What training and information do employees require under PUWER?
Under PUWER, employers need to ensure that work equipment is only used by those who have received adequate training and instruction to enable them to carry out the work safely. What constitutes adequate training varies depending on the complexity of the work equipment and the employee’s existing level of competence.
The competence of new employees, both permanent and temporary, should be evaluated in order to ensure they are only operating equipment that they are qualified to use. If you require staff to use a piece of equipment they are not currently qualified to operate, then you must provide them with the relevant training before they are left to use the equipment unsupervised.
Any instructions specific to a piece of work equipment should be written down and provided to each employee who will use it. These instructions should include details about how the equipment should be used alongside any potential safety issues that could arise during its operation, as well as advice on how to solve these. Any instructions, guidance, and safety information provided by the manufacturer should also be included.
If an employee spots any more potential safety issues during the everyday use of the equipment, it is their duty to add them to the written instructions and make sure all relevant people are made aware of them.
Manufacturers have a duty to provide all of the information required for the safe installation and operation of their work equipment. In the case of complex machinery, if this is not provided alongside the equipment at the point of sale, you should not proceed with its installation until you’ve contacted the manufacturer and received the necessary schematics.
What is a PUWER inspection?
The purpose of a PUWER inspection is to ensure that a piece of work equipment is safe to operate and any deterioration to the equipment is detected and remedied before it develops into a serious safety risk.
To qualify under PUWER regulations, work equipment must undergo periodic inspections to ensure it is safe to use. Each piece of equipment must also undergo an inspection when it is first installed and whenever it is relocated.
A PUWER inspection should focus on the parts of work equipment that are most likely to deteriorate and pose a risk to a user’s health and safety. Depending on the type of equipment and how often it is used, this may vary from a simple visual examination to a detailed inspection after it has been dismantled.
Simple hand tools generally only require minimal maintenance, and should be repaired or replaced if they deteriorate, to ensure the safety of your employees. More complex work equipment, such as machinery, will usually be accompanied by a user’s manual that will include suggestions regarding routine and specialist maintenance that needs to be performed at certain intervals. If you follow the manufacturer’s guidance and log each instance of maintenance performed by a competent person, this is usually enough to be covered by PUWER regulations.
A PUWER inspection should always include a look at the parts of the equipment that are necessary for the safe operation of equipment, such as emergency stop switches.
How frequently should PUWER inspections be carried out?
The frequency of the inspections is down to the employer’s discretion, but each piece of equipment should be regularly checked to ensure that its safety features are in full working order. The regularity of these inspections should take into account how frequently and intensely each piece of work equipment is used, as well as the risk to a user’s health and safety that would occur from malfunction or failure.
Those with a duty to ensure work equipment complies with PUWER regulations should refer to the user’s manual of more complex machinery for an indication of how frequently to perform an inspection. They should also take into consideration how frequently the equipment is used, as well as the conditions in which it is operated. For example, a piece of work equipment will need to be inspected more regularly if it is used on a construction site than if it is used in the less demanding environment of a warehouse.
The PUWER APOC also notes that an inspection is necessary whenever “exceptional circumstances” have occurred that may affect the safety of the work equipment. These “exceptional circumstances” include:
- Major modifications, refurbishment, or repair work.
- Any known or suspected significant damage.
- A substantial change in the nature of the equipment’s use, including an extended period of use.
How should PUWER inspections be recorded?
Every time a piece of work equipment undergoes a PUWER inspection, the details should be logged for future reference. The PUWER ACOP does not specify a particular format in which these inspections must be recorded, noting anything from a pre-printed form to an entry in a diary is acceptable. However, it does specify that the report should include:
- The type and model of equipment.
- The equipment’s identification mark or number.
- The equipment’s usual location.
- The date of the inspection.
- The name and job title of whoever carried out the inspection.
- Any faults with the equipment.
- Any actions taken or planned to rectify the faults.
- Who the faults have been reported to.
- The date repairs or other necessary actions were carried out.
For consistency and to save time, it’s a good idea to create a form that can be printed and filled out whenever a PUWER inspection is performed on your site. However, no matter how you choose to record the information of the PUWER inspections performed on your work equipment, you should make sure to have a digital backup, as you may fail a health and safety inspection if these records are lost or destroyed.
Keeping a detailed maintenance log for each piece of work equipment will ensure that all future inspections can be carried out with this information in mind. In the event of a malfunction, this will also provide evidence that the requisite inspections were performed in order to ensure your employees’ safety to the best of your ability.
What constitutes a ‘competent person’?
All PUWER inspections must be carried out by a competent person, which the PUWER ACOP defines as someone who has “sufficient knowledge and experience” to be able to decide:
- what the inspection should include,
- how it should be performed, and
- when it should be carried out.
Depending on the complexity of the equipment, this knowledge and experience may not be available in-house, in which case you should hire a third party to perform the inspection. This also has the added benefit of ensuring the inspection is sufficiently objective, meaning its validity cannot be doubted if there ever is a work equipment–related accident on your premises.
If you buy your work equipment from Penny Hydraulics, you’ll be able to take advantage of our service agreement, which includes a thorough examination from one of our impartial engineers during installation. It also includes the option of an additional third-party examination every 12 months to ensure you meet PUWER regulations each year.
If you have any questions about PUWER regulations that haven’t been answered in this guide, contact us today to speak to one of our experts, who’ll be more than happy to help with your query.
Please bear in mind that the information presented in this short guide is not comprehensive, and you should refer to the Provision and Use of Work Equipment Regulations 1998 Approved Code of Practice (PUWER ACOP)for official guidance.