Spiers Safety have developed a PUWER risk mapping method called “PIPP”. This enables your organisation 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.
Within any formal management system, it is necessary to keep records to track changes and review over time. The absence of a controlled list of items of work equipment i.e. The PUWER Register, means that there is in effect no control or review.
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The immediate benefit of having a formal and recorded approach include:
“An immediate reaction to an event without thinking or examining the root cause”.
Nothing really shouts ‘low hanging fruit’ to the enforcement authorities like a company who fail to plan for safe work equipment and suddenly move it to the top of their priority list after magically finding the will and resources following an accident, incident or notice issued by UK HSE.
The inevitable outcomes of the ‘knee jerk’ is a recurring cyclic spike in spending on PUWER inspection services.
This PUWER inspection is often farmed out to a third party since the organisation has neglected the internal competencies and arrangements required in order to complete these inspections inhouse.
It is with this understanding that the value of PUWER Planning and Prioritisation (PIPP) can be best understood. PIPP aims to avoid the knee jerk by giving you a position to defend in the unfortunate event of an accident related to work equipment that occurs despite your best efforts to avoid it.
PUWER ‘98 implies that a PUWER register is required that identifies which assets require PUWER inspection and when. The PIPP process is most relevant and beneficial in this planning stage of a new PUWER ‘98 initiative where a large number of assets are to be covered by a single internal process for the purposes of meeting your statutory requirements for machine inspection.
As explained in PIPP, when identifying what needs to be inspected, a competent person should determine by risk assessment under the management regulations if there is a significant risk to the operator or other workers from the installation or use of the work equipment.
This implies that if the risk is determined to be less than significant during the initial risk assessment under the management regulations then work equipment does not require PUWER inspection.
Note: Despite the absence of the statutory need for an inspection the rest of PUWER is still applicable.
Caution: You must provide evidence to protect yourself in the event of an accident.
Where you choose this approach to explain why not to PUWER inspect a piece of work equipment you should provide the evidence behind that decision for future scrutiny in the event of an accident. PIPP is an excellent and well thought out risk modelling method for evidencing this decision.
The ‘PUWER register’ is a shorthand term to refer to what is inevitable for any business trying to plan for PUWER within their business.
Within any formal management system, it is necessary to keep records to track changes and review over time.
When establishing the register you have a great opportunity to give each piece of work equipment an overall risk rating based on its nature, condition (based on preventative maintenance) and environment of use. This risk rating can be used as a justification to either extend or shorten the inspection intervals determined by the competent person.
PIPP is a method of implementing proactive PUWER compliance management. Using PIPP your business will demonstrate that a systematic approach risk based approach is in place to identify whether work equipment used/controlled by you requires an inspection record. The output of PIPP is:
RiskMach gives you practical tools for implementing PIPP and includes apps and web based management systems so that your PUWER compliance management can get off to a flying start.
It is theoretically possible that PUWER inspections at intervals can even be removed completely where it is found that deterioration of the work equipment is not foreseeable due to the high standard of preventative maintenance and other checks. However in practice most users of work equipment in industrial environments don’t have enough confidence to take this position. Therefore, it is strongly advised that PUWER inspections are planned in at regular intervals.