PUWER pre-use checks and inspections: what the law requires

What PUWER says about checking work equipment

The Provision and Use of Work Equipment Regulations 1998 (PUWER) give every employer three linked duties for the equipment they provide: it must be suitable, it must be maintained, and some of it must be inspected. In the words of the regulations on legislation.gov.uk:

• Regulation 4, suitability: "Every employer shall ensure that work equipment is so constructed or adapted as to be suitable for the purpose for which it is used or provided."
• Regulation 5, maintenance: work equipment must be "maintained in an efficient state, in efficient working order and in good repair", and where a machine has a maintenance log, the log must be kept up to date.
• Regulation 6, inspection: where safety depends on how it's installed, equipment is inspected after installation and before first use. Equipment "exposed to conditions causing deterioration which is liable to result in dangerous situations" is inspected "at suitable intervals" and after "exceptional circumstances". The result is recorded and kept until the next inspection is recorded (regulation 6).

Work equipment is a broad term. HSE's brief guide lists hammers, knives, ladders, drilling machines, power presses, circular saws, photocopiers, lifting equipment, dumper trucks and motor vehicles, and it covers equipment employees bring from home (INDG291).

PUWER never uses the phrase "pre-use check". The expectation comes from regulations 4 and 5, because you can't know a machine is suitable and in good repair today unless someone looks, and from HSE's guidance on how to meet regulation 6.

Pre-use check, inspection or thorough examination?

A pre-use check is the operator's quick look and function test before use. A PUWER inspection is a planned, recorded check at intervals set by risk assessment. A thorough examination is the separate, deeper examination LOLER requires for lifting equipment. HSE's inspection guidance gives examples of each level:

HSE's Approved Code of Practice for PUWER draws the line plainly: "For the purpose of this regulation, inspection does not include a pre-use check that an operator makes before using the work equipment. While inspections need to be recorded, pre-use checks do not" (L22, paragraph 81).

When is a quick pre-use check enough?

For a lot of equipment, a quick check before use is all PUWER needs. HSE: "Not all work equipment needs formal inspection to ensure safety and, in many cases, a quick visual check before use will be sufficient." Formal inspection is needed "for any equipment where significant risks to health and safety may arise from incorrect installation, reinstallation, deterioration or any other circumstances", and your risk assessment decides which equipment that is.

L22 gives examples at both ends. Equipment that may need formal inspection includes most fairground equipment, machines where people approach the danger zone in normal use (such as paper-cutting guillotines and horizontal injection moulding machines), complex automated equipment and integrated production lines. Equipment unlikely to need it includes office furniture, hand tools and non-powered machinery. Most mobile plant sits in between: a pre-use check by the operator plus periodic inspections.

A practical way to decide:

• A fault would be obvious before it hurt anyone, and the operator would spot it: a pre-use check is probably enough.
• Deterioration is hidden or gradual, like wear on interlocks, guards or structural parts: schedule a recorded inspection.
• The manufacturer specifies inspections: follow them, and record them.
• Something exceptional happened, such as a major modification, known or suspected serious damage, or a long spell out of use: inspect before it's used again.

Do PUWER pre-use checks have to be recorded?

Usually not. HSE: "Records are not normally required to be made for the simplest pre-use checks." Inspections under regulation 6 are different: "The result of the inspection should be recorded and this record should be kept at least until the next inspection of that equipment."

Two common kinds of equipment are exceptions in practice:

• Forklifts and other lift trucks. HSE's lift truck guidance says the operator should check the truck at the start of each shift "and document the results". See forklift pre-use checks in the UK.
• Goods vehicles and buses. DVSA's Guide to maintaining roadworthiness expects a documented daily walkaround check, and says drivers' defect reports must be kept for at least 15 months.

There's also a practical reason to record checks anyway: if something goes wrong, a dated record of who checked what is your evidence the check happened. HSE's warning is against overdoing paperwork, not against keeping a record.

What a PUWER inspection record should contain

There's no set form. L22 says records "can be handwritten or stored electronically – from a pre-printed form to an entry in a diary", and suggests including:

• the type and model of equipment, and any identification mark or number;
• its normal location;
• the date of the inspection and who carried it out;
• any faults, the action taken, and who they were reported to;
• the date repairs or other action were carried out.

HSE adds that records "do not have to be made in writing but, if kept in another form (eg on a computer), these should be held securely and made available upon request by any enforcing authority."

Equipment that leaves your business, or arrives from another (hire is the usual case), must come with "physical evidence that the last inspection required to be carried out under this regulation has been carried out" (regulation 6(4)). For large items that's usually a copy of the last record; for small ones, HSE suggests "some form of tagging, colour coding or labelling system".

Who can carry out PUWER checks and inspections?

Anyone competent for that equipment. HSE says equipment "can be inspected by anyone who has sufficient knowledge and experience of it to enable them to know: what to look at; what to look for; what to do if they find a problem." That can usually be done in-house, by experienced staff working from the manufacturer's recommendations and industry advice.

The person who decides what an inspection covers doesn't have to be the person who does it, as long as both are competent. A supervisor can set the inspection; a trained operator can carry it out. For pre-use checks, the operator does them, so PUWER's training duty matters: operators need to know what each item on the check is for and what a fail looks like. More in what is a competent person.

How often should work equipment be inspected?

As often as your risk assessment says, not on a fixed national schedule. HSE says frequency should take account of "the manufacturer's recommendations, industry advice and your own experience", that equipment in harsh outdoor conditions is "likely to need more frequent inspections" than equipment used indoors, and that intervals "can be increased if the inspection history shows negligible deterioration, or shortened where experience shows this is necessary to prevent danger."

That last point is where records earn their keep: without a history of what each inspection found, you can't justify changing the interval in either direction.

Avoiding tick-box checks

The best PUWER check is short and specific to the equipment. HSE warns that "Requiring too much detail too often can lead to inspection activity becoming burdensome with the risk of a superficial 'tick box' approach or even, in some cases, the inspection activity ceasing altogether. You only need to inspect what is necessary for safety."

In practice: build each checklist from the manufacturer's daily checks, keep it to 10–25 items, write what a pass looks like, and drop items that belong in planned maintenance instead. See how to write a pre-use inspection checklist and pencil-whipping.

Keeping pre-use checks and inspections on a phone

If you want checks recorded without the paperwork, CheckBadges puts a QR sticker on each machine. The operator scans it with their own phone's camera and does that machine's check in the browser, with no app or login. Each check is filed under the machine with the operator's name and the time; a problem emails you with photos and is shown to the next operator who scans until you mark it fixed. You can print any record or export a CSV when an inspector asks. It records what you decide to check; PUWER and your risk assessment decide what that is.