSH regulation requires welding rooms to have ventilation that effectively removes health-harmful contaminants (§ 8) and fixed welding stations that can emit harmful dusts and gases to have workstation (local) ventilation (§ 9).

Selection and protection factors (CIOP-PIB guidance)

CIOP-PIB, the national OSH research institute, publishes the selection method used in practice. Its guidance defines a minimum required protection factor (MPF) as the measured workplace concentration divided by the NDS, and states that correctly selected equipment should have a nominal protection factor (NPF) higher than that MPF. CIOP-PIB’s 2024 training material (task 7.ZS.07, Łódź 2024) tabulates both nominal and assigned (“wyznaczony”, APF) protection factors for powered air-purifying equipment: loose-fitting devices (hoods/helmets, the PN-EN 12941 type used in welding PAPR) — TH1 NPF 10 / APF 10, TH2 NPF 50 / APF 20, TH3 NPF 500 / APF 100; tight-fitting devices (PN-EN 12942 masks, power on) — TM1 NPF 20 / APF 10, TM2 NPF 200 / APF 50, TM3 NPF 2000 / APF 500. As an illustration, CIOP-PIB material shows that at roughly 4× NDS a class-1 device is arithmetically sufficient but a class-2 device is recommended for margin; for high-exposure scenarios its examples point to TH3 hood/helmet devices or TM3 masks. With chromium(VI) NDS at 0.005 mg/m³, stainless-steel MIG/TIG work can generate high NDS multiples, which is why the class calculation matters. These CIOP-PIB values are institute guidance, not a binding legal protection-factor table — Poland has no regulation fixing assigned protection factors.

What changed recently and what is changing

Poland’s framework moved substantially in 2024–2026. From 28 July 2024, the new Minister of Health regulation (Dz.U. 2024 poz. 1126) replaced the 2012 carcinogen rules and extended registers, measurement and information duties to reprotoxic substances; the measurements regulation was amended in parallel (consolidated text now Dz.U. 2025 poz. 949). From 18 January 2025, nickel-compound NDS values dropped to 0.05/0.01 mg/m³ (inhalable/respirable) under Dz.U. 2024 poz. 1017. The amendment of 26 March 2026 (Dz.U. 2026 poz. 447, in force 2 April 2026) replaced the whole NDS annex, implementing Directives (EU) 2023/2668 (asbestos) and 2024/869 (lead and diisocyanates): lead falls from 0.05 to 0.03 mg/m³ (from 9 April 2026, flagged as a non-threshold reprotoxic substance), a group NCO diisocyanate limit of 0.01 mg/m³ (NDSCh 0.02) applies until 31 December 2028, and asbestos keeps a transitional 0.01 fibres/cm³ until 20 December 2029. On standards, PKN has withdrawn PN-EN 12941:2002 and PN-EN 12942:2002 and replaced them with PN-EN 12941:2024-06 and PN-EN 12942:2024-06, the identical adoptions of the revised EN 12941:2023 and EN 12942:2023 — the revised EN 12941 title now describes “loose-fitting breathing devices” rather than only helmets/hoods. Current as of July 2026.

Sources & disclaimer

This page is information, not legal or safety advice. It summarises the cited public sources as of the date above; regulations change — verify against the primary source before relying on it. Product-level approval status is covered by our four-tier compatibility system.