Maintenance of work equipment
The UK has left the EU, and some rules and procedures have changed from 1 January 2021.
PUWER requires that: all work equipment be maintained in an efficient state, in efficient order and in good repair; where any machinery has a maintenance log, the log is kept up to date; and that maintenance operations on work equipment can be carried out safely.
What you must do
In order to ensure work equipment does not deteriorate to the extent that it may put people at risk, employers, the relevant self-employed and others in control of work equipment are required by PUWER to keep it 'maintained in an efficient state, in efficient order and in good repair'. If you are self-employed and your work poses no risk to the health and safety of others, then health and safety law may not apply to you. HSE has guidance to help you understand if the law applies. Such effective maintenance can not only help in meeting PUWER requirements but can also serve other business objectives, such as improved productivity and reduced environmental impact.
The frequency and nature of maintenance should be determined through risk assessment, taking full account of:
- the manufacturer's recommendations
- the intensity of use
- operating environment (eg the effect of temperature, corrosion, weathering)
- user knowledge and experience
- the risk to health and safety from any foreseeable failure or malfunction
Safety-critical parts of work equipment may need a higher and more frequent level of attention than other aspects, which can be reflected within any maintenance programme. Breakdown maintenance, undertaken only after faults or failures have occurred, will not be suitable where significant risk will arise from the continued use of the work equipment.
The manufacturer's instructions should describe what maintenance is required to keep the equipment safe and how this can be done safely. These instructions should always be followed, unless there are justifiable reasons for not doing so (eg where more frequent maintenance is necessary, due to intense use, adverse environmental conditions or when other experience shows this need). Maintenance on a less frequent basis than the manufacturer's recommendation should be subject to careful risk assessment and the reasons for doing so should be reviewed at appropriate intervals. For example, where there is already an inspection regime, perhaps for lightly used equipment, less frequent maintenance may be justified because of the condition monitoring already provided by the inspection programme.
There is no requirement for you to keep a maintenance log, although it is recommended for high-risk equipment. Maintenance logs can provide useful information for the future planning of maintenance, as well as informing maintenance personnel of previous action taken. However, if you have a maintenance log, you must keep it up to date.
Undertaking maintenance safely
Steps should be taken to manage any risks arising from maintenance activity. Manufacturer's instructions should make recommendations on how to safely undertake maintenance of their work equipment and, unless there are good reasons otherwise, these should always be followed.
Where possible, equipment should normally be shut down and any residual / stored energy safely released (eg pneumatic pressure dumped, parts with gravitational / rotational energy stopped or brought to a safe position). For high-risk equipment, positive means of disconnecting the equipment from the energy source may be required (eg isolation), along with means to prevent inadvertent reconnection (eg by locking off). Formal systems of work, such as a permit to work, are required in some cases to safely manage high-risk maintenance operations.
In some cases, it may not be possible to avoid particular significant hazards during the maintenance of work equipment so appropriate measures should be taken to protect people and minimise the risk. These may include:
- physical measures, eg providing temporary guarding, slow speed hold-to-run control devices, safe means of access, personal protective equipment, etc
- management issues, including safe systems of work, supervision, monitoring
- personnel competence (training, skill, awareness and knowledge of risk)
It is important that these situations are properly assessed. Staff undertaking maintenance may need to undertake significant on-the-job risk assessment (essentially considering what could go wrong and how to avoid injury), as the situation may develop and change in ways that could not be foreseen at the outset.
HSE's Safe maintenance health check provides a question list which can help you in undertaking safe maintenance, while there is also a short video forming part of the current European Campaign on Safe Maintenance.
Work equipment may need to be constructed or adapted in a way that takes account of the risks associated with maintenance work. For example, lubrication and adjustment points can be repositioned / adapted to enable the work to be carried out at ground level; safe means of access can be provided on the equipment (eg handholds, anti-slip surfaces for feet), or so that guarding to prevent contact with dangerous parts can be kept in place. In most cases (all machinery supplied since 1995), this should have been taken into account by the manufacturer in the design of the equipment, and by you when deciding which product to purchase. However, this may not always be the case and it may not apply to older work equipment on your site.
What you should know
The duty to maintain work equipment (PUWER regulation 5) and take measures to manage the risks from maintenance (PUWER regulation 22) builds on the general duties of section 2 of the Health and Safety at Work Act, which requires work equipment to be maintained so that it is safe, and work to be undertaken safely, so far as reasonably practicable.
Closely linked to maintenance are the duties to inspect work equipment (PUWER regulation 6, and 33 for power presses) and undertake thorough examinations (LOLER regulation 9, and PUWER regulation 32 for power presses). Inspection may be part of the overall maintenance programme and, like thorough examination, may be one of the techniques for validating the maintenance programme.
Who can undertake maintenance of work equipment
Maintenance work should only be undertaken by those who are competent to do the work, who have been provided with sufficient information, instruction and training (PUWER regulations 8 and 9). With high-risk or complex equipment, these demands may be significant and, in some cases, may be best undertaken by the manufacturer or specialist contractors. But, in many cases, maintenance can be done in-house by suitably trained, competent staff.
For some maintenance work, eg the changing of abrasive wheels, there are well-established industry training schemes. In other cases, such as for the use of small-scale scaffold towers, sufficient training may be provided by the hirers of such equipment. In others, such as hand-held chainsaws, training on the safe maintenance of the equipment is normally provided as an integral part of the basic training in the safe use of the equipment.