What Is A Good Example Of A PUWER Checklist?
We are often asked for a PUWER checklist, so in this article, we share our top tips for ensuring older equipment within your company is compliant and what to do if it’s not.
Mobile and large items of fixed machinery are expensive and for this reason, employers often continue to use old or purchase second-hand work equipment because buying brand new is not cost-effective.
This is perfectly acceptable from a legal perspective but what many employers do not realise is that there is no cut-off date for complying with the Provision and Use of Work Equipment Regulations (PUWER) 1998.
Therefore even if you purchase or use equipment that was manufactured before 1998, PUWER still applies.
The problem with older equipment is that a lot of it is not fitted with the safety features that is factory fitted to the equivalent newer versions. In addition older technology means that it often generates more noise, heat and vibration than brand new machinery.
Top Tip #1
Carry out an audit of the mobile equipment that your company owns and what it is used for.
PUWER states that work equipment should be suitable and robust enough to use for the intended purpose and conditions it will be used in. Older equipment may have originally been purchased for slightly different purposes or conditions.
If employees have to modify the way in which they use equipment so it is operated in a different way to which the manufacturer intended, for example tampering with guards or driving along hanging out of the cab, then it is not suitable for that purpose.
If you find that you have equipment being used under these circumstances then remove it from use. Similarly, if the equipment is being used in unsuitable conditions, such as gas-powered warehouse forklifts being used on rough ground, then you are also in contravention of the legislation.
Top Tip #2
Check each piece of equipment for defects and missing safety features. Have standard parts been replaced with non-standard parts such as steel bars in place of towing pins or are safety-critical items such as mirrors missing?
You should also look for safety deficiencies. Older equipment may not be fitted with seatbelts, rollover or falling object protection. If these types of safety controls are not fitted then you should look at retrofitting them in order to comply with PUWER. An operative should not be able to fall out of the cab or have objects hit them. If retrofitting, seek the advice of a qualified mechanic, do not attempt to fabricate a solution yourself as this could end up being more dangerous.
On older, mobile equipment visibility is often an issue, particularly when reversing. Could you add more mirrors, reversing sensors or even a camera? Make sure that others are aware of the dangers too by fitting lights and warning beacons.
Top Tip #3
Risk assess the equipment and identify what hazards will arise from using the equipment. Work logically and categorise the hazards as either mechanical or non-mechanical.
Mechanical hazards are those that occur from contact with moving parts of the equipment, such as entanglement of hair or clothing in rotating parts or contact injuries where moving blades may spin and sever hands or fingers.
PUWER states that there must be control measures to prevent operatives from coming into contact with moving parts. Fixed guards are the most effective at preventing harm, but there may be times when employees need access to these parts for maintenance tasks. Do not forget that in some machines the moving part does not stop as soon as the equipment is switched off.
In these cases, time must be allowed for it to come to rest before attempting to access the part and this should be clearly communicated to employees. There are other types of guards which are fitted on new machines that will allow access once the machine has been switched off and movement has stopped, but on older machines guarding may be completely absent. If you have equipment where employees are exposed to the moving parts then seek advice about retrofitting protection.
Non-mechanical hazards include exposure to noise and vibration, hot surfaces and generation of dust or fumes. Due to progress in technology over the last few years, older equipment is more likely to generate more of the non-mechanical hazards listed above. Safety legislation states that if the technology exists to keep employees safe from harm then it must be used. Look to see if there is anything that can be done to improve the equipment’s features to safeguard employees further.
Top Tip #4
If you look at new equipment you will see that it will display various safety signs. These will warn of hazards such as moving parts or hot surfaces. It is easy to fit signs to older equipment, use new machinery as a reference point for where to fit them.
Top Tip #5
Finally, make sure that your employees are competent to use the equipment no matter how old it is.
Often training is not given on older machines as the assumption is made that they have been in use a long time therefore everybody knows how to operate them. Knowing how to operate machinery is very different to knowing how to operate it safely.
Training should encompass not only the use of the machine but education on the hazards and control measures. Always consult manufacturers’ instructions and make sure your staff have access to them. This is particularly important if you expect your staff to carry out any maintenance tasks where they have to come into contact with the moving parts of the machinery.
What the Law Says
The Health and Safety at Work etc Act 1974 (HSWA) requires employers to provide and maintain safe plant.
All existing and new work equipment, including everything hired or purchased second-hand, must comply with the Provision and Use of Work Equipment Regulations 1998.
Check out this Health and Safety Executive (HSE) guide on Providing and Using Work Equipment Safely.