What Inspection Records Does PUWER Require? A Site Checklist

What Inspection Records Does PUWER Require? A Site Checklist

Use this checklist when reviewing machinery files, preparing for an HSE inspection, or responding to an insurer’s request for evidence. The central question is: what inspection records does PUWER require? The answer depends on the equipment, the risks, its installation conditions and any deterioration or exceptional event.

PUWER does not impose one universal inspection interval for every machine. Regulation 9 requires a suitable inspection by a competent person where safety depends on installation conditions, deterioration or other circumstances. The record must show what was checked, what was found and what happened next.

1. Confirm that the equipment is within scope

• Identify the work equipment. Record the machine, tool, lifting accessory, vehicle or process equipment by description, manufacturer, model and unique asset number. The pass criterion is an unambiguous link between the item and its inspection history.

• Name the dutyholder. Record the employer or self-employed person responsible for the equipment under PUWER 1998. Where equipment is hired, leased or supplied by another business, document who controls inspection, maintenance and corrective work.

• Check the risk assessment. Regulation 4 requires equipment to be suitable for its intended use. The file should identify foreseeable risks, operating limits and the controls needed for guards, emergency stops, isolation and safe access.

• Verify conformity information. Retain the declaration of conformity, manufacturer’s instructions and relevant installation or commissioning documents where applicable. PUWER compliance is not proved by a CE or UKCA marking alone; the equipment must also be suitable, maintained and used safely.

2. Apply the correct inspection trigger

• Inspect after installation where installation affects safety. Regulation 9(1) and 9(2) require inspection when safety depends on installation conditions. The record should confirm checks such as anchorage, stability, guarding, electrical connections, controls and interfaces with adjacent equipment.

• Inspect after assembly at a new location. For equipment assembled or installed at another site, record the new location, assembly date, person responsible and the checks completed before use. The pass criterion is documented evidence that the new setup is safe before operation.

• Inspect after exceptional circumstances. Regulation 9 covers events likely to jeopardise safety, including major modification, accident, prolonged inactivity, fire, flood, impact or a significant control-system fault. Record the event, the examination scope, defects and the decision to return the equipment to service.

• Set a risk-based interval. Regulation 9 does not prescribe a single UK work equipment inspection frequency. Set the interval using the manufacturer’s instructions, operating environment, intensity of use, age, likelihood of deterioration and the consequences of failure.

A written schedule should state the next due date or trigger, the competent person, the inspection scope and the rules for extending, reducing or suspending use. A generic annual sticker is not a substitute for a documented risk-based decision.

3. Check the inspection record itself

A useful record should answer five questions: what was inspected, when, by whom, against which criteria and with what result. For each inspection, verify the following:

• Asset identity: equipment description, asset number, location and, where relevant, serial number.
• Inspection date and trigger: scheduled inspection, installation, relocation, modification or exceptional circumstance.
• Scope and criteria: manufacturer’s instructions, risk assessment, relevant maintenance procedure, previous defects and any statutory examination requirement.
• Competent person: name, employer, role and evidence of suitable training, knowledge and experience.
• Findings: satisfactory items, defects, measurements, photographs or test results where these support the conclusion.
• Corrective action: defect reference, risk ranking, action owner, target date, completion date and verification.
• Use decision: available for use, restricted use, isolated, quarantined or removed from service.
• Next action: next inspection date, condition-based trigger or confirmation that a separate examination regime applies.

The pass criterion is traceability from each defect to its closure. A form marked only “OK” or “passed” is weak evidence because it does not show what the competent person actually assessed.

4. Separate PUWER inspections from thorough examinations

PUWER inspection records are not automatically the same as PUWER thorough examination records. PUWER Regulation 9 concerns inspection of work equipment. Lifting equipment is also subject to the Lifting Operations and Lifting Equipment Regulations 1998, commonly called LOLER, where applicable.

Under LOLER Regulation 9, lifting equipment normally requires a thorough examination at least every 12 months, unless a written examination scheme sets another interval. Accessories for lifting normally require examination at least every six months. The interval can be shorter where the risk, use or environment warrants it.

Keep the LOLER report separate or clearly cross-referenced. It should identify the equipment, examination date, defects affecting safety, safe working load where relevant, limits or conditions of use, and the date by which remedial action is required. A PUWER checklist cannot replace a LOLER report.

The same distinction applies to pressure systems, local exhaust ventilation, electrical safety and other regimes. Check whether another law requires a specific examination, test certificate, written scheme or retention period before closing the file.

5. Close defects before releasing equipment

• Classify the defect. State whether it presents immediate danger, requires restricted use, or can be managed until planned maintenance. Use the risk assessment rather than an arbitrary colour code.

• Control unsafe equipment. Regulation 4’s suitability requirement means equipment with a safety-critical defect should be isolated, locked out or clearly marked against use until repaired and verified.

• Record the repair. Link the work order to the inspection record. Include the part replaced, repairer, date, test performed and person who authorised return to service.

• Reinspect after significant repair or modification. If the work may affect safe operation, record a post-repair inspection before normal use. Update the risk assessment and instructions where the equipment’s function or hazards have changed.

• Keep operator checks visible. Daily or pre-use checks support the formal programme but do not replace a Regulation 9 inspection. Give operators a simple defect-reporting route and require them to stop work when a serious defect is found.

6. Prepare the file for an audit

A practical PUWER inspection checklist HSE reviewers can follow should include the asset register, risk assessments, manufacturer information, inspection schedule, completed reports, defect log, repair evidence and training records. Arrange documents by asset rather than storing unrelated certificates in one folder.

Records should be available to the relevant enforcing authority and to people responsible for operating or maintaining the equipment. PUWER Regulation 9 requires the result of an inspection to be recorded and, where applicable, the record to be kept until the next inspection. Retaining the complete history for the equipment’s service life is usually more useful for trend analysis, insurer reviews and recurring-fault investigations.

Before an audit, sample several assets from different risk groups. Confirm that the last inspection was completed on time, open defects have owners and deadlines, reports identify the competent person, and any LOLER or other statutory examination is present. Missing evidence should be treated as a control gap, not solved by backdating a form.

Takeaway: make every record prove a decision

The strongest answer to “what inspection records does PUWER require?” is not a particular form or calendar interval. It is a connected evidence trail showing why inspection was needed, what a competent person checked, what defects were found, how risk was controlled and when the equipment could safely return to service.

Review the programme whenever equipment changes, operating conditions deteriorate or incidents reveal a new failure mode. That approach is more defensible than relying on a fixed annual date and is better aligned with the risk-based structure of PUWER 1998.