Most facilities managers understand that their site’s lifting equipment is subject to LOLER, but far fewer can explain how PUWER applies to the rest of the equipment in the shop. The Provision and Use of Work Equipment Regulations 1998 cover nearly everything a business uses to get its work done, including pallet trucks, bench grinders, CNC machines, and conveyor belt systems; this is one of the common missing pieces we see when we engage procurement and health and safety teams in conversations across the sector.
PUWER applies to any employer, self-employed individual, or person or business entity that exercises control over work equipment. It makes no difference whether the equipment is owned, leased, hired, or even borrowed from a different business on a shared site; if your workforce operates it, you have obligations under the regulation. Such duties include ensuring that equipment is appropriate for the purpose for which it is used, adequately maintained, and that only trained and informed personnel operate it.
Where compliance with PUWER fails
In broad terms, there are many ways compliance can slip. A classic example is a machine purchased for one purpose, then later repurposed without anybody reassessing whether it is still suitable. Another example includes equipment modified on-site by maintenance, who mean well, but haven’t had formal reviews of the modifications. Guarding is another recurring theme. Dangerous areas of machinery have fixed or interlocked guards that must be installed, and wherever possible, they cannot be removed. However, guards are often removed for cleaning or quick maintenance and not replaced at all, or in some cases not replaced before the machine is put back in service.
Particular attention should be paid to maintenance records. PUWER does not stipulate a fixed inspection interval as LOLER does for lifting equipment, but it does state that maintenance should be performed at suitable intervals, and in the absence of such documentation, the liability can be attributed to whoever is responsible. This essentially creates an obligation for maintenance logs that is greater than just good practice. This is the evidence you would need to produce if the HSE ever asked how you assessed the risk on a particular piece of equipment, and the risk to health and safety could have been significant.
Training stands as the other pillar which is often underestimated. Merely having an operator competent to use a machine is insufficient; PUWER stipulates that any person using work equipment must have sufficient training in respect of health and safety, including the dangers and the necessary precautions. This also applies to supervisors, who need sufficient knowledge of the equipment to identify when something is amiss.
Integrating PUWER into procurement
The best way to approach your PUWER obligations is to not treat them as compliance tasks that are bolted on after the equipment has arrived, but rather to embed the assessment into the procurement process. Prior to the purchase of the machinery or equipment, request the technical file, CE or UKCA declaration of conformity, and the instructions for use in English from the supplier. Verify what guarding is supplied as standard and if a specific risk assessment will need to be conducted at the time of installation. For equipment that will be utilized by several teams or shifts, arrange the training program before the machine is delivered instead of rushing after it is already on the work floor.
The process can be simple, but it should be intentional. Carrying out a PUWER checklist at the time of purchase, and then again any time equipment is changed, reused, or brought in from other locations, will identify the majority of issues that arise during HSE visits or, worse, after incidents. Considering the vast amount of equipment at an industrial site that falls under regulations, it is a small amount of effort that can have a significant impact on risk reduction.