What is a PUWER inspection and how often should it take place?
Spiers Engineering Safety’s engineers have over 100 combined years of experience in machine safety services. This article explores the importance of PUWER inspections and how often they should be inspected.
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.
What is PUWER?
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.
Work equipment, PUWER risk assessment and PUWER inspections – what do these terms mean?
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:
- Any machine
- Any appliance
- Any apparatus
- Any tool
- Any installation (used for work purposes) 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.
Are any items of work equipment exempt from Regulation 6 inspection requirements under PUWER?
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 initially 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.
What about equipment with specific legislation and additional inspection requirements?
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 the 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.
- Details of Regulation 6 can be found in the PUWER ACOP (pages 22-27)
- Guidance on the ACOP ‘Pressure Safety System regulations 2000’, can be found here.
How often should PUWER inspections be carried out?
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.
Is it possible to extend or reduce the frequency of PUWER inspections?
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.
What’s the difference between a pre-use check, a visual inspection and a thorough inspection?
Pre-use Checks
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.
Visual Inspection
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 Examination
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:
- LOLER (Lifting Operations and Lifting Equipment Regulations 1998)
- PSSR – Pressure Systems Safety Regulations 2000 These tend to be carried out less frequently due to the invasive nature of the inspection as this could potentially cause damage to the equipment, therefore increasing the risk of unsafe conditions developing over time.
3 ACOP Guidance for the ‘Safe Use of Power Presses’ can be found here.
Why is it important to get the PUWER inspection type and frequency right?
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 resources 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 your inspections, ensuring the correct frequency is implemented
Plan for PUWER in 2023 by booking your site audit with Spiers. We are offering a discounted price per asset. To find out more contact us today!
