This is a short, succinct PUWER inspection guide for the person actually tasked with doing the PUWER inspections and resulting risk assessment (PUWER Assessor).
We have stripped out the jargon and legal bumph leaving only what is relevant to you as you look at the machine or work equipment.
Some aspects of the safe system of work (SSoW) which must be considered under PUWER have been removed as they are not applicable or practical to apply at the point of inspection. Some other arrangements should be made for these.
Regulation 1 – Citation and commencement (IGNORE)
Regulation 2 – Interpretation; avoiding the long version. If you have been tasked with doing a PUWER inspection on it then continue.
Regulation 3 – Application (IGNORE)
Regulation 4 – Suitability of work equipment. Issues to include:
Using something not as intended by original design. E.g.; poor modifications, poor original design, poor ergonomics (repetitive tasks)
Regulation 5 – Maintenance
State of repair must be good, all round special attention to safety critical parts such as interlocks, brakes, some seals etc.
Regulation 6 – Inspection (IGNORE)
Regulation 7 – Specific Risk
There is always residual risk. This is why the SSoW restricts use ‘authorised’ people.
Decide if it is an acceptable or a fair risk. If not, then add a risk assessment elsewhere. You need a good knowledge of best practice for that machine/equipment type to do this.
If it is acceptable, then IGNORE.
Regulation 8 – Information and instructions
This includes SOP’s, handbook, technical schematics, other info for fault diagnosis and PMs. They should be nearby or accessible with ease in English.
Regulation 9 – Training (IGNORE)
Regulation 10– Conformity with community requirements
Instruction handbook must be suitable and representative Identify obvious faults (including design faults). Knowledge of machine safety best practice and CE requirements is required
Regulation 11 – Dangerous parts of machinery
No access to moving parts where feasible is permitted. Check that preference been given, in descending order, so far as feasible by design to:
F – Fixed guards
I- Interlocking guards, trip devices, etc.
P – Protective appliances (non-interlocked physical measures other than guards)
S – Safe Systems of work
Regulation 12 – Protection against specified hazards
Check for the possibility of parts/objects/fluids/materials used or stored in the machine falling, or being ejected or exploding due to rupture or disintegration. Check for catching fire or overheating in the process or parts of the machines due to incorrect specification/modification/ maintenance practices. Where not feasible to design out, check suitable PPE is specified Regulation 13.
High or very low temperatures – check touch surfaces, fluids etc above/below a tolerable temperature. Typically above 65C and below -20C cause injury potential.
Regulation 14 – Controls for starting or making a significant change in operating conditions
Unless risk is negligible, check there is a start command that avoids accidental start. It must not start auto unless safe to do so (by guarding) and any change of mode/speed parameter that increases risk requires an operator intervention.
Regulation 15 – Stop controls
Check there is a stop control, that is stops safely, that is has priority over the start control and that stored energy is dissipated where required for safety.
Regulation 16 – Emergency stop controls
In most cases, by risk, there must be an Estop. It must be easily accessible from task areas and not be used other than testing and in an emergency and have priority over all start commands.
Regulation 17 – Controls
All controls must be clear and unambiguously identified in a manner appropriate to the environment. Their location must not be in a danger zone where feasible unless suitable additional measures for suspension of safeguards are taken (e.g. safe limited speed withhold to run).
Regulation 18 – Control systems
Check the original design is suitable (see Reg. 10). Functional checks to verify continued performance as specified by instruction handbook (assuming the handbook is available, full and complete… it often is not)
Regulation 19 – Isolation from sources of energy
Check that switches, valves and vents are provided, suitable and lockable in the off position. Information and marking should be clear as to purpose and affect.
Regulation 20 – Stability
Check for bolted to the floor if appropriate. Portable equipment needs means to restrain. Structural stability should not be compromised by the condition, environment or modification.
Regulation 21 – Lighting
Work equipment should be suitably and sufficiently lit by ambient lighting. However, detailed work may require additional lighting. Check it is identified and available.
Regulation 22 – Maintenance operations
The machine should designed or adapted so that maintenance tasks don’t expose anyone to any risk. Suitable measures need to be taken where this is not achieved.
Regulation 23 – Markings
Controls and other facets of the machine should be correctly and appropriately marked in a clear and consistent way.
Regulation 23 – Warnings
Warning notices and warning devices will make the user aware of hazards in order that they can avoid them during foreseeable tasks.
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