Getting your head around things with PUWER inspection and PUWER planning can be difficult when you have many other things to be thinking about too. This page walks you through some basics.
Navigate to the most popular sections of this article with the below links:
PUWER (Provision and Use of Work Equipment Regulations 1998) covers a set of regulations designed to ensure that all equipment and machinery in the workplace are safe to use and pose no significant, foreseeable risk to the health and safety of employees, employers and anyone else who has access to them.
If you would like to learn more about PUWER read our Guide: The Ultimate Guide to PUWER
In general terms, PUWER places duties on people who own, operate or control any work equipment and machinery used in any workplace to select appropriate equipment for their operations and ensure that it is fit for use through appropriate inspection and maintenance regimes. Work equipment is broadly defined by Regulation 3 of PUWER as:
Regulation 6 of PUWER specifies the requirement to complete suitable inspection and maintenance on all work equipment. A PUWER inspection can be either visual or a full system check with an element of testing, and must be carried out by a competent person.
Regulation 6 (5) of PUWER states that:
“(5) This regulation does not apply to;
(a) a power press to which regulations 32 to 35 apply;
(b) a guard or protection device for the tools of such power press;
(c) work equipment for lifting loads including persons;
(d) winding apparatus to which the Mines (Shafts and Winding) Regulations 1993 apply;
(e) work equipment required to be inspected by regulations 31(4) or 32(2) of the Construction (Design and Management) Regulations 2007*;
(f) work equipment to which regulation 12 of the Work at Height Regulations 2005 applies.”
*Now Regulations 22(4) and 23(2) of the Construction (Design and Management) Regulations 2015
Where work equipment is explicitly exempt from inspection there is no need to do one. In certain cases, even where equipment is not exempt from inspection you may make a risk based justification for not inspecting either inititially or at suitable intervals. A risk-based approach may be used to extend inspection intervals and may also provide justification for not re-inspecting an item if it is not reasonable to do so. However, the inspection prior to first use is still required and should be recorded in your formal safety management system. You can find out more here.
Certain types of work equipment that Regulation 6 of PUWER applies to also have additional inspection requirements attached to them under other legislation (e.g. LOLER, PSSR etc.). In some cases compliance with these separate requirements fulfils the general Regulation 6 inspection duty under PUWER. This depends on the asset type and hazard profile.
An example of equipment with additional inspection requirements but where Regulation 6 of PUWER still applies is a pressure system as part of machinery. The Pressure Systems Safety Regulations 2000 and associated inspection guidance documents specify timescales and inspection types, with timescales ranging between 12-120 months, depending on the vessel/pipework type, contents and application. However, if the PUWER inspection covers the pressure system to such an extent that further inspection under PSSR would not add value then that pressure system does not need the further inspection. The same is true in reverse i.e. if the PSSR inspection has considered failures that may result in release of pressure/steam then no further inspection is needed under PUWER due to the presence of that hazard/failure mode. However it is still likely that a PUWER inspection will be needed for other hazards and failure modes not covered by PSSR, e.g. dangerous moving parts failure to stop due to a loss of pressure.
A competent person is needed to plan an appropriate range of inspections based on the risks that are present and the scope/requirements for statutory inspection within the Regulations/ACOPs.
Equipment must be fully inspected and tested at installation and prior to first use in order to ensure it has been installed correctly and is safe to use. However, Regulation 6 of PUWER also requires that:
"where the work equipment is exposed to conditions causing deterioration which is liable to result in dangerous situations, it must be inspected at suitable intervals in order for any deterioration to be “detected and remedied within good time”.
This requirement is where 're-inspection' is required. For this purpose is not sufficient only to inspect new or modified work equipment. In addition to inspecting new/modified work equipment you must also determine an interval and schedule the next inspection.
The findings of these inspections and any resultant actions taken must be recorded until at least the next inspection.
A regime of future inspection and maintenance must then be put in place in accordance with PUWER and any other applicable legislation, taking into consideration risk assessment findings and manufacturer recommendations in terms of equipment inspection and maintenance intervals.
Inspection intervals depend on the equipment type, the associated risks and the particular work environment it is used in as this may cause more rapid deterioration. For example, equipment used outdoors may require more frequent inspection due to weather related factors.
Regulation 6 of PUWER requires that inspections are carried out by a competent person and that records are maintained, highlighting any defects found and the remedial actions required and subsequently taken. These records may be used to extend or reduce inspection intervals.
Intervals can be extended, and in rare cases no further inspection carried out, if the inspection history shows no defects or low levels of deterioration and the PUWER risk assessment shows the risk to be low. Conversely, intervals should be shortened where inspection findings show the risk is increased due to a volume of defects being consistently recorded.
It is difficult to justify not carrying out re-inspections as this relies on total confidence in the inspection and maintenance processes of an organisation. It also relies on robust change management procedures to ensure appropriate PUWER inspections are triggered for any new or repurposed work equipment.
A pre-use check is a general safety check that the equipment and any associated safety devices are functioning properly prior to each use – this is usually carried out by the equipment operator and is not classed as an inspection under PUWER, however it is noted as best practice in the associated guidance.
A visual inspection is where the equipment is visually checked for any obvious external deterioration and also to ensure all equipment parts that ensure the safe operation (such as guarding) is in good condition. This is not normally an in-depth check, but is more detailed than a pre-use check and is generally carried out more frequently than thorough inspections.
Thorough examinations comprise of a full functional check, usually with an element of testing involved. These are not required for work equipment unless it is a power press3.
Regulations that do normally include a thorough examination include:
3 ACOP Guidance for the ‘Safe Use of Power Presses’ can be found here.
More frequent inspections than are necessary can lead to equipment failure. This is particularly an issue for safety devices such as emergency stop buttons, which can often be over-tested if incorporated into pre-use check routines.
Inspections may be carried out weekly when the manufacturer recommendations coupled with risk assessment findings evidence that monthly would be sufficient; this could lead to that equipment failing unexpectedly (as well as wasting valuable resource and potentially increasing equipment downtime to carry out these increased inspections).
It is imperative that a full PUWER inspection and subsequent risk assessment on any defects, are completed and documented. Any equipment-specific legislative requirements and manufacturer recommendations must also be taken into consideration which will ensure appropriate ongoing inspection and maintenance regimes.
Spiers Engineering Safety have developed a PUWER Risk Mapping tool called ‘PUWER Inspection, Planning and Prioritisation’ (or ‘PIPP’, for short). This tool will help your to prioritise resources where they are most needed, based on risk. The purpose of this process is to provide a rationale for generating the PUWER register and maintaining it. This process will also help you plan in your inspections, ensuring the correct frequency is implemented.