Plant & Machinery Statutory Inspections
INTRODUCTION
In conducting an overview of the liability risk, it is important that enquiries are made as regards compliance with statutory examinations of lifting equipment, pressure systems and other plant. Such examinations are often carried out as part of an engineering insurance contract that combines insurance against the consequences of breakdown with an inspection service.
The Provision and Use of Work Equipment Regulations (PUWER) 1998 covers all work equipment and any activity involving the equipment – including starting, stopping, programming, setting, transporting, repairing, modifying, maintaining, servicing, inspection and cleaning. Users must carry out risk assessments and make sure that all equipment is both safely installed and safe to use in accordance with duties under PUWER. In addition, there are specific regulations applying to particular types of equipment as follows:
LIFTING EQUIPMENT
The main item of legislation concerning lifting equipment is the Lifting Operations and Lifting Equipment Regulations (LOLER) 1998 which covers all work equipment with a lifting function. It applies in addition to PUWER and is aimed at providing adequate safeguards to people working with lifting equipment.
Under these regulations, a thorough periodic examination and inspection of lifting equipment by a suitably competent person is required within specified intervals, unless the scheme of examination states otherwise. A report of each thorough examination must also be provided. Examples of intervals between examinations are as follows:
PRESSURE SYSTEMS
The Pressure Systems Safety Regulations (PSSR) 2000 requires pressure systems to be thoroughly examined in accordance with a written scheme of examination. PSSR applies to plant containing a “relevant fluid” which is defined by the regulations as:
A compressed or liquefied gas, including air, at a pressure greater than 0.5 bar
Pressurised hot water above 110⁰C
Steam at any pressure
The extensive range of equipment covered by PSSR typically includes:
Compressed air systems;
Steam boilers;
Refrigeration plant (where installed power exceeds 25kW);
Fixed LPG systems (e.g. for heating);
Steam sterilising autoclaves; and
Electrically heated cafe boilers/ sets
Following an assessment, a written scheme of examination must be drawn up by a competent person, and must include a definition of the items included in the system, and details of the frequency of inspection. Inspection intervals may vary according to usage and/or risk assessment. The following table lists inspection periods recommended by the Safety Assessment Federation (SAFed):
Note: For pressure systems containing a relevant fluid other than steam, a written scheme of examination is only required where the system incorporates a vessel/ or vessels (e.g. air receiver) which has a stored energy level of 250 bar litres or more (i.e. product of pressure in bars and the internal volume in litres of each vessel in the system).
POWER PRESSES AND MACHINERY
Requirements for the thorough examination and inspection of power presses are covered in Part 4 of PUWER – the Safe Use of Power Presses. This requires that power presses (and press brakes with flywheels) are thoroughly examined and inspected by a competent person in accordance with the frequencies detailed below and a report provided. In addition, a suitably competent, appointed person (usually an employee, e.g. trained tool-setter, etc.) must inspect and test the guards and safety devices each day before use (i.e. within the first 4 hours of use) and, after setting, re-setting, or the adjustment of tooling with a log kept.
For hydraulic (incl. injection moulding machines) and pneumatic presses, a regular system of inspection by an authorised person on behalf of the company would be expected with a record retained.
Other process machines with guards and safety devices should also be inspected regularly under PUWER, although intervals are not typically specified. Inspections are required where there is a significant risk of injury and the extent of the inspection will depend on the potential risks from the work equipment. Inspections should include, where appropriate, visual checks, functional checks and testing.
The level of inspections required would normally be less detailed and less intrusive than the thorough examination required in respect of power presses, LOLER, etc. However, an inspection should always include those safety related parts which are necessary for the safe operation of equipment, for example, overload warning devices, limit switches, electrical safety interlocks, isolators, E-Stops and light guards etc.
Records of such examinations should be retained for a minimum period of three years.
LOCAL EXHAUST VENTILATION (LEV)
There are three sets of Regulations, which require employers to operate and maintain LEV equipment:
The Control of Substances Hazardous to Health Regulations (COSHH) 2002
The Control of Lead at Work Regulations 2002
The Control of Asbestos Regulations 2012
To meet the requirements of COSHH Regulation 9 (Examination and Maintenance), employers are required to ensure that local exhaust ventilation is thoroughly examined and tested by a competent person to ensure that it continues to perform in accordance with its design specification with the results suitably recorded. Recommended frequencies are as follows:
REPORTING AND RISK IMPROVEMENTS
Non-compliance with statutory inspections should be reported in the appropriate manner and risk improvements raised where applicable which, in the majority of cases, are to be submitted as requirements, owing to a breach of statutory obligations.
ADDITIONAL INFORMATION
A range of guidance publications are available from the HSE on free download. These include:
INDG178: Written schemes of examination – Pressure Systems Safety Regulations 2000
INDG 261: Pressure systems – safety and you
L122: Pressure Systems Safety Regulations 2000 – Approved Code of Practice
INDG291: Simple guide to the Provision and Use of Work Equipment Regulations 1998
L22: Provision and Use of Work Equipment Regulations 1998 – Approved Code of Practice
INDG290: Simple guide to the Lifting Operations and Lifting Equipment Regulations 1998
L113: Lifting Operations and Lifting Equipment Regulations 1998 – Approved Code of Practice
L112: Safe use of power presses. Provision and Use of Work Equipment Regulations 1998 as applied to power presses - Approved Code of Practice and guidance
INDG408: Clearing the air - A simple guide to buying and using local exhaust ventilation (LEV)
There are also a number of publications available from SAFed, including Guidelines for the examination of electrically heated café boilers, on free download at www.safed.co.uk.