What is PUWER?

Certain types of work equipment that Regulation 6 of PUWER still applies to also have additional inspection requirements attached to them under separate legislation. Compliance with these separate requirements fulfils the general Regulation 6 inspection duty under PUWER.

You probably already know that ensuring regulatory compliance lies within the responsibilities of the employer but it can often be difficult to keep track of all compliance activities and operate a reliable, auditable risk management system, especially when it comes to a sizable project, assembly of machines or large manufacturing plants. If you find yourself wondering whether you are doing enough for your business to be PUWER compliant, PUWER Inspection Planning and Prioritisation (PIPP) could be the answer you are looking for.

Developed by the experienced engineering safety specialist at Spiers Engineering Safety, this systematic approach to PUWER compliance gives you the peace of mind that each and every machine you use in your business operations is compliant with all the regulatory requirements covered by PUWER 1998: Provision and Use of Work Equipment Regulations.

What is PIPP?

PIPP stands for PUWER Inspection Planning and Prioritisation. It’s a unique risk mapping method designed by Spiers Engineering Safety to ensure that your fundamental machine safety management responsibilities are covered and you are compliant with all legal requirements under the scope of PUWER.

How does it work? – The PIPP Method Step by Step

So how does it all work? The PUWER Inspection Planning and Prioritisation method can be broken down into the following ten steps:

Step 1: Compile a list of all work equipment maintained by your business to create your asset register Step 2: Identify any work equipment that requires inspections under the scope of PUWER Step 3: Use a risk estimation matrix to assess the likelihood and severity of each hazard to categorise risks as low, medium or high and establish an order of priority Step 4: Establish a suitable frequency for re-inspections and schedule PUWER inspections in advance to ensure nothing gets missed Steps 5: Identify the competent people who can complete the inspections Step 6: Carry out the PUWER inspections as scheduled Step 7: Conduct a PUWER risk assessment as part of the inspection to identify remedial actions Step 8: Implement controls to eliminate or minimise risk as required by the risk assessment Step 9: Verify actions taken and update your PUWER records Step 10: Regularly check that all stages of this process are done as intended

One of the best things about the PIPP method is that once you have adopted the strategy fully and you maintain your register up-to-date with any relevant changes to the business, you gain full control over your PUWER compliance and you could completely internalise the process within the expertise of your team.

Where does PIPP fit in the big picture?

The method is designed to fit into your overarching risk management strategy but you may be surprised to find out how far back the PUWER compliance journey really begins. To give you an idea, check out the following roadmap showing where PIPP comes in:

CE/UKCA Audit -> Design Risk Assessment ->

PIPP planning -> PUWER inspection – >

Risk Assessment -> Task-Based PUWER Compliance

CE/UKCA Audit & Design Risk Assessment

Wondering why we are talking about CE and UKCA certification when you are interested in PUWER compliance? Well, the answer is due diligence. To gain a CE or UKCA marking, the machine manufacturer has had to define the intended use and method of use of the machine. Until you have done your own CE/UKCA Audit, you rely fully on the manufacturer’s safety practices.

An audit commissioned by you ensures all CE/UKCA documentation is checked and verified, while the Design Risk Assessment identifies any obvious issues with the design before you commit to investing in an expensive piece of machinery. In other words, every machine you put into your production system is a potential point of failure and these extra steps help you minimise the potential risk.

Need help with UKCA/CE certification? Streamline the self-certification process and ensure compliance with our comprehensive CE/UKCA certification support service.

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PIPP Planning

Starting with the creation of a PUWER Inspection Register that can be easily updated and maintained, PIPP not only ensures you never miss a PUWER inspection again but also helps you implement a reliable change management procedure that remedies the risk of alterations made to machines as part of your risk management practices.

As you also get access to all your risk management records and plans, all available on-demand via our purpose-built risk management software tool – RiskMach, you can collaborate with your safety experts in real time and always stay on top of your legal compliance responsibilities.

Risk Assessment

You should make sure that every PUWER inspection is accompanied by a complete risk assessment. It is a necessary step implemented to identify the level of risk and establish a priority for your risk management activities. This way you can take adequate actions to safeguard the people in your workplace in line with the recommendations of the PUWER inspector.

Based on the risk analysis, you can also determine whether a follow-up PUWER inspection is necessary and why. Taking into account the deterioration rate of each machine you use to set an appropriate inspection frequency, you will be a step closer to achieving regulatory compliance.

Keeping a record of the decisions made, as well as the justification for them can be used as evidence in case you need to prove your risk management practices are compliant.

Task-Based PUWER Compliance

In addition to inspecting the functional aspect of a machine and any possible mechanical issues related to deterioration, you should also establish whether there are any hazards related to the way the machine is being used. To do that, you need to carry out a task-based risk assessment that purely looks at operational risk for the relevant piece of equipment.

If user behaviour is identified as a problem and it puts people at risk, the measures that you can put in place include changing the process and user protocol and increasing the users’ competence by offering additional training.

Why implement PIPP?

If you are already working towards PUWER compliance you probably already have processes in place to carry out PUWER inspections and fulfil your legal responsibilities. With that in mind, you might be wondering if it’s worth making the change to PIPP.

To help you decide whether the PIPP method is the right choice for your business, here are some of the main benefits that it brings to the table:

(1) Implement a Holistic Approach to PUWER Compliance

Some businesses will use a patchwork approach to PUWER compliance with individual members of the team being responsible for the different aspects of compliance, such as mechanical and electrical inspections. However, this makes it difficult to track what has been done and makes it hard for auditors to piece together the bigger picture. PIPP offers a holistic alternative where all your PUWER records and activities are organised in a way that can easily be monitored and relied upon as evidence if needed.

(2) Create & Maintain a Functional PUWER Compliance Register

PIPP produces a compliance register for all your machinery and equipment that can be managed dynamically in real time. It not only gives you full visibility of upcoming PUWER inspections but also allows you to oversee any new risks and changes to existing risks. This means you will never miss a PUWER inspection again and you will have an easy method of tracking all your PUWER compliance activities at your disposal.

(3) Budget for PUWER to Save Time & Money

Adopting a risk-based approach, PIPP allows you to prioritise your compliance activities, plan follow-up PUWER inspections (including deciding whether an inspection is needed at all) and budget both for the inspections and the actions suggested by the competent person as a result of an inspection. This saves you the stress involved in carrying out ad-hoc PUWER inspections on short notice and helps you get better value for your money with sustainable rolling contract solutions for PUWER.

(4) Go Digital & Streamline PUWER Compliance

PIPP equips you with the tools you need to streamline all your risk management practices. Powered by RiskMach, the leading risk management software tool on the UK market, your PIPP records can be accessed from any device, any time anywhere in the world. You can collaborate with your team and keep track of your PUWER compliance activities with instant notification and actionable reports of each PUWER inspection.

(5) Prove Your PUWER Compliance

Ultimately, PIPP gives you peace of mind knowing that you are fully PUWER compliant and you can prove that in the event of an incident at work. With a digital PUWER register that is logically organised and readily available upon request, you will have solid evidence of your risk management practices to show the authorities if you are required to do so.

(6) Protect Your Business and Its People

Being able to back up your PUWER compliance activities and prove you are fulfilling all your legal requirements means that you are protected in case something goes wrong and someone gets hurt at work. With PIPP in place, you have the evidence needed to limit the financial, reputational and commercial impact of a possible incident on your business. And last but not least, you ensure that you have done everything in your power to protect the health and safety of everyone in your workplace.

How do I get started with PIPP?

Ready to move away from relying on one-off PUWER inspections and implement a compliance plan? With the comprehensive PIPP service by Spiers Engineering Safety, you can have the system implemented by our experienced PUWER specialists for you.

Here’s what we’ll do:

• Come on-site, complete a survey that identifies work equipment that requires a PUWER inspection
• Create a register of all work equipment organised by place and risk
• Organise your register using identifiers such as name, place, serial number, photo(s) and a unique ID food-safe QR Sticker for easy identification in RiskMach.
• Conduct a general risk assessment of each piece of work equipment, (as per the Management of Health and Safety at Work Regulations (MHSWRs))
• Support you by providing reasonable assistance in understanding or adjusting the register

All you have to do is give us access to your work equipment and information relating to it, as well as a contact on your end who we can coordinate with to put PIPP in place.

Want to know more about PIPP? Speak to the Spiers Engineering Safety team at +44 24 7542 2624 or email us at info@spierssafety.co.uk to find out more about PIPP and how it could benefit your business.