PUWER inspection, LOLER thorough examination, and the insurance visit that is neither

Ask a maintenance manager when the overhead crane was last examined and you will usually be told the date the insurance engineer came. That is often the right date. It is not necessarily the right answer, and the gap between those two statements has caught out organisations that thought they were well run.

Three separate things are involved. They get collapsed into one.

LOLER thorough examination

Regulation 9 of the Lifting Operations and Lifting Equipment Regulations 1998 sets the intervals for lifting equipment exposed to conditions causing deterioration liable to result in dangerous situations:

• At least every 6 months for lifting equipment used to lift people, and for accessories for lifting. Slings, shackles, eyebolts, chains.
• At least every 12 months for other lifting equipment.
• Or in accordance with an examination scheme drawn up by a competent person. That is the route that lets intervals follow actual use instead of the default.

Equipment must also be thoroughly examined each time exceptional circumstances liable to jeopardise its safety have occurred. A collision, an overload, a long period out of use, a modification. Where safety depends on the installation conditions, it must be examined after installation and before first use, and again after assembly at a new site or location. The mobile gantry moved between bays is the one people forget.

PUWER inspection

Regulation 6 of the Provision and Use of Work Equipment Regulations 1998 is a different duty with a different name. Where the safety of work equipment depends on the installation conditions, or where it is exposed to conditions causing deterioration liable to result in dangerous situations, it must be inspected by a competent person, at suitable intervals, and the result recorded.

Note what PUWER does not do. It does not give you a number. The interval comes from the equipment, its use and its environment, so it has to be reasoned and written down instead of looked up. Press brakes, guarding interlocks, extraction, racking, access platforms and vehicle lifts usually sit here. They also usually sit nowhere at all.

The insurance visit

Most organisations meet their LOLER duties through their insurer’s engineering surveying arm, and there is nothing wrong with that. The competent person carrying out the thorough examination often is the insurance engineer. Two things still have to be true, and neither is automatic.

The duty stays with the employer. LOLER places it on the person who has control of the equipment. Buying a policy does not transfer the duty. It buys a service that helps discharge it. If the visit does not happen, or happens late, or covers less than the schedule requires, that is the employer’s failure and the employer’s liability.

Not every insurance survey is a statutory thorough examination. Insurers carry out risk surveys for underwriting as well as statutory examinations under contract. From the shop floor they look similar. They are not the same document. A thorough examination produces a report in the form the regulations require, identifying defects and the timescale for putting them right, and naming the competent person.

The practical version

Three questions. Most organisations cannot answer all three today.

1. Which of your equipment is lifting equipment, which is accessories for lifting, and which is work equipment under PUWER? That answer sets the interval and the duty.
2. For each item, is the interval six months, twelve months, or an examination scheme? If a scheme, where is it and who wrote it?
3. When a defect is reported on a thorough examination, what happens next, and how would you evidence that it was actioned?

The third is where the exposure sits. Reports come back with defects and timescales. They get filed. The timescale passes. The examination regime is intact and the finding is open, which, as with any assessment, is a written record that you knew.