What is PUWER?
PUWER is an abbreviation of duties placed on individuals who operate, own, or control any work equipment and machinery used in the workplace by employees. PUWER (Provision and Use of Work Equipment Regulations 1998) is in place to select appropriate equipment for specific operations and ensure that its function is fit, in working order, safe for use, and has undergone the proper inspection and maintenance regimes required by the regulation. PUWER is also in place to ensure that only those who are fully trained and qualified operate certain pieces of work equipment and are used appropriately and accurately.
There are five types of work equipment that are defined by Regulation 3 of PUWER. These include:
- Any apparatus
- Any appliance
- Any machine
- Any tool
- Any installation used for work purposes.
What is a PUWER inspection?
Regulation 6 of PUWER details the requirement and importance of completing proper inspections and regular maintenance work on all work equipment. PUWER inspections can take place in one of three ways. A pre-use check, a complete visual check, and a thorough inspection. These inspections must only be performed by a fully qualified and certified professional who is competent within their field.
What is a pre-use check?
A pre-use check is exactly what it states. A general safety check that is carried out on the equipment before each first use. This check is performed to ensure all safety devices are functioning correctly and safely before each individual use. Carried out by the equipment operator, this check is not officially classed as an inspection under the PUWER legislation. However, this does not take away its importance and is known as best practice in the associated guidance.
What is a visual inspection?
A visual inspection is used to visually check the equipment and identify any apparent external damage or deterioration. This ensures that all equipment is safe for use and operation and remains in a good and satisfactory condition. Although these checks are not usually carried out as an in-depth check, it is a more detailed and thorough check as opposed to a pre-use check and tends to be performed more often as it is a form of safe and good practice.
What is a thorough examination?
A thorough examination is a check that is performed in more depth than the previous two. A thorough inspection involves a complete function check and usually includes an element of testing. These are only required for work equipment that is a power press3.
Some regulations do not require a thorough examination. These include
- LOLER (Lifting Operations and Lifting Equipment Regulations 1998)
- PSSR (Pressure Systems Safety Regulations 2000)
These are carried out less often as the inspection process is invasive and has been known to cause damage to the equipment if carried out too frequently. Potentially increasing the risk of the equipment becoming unsafe for use over time.
How often do PUWER inspections take place?
PUWER inspections can vary depending on the type of conditions the equipment is exposed to. Inspections must occur at suitable intervals so any deterioration that can cause severe damage can be detected and assessed to allow it to be rectified within a reasonable time. Any findings or actions taken must then be recorded in writing and remain on file until at least the next inspection.
A PUWER inspection must take place before first use regardless of any previous checks or reports. A complete inspection is required to take place to ensure all equipment has been installed correctly by a qualified individual and that it is safe for use. From here, somebody can then schedule any future inspections and maintenance to ensure the equipment meets the regulations of PUWER and any other applicable legislations whose category it may fall within. Any risk assessments and manufacturer recommendations must be taken into consideration when scheduling future inspections and maintenance intervals.
Inspection intervals are based on the type of equipment and any risks that may be associated. Equipment used outdoors tends to be more exposed to adverse weather conditions and therefore may require more frequent inspections to ensure any damage can be assessed quickly. The work environment must also be considered as different settings can cause more significant levels of deterioration.
Are all items of work equipment required to have a Regulation 6 inspection under PUWER?
The answer to this is no. The regulation does not apply to;
- A power press to which regulations 32 to 35 apply
- A guard or protection device for the tools of such power press
- Equipment that is used for lifting loads, including persons
- Winding apparatus to which the Mines Regulations 1993 apply
- Work equipment that is required to be inspected by regulations 31 or 32 of the Construction Regulations 2007
- Work equipment to which regulation 12 of the Work at Height Regulation 2005 applies
Although the regulation does not apply to these types of equipment, the inspection before first use is still required and must be recorded in the formal safety management system. Instead, a risk-based approach may be used to enable the extension of the inspection interval. In certain instances, even where work equipment is not exempt from inspection, a risk-based justification may be made for not performing inspections at suitable intervals. This may also provide an explanation for not re-inspecting an item if it is not reasonable to do so.
What about equipment with specific legislation and additional inspection requirements?
There are certain types of work equipment that Regulation 6 of PUWER still applies to. These types of equipment have additional inspection requirements that can be found attached under a separate legislation. In order to fulfill the general Regulation 6 inspection duty under PUWER, these separate requirements must be complied with.
The Pressure Systems Safety Regulations 2000 and associated inspection guidance are a key example of equipment with additional inspection requirements. However, Regulation 6 of PUWER still applies and specifies timescales and inspection types that can vary between 12-120 months. This timescale is based on the vessel type, contents, and application.
Can the frequency of PUWER inspections be extended or reduced?
It is possible for intervals to be extended and, in some cases, for no future inspections to be carried out. This is only feasible if the inspection history identifies there have been no defects and that the level of deterioration has been low. The PUWER risk assessment must also state the risk to be low. Equally, intervals should be reduced if an increased risk has been identified due to a high volume of defects being consistently recorded.
Regulation 6 of PUWER clearly states that a qualified and competent individual must carry out inspections. Any recorded findings must be maintained, any defects that have been identified highlighted, and must state the required actions.
Why it is essential to get the PUWER inspection type and frequency correct
Occasionally PUWER inspections can be carried out too frequently. Although this sounds perfectly harmless, it can lead to equipment failure. Devices such as emergency stop buttons must only be tested when required as over-testing can lead to fault and damage if incorporated into pre-use check routines.
When recommended by the manufacturer, inspections may be carried out weekly. It may be deemed that monthly inspections would be sufficient. Performing PUWER inspections outside of the recommended timescales could lead to equipment failing unexpectedly and a waste of valuable resources.
Any complete PUWER inspections and defects that are found must be identified and reported. If equipment has a specific legislative requirement and manufacturer recommendations, they must be taken into account to ensure appropriate ongoing inspection and maintenance regimes.
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