Complying with PUWER is about more than checking your equipment whenever you remember, and fixing things as and when they break.

You need to follow a process in order to really fulfil your responsibilities under the HSE regulations.

What is PUWER?

PUWER stands for the Provision and Use of Work Equipment Regulations, an HSE (Health & Safety Executive) code regulating the safe use of plant machinery and work equipment, established in 1998.

As this page points out, PUWER specifically outlines the responsibilities of “people and companies who own, operate or have control over work equipment”, primarily around safety and maintenance of that equipment. This can include businesses and organisations whose employees use work equipment, whether owned by them or not.

Why do you need to comply with PUWER?

Besides it being a legal health and safety requirement, complying with HSE regulations is also a sensible business decision. Keep your plant machinery and equipment running smoothly and your business can run smoothly.

Preventing accidents and incidents is part of that smooth running of the business, as is avoiding criminal proceedings, by showing a due process where accidents and incidents do occur. As fines and prosecutions by the HSE have increased in recent years, it is increasingly essential to have proper processes in place to manage safety checks.

What are the check requirements for PUWER, and how can you easily manage that checking and maintenance process?

There are five key aspects of the HSE’s online guidelines around PUWER:

Selection

Selection, or “selection and conformity of work equipment” relates to the process of bringing work equipment into your business. This equipment must be:

  • “Suitable for its intended purpose“
  • “Selected so that the risks to the health and safety of users can be managed“
  • and “used only for the operations for which it is suitable“

The selection of equipment and plant machinery for work use will likely inform your maintenance and check procedures. You are advised to use manufacturers’ information and risk assessments to select the appropriate equipment and machinery, taking into account factors like:

  • Does it conform to European safety requirements?
  • Where will it be used?
  • What purpose and activities do you plan to use it for?
  • Consider any ergonomic factors – is it likely to put a strain on the user? How can any undue strain be avoided?
  • What space and access requirements are needed for maintenance activities?
  • What forms of energy (like radiation, vibration or noise) or substances (like fumes)are used or produced, that may need to be mitigated?

This combination of official information and risk assessment should then inform your inspection and maintenance procedures. While newly purchased work equipment should be compliant with common minimum European safety requirements, operators are advised to undertake an inspection before putting any new work equipment into use. Pre-use inspection requirements for new machinery are outlined in detail in the HSE Guide to Buying New Machinery and should, at a minimum, include:

  • Confirm that the equipment is not obviously unsafe
  • Is the equipment fitted with any necessary safety features (like machinery guards)?
  • Is the equipment “suitable for the purpose to which it is to be used or provided“?
  • Are user instructions (in the English language) available for the equipment?
  • Has information on noise and vibration emissions been provided?
  • Does the equipment have a CE mark, and a Declaration of Conformity, where required?

Stream Check for plant machinery and work equipment can be configured to include a check type for these pre-use inspections.

Inspection

“Inspection of work equipment” refers to the process of regularly inspecting work equipment and machinery to ensure that it is safe to use. Regular inspections can detect and identify defects or deterioration, and ensure that issues are remedied before use.

The inspection phase of PUWER relates directly to the Stream Check driver app. Once a schedule for inspections has been identified, operatives will receive push notifications on their device, reminding them to open the app and conduct an inspection. Operatives will be required to inspect each check item (for example, to check the tires or the safety guard), and mark it either as safe to use or as a defect. In the case of defective components, operatives can select the defect type (for example, they could choose between ‘deterioration’ and ‘damage’), record more information about the defect (including notes and photos), and make a record of who they reported the defect to, giving you a clear chain of command on defect resolution.

In the equipment details screen, you are able to manage checks for each type of equipment, so operatives will only check aspects relevant to that piece of equipment, instead of having a generic list of checks.

Which pieces of equipment need to be inspected?

Not every single piece of work equipment requires a formal inspection process.

Having completed a risk assessment for each piece of equipment, you should have a good understanding of the level of risk involved in using that equipment in your workplace. The HSE guidance suggests a simple tagging or labelling system to mark smaller, low-risk pieces of equipment as visually checked over.

However, any piece of equipment or machinery that has been identified as posing a “significant risk (for example, of major injury) to operators and others from the equipment’s installation or use” should be thoroughly inspected on a regular basis. This inspection process should include a formal system for recording and storing the results of each inspection (at least until the next inspection of that equipment).

How often should each piece of equipment be inspected?

Once you have determined which pieces of equipment require regular inspection, you must determine how often the inspections should take place. An inspection schedule should be dynamic, depending on various factors, including:

  • Is the safety of equipment dependant on installation conditions? Post-installation, pre-first-use, and post-reassembly checks may be required.
  • Is the equipment regularly exposed to conditions causing deterioration (for example, equipment stored outdoors)? Schedule inspections at suitable intervals.
  • Has anything happened to the equipment since the last time it was inspected? Inspect equipment after any exceptional circumstances, including “major modifications, known or suspected serious damage, or substantial change in the nature of use“

It is a good idea to review inspection frequencies and schedules regularly, and either increase the time between inspections (where “negligible deterioration” is shown in the inspection history) or conduct inspections more regularly (where experience or changing circumstances suggest heightened risk).

Equally, different aspects of each inspection may require different frequencies. Having various inspection types (on various inspection schedules) for each piece of equipment makes it easy for operatives to focus on checking only the equipment features that are critical. Inspection types could include:

  • Quick pre-use checks  (including, for example, functional brake testing)
  • Weekly checks (including, for example, gauging tyre pressure)
  • Regular extensive checks monthly, quarterly or annually (including, for example, close examination of a safety harness) 

At the end of the day, inspections must be carried on on a frequency that ensures healthy and safe conditions are maintained. Inspection schedules can be assigned and edited in the Stream Check equipment management screen, with notifications sent directly to operatives as a reminder to complete their inspections.

What does an inspection of work equipment involve?

Once an inspection frequency has been determined for each piece of equipment that requires documented safety check, the actual safety check process should be determined.

With Stream Check, a multiple checks can be outlined for each piece of equipment, so that operatives only carry out checks relevant to the safety and maintenance of that each piece of equipment.

The actual checks that must be undertaken will depend on various factors, including:

  • The type of work equipment
  • The intended use of the equipment
  • The conditions to which the equipment is exposed, either in use or in storage
  • Risk factors highlighted through a risk assessment
  • Manufacturer’s recommendations
  • Advice from authorities, like trade associations, consultants, and published health and safety advice

Though storing and recording the checks is not usually necessary for the simplest pre-use checks, having an easy way to securely store check records, and find them again when required, can be indispensable when it comes to proving compliance and due-diligence. The HSE guidelines specifically state that checklists and records used for inspections “should be tailored to the particular type of work equipment to minimise the burden to what is strictly necessary for safety“. This is a key feature in Stream Check: you are able to easily specify checks for each equipment type, as well as having various check types for each piece of equipment.

Who is responsible for work equipment inspections?

Overall responsibility for maintaining the safety of work equipment under PUWER falls to “people and companies who own, operate or have control over work equipment” as well as “businesses and organisations whose employees use work equipment, whether owned by them or not“.

In terms of the actual inspections, HSE guidelines specify that they must be carries out by a person who “has sufficient knowledge and experience of [the equipment] to enable them to know what to look at, what to look for, and what to do if they find a problem“. This means that regular inspections of work equipment can usually be carried out by the operative.

The person carrying out the inspections may not, however, be responsible for determining the nature of the checks. This should be decided by a competent person, based on recommendations from the manufacturer, industry advice and experience of that piece of equipment, the specific workplace where the equipment will be used, and the competence level of the operative likely to be using it.

Once a set of required checks has been determined for each piece of equipment, that can be entered int the equipment details screen in Stream Check, so the operative always knows which checks to carry out when inspecting a piece of equipment.

Maintenance

For “maintenance of work equipment”, PUWER requires that equipment is “maintained in an efficient state, in efficient order, and in good repair“. Maintenance of work equipment involves work carried out to ensure the safety and efficiency of work equipment.

What is the difference between maintenance of equipment and inspections of equipment?

While they are closely linked the PUWER requirement for inspections and for maintenance serve different functions.

“Inspection may be part of the overall maintenance programme. [It] may be one of the techniques for validating the maintenance programme“.

This essentially means that the maintenance of work equipment relates to actually keeping the equipment safe and efficient, while the inspection of work equipment relates to checking that the equipment is safe and efficient.

Maintenance work should be carried out both on a schedule (for example, some machinery may require that the oil is changed every six weeks) and on an ad-hoc basis as required (for example, where a weekly inspection on the machinery shows that the oil levels are low).

Inspections (checking that the equipment is safe to use) and maintenance (carrying out any work on the equipment that will make it safe to use) go hand-in-hand to ensure the safety of work equipment and operatives.

How often should maintenance work be carried out on work equipment?

Maintenance frequency, like inspection frequency, should be determined based on a number of factors and scheduled accordingly. Factors involved in determining maintenance frequency include:

  • Risk assessment
  • Manufacturer’s recommendations
  • Intensity and frequency of equipment use
  • The environment for operations and storage (accounting for factors like temperature and weather)
  • The knowledge and experience of operatives

The key factor for determining maintenance schedules should be the manufacturers’ recommendations. These should only be disregarded where there is a clear reason to do so, with no negative impact on risk. The maintenance frequency recommended by the equipment manufacturer could be modified with:

  • Increased frequency (In the case of intense use or adverse environmental conditions, or where unscheduled maintenance work is required on an ad-hoc basis, as the result of defects or deterioration discovered in a routine inspection, to ensure equipment remains in a safe condition)
  • Decreased frequency (For example, in the case of equipment that is rarely or lightly used, where regular inspections are in place to monitor the condition). In the case of maintenance work being carried out with less frequency than recommended by manufacturers, the HSE guidelines advise that this “should be subject to careful risk assessment and the reasons for doing so should be reviewed at appropriate intervals“.

What does equipment maintenance involve?

Maintenance activity refers to the maintenance work undertaken to keep work equipment working safely and efficiently.

Maintenance activity should always be carried out safely, with precautions like:

  • Following the manufacturers’ instructions
  • Shutting down equipment where possible
  • Safely releasing any stored energy
  • Positively disconnecting the equipment from the energy source, where possible (particularly for very high-risk equipment), via isolation and locking off to prevent inadvertent reconnection
  • Production of a permit to work where required (as in the case for maintenance work on some  very high-risk equipment)
  • Any physical measures that could be taken (for example, temporary guarding, and PPE (personal protective equipment)
  • Having management and supervisory systems in place (including a safe system of work, and supervision or monitoring)
  • Ensuring staff carrying out maintenance work are competent to do so, with the relevant “training, skill, awareness and knowledge of risk” in place

As far as recording and reporting, there isn’t any legal requirement for operators to record or log maintenance procedures. recording and logging maintenance procedures is recommended in the case of equipment that has been deemed to pose a high risk, during the risk assessment stage. Recording maintenance procedures offer useful information for planning and carrying out future maintenance work. HSE guidelines instruct that the most important consideration about maintenance logs is that they are kept up to date. This can be accomplished with Stream Check, as all maintenance work is logged via Stream’s mobile App.

Who is responsible for work equipment maintenance?

AS with responsibility for inspections, overall responsibility for maintaining the safety of work equipment under PUWER falls to “people and companies who own, operate or have control over work equipment” as well as “businesses and organisations whose employees use work equipment, whether owned by them or not“.

However, a key difference between maintenance of work equipment and inspection of work equipment is the level of competency required to carry it out. Where Inspections can usually be carried out by the operative who will be using the equipment, maintenance work generally requires a higher level of expertise. depending on the complexity of the equipment, and the risk involved, maintenance work should be carried out by:

  • The manufacturer
  • Specialist contractors
  • Suitably trained and qualified, competent staff within your organisation

Competence

“Training and competence” for PUWER refers both to the requirement for operatives to be competent and able to carry out their work tasks and use equipment safely, and to the requirement for anyone undertaking inspections and maintenance work to be competent (and, where necessary, trained and qualified) to carry out the work required to ensure the continued safety of work equipment.

HSE guidelines on PUWER state that employers must “ensure that all persons who use work equipment have received adequate training for the purposes of health and safety, including training in the methods which may be adopted when using work equipment, and risks which such use may entail and the precautions to be taken“.

The level of training required can vary, depending on factors like the manufacturers’ recommendations, the level of risk identified at the risk assessment stage, and the degree of supervision typically in place during operation. Competency may be based on:

  • Advice and training schemes from the relevant trade association
  • Industry-recognised and externally-provided training and certification
  • In-house training is also suitable for some equipment, so long as the person providing the training is suitable competent and experienced
  • Ultimately, any training provided must be of a “standard necessary to ensure health and safety“

In Stream Check, the equipment management module allows you to set the level of competency required for operatives of each equipment type (for example, that operatives must have completed specific in-house training to operate one piece of equipment and hold specific qualifications or certifications to operate another piece of equipment).

Then, from the operative management module, you are able to add specific training and competency to each operative. When operatives sign into the Stream Check mobile App, they will only be able to complete inspections and maintenance on equipment that they are sufficiently trained to handle.

Mobility

The safety requirements under PUWER in relation to “mobile work equipment” refers specifically to work equipment that may be used on public roads. Further safety regulations apply to this type of work equipment, In addition to:

For organisations and operators with mobile work equipment, there must be safety measures in place that relate specifically to the risks associated with this kind of equipment. By law, safety measures that manage the risks associated with mobile work equipment should be in place in any equipment manufactured after 1998.

It is still the responsibility of employers to ensure that this equipment is in place and functioning properly, to mitigate the risk of accident and injury. The management of the particular risks arising from mobile work equipment may include measures such as seats, restraints and rollover protection, as well as specialist training for any operatives using this type of equipment.

How Stream Check can help you to manage safety checks and stay PUWER compliant

As you can see, Stream Check is built flexibly enough to fulfil the needs of businesses operating work equipment which falls under PUWER regulations.

You can set up check types and inspection schedules for every piece of equipment, manage operatives training and competency and ultimately ensure the safe use of your work equipment.

This keeps you compliant (and proves your compliance) as well as improving overall productivity by keeping the parts of your business that rely on plant machinery and work equipment running smoothly.

Schedule your demo to learn more about how Stream Check can help you to maintain compliance with PUWER guidelines.

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