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

Regulation 9 Training

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

  1. Every employer shall ensure that all persons who use work equipment have 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
  2. 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 that either use the work equipment or manage/supervise those that do so with adequate training of how to use the work equipment, any risks that may occur from the use of the work equipment and what precautions should be taken.

The phrase “Adequate training” can be quite ambiguous, and what constitutes as adequate training will differ depending on the employees job, the activity they are undertaking and what the work equipment is. In order to ascertain the correct level of training an employer should determine the existing level of competence and then provide training where necessary.

The following steps can be taken:

  • Evaluate the existing competence of employees and others to operate the complete range of work equipment they will use safely. This includes any temporary workers such as those supplied by an employment agency.
  • Evaluate the competence they need to supervise or manage others to use the work equipment
  • If there is a shortfall between an employee’s existing level of competence and the level that is required to carry out work in a safe manner with due care to health and safety, then further training should be given to eliminate that shortfall

Points to Consider…

Here are some other things to consider and look out for when evaluating your employees' training and competence levels:

  • 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 where English is not their first language, as it could be difficult for them to understand or receive any instructions or information given to them. Special arrangements may need to be made in these cases to help ensure that any instructions are understood, such as using an interpreter, or supplying other learning methods such as a DVD to watch rather than printed instructions.
  • Training and supervision of young people is particularly important due to their unfamiliarity with the working environment, a lack of previous experience to draw from and their relative immaturity, thus putting them at a higher risk level. (Although PUWER does not contain any specific requirements relating to the age of people using work equipment, there is a general guidance relevant to the provision and use of machinery under regulation 19 of the Management of Health and Safety at Work.)

When is training necessary?

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

  • The greatest need for training will be on recruitment
  • If the risks to which people are exposed change due to a change in their working tasks
  • When new technology or equipment is introduced
  • If the system of work changes.
  • Refresher training should be provided when necessary as skills decline if they are not used regularly. For example, an employer might want to check if refresher training is needed if a worker is moved onto a work process that has been changed since the last time they conducted it, or if they have had an extended period of absence from work. Particular attention should also be paid to those who infrequently deputise for others, as they may need more frequent refresher training than those who conduct the task regularly.

At Pilz, we take training seriously, not only is regulation 9 covered in detail in our PUWER Inspection service, but we also offer a range of Machinery Safety training courses. These are available to run from our Corby HQ or from your own site.

For more information about PUWER Inspections email
If you would like more information about our range of training courses email


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

Telephone: +44 1536 460766

Pilz Automation Ltd

Telephone: +44 1536 460766