PUWER FAQ

All your questions - answered

 

There are a number of questions we are frequently asked about PUWER. On this page we have collated these into a list and utilized our industry-leading knowledge to answer them.

Have you got a question about PUWER not covered in this list? Contact our Machinery Safety Experts for an answer to your query:

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PUWER FAQs

General

What does PUWER stand for?

PUWER stands for The Provision and Use of Work Equipment Regulations. PUWER Regulations came into force on 5th December 1998 and they apply to all UK work activities.

Compliance with the Regulations is a legal requirement for those who operate or have control over work equipment - in short, both employers and employees.

What is the meaning of PUWER?

PUWER, The Provision and Use of Work Equipment Regulations, is a statutory instrument of the United Kingdom. The main purpose of PUWER is to ensure the provision of safe work equipment throughout the lifetime of its use, regardless of its condition, age or origin. The regulations came into force on 5 December 1998 and was formerly known as PUWER98.

The regulations require that machinery provided for use at work is:

  • Suitable for its intended use
  • Safe for use - including keeping it maintained in a safe condition with regular inspections to ensure it is installed correctly and that its level of safety doesn't subsequently decline
  • Used only by people who have received adequate training, instruction and information
  • Accompanied by suitable health and safety measures, such as protective controls and devices
  • Used in accordance with specific requirements - mobile work equipment and power presses

There is some overlap between PUWER and other sets of regulations - for example CE & UKCA Marking. For more detailed information on how Pilz can help you with your PUWER or CE/UKCA compliance contact us on [email protected]

What equipment is covered by the PUWER Regulations?

Essentially it is 'work equipment' that is covered by the PUWER Regulations - as is referenced in the full title, the Provision and Use of Work Equipment Regulations.

But what exactly is work equipment? The scope is very broad - it covers almost any equipment used at work, and also covers second hand, hired and leased equipment.

Equipment used at work includes the following (but is not limited to):

  • Hand tools - drills, hammers, handsaws, meat cleavers, knifes, sharpening tools, riveters etc
  • Single stand-alone machines – workshop equipment, CNC machines, circular saws, grinders, pillar drills, lathes, band saws, hydraulic press, milling machines etc.
  • Apparatus – laboratory apparatus, autoclaves, measuring devices, hot water baths, water distilling, fume extraction
  • Lifting equipment – elevating work platforms, cranes, lift trucks, hoists etc
  • Other equipment – pressure washers, ladders etc
  • Complex Installations - series of machines connected together to form Production lines

If you have and use any of the forementioned equipment then abiding by the PUWER Regulations is mandatory. Employers must ensure that all work equipment meets the essential requirements of the regulations laid down for the manufacture of that equipment, and that inspections are carried out in the right manner, by an appropriate party.

How many PUWER Regulations are there?

There are 37 PUWER Regulations in total. They are then split into 6 parts - Interpretation, Management, Physical, Mobile Work Equipment, Power Presses and Exemptions & Transitionals.

Each Regulation covers a different aspect of the safe use and provision of work equipment - specifically they are as follows:

Interpretation

  • Regulation 1: Citation and Commencement
  • Regulation 2: Interpretation
  • Regulation 3: Application

Management

  • Regulation 4: Suitability of Work Equipment
  • Regulation 5: Maintenance
  • Regulation 6: Inspection
  • Regulation 7: Specific risks
  • Regulation 8: Information and Instructions
  • Regulation 9: Training
  • Regulation 10: Conformity with Community Requirements

Physical

  • Regulation 11: Dangerous Parts of Machinery
  • Regulation 12: Protection against Specified Hazards
  • Regulation 13: High or Very Low Temperatures
  • Regulation 14: Controls for starting or making a significant change in operating conditions
  • Regulation 15: Stop Controls
  • Regulation 16: Emergency Stop Controls
  • Regulation 17: Controls
  • Regulation 18: Control Systems
  • Regulation 19: Isolation from Sources of Energy
  • Regulation 20: Stability
  • Regulation 21: Lighting
  • Regulation 22: Maintenance Operations
  • Regulation 23: Markings
  • Regulation 24: Warnings

Mobile Work Equipment

  • Regulations 25 - 30: Mobile Work Equipment

Power Presses

  • Regulations 31 - 35: Power Presses

Exemptions & Transitionals

  • Regulation 36: Exemptions
  • Regulation 37: Transitional Provision

Who is responsible for PUWER?

The approved code of practice and guidance (ACOP) for PUWER (formerly PUWER98) states that duties, or responsibilities, are placed on the following:

  • Employers
  • The self employed
  • People who have control of work equipment

Employer's Duties

To ensure that work equipment and machinery provided to your employees (including self-employed that are working for you) complies with PUWER. It is also a legal duty to discuss matters relating to health & safety in the workplace with your employees.

Self-Employed People’s Duties

To ensure that the work equipment and machinery you provide for work or use at work complies to PUWER.

The Duties of Those in Control of Work Equipment

To ensure that the work equipment and machinery complies to PUWER if you provide it for use at work, where you do not control its use or the premises where it is to be used.

For further information on PUWER duties refer to the guidance section for regulation 3 in the PUWER Approved Code of Practice and Guidance (ACOP) L22 (4th edition).

Can I carry out a PUWER Inspection?

The PUWER ACOP (Approved Code of Practice) states that an inspection of work equipment must be carried out when it is:

  • First installed
  • When it is moved or relocated

This is to ensure that it has been correctly installed and is operating safely. Work equipment must also be inspected regularly where it is exposed to conditions that could cause it to deteriorate.
 
It then goes on to state that the people who determine the nature of the inspections required and who carry out the inspections are competent and should have the necessary knowledge and experience to do so.

Determining the nature of the inspection & carrying out a PUWER Inspection

The person who determines the extent of the inspection should have sufficient knowledge and experience, so that they can decide:

  1. What the inspection should include
  2. How it should be done
  3. When it should be carried out

The inspector needs to have sufficient experience and knowledge to be able to identify what needs to be inspected, and to be able to detect damage or faults resulting from deterioration.

They should also be able to determine whether any tests are needed during the inspection to see if the equipment is working safely or is structurally sound. They should have sound knowledge of the equipment so that they:

  1. Know what to look at (the key components)
  2. Know what to look for (fault-finding)
  3. Know what to do (reporting faults, making a record and who to report to)

Most importantly the inspector must be competent enough to carry out the inspection properly, thoroughly and safely. The necessary level of competence will differ depending on the type of equipment, its location and how it is used.

For many organisations the level of competence to determine the nature of the inspections or to carry them are not available in-house, in which case they seek the help of another body with the relevant competence, knowledge and experience needed to conduct a thorough and safe PUWER Inspection.
 
Want the knowledge to carry out your own PUWER inspections? We've got training courses for that!

PUWER Training

What does PUWER Regulation 18 - Control Systems - cover?

PUWER Regulation 18 covers the safety and reliability of control systems on work equipment. It requires employers to ensure, so far as is reasonably practicable, that control systems are designed and maintained so they do not create additional risk — including in the event of faults, failures or loss of power.

Control systems should:

  • Not lead to dangerous situations if a fault occurs
  • Not interfere with other safety measures
  • Allow stop and emergency stop functions to operate correctly
  • Bring the machine or process to a safe condition where necessary

Failure of the control system or its power supply should result in a safe state. Rather than “fail-safe”, this is better understood as minimising the likelihood of dangerous failure, often expressed using measures such as Probability of Dangerous Failure per Hour (PFH). The higher the risk, the more reliable and fault-tolerant the system must be.

In many cases, a safe stop is appropriate. However, for some processes (e.g. chemical systems), stopping may introduce additional hazards. In these situations, control systems should be designed based on risk assessment, using measures such as controlled shutdown, redundancy or diversion to a safe state.

The current PUWER Approved Code of Practice (L22) was published in 2014, with amendments made in 2018.

Which standards apply to control systems under PUWER?

PUWER does not mandate specific standards, but recognised standards are widely used to demonstrate compliance with current good practice.

Key standards include:

ISO 13849-1 is widely used across a broad range of machinery and technologies, while EN IEC 62061 is often applied to more complex or programmable systems, particularly where a SIL-based approach is preferred. Both aim to ensure control systems achieve an appropriate level of safety and reliability.

Is Employee training covered in a PUWER Inspection?

Employee training is covered within Regulation 9 of PUWER and mainly focuses on:

  • Providing training to employees who use work equipment and/or machinery
  • Providing training for those employees who supervise or manage the use of work equipment and/or machinery

The current PUWER Approved Code of Practice (L22) was published in 2014, with amendments made in 2018.

Regulation 9 Training

The PUWER Approved Code of Practice (ACOP) states that:

Every employer shall ensure that any of his employees who supervises or manages the use of work equipment has received adequate training for purposes of health and safety, including training in the methods which may be adopted when using the work equipment, any risks which such use may entail and precautions to be taken

What does this mean?

In short, an employer must provide all staff who use, supervise or manage work equipment with adequate training on:

  • How to use the equipment safely
  • The risks associated with its use
  • The precautions required to control those risks

The phrase “adequate training” can be quite broad. What is considered adequate will depend on:

  • The employee’s role
  • The activity being undertaken
  • The type and complexity of the work equipment

To determine the right level of training, employers should assess existing competence and provide additional training where needed.

The following steps can be taken:

  • Evaluate the existing competence of employees and others to safely operate the full range of work equipment they will use. This includes temporary and agency workers
  • Evaluate the competence required to supervise or manage others using the equipment
  • Identify any gaps between existing competence and the level required for safe use, and provide further training where necessary

Points to Consider…

It’s important to remember that training employees includes other types of workers such as agency or temporary workers, interns and work experience along with existing, permanent workers.

Pay particular attention to any employees who have disabilities, language difficulties or limited understanding of English. This could include interpreters or alternative training formats such as visual, digital or video-based learning.

Young or inexperienced workers may require closer supervision and more structured training due to their lack of experience. Additional duties for young persons are set out in the Management of Health and Safety at Work Regulations 1999.

When is training necessary?

The PUWER ACOP states that training is necessary in the following situations;

  • On recruitment. Typically the greatest need for training.
  • When working tasks or associated risks change
  • When new equipment or technology is introduced
  • When systems of work are updated

Refresher training should also be provided where necessary, as competence can decline over time. For example:

  • Where processes have changed
  • Following a prolonged absence
  • Where workers only occasionally carry out a task

Particular attention should be given to employees who infrequently deputise for others, as they may require more frequent refresher training.

At Pilz, we take training seriously. Not only is Regulation 9 covered in detail within our PUWER Inspection service, but we also offer a range of Machinery Safety training courses. These can be delivered at our Corby headquarters or on-site at your premises.

Pilz PUWER Training

Is it just work equipment and machinery that is inspected under PUWER?

No, it isn't just work equipment and machinery that is inspected under PUWER - an inspection will also include:

  • Training records and procedures
  • Maintenance operations
  • Standard operating procedures
  • PPE requirements
  • General working environment (lighting, warning signs...)
  • General health and safety of the site

Are light curtains inspected during a PUWER assessment?

Light curtains can be inspected as part of a PUWER assessment; they fall under regulation 11 of PUWER – Dangerous parts of machinery.

Regulation 11 of PUWER sets out the following:

  • Employers are required to take effective measures to prevent access to dangerous parts of machinery or stop their movement before any part of a person enters a danger zone
  • The measures which you should take to prevent access to the dangerous parts of the machinery to achieve compliance with regulation 11
  • The various requirements for guards and protection devices
  • Regulation 11 can cover many parts and types of machinery; the HSE has many publications that contain specific guidance on particular machines or for particular industries and describe the measures that can be taken to protect against risks associated with dangerous parts of machinery

During a Pilz PUWER inspection, where light curtains are used to protect against dangerous parts of machinery, we inspect the following areas:

  • Location – Physical location or positioning of devices
  • Testing & Inspection – The maximum period between each periodic inspection and test for a Type 2 Light Curtain is 12 months and for a Type 4 is 6 months. What the light curtain is fitted to and the risk as a whole is also considered
  • Reset – Are the devices not easily bypassed or disabled

One of the common non-conformances associated with light curtains during a PUWER assessment is that they are not situated a sufficient distance away from the danger zone. When a light curtain is improperly situated it defeats the purpose of its intended use, subsequently creating a dangerous working environment.
 
Conducting a PUWER inspection can help organisations to identify potentially dangerous situations within their plant, site, machinery or work equipment and create a plan to remedy this so that a safe working environment is created through having safe work equipment. Pilz also offer an Inspection of safeguarding devices service that will determine the proper installation, safe distance, function and incorporation into the machine control system.

To find out more about how PUWER is applied during an inspection contact us on [email protected].

Pilz Inspections

What is included in a Pilz PUWER report?

  • Results of a machine assessment to PUWER covering the applicable regulations
  • Risk evaluation that identifies, estimates and evaluates any potential hazards and risks relating to the regulations within PUWER
  • Executive summary, covering the key points of your PUWER assessment including a categorised breakdown of any non-conformances

Once the report has been quality checked at our head office, you will receive copy of the PUWER report via email. A hard copy can also be sent out via post if required - just let your PUWER assessor know.

To get an idea of the reports we produce contact us:

Sample Report Request

How much does a Pilz PUWER inspection cost?

The total cost is dependent on the size, quantity and complexity of the machinery being inspected. A quotation can be based on the information you provide, such as machine images, drawings or site layout. If required a site visit can be arranaged to gather the necessary information to provide a detailed quotation.

To enquire about a Pilz PUWER Inspection click the button below to contact us via email:

Inspection Enquiry

How many machines can be inspected in one day?

We estimate we can inspect up to 15 small machines in a day*. Small machines include:

  • Workshop equipment - pillar drills, lathes etc
  • Small mixer

On average we can inspect up to 10 medium machines per day*. Medium machines include:

  • Box erector
  • Wrapper
  • Corrugator
  • Bailer

We estimate that we can inspect up to 5 large machines per day*, Large machines include:

  • Palletisers & de-palletisers
  • Conveyor systems
  • 1 x robot cell

The best way to find out how many days you would require for a PUWER assessment is to get in touch to discuss your requirements - you can either give us a call on 01536 460766 or click the button below to email us.

Inspection Enquiry

Achieve PUWER Conformity with Pilz

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Contact

Pilz Automation Technology
Pilz House, Little Colliers Field
Corby, Northants, NN18 8TJ
United Kingdom

Telephone: +44 1536 460766
E-Mail: [email protected]

Pilz Automation Technology

Pilz House, Little Colliers Field
Corby, Northants, NN18 8TJ
United Kingdom

Telephone: +44 1536 460766
E-Mail: [email protected]

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Telephone: +44 1536 460866
E-Mail: [email protected]

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