I have been inspired to write this article on PUWER as so many of the companies I have worked for were initially not compliant to this legislation.
The regulations came out in 1998 and we are now over 20 years down the road.
So, what is stopping companies embracing this legislation?
I hope this article will go some way to explain this and explain what a company needs to do to be compliant.
So, what is PUWER and what does it cover?
The regulations deal with the work equipment and machinery used every day in work places and aims to keep people safe wherever equipment and machinery is used. It places a duty on the employers to ensure the following requirements are in place: –
- To ensure that the equipment used is suitable for its purpose
- Maintained to a safe standard and not to risk health and safety
- Inspected by a competent worker who should record the results
- Only used by people who have received adequate training
Why haven’t companies embraced this regulation?
There are a number of reasons why in my opinion, and that of others, why this regulation is not embraced by companies.
Reason 1 – Confusion and complication: Many companies don’t know where to start let alone what equipment and machinery needs to be assessed, or the site does not have the onsite expertise to complete this task. From experience, the criteria above doesn’t sound complicated but as you read the regulations it does become confusing, even to the most experienced HSE professionals.
Reason 2 – What to assess: Companies don’t understand what needs to be assessed due to Reason 1 above. The asset register is the place to start looking. Not every company has an asset register in place or the HSE person does not know it exists and if there is one who should maintain it.
I worked for one company who identified over 24,000 pieces of equipment and machinery that needed to have an assessment conducted on them. They had four PUWER Risk Assessors at the time who estimated that it would take over seven years to complete the assessments. In the end a decision was made to outsource to an external company who specialised in PUWER risk assessments.
Reason 3 – Training: Companies don’t have trained PUWER Risk Assessors or provide awareness training for people using the equipment and machinery. Without the assessors and trained employees then the company is unable to deliver the requirements of this legislation.
Reason 4 – Cost: Companies understand that this legislation could potentially cost them substantial amounts of money therefore choose to ignore it. There will be a lot of actions that will be identified during the initial risk assessments, some of which will need vast sums of money spending to be able to rectify the issue. With training and/or outsourcing, complying with PUWER is potentially a costly piece of legislation to implement.
How to be compliant?
There are a number of steps that I would consider in order to ensure you are compliant with this standard. The list is not exhaustive. I have personally implemented PUWER using the following steps:
Step 1 – Assets Register
You first need to understand how many pieces or work equipment and machinery you have on your site that needs to be assessed. If you have a company asset register this is a good place to start, if not then you will need to walk the site and list everything.
Once you have this list you can then see how many machines are the same so that you can group them together when it comes to the assessments.
Step 2 – Training
Now that you know how many risk assessments need to be completed, you can now determine how many PUWER Risk Assessors you will need. Make sure that the employee has either already completed the General Risk Assessor training otherwise they will need to attend a double course – General Risk Assessor and then PUWER Risk Assessor training. The key to success is ensuring the personnel trained know what it is that you are expecting them to do, and how long the project is. Be transparent!
Based on the number of assessments to be completed and the number of assessors you have trained you will now need to determine how many assessments each assessor is required to do each month. Prioritise high risk equipment first.
An alternative, if you do not want to train your employees, is to hire an external company. Your employees should shadow the external company so as to improve their knowledge or alternatively the external company will complete all the assessments and you will manage the actions.
Awareness training will also need to be delivered to all employees who work or supervise on the identified equipment and machinery. The training will need to be refreshed at regular intervals or if a serious incident has occurred or new machinery has been installed or changed substantially.
Step 3 – Communication
This is probably a step that most companies forget to do. You must communicate to the workforce what the project is, what needs to be done, how long it is going to take and possible disruptions during the project.
Ensure that you communicate progress at regular intervals outlining how many assessments have been completed, how many actions have been identified and how many have been closed. Again, be transparent.
Step 4 – Risk Assessments
Although there is no mention about risk assessments in the PUWER Regulations, there is an overlap with the Management of Health and Safety at Work Regulations that covers risk assessment.
The risk assessment carried out, under regulation 3 of the Management Regulations, should identify hazards presented by machinery. It should evaluate the nature of the injury, its severity and likelihood of occurrence for each hazard identified. This will enable you to decide whether the level of risk is acceptable or if risk reduction measures are needed. In most cases, the objective of risk reduction measures is to prevent contact of part of the body or clothing with any dangerous part of the machine, for example guarding.
When looking at the risks from machinery it is easy to focus only on the safety risks. However, risks to the health of your workers from manual handling, dust, fumes, noise, hand/arm vibration etc are equally important, and should always be considered in your risk assessment.
There are many examples of PUWER risk assessment forms that you can use which can be found on the internet, however if you would like a copy of one then please get in touch.
Step 5 – Action Tracking
I can guarantee that you will find numerous actions during the initial risk assessments. Some will be quick fixes that will cost little to nothing, and there will be others that you will have to spend substantial amounts on. There will be some actions that will need capital expenditure for example you may need to replace a machine or install fencing around a robot.
Ensure the actions are tracked through to closure and include in the communication details such as how much money has been spent to show employees that you take this seriously.
This isn’t an easy regulation to become compliant with especially if you don’t have the expertise on site. However, if you follow the steps above it will get you on the right track to ensuring that your employees are working with equipment that is safe and fit for purpose.
Written by Dawn Hemmings, Manager, Operational Excellence, LyondellBasell
Please note, the views expressed by the original article author are theirs alone and do not necessarily represent those of Washingtondowling Associates Ltd or The SHE Show and therefore we take no responsibility for the content or accuracy of this post.