Most modern businesses believe they have a grasp on PUWER – but we see all types of misconceptions about the regulations.

The Provision and Use of Work Equipment Regulations 1998 were created in order to prevent injuries and fatalities from hazardous machinery and equipment in workplaces. By laying out legal responsibility in regulatory form, it place the onus of safety onto directors and owners of companies who utilise dangerous work equipment in day to day use. PUWER is relied upon to give an appropriate overview as to if a machine is designed safety and is used in a safe manner. There are 5 key questions that envelope what PUWER, and the adjacent inspections against PUWER, is used to discover.

1. Is the equipment or machinery suitable for its intended use?
2. Is a machine in a safe condition to use and not likely to suffer from unplanned deterioration?
3. Are the people using the equipment instructed, informed, and trained properly?
4. Are the safety systems and controls, both mechanical and electrical, suitable?
5. Is the machinery or equipment used in accordance with specific or legal requirements?

Now that we have a better understanding of what PUWER is and what it is used for, we can look at common misconceptions surrounding these regulations. These are things that we often see online or hear when discussing health and safety in certain communities – even out on site.

The first and likely most common misconception we see – PUWER isn’t really necessary, my machine works fine. It has a CE mark. There are quality assurance certificates, there are full electrical designs, there are…

As much as these things can sound great, they do not matter. In an extreme example, if a factory procures a large scale paper bag processing line yet they are manufacturing plastic bags, immediately there should be a red flag raised against the suitability of the machine for the media. Hypothetically, if this machine had been modified to be able to manufacture plastic bags, we could be treading even further down an already dangerous road. Modifications like this could lead to incorrect use of the machine by operators. Incorrect machinery equals incorrect usage. It creates unnecessary risk.

It is simple enough – buy the correct equipment for the job. Assess it against PUWER. Is it still the correct equipment for the job? If something is modified on that equipment such as the media, the process, or the parts, it is worthwhile questioning whether a re-assessment is justifiable.

The second misconception, which coincidentally coincides with the first misconception, is that a machine that is CE or UKCA marked is perfect in every way.

It might be. It might not be.

Manufacturers aren’t perfect – sometimes they make mistakes and it is okay to question these mistakes. Most manufacturers will, if they value their customer relationship and brand reliability, work together to find a suitable outcome.

Sometimes manufacturers are perfect – the Directives and Standards that OEMs are required to meet, a lot of the time, don’t take PUWER into account and therefore after conducting a PUWER assessment, businesses may be confused that certain recommendations have been made. It is because your machine may meet current Standards but not the PUWER regulations. In certain rarer circumstances, PUWER is unable to be followed but risk has been reduced as low as is reasonably practicable.

Third and finally – Conducting a PUWER Assessment is the be all and end all. Everything else is easy.

The hardest part after having equipment assessed is carrying out remedial work. Remedial work often requires experienced personnel in those areas to find solutions which can be expensive to achieve, especially if the requirements are specialised.

Once problems have been identified, they need to be rectified!

The takeaways:

1. PUWER is always necessary and a legal requirement.
2. Don’t necessarily take signage at face value – it is your right to question things.
3. Fix safety issues and re-assess.

At ISS Safety, we offer comprehensive PUWER problem solving. A true one-stop shop for all industrial safety requirements. If you find yourself bringing truth to these misconceptions, don’t hesitate to call us and get no nonsense assistance.