When does site equipment need a PUWER inspection?
PUWER regulation 6 requires an inspection where an item's safety depends on how it is installed, and where it is exposed to conditions that cause deterioration liable to lead to danger. The result must be recorded. Plenty of site kit only needs a quick check before use, and lifting equipment is covered by LOLER instead.
What the law requires
PUWER is the Provision and Use of Work Equipment Regulations 1998, which apply in Great Britain. The duties fall on employers, self-employed people the regulations cover, and anyone who controls the equipment. Regulation 6 requires that:
- where safety depends on how equipment is installed, it is inspected after installation and before first use, or after assembly at a new site or location, to make sure it is correct and safe to operate
- equipment exposed to conditions causing deterioration that could lead to danger is inspected at suitable intervals, and each time exceptional circumstances occur that could jeopardise its safety
- the result of each inspection is recorded and kept until the next inspection is recorded
- equipment that leaves your business, or that you hire in, is used only if it comes with physical evidence of its last required inspection
Regulation 6 does not apply to lifting equipment, to equipment inspected under CDM 2015 as part of an excavation or cofferdam inspection, or to equipment covered by regulation 12 of the Work at Height Regulations 2005, such as working platforms. It sets no fixed interval. The word it uses is suitable.
What HSE suggests
The following is HSE guidance, not a legal requirement:
- decide through risk assessment whether an item needs inspecting and how often, taking the manufacturer's recommendations into account
- inspect only what matters for safety, and tailor checklists to the equipment, because too much detail too often leads to tick-box checking
- records need not be on paper, but electronic records should be held securely and be available to an enforcing authority
- for smaller items, tagging, colour coding or labelling can serve as evidence of the last inspection
- harsh outdoor conditions are likely to need more frequent inspection, and intervals can be lengthened or shortened in light of what inspections find
Who inspects
Regulation 6 does not say who must carry out an inspection. HSE says it can be anyone with enough knowledge and experience of the equipment to know what to look at, what to look for and what to do if they find a problem, and that this can often be done in-house. The competence needed depends on the equipment and how it is used. For specialist kit, check with the supplier.
Pre-use checks, inspections and maintenance
Not everything needs a formal inspection. HSE says a quick visual check before use is often enough, such as the cable on a hand-held power tool or the brakes and lights on mobile machinery, and records are not normally needed for the simplest of these. HSE describes a range, from pre-use checks to weekly checks of guards, safety devices and tyres on mobile plant, to detailed examinations every few months or longer.
Maintenance is a separate duty that always applies. Regulation 5 requires work equipment to be kept in an efficient state, in efficient working order and in good repair, and any maintenance log to be kept up to date.
Guards, information and training
- Guards (regulation 11). The law requires effective measures to stop people reaching dangerous parts of machinery, or to stop the parts before a person enters the danger zone. Fixed guards come first where practicable, then other guards or protection devices, then jigs, holders or push-sticks, plus the information, instruction, training and supervision needed. Guards must be maintained and not easily bypassed.
- Information (regulation 8). Users, and employees who supervise them, must have adequate health and safety information and, where appropriate, written instructions they can understand.
- Training (regulation 9). Users and supervisors must have had adequate health and safety training. HSE says in-house training using the manufacturer's instructions can be enough for everyday equipment, and that it should be in working hours at no cost to the worker. The PUWER Approved Code of Practice says self-propelled equipment should only be driven by trained workers.
An Approved Code of Practice is not law, but HSE says following it normally means you are doing enough to comply.
How PUWER fits with LOLER
Lifting equipment is also work equipment, so PUWER duties such as maintenance, information and training apply to it as well as LOLER. The difference is inspection. PUWER regulation 6 leaves lifting equipment out because LOLER regulation 9 sets thorough examination and inspection for it. For a lift truck, HSE says other parts such as brakes and lights come under PUWER, with essential daily pre-use checks.
Sources
- legislation.gov.uk: PUWER 1998, regulation 3 (application)
- legislation.gov.uk: PUWER 1998, regulation 5 (maintenance)
- legislation.gov.uk: PUWER 1998, regulation 6 (inspection)
- legislation.gov.uk: PUWER 1998, regulation 8 (information and instructions)
- legislation.gov.uk: PUWER 1998, regulation 9 (training)
- legislation.gov.uk: PUWER 1998, regulation 11 (dangerous parts of machinery)
- legislation.gov.uk: Work at Height Regulations 2005, regulation 12
- HSE: Inspection of work equipment
- HSE: Maintenance of work equipment
- HSE: Training and competence (PUWER)
- HSE: PUWER overview
- HSE: LOLER frequently asked questions