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Audits ensure PUWER compliance

A Laidler Associates product story
Edited by the Engineeringtalk editorial team Jun 17, 2004

To fully comply with PUWER, any new equipment should be inspected after installation and before it is put into use to make sure it is safe.

When the Provision and Use of Work Equipment Regulations (PUWER) first came into force in 1992 they included a very simplistic view on CE marking: the end-user only had to check that the equipment concerned carried a CE Mark.

If it did they were OK.

PUWER was updated in 1998 and one of the more important, but easily overlooked, changes was that the onus was now put on the end user to make sure that the equipment complies with all relevant legislation such as CE marking.

This point has been further backed up in other guidance from HSE including Information sheet FIS 25.

Even though this is specifically for flatbed conveyors for the food industry, the outlook is clear.

This sheet states: "Even when a machine is supplied CE marked, users should not assume that it is safe".

"Users should check for themselves that all relevant essential requirements are met and that the machine supplied is in fact safe".

If this is the case, and the end-user should now check more thoroughly regarding the CE marking of new equipment, what is the best way to do this?.

To fully comply with PUWER, any new equipment should be inspected after installation and before it is put into use to make sure it is safe.

This inspection, if carried out correctly, will highlight any safety issues, which may have an affect on the CE marking of the equipment.

Any issues that appear to relate to the CE marking of the equipment should be raised with the manufacturer or supplier of the equipment.

However, as the equipment has been installed it may be more difficult to deal with.

A solution to this may be to inspect or audit the equipment before it is shipped from the manufacturer or supplier.

Any potential issues can be raised with the manufacturer and either dealt with before it is shipped or at least be planned into the installation process once the equipment has been shipped.

Retrofitting is the more difficult method of compliance; it is always advisable to deal with safety as early as possible in the purchasing process, the design stage being preferable.

So, if as a company you decide to include such an audit in your equipment purchasing policy, what would you need to look at and who should carry out the audit?.

Dealing with the person first, they should have a good knowledge of the equipment type itself as well as competent understanding of PUWER and CE marking legislation.

As for what needs to be assessed, essentially, the Essential Health and Safety Requirements (EHSRs) of the relevant CE directive need to be covered, as these are what the manufacturer should be using to carry out the CE marking in the first place.

Although the auditor may not go through the EHSRs in as much depth as the manufacturer, the same areas need to be covered.

It may be beneficial for the auditors to create a generic checklist that can be used so that all people who are carrying out an audit for the company are looking at the same points.

Areas to look at include: documentation, electrical wiring and termination, utilities, control systems, mechanical hazards, ergonomic assessments, maintenance and cleaning procedures, training requirements, and safety controls.

It may also be beneficial at this stage to collate all the relevant documentation such as manuals, drawings etc so that a file is in place when the equipment arrives on site.

There may be many reasons why a company feels that a prepurchasing audit is not feasible.

It may be manpower, time, competence or a mixture of the free.

Laidler Associates currently carries out this kind of audit for a number of major blue chip companies, both in the UK and abroad.

Following the audit, the client will receive a full report highlighting any problem areas with a recommended corrective action.

Laidler can also carry out an inspection to enable compliance with PUWER and project manage any retroengineering that needs to be carried out.

Find out more about this article. Request a brochure, download technical specifications and request samples here.
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