How to prepare for a PUWER inspection

This Article is a sub-topic of the PUWER Guide
Aug 04, 2023

Responding to Defects

As a result of statutory inspections required by PUWER, COSHH, DSEAR, LOLER and others there are going to be defects found. After all, that is the point. For each defect you will have a risk estimation provided to help you (the user) make good decisions about where to apply resources to protect your workers and others most effectively.

The problem comes where you have a large operation with many instances of defects. It would be great if resources were available to cover 100% of actions that are required but that isn't a reality for most businesses. Even if you have the cash to cover the actions required, the marketplace (external providers) or workforce (internal resources) may only provide a certain capacity and rate at which they can address the actions for you. There is no silver bullet.

Other factors also come in to play. Some changes may have immediate operational impact that pose a threat to business continuity. Or perhaps a litigation is required to recover costs for corrections from a supplier or integrator. Suffice to say, things are not always as simple as we would like them to be and poor decision making can threaten jobs.

Each business, decision makers, duty holders and supervisors, must find a sustainable way forward that is acceptable and despite the many slogans such as 'safety first' and 'no job is worth doing if it isn't worth doing safely' fade into white noise as decisions are made that expose workers to risk that is deemed 'reasonable' given the alternative. Once risk is introduced to the workplace this is inevitable. Therefore checks on new ways of working, new work equipment or modifications etc are very important to achieve sustainable safety. The aim being to avoid or reject the change that is bringing the 'off-side' risk into your workplace. But what if this change is crucial to the business short term or long-term objectives in relation to competitiveness?

This moral conundrum is rarely acknowledged outside of the senior's meetings, but it plays a huge part in every business at all levels with great influence on the resulting risk profile that workers are exposed to. Subsequently these workers familiarise themselves with these risks and with familiarity comes contempt and ambivalence. Before you know it you have a safety culture problem as the presence of one risk justifies another by comparison.

Governance is Key

You can't remove the moral and practical conundrums, but you can establish the criteria by which you hold the business to account. In this way you are increasing the consistency with which you measure the rate of progress towards compliance with the control measures determined by the inspector/assessor thus reducing risk in the workplace.

As an example, the Preliminary Hazard Analysis risk estimation methodology provides not only a way to estimate risk but also a time within which you should 'agree action requirement to reduce the hazard rating number (HRN). The intention is to set a pace for decision making that is proportional to the risk level. Note: For the purposes of this explanation we will take HRN to be synonymous with 'Risk Level'.


Working with Risk

As discussed previously, it is not uncommon to have a mismatch between resources that are practical and available versus the number of defects identified that require those resources. It is necessary to prioritise and accept some delay in decision making as a result of this but this method provides the extent to which delays in decision making should be acceptable.

The 'agree action response time' is the time permitted to decide how to proceed safely towards a state of compliance i.e. implement the control measure as given in the defect risk assessment. It is not the time permitted in order to complete the control measure. Depending on the risk assessment and the business risk tolerance, the action response may introduce some temporary measures that permit continued use/working leading up to a time that the permanent fix can be applied.

In our experience there are rarely any circumstances where the above timelines cannot be achieved.

Our guide for PUWER inspection Planning and Preparation (PIPP) includes an example workflow that shows how risk based decision making fits in to a coherent strategy for PUWER and Machine safety.

To learn more about PUWER read our Guide: The ultimate guide to PUWER

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