Meeting the requirements of the Provision and Use of Work Equipment Regulations can sometimes seem like an almost impossible task. But, if a logical and realistic approach is adopted, it doesn’t have to be daunting, says Paul Laidler of TÜV SÜD Product Service.
There’s no denying that PUWER is very wide ranging – essentially, anything that falls under the Health & Safety at Work Act 1974 is covered by PUWER 98, the current version of the regulations. It’s also important to note that, unlike CE marking which is effectively a one-off “stamp of approval”, PUWER assessment is an ongoing process. The assessment must be repeated at appropriate intervals, and it always refers to the latest standards and not, for example, to the standards that may have been applicable when a machine was first brought into service.
At first glance, PUWER may not seem too challenging – after all, there are only 39 regulations in total! However, as always, the devil is in the detail. Let’s take a look at Regulation 6, for example, which deals with inspection. The Regulation itself, together with the associated guidance notes and Approved Code of Practice take up almost 2,500 words, which is more than twice the length of this whole article. And that’s just one regulation!
Fortunately, for most of the regulations, it is possible to construct a simple checklist to determine what, if anything, needs to be done to ensure compliance. As an example, consider Regulation 11, which relates to dangerous parts of machinery.
Part of the checklist might include these questions:
- Is there access to dangerous parts of machinery?
- Are all guards securely held in place?
- Are the interlocks working?
- Are the interlocks of the correct type?
- Can the guarding be bypassed or disabled?
All of these questions have simple yes/no answers and, where an answer shows that there is no associated hazard, – for example, if the answer to the first question is “no” or the answer to the second question is “yes” – no further action is needed. If, however, the answer shows that a potential hazard exists, then it’s necessary to carry out a risk assessment and to follow it up by implementing and recording appropriate control measures.
It can be seen that handling PUWER assessments in this way is, at least in principle, relatively straightforward, but there are still a few issues to be tackled. Where do the checklists come from, for example, and how can users be sure that all the necessary areas have been covered? How can the results be conveniently recorded so that they can be readily produced on demand? And finally, what’s the best way of dealing with all of the action points that will almost inevitably be generated?
The answer to the first three questions is to use a software package that has been specifically developed and designed to aid PUWER compliance, such as the mCom package from TÜV SÜD Product Service. This will have built into it all of the checklists needed for most users, and the suppliers of the best packages will be happy to augment these checklists as necessary to deal with special requirements.
The software, if it is well designed, will also make it impossible to miss any of the areas that need to be covered. If a question is left unanswered, it will be impossible to proceed, and if a risk assessment and action details are required, the software will not allow the PUWER assessment to be completed until the appropriate information is provided.
It’s worth noting, however, that even at this stage of the assessment, perfection is not always possible. Consider Regulation 16 that deals with emergency stops. One of the key questions in the checklist is “Do the emergency stops function correctly?” That’s all well and good, but few plant managers are likely to be enthusiastic about production being disrupted while the e-stops are tried out.
In such cases, a pragmatic approach based, of course, on assessment of risk, needs to be adopted. If the e-stops have recently been tested, and the hazards created by the machine are relatively minor, it may be acceptable to simply include a note in the PUWER assessment stating that, on this occasion, it wasn’t possible to carry out functional testing.
For a more hazardous machine, or where the e-stops had not been tested for some time, however, such an approach would be unlikely to be acceptable. This raises an important issue. Good software will guide the user through the PUWER assessment process and ensure that nothing is missed, but it can never relieve the user of the responsibility for making the ultimate decision about what is and what is not acceptable.
Well-designed software for use in PUWER assessments can be expected to store and organise results and to produce the reports necessary to confirm that the work has been carried out correctly and conscientiously. It is also very probable that it will generate a report of outstanding action points and, in a typical factory, there are likely to be quite a few of these.
What’s to be done? If the plant doesn’t comply with PUWER, surely it has to be shut down until remedial action is taken? In a perfect world, that would probably be true, but in the real world, a slightly more pragmatic approach is needed. Let’s be very clear, though, that there are some types of non-compliance where an immediate plant shutdown may be the only possible course of action.
Missing guards, for example, and other obviously dangerous conditions fall into this category, but it is to be hoped that machines that machines that are obviously dangerous would anyway be taken out of use, without waiting for someone to carryout a PUWER assessment to confirm the severity of the hazard.
In reality, most of the PUWER infringements are likely to be of a much more minor nature. This doesn’t of course mean that they can be ignored, but it does mean that they can be prioritised and dealt with over a period of time. It would rarely be necessary, for example, to shut a plant down because the pushbuttons are labelled with words rather than the pictograms that are now preferred, or because the fixings on a guard are not permanently held in place.
What is important is to prioritise the remedial work according to the risks involved, to ensure that efforts really are made to tackle the work, and to ensure that the results of those efforts are reflected in subsequent PUWER assessments. Remember that PUWER is an iterative process! Once again, well-designed software can help in all of these areas.
Carrying out the PUWER assessments for a machine or plant will never be a trivial task – there’s simply too much involved and too much at stake. The effort involved in PUWER assessments can, however, be reduced to manageable proportions by adopting a structured approach, supported by appropriate software. And there’s usually plenty of scope for implementing the findings of the assessments in an incremental and affordable way.
Nevertheless, PUWER is undoubtedly a complex subject and expert advice will often prove invaluable, repaying its modest cost many times over.