PUWER (Provision and Use of Work Equipment Regulations) Policy

The Chief Operating Officer (COO) is responsible to the Vice Chancellor on a delegated basis for the general oversight and development of health and safety policy and for ensuring co-ordination of such policies and practice across the University. The COO has responsibility for ensuring that the arrangements to manage health and safety in accordance with University policy are effective. The COO has line management responsibility for the Director of Health Safety and Wellbeing in order to oversee health and safety compliance and performance.

• Appoint Authorised Persons(s) for their areas/departments and ensure the competency of the Authorised Person (AP) by ensuring that the person  has suitable ability, experience, training and resources to enable them to carry out their duties defined in the policy.
• Ensure all PUWER policy and guidance documents are available and accessible to all persons with responsibilities under this policy.
• Ensure all supervisors (including Academic, Research, Technical, Professional and
• Administrative) are given necessary information, instruction and training with regards to PUWER.
• Ensure that PUWER is complied with and the risk from work equipment is satisfactorily controlled.
• Cooperate with arrangements for examination and testing by a ‘Competent Body’ (e.g. insurance inspector) followed by resultant remedial work.
• Responsible for the adoption of the University Policies within their area of control.
• Responsible for appointing School/Departmental Safety Officer(s)
• Set local health and safety policy based on institutional requirements by informing staff of their responsibilities, the arrangements for the introduction and maintenance of measures designed to identify, assess, control and monitor risks.
• Ensure staff provide appropriate supervision of researchers and students based on their risk assessments.
• Ensure that any matter brought to their attention by safety representatives is given prompt and appropriate attention.
• Take personal action to suspend or stop any activity that is dangerous or not carried out within local health and safety policies and arrangements.         

• Appoint Authorised Persons(s) for their areas/departments and ensure the competency of the Authorised Person (AP) by ensuring that the person has suitable ability, experience, training and resources to enable them to carry out the duties defined in the policy.

• Ensure all PUWER policy and guidance documents are available and accessible to all persons with responsibilities under this policy.
• Ensure all supervisors (including Professionals, Research, Technical and Administrative) are given necessary information, instruction and training with regards to PUWER.
• Ensure that PUWER is complied with and the risk from work equipment is satisfactorily controlled.
• Cooperate with arrangements for examination and testing by a ‘Competent Body’ (e.g. insurance inspector) followed by resultant remedial work.
• Responsible for the adoption of the University Policies within their area of control.
• Responsible for appointing Health and Safety Leads/Departmental Safety Officer(s)
• Set local health and safety policy based on institutional requirements by informing staff of  their responsibilities, the arrangements for the introduction and maintenance of measures designed to identify, assess, control and monitor risks.
• Ensure that any matter brought to their attention by safety representatives is given prompt and appropriate attention.
• Take personal action to suspend or stop any activity that is dangerous or not carried out within local health and safety policies and arrangements.

• Ensuring health and safety audits are performed and results forwarded to the Health and Safety Services.
• Ensuring the Health and Safety Committee meets at least three times a year.
• Ensuring that all accidents and near misses are reported to the Health and Safety Services.
• Ensuring that all action is taken to remove causes of accidents or near miss events.
• Reviewing Procedures for producing Risk Assessments and ensure Risk Assessments are suitable, sufficient and up to date.
• Bring to the attention of the Dean or Head of Professional Service any breach of statutory requirement or other health and safety concern that cannot be resolved.

• Undertake health and safety training to appropriate level of competence.
• Be fully familiar with University Health and Safety Policies and assist the Head of Department to develop, implement and review local policies and procedures.
• Undertake regular safe use of work equipment audits.
• Ensure all occupational ill-health, accidents and incidents are investigated and subsequent actions carried out.
• Disseminate health and safety information and ensure necessary provision of health and safety training.
• Monitor that the PPE provided is adequate.
• Monitor that all plant, equipment and processes within their area are maintained in a safe condition.
• Monitor safe working practices based on risk assessments.
• Ensure work equipment is satisfactorily maintained.
• Ensure work equipment is positioned and installed to minimise risks.

• Ensure they are familiar with University and local health and safety polices that apply to their area(s).
• Ensure staff are sufficiently trained to enable them to carry out suitable and sufficient risk assessments where required.
• Ensure that staff operate in accordance with University and local Health and Safety Policies relevant to their work.
• Ensure that all staff are trained in the principles, operations and emergency procedures necessary for health and safety.
• Ensure staff know the University procedure for accident/near miss reporting.
• Ensure Training and competence of staff.
• Ensure safe working practices within a safe working environment are used by all staff.
• Ensure all work equipment is fit for purpose and maintained in good working order.
• Ensure suitable PPE is supplied and provision made for its safe storage and cleaning
• Ensure all work equipment has been designed and constructed in accordance with the relevant legislation, carry the CE mark and are in possession of the Declaration of Conformity and operating instructions.
• Ensure equipment is appropriately guarded in order to prevent contact with dangerous parts and protection provided against specified hazards.
• Ensure equipment is provided with the relevant warnings and markings.
• Ensure there is a maintenance schedule for work equipment which requires it and the equipment is examined, inspected and tested at the frequency the risk assessment requires
• Ensure records are kept for maintenance, examination, inspection and testing.

• Make themselves familiar with University and local health and safety polices relevant to their work.
• There is a general legal duty to take reasonable care of yourself and others who could be affected by your actions and co-operate with your employer to comply to health and safety regulations.
• Undertake as required all health and safety training deemed necessary by their manager/supervisor.
• Report any occupational ill health issues, accidents, incidents and dangerous occurrences to your manager/supervisor.
• Use the equipment and safety devices supplied in accordance with the training provided.
• Make full use of appropriate Personal Protective Equipment (PPE) and safety equipment and devices provided. If you have any doubt that any of this equipment is appropriate do not undertake the work and report this to your line manager/supervisor/task manager, normally a new Risk Assessment would be undertaken to confirm PPE and safety equipment and devices provided are appropriate before proceeding.
• Maintain tools and equipment in good condition reporting any defects to their manager/supervisor.
• Conform to all instructions either oral or written given to ensure their personal safety and that of others.
• Shall not, intentionally or recklessly, interfere with or misuse anything provided by the University in the interests of health, safety and welfare.
• Shall not, without consent from the manager/supervisor, introduce any equipment for use on University Premises, alter any fixed installations, alter or remove health and safety notices or equipment or otherwise take any action which may create hazards for others.
• Undertake any pre-use inspections of work equipment as required.

• At all times whilst they are on University premises or taking part in University activities follow the University and local health and safety polices and health and safety instructions given to them.
• There is a general legal duty to take reasonable care of yourself and others who could be affected by your actions and co-operate with your employer to comply to health and safety regulations.
• Undertake as required all health and safety training deemed necessary by their line manager/supervisor.
• Report any occupational ill health issues, accidents, incidents and dangerous occurrences to your line manager/supervisor.
• Use the equipment and safety devices supplied in accordance with the training provided.
• Shall not, without consent from a member of staff, introduce any equipment for use on University Premises, alter any fixed installations, alter or remove health and safety notices or equipment or otherwise take any action which may create hazards for others.
• Make full use of appropriate Personal Protective Equipment and safety equipment and devices provided.
• Maintain tools and equipment in good condition reporting any defects to their line manager/supervisor.
• Conform to all instructions either oral or written given to ensure their personal safety and that of others.
• Shall not, intentionally or recklessly, interfere with or misuse anything provided by the University in the interests of health, safety and welfare.

A person, employed by the University, with the required knowledge, training and experience, appointed by the Chief Operating Officer (COO) in writing, to take managerial responsibility for the implementation of policy and procedures for a specific area of health and safety legislation including:

• Ensuring competency of all Authorised Persons (appointed under section 3.2) by ensuring that the person has suitable ability, experience, training and resources to enable to carry out the role.
• Responsible for the policy and implementation via schools and departments.
• To communicate by whatever means possible information to employees with regards to relevant information on the risks and control measures being undertaken.
• To ensure day to day compliance in regard to PUWER.
• To review as necessary the university PUWER Policy.
• To assist and offer advice in regard to PUWER across all areas of the University.
• To review that the PUWER Registers are up to date.
• Promote and ensure inspections are carried out in accordance with the risk assessment and other related requirements.

A Person, either employed by the University School / Department or another organisation possessing proficient knowledge and having received appropriate training appointed by the Dean or Directors (FM/Professional Services) to take operational  responsibility for the implementation of the policy and procedures for a specified area of Health and Safety legislation (in this case PUWER) including the duties:

• Day to day responsibility for controlling identified risk from work equipment in their areas.
• Advise the Dean/Director of any changes, modifications or areas of concern for any work equipment.
• Ensure all control measures are in place and effective.
• Carry out audits to ensure risk assessments are in place and comply to regulations.
• Promote and ensure Competent Persons are identified in their work areas.

NOTE: It is understood that certain staff may hold a number of concurrent roles and this authorised person role. This is not considered to be a conflict of interest or compromise the integrity of the system. Any member of staff who feels conflicted should speak to their Dean or Head of Department.

A competent person is someone who has sufficient training, experience or knowledge to competently and safely use and manage work equipment or laboratories and facilities that contain work equipment that they are competent in using.

The Competent Body appointed by Loughborough University for conduction of ‘thorough Examinations/Insurance Inspection’. Loughborough University current Inspection Service Provider is British Engineering Services insurance engineer(s)/surveyor(s).

5.1 Instructions/Standard Operating Procedures

Each piece of equipment should have clear written instructions. These can be in the form of:

• Standard Operating Procedures (SOPs)
• Working method statement (can be part of Risk Assessment form)
• Other clear written operating instructions (worksheet, manuals, training manuals, poster)

The instructions should include:

• Information about the way in which the equipment should be used.
• Safety related devices (guards, hazards etc).
• Setting up procedures, normal operation, shut-down procedures, cleaning.
• Personal Protective Equipment required.
• The conditions under which it can be used.
• Troubleshooting.
• Maintenance procedures.
• Specific health and safety information.
• Documentation/Records to be kept.

These instruction documents should be up to date and made available to those who use the equipment. This includes temporary workers, maintenance and supervisory staff.

NOTE: Give consideration and support to those whose first language is not English and those with intellectual disability to ensure the information has been understood. You may need make special arrangements in these cases for example visual DVD’s or translation into a different language. Give consideration to the format for those who may be visually impaired or dyslexic.

5.2 Training

A training programme will need to be developed for the equipment in your area. Supervisors and managers should keep suitable training records or authorisations to use to demonstrate training and competency of individuals. Employees and students should be encouraged to keep training records up to date when new training is undertaken. Please refer to Appendix 7 for an example template of an Authorisation to Use/ Training Record.

Teach users about the dangers and why we have the safety procedures we do. (e.g. the reason why we have to tie long hair back or avoid wearing loose clothing when using rotating machinery).

Ensure training includes the dangers arising, precautions to be observed, requirements of the law and methods for using guards, protection devices and PPE. The Greater the danger the higher level of training required.

5.2.1 Work Equipment Training & Supervision for Students

Training and proper supervision of students is important because of their relative immaturity and lack of familiarity with the working environment. Induction training is of particular importance. There are no general age restrictions in PUWER relating to the use of work equipment, although there are some restrictions in the ACOPs covering lifting, power presses, woodworking machinery, and fork lift trucks. Risk assessments should consider carefully the training needs of students, taking into account their inexperience, lack of awareness of potential risks and their immaturity, to determine whether they should undertake certain work activities. 

Guidance Points for Training

• Consider level of experience, degree of supervision and complexity of equipment.
• Consider diversity of staff & students especially young people as they will have an unfamiliarity with the working environment and limited experience to draw on. Ensure adequate supervision is given.
• Consider the delivery of the training so that it reflects diversity of staff & is inclusive to all. Ensure any practical training is inclusive to those with health conditions or impairments.
• Consider flexibility of the training to ensure equality & inclusivity to all to reflect dynamic working patterns/ part time workers/those with caring responsibilities .
• Training can be in the form of external courses, in-house training programmes, work shadowing, demonstrations, online courses or a combination of these. Training should include general safety, equipment specific and on the job training under supervision.
• Ensure there are written information and instructions. Manufacturers manuals may need supplementary instruction sheets to inform users of how this applies in individual workplaces.
• Consider refresher training when necessary especially if there are changes to the system of work, new equipment or technology is introduced or if skills are not used regularly.
• Ensure any changes to the use of the equipment is effectively communicated to all ( e.g team briefings).
• Establish a management process within your local area to address the various users of work equipment taking into account the risk level & experience. You might want to consider a colour coded system for various pieces of equipment indicating training or supervisory requirements for the user. Alternatively, you may wish to have named users who you group into various levels ( basic users, competent user, trainer) & record this information on each piece of equipment. A training matrix could be developed to record this. The SOP or Risk Assessment could also be a way of recording the level of training or supervision a user requires to use a piece of equipment.

5.3 Competence for Use of Work Equipment

Competence must be demonstrated and assessed and never assumed. You may need to consider a period of supervision while competency is demonstrated and recorded. Please refer to Appendix 7 for an example template of an Authorisation to Use/ Training Record. The length of this supervision will be determined by the type of equipment and risk involved.

 Ensure individuals are trained for the full range of work equipment they will be expected to use and consider all eventualities and risks including working out of hours. Ensure extra support is given to those who require it. Consider the capabilities of each individual & ensure they have the physical strength to use the equipment you are asking them to use. A formal qualification maybe required for using some equipment. Occasionally a medical fitness or mental aptitude test may be required to use certain equipment. A list of authorised persons to use certain equipment should be available near the respective equipment.

6.1 Hazards

There should be measures to minimise the effects of the hazard as well as reduce the likelihood of the hazard occurring:

• Article or substance falling or be ejected from work equipment.
• Rupture or disintegration of parts of work equipment.
• Potential for entanglement or entrapment
• Work equipment overheating or catching fire.
• Premature discharge of gas, liquid, vapour.
• Premature explosion of work equipment or substance stored in it.

6.2 High or Low Temperature

Many items of equipment have exposed surfaces or can contain very hot or very cold substances which represent sources of risk. (e.g. Liquid Nitrogen tanks, gas cooker, soldering iron). The risk should be assessed for each piece of equipment and control measures put in place to mitigate (e.g. the use of Personal Protective Equipment, limited exposure time, provision of guards.) Other important factors to consider are adequate training, warning signs and working under supervision or working in pairs.

6.3 Controls (including stop controls)

A control system is defined as “a system or device which responds to input signals and generates an output signal which causes the equipment under control to operate” (PUWER Regulations 1998).

 Work equipment must be provided with controls for starting, stopping, controlling the change in the speed or pressure conditions. Control systems operating and interlock conditions must be met before equipment may start, this prevents machines from starting up unintentionally. A stoppage may have happened due to the activation of a protection device. There must be procedures in place to guide workers to re-start equipment in this instance.

 A stop control should bring the equipment to a stop position in a safe manner and should only require a short accessible  manual action to activate it. This may not mean an immediate stop that might cause additional risks (for example time for a dangerous part to be stored in a locked position). A stop control should switch off all sources of energy from the equipment after it has stopped if this is necessary to prevent or minimise risk. Controls must be maintained & checked  to be operational at all times while the equipment is in use. Controls must be sufficient & appropriate to minimise risk.

Controls should be designed and fitted to:

• Ensure it is easy to identify what each control does and which equipment it effects.
• Start and stop buttons are accessible.
• Controls and their markings are clearly visible & indicate their function.
• It should only be possible to start or re-start equipment by using the appropriate control (e.g. it should not be possible to restart equipment by simply re-setting a protection device)
• Start controls should not be combined with ‘emergency stop’ controls.
• Any Change in the operating conditions of the equipment should only be possible by the use of a control.
• Use timed interlocks or trapped key systems to allow rundown and prevent operators entering the danger area before the machine has fully stopped.
• “Hold to run” controls should be designed so that the stop function has priority over the start control following the release of the control.
• Controls should be designed to ensure they cannot be started accidently so should be encased in locking facility.
• Position two hand controls at a safe distance from the danger area.

6.3.1 Lock-off and Isolation Procedures

These procedures should be used to make equipment safe:

• During Maintenance.
• When unsafe conditions develop.
• When a temporary situation makes it unsafe to use the equipment.

Isolation entails breaking the energy supply in a way that ensures inadvertent reconnection is not possible. This could be removing the plug from the mains or it could be an isolation switch which is locked in the closed position to avoid reconnection. When equipment contains stored energy, this should be dissipated in addition to effective isolation of the machine before any maintenance or repair work begins.

An interlock is a means of linking a safeguard to the control circuitry of a piece of equipment so that the equipment may not operate when the safeguard is not in place.

Lock Out Tag Out ( LOCO) is a safety procedure that ensures that dangerous machinery and energy sources are properly shut off and not started up unexpectedly while maintenance or service works is being completed. It prevents accidents from moving parts. It is not enough to just switch off a machine if you need to access it. All energy sources must be controlled, isolated and locked. A lock is secured to the power source to prevent it being switched on. A high visibility warning tag is fixed to the energy isolating locking device to warn employees not to turn on the machine. It is best to use both methods together. There should be a Lock out procedure in place, training provided & inspections/audits of the devices.

6.3.2 Emergency Stop Controls

An emergency stop control should be provided where the other safeguards in place are not adequate to prevent risk when an irregular event occurs. Emergency stops are provided to enable a rapid response to a dangerous situation. However, they are not a substitute for safeguarding. They should be easy to use and easy to reach. This is often achieved by using the ‘mushroom’ type controls  which are larger & more obvious.

6.4 Guarding and Protective Devices and Protection Appliances

Machinery should be constructed to prevent contact of any part of the body or clothing with a dangerous part of the machine (moving, sharp, hot).

Measures must be taken to prevent access to dangerous parts of machinery. They must be suitable for the purpose, be maintained, not easily by-passed and training provided.

Assess the guards and devices you have. Are they easily defeated, difficult to use or inhibit work leading to the temptation to not use them?

Consider if the material the guards are made from are suitable for the job & properly designed. Guards must conform to regulations. Guards should be properly maintained and designed to allow equipment to still be cleaned and maintained as this could lead to further hazards. Guards should not restrict visibility.

Your control strategy should follow the following hierarchy:

• Fixed Guards to enclose dangerous parts- Should remain in place at all times (except by authorised person for maintenance).
• Guards (closed tools, interlocking, adjustable, automatic, self-closing – choice will depend on need for/frequency of access).
• Protective devices (Captive keys, sensing devices, infra-red device, pressure mats, tripping devices).
• Protection appliances (jigs, holders or push sticks to help keep fingers a safe distance away).
• Braking Devices – Consider fitting these to reduce the   rundown time of cutting tools.

6.5 Lighting

You must ensure there is suitable and sufficient lighting which takes into account the operations to be carried out where people use equipment at work (including emergency operations). Extra lighting might be required to give a sufficient view of a dangerous process or reduce visual fatigue. Consider using strobing or rotating equipment. Where there is no natural light available supplementary lighting is necessary. Additional lighting may be provided in a temporary format such as portable lights. Consider where tall equipment may block light to equipment nearby. Give consideration to those who may be visually impaired & may require additional lighting requirements ( types of bulbs, consistent controllable lighting levels, preventing glare, good distribution of light ) to carry out work safely. 

6.6 Markings

Equipment must have clear markings for reasons of health and safety (e.g. Start/Stop controls, hazard warning symbols, maximum speed for rotating parts, frequency of inspection etc).

Markings can be letters, numbers, symbols but they must be clear and unmistakeable. They need to be fixed to the machinery as appropriate to indicate the presence of hazards. Where international symbols are used ensure they conform to published standards. Consider what other markings may be specific to the working area. Ensure markings are visible & inclusive to all who need to see them by considering the diversity of the workforce ( e.g being placed too high/low, being too small for visually impaired, format is suitable for those with dyslexia/colour blind ).

6.7 Warnings

Equipment must have clear warnings for reasons of health and safety. They must be easily understood and unambiguous. A warning is usually in the form of a notice which can be positive instructions or prohibitions. The warning can be visual or audible and must be associated with the equipment it is intended for. (e.g. “Hard Hats must be worn”). Warnings can be permanent or temporary. Consider factors which may affect people’s perception of warnings such as the choice of colour or constant flashing signal can have a different impact in different situations. Be inclusive of those with hearing impairments who may require a visual signal too.

The design of the warnings must consider ‘sensorial saturation’ which can result from too many visual and or acoustic signals which can lead to defeating the object of the warning device.

Consider what warnings may be specific to the working area. Ensure warning signs  are visible & inclusive to all who need to see them by considering the diversity of the workforce ( e.g being placed too high/low, being too small for visually impaired, format is suitable for those with dyslexia/colour blind ).

6.8 Signage

Safety signage must be provided in circumstances where there is a significant risk to health and safety which has not been removed by other means or where the use of the sign can further reduce the risk. Safety signs must be adequately maintained. Signage should include words & images to aid understanding. Unfamiliar signs must be explained . Examples of signs include those which prohibit behaviour ( Red) , warning signs ( yellow) mandatory signs ( blue) & emergency signs ( green). Ensure signage is inclusive to all by considering the diversity of the workforce. Those working with equipment should look at relevant signage before starting work with equipment. 

6.9 Lightning Strikes

Ensure that where there is a risk to workers from lightning strikes to work equipment when it is being used, adequate safety precautions must be followed. Refer to the PUWER regulations for more details.

6.10 Stability

Work equipment must be stabilised or clamped for purposes of health and safety. This should be done each time the equipment is repositioned. Most machines should be bolted or fastened to ensure they do not move or rock during use.

6.11 Personal Protective Equipment (PPE)

Personal Protective Equipment means all equipment intended to be worn or held by a person at work which protects them against risks to health and safety. This can be in the form of gloves, safety goggles/visors, safety shoes, overalls/lab coats or safety harnesses. PPE is to be used as a last resort if that hazard has not been controlled by other means. PPE can be used in combination with other control measures such as engineering or procedural controls. PPE must be suitable for the purpose & person. Individuals should be provided with training on the use & cleaning  of PPE and supervisors should be actively enforcing the requirement for appropriate PPE to be worn.

 When choosing PPE consideration should be given to:

• Latest regulations and University Policies.
• The Task and risk for which protection is needed.
• Physical effort of the tasks and duration of the task.
• Requirements for visibility and communication.
• The Environment the task takes place in.
• The person – consider  the diversity of people using the PPE  & be supportive of specific requests due to health, allergies , facial hair, ergonomic effects (including fit) & disabilities.
• Equipment must be compatible if more than one item of PPE used.
• PPE should be maintained in good working order, checked for damage, cleaned and replaced when required.
• PPE should be stored to prevent damage, contamination and loss.
• Ensure individuals have had sufficient training on how to use the PPE appropriately including exposure limits.
• Footwear – Consider the hazards (e.g. steel shoes for working with heavy equipment)
• Consider specialized eye protection (ultraviolet light/laser wavelength)
• Hand Protection – consider the hazard – biological, hot/cold/cut resistant

Please refer to the University Personal Protective Equipment Policy and Guidance for more information.

7.1 Portable Appliance Testing

7.2 Asset Register

The Asset Register is to list all PUWER related Work Equipment and act as the prime record for PUWER equipment for each School/Service/Department. Please refer to Appendix 5 for an example template for an Asset Register.

8.1 Pre-use Checks

Pre-use checks are recommended to be carried out as appropriate on the equipment before being used by a competent operator before use . The aim of such checks is to pick up faults due to day-to- day wear and tear and malfunction of safety-related equipment ( e.g damaged cables). If any defects are found the user or operator should report the defect or, if competent to do so, take action to rectify it. It is good practice to have a ‘checklist’ near the equipment for the operator to complete to evidence that pre-use checks have been completed. The Level of skills to do the checks depend on the type of equipment but training must be provided.

Guidance Points for Pre-Use Checks of Equipment

Before Use Consider:

• Do any parts look worn or dangerous?
• Are the guards in the right place?
• Is the appropriate PPE available?
• What happens if the machine starts up unexpectantly?
• What happens if tools break during use?

8.2 Maintenance

Maintenance of equipment is vital to the safety of the equipment and can prolong the life of the equipment reducing costs for repairs and replacement.

The extent, frequency or complexity of the maintenance will depend on the equipment. You should consider:

• The Intensity of use - frequency and maximum working limits.
• The Operating environment – Indoors or outdoors.
• Number of different tasks and functions the equipment performs.
• Risk to health and safety in the event of malfunction.
• The manufacturer’s recommendations (e.g. periodic lubrication, replacement of parts such as a rotor on a centrifuge.)
• Each piece of equipment should have a clear written maintenance plan/ schedule/fault reporting system  and a record log.
• There should also be regular checks made to ensure maintenance is being performed.
• Review of maintenance procedures may be required if circumstances change for example increase in use.
• Please refer to Appendix 6 for an example template for maintenance records.

NOTE: If equipment is hired it is important to establish who is responsible for carrying out the safety related maintenance. This is particularly important for long term loan. The terms of agreement should be recorded in writing.

Guidance Points for Maintenance of Equipment

Before any maintenance commences consider safety systems of work first.

• Consider if the work requires a  ‘Permit to Work’ to ensure everything has been assessed. Please see more details in Permit to work policy.
• Ensure work equipment is a safely isolated and power disconnected before maintenance commences where possible. Most equipment should be designed so this is possible for safety. If equipment has to  be running ensure measures are taken to reduce the risk.  Consider if there needs to be physical disconnection from the power source e.g requesting the switching off the supply to high voltage cables
• Lock off machines if there is a chance the power could accidentally be switched back on using Lock Out Tag Out ( LOCO) safety procedures.
• Avoid entering tanks, vessels or confined spaces where possible.
• Does the work need doing by specialist contractors? Ensure the maintenance is performed by competent persons. Provide training where required.
• Plan the maintenance – use the manufacturer’s instructions. Plan maintenance during ‘down time’ where possible to minimise risk to other workers and the person performing the maintenance.
• Are the correct PPE and correct tools available?
• Consider diversity of human shape & size in relation to accessibility to do the maintenance.
• Remove loose clothing/loose jewellery and tie back long hair that could get trapped.
• Consider barriers/signage to prevent access.
• Don’t get distracted.
• Allow hot equipment to cool down before maintenance commences.
• Ensure safe access if work is carried out at height
• For lines/pipes under pressure or containing hazardous material isolate by closing and locking off valves. Release residual or stored energy ( e.g electrical ,mechanical, gas, hydraulic) .
• Secure any parts which could fall & ensure equipment is stable
• Take care with equipment which has contained flammable materials ensuring you decontaminate.
• Decontaminate work equipment if exposed to hazardous material (Biological, chemical, radioactive before maintenance takes place). Consider a decontamination certificate as evidence of the precautions taken.
• Have a procedure in place for workers to report issues.
• Do not ignore maintenance, use faulty equipment or fail to report any safety concerns

8.2.1 Hand Tool Maintenance

Hand tools should only be used for the task they were designed for, be checked by the user before use and replaced or repaired if damaged.

Hand tools are unlikely to require formalised maintenance, but it is important they are inspected regularly, and that equipment is lubricated, or parts replaced (e.g. sander piece) as required. Pre-use checks are sufficient instead of formal inspection procedures as long as users are trained to know what to look for as part of the pre-check. More information can be found on the HSE website.

8.2.2 Repairs

Repairs to equipment should only be carried out by those trained and competent to do so.

8.2.3 Equipment Storage

Workplaces should have safe storage for work equipment when not in use. These should be suitably controlled. Storage areas should be safe to access & equipment placed on appropriate racking/shelving/benches for their size/shape. Storage areas should be inside a building. Only equipment not effected by weather should be left outside. 

9.1 Maintenance/Service Logs

It is good practice to keep detailed up to date logs of equipment maintenance. Create a technical compliance file for key equipment to keep all information about the equipment together. Detailed maintenance logs can minimise the number of expensive repairs, increase operator safety, provide information about previous maintenance performed, patterns of faults and future planning of maintenance. They also evidence that employee’s safety has been considered. Logs can take the form of a logbook or a sheet on the wall/equipment/in a folder.

 Please refer to Appendix 6 for an example of a template maintenance record.

 High Risk equipment should have a formalised system for maintenance and operator checks. (This could be a record card in a plastic wallet by the equipment). Details which should be recorded are:

• Equipment name/ID number
• Date of maintenance
• Name of person carrying out the maintenance
• Details of the maintenance e.g. service, parts replaced

9.2 Inspection Reports

Inspection Reports can be from external organisations or from in-house inspections.

Records do not have to be in a particular format. They can be stored as a hard copy, but you must have a digital back up as you may fail an inspection if you cannot provide these records if they are lost or destroyed.

Records should be kept within each Department/School/Professional service on the workspace and be easily accessible to users and for audit purposes. It might be an idea to create a form that can be printed and completed for each inspection.  Thorough inspection records are stored on the British Engineering Services Register (Portal) which is operated and maintained by the Competent Person (British Engineering Services)

The information that should be contained in the record is:

• Type and model of equipment
• Location
• Identification mark or number
• Date of inspection
• Who carried out the inspection
• Any Faults, action taken and who reported to
• Date when repairs were carried out
• Date of next inspection
• Training Records

Physical Evidence of Inspection

This can be a record or a label/tag/colour coding. This shows easily that an inspection has been carried out (e.g. for Lifting Equipment), when it was, the date of the next inspection and should link back to the records.

10.1 Supply of Machinery Regulations and Essential Health and Safety Requirements (EHSR's)

Most new machinery is covered by the Machinery Directive 2006/42/EC. These directives are implemented by the supply of Machinery (Safety) Regulations 2008. These regulations apply to all new machinery placed on the UK market or put into service in the UK. The EHSR’s demand that the machine manufacturers identify the hazards which their product contains and then the risk which these hazards present to users. Any risk must be reduced to as low a level as is reasonably practicable.

The Regulations require that:

• Machinery meets all Essential Health and Safety Requirements

• A “technical file” is produced
• Machinery is issued with a Declaration of Conformity or Declaration of Incorporation (if it being placed on the market)
• UKCA/CE marking is affixed to the machinery (if it is being placed on the market)

The Manufacturer must:

•  Carry out a risk assessment to identify the risks (EHSR’s should be used to ensure all  possible hazards have been addressed).

• Eliminate significant risks
• Provide safeguards
• Provide information about residual risks not able to be designed out.

EHSR's Cover:

• Physical Safety, including health effects of a product in all its various aspects (selection of materials used, means of control, safeguards, containment of fragmenting work pieces, emissions from the product)
• Protection against other hazards (errors due to incorrect replacement of parts, temperature extremes, fire and explosion, noise)
• Maintenance (safe means of adjusting, lubricating, cleaning)
• Principles of safety by design taking into account foreseeable use and misuse
• Information for end users (markings, warnings, instructions)

How can Essential Health and Safety Requirements be met?

• Firstly, risk Avoidance by Design

• Secondly, protection against risks that cannot be eliminated
• Thirdly, warning of any residual risks that remain.

Product Design

The Job of the product/equipment designer is to consider all relevant essential requirements and seek the best methods of meeting those objectives.

PUWER gives some guidance to the Machinery Directive but is a separate entity and is really a continual assessment requirement. The Machinery Directive is consulted at the concept design stage but once the machine has been produced it is then up to the user to perform a PUWER Assessment even if the machinery has been designed and built in house.

Notwithstanding any obligation to UKCA/CE mark the equipment, employers in the UK have an obligation under PUWER and the Health and Safety at work Act to ensure that the equipment which is supplied for use by employees complies with any applicable Essential Requirements. Regulation

10.1 of PUWER 1998 states that every employer shall ensure that an item of work equipment has been designed and constructed in compliance with any essential requirements, this is to say requirements relating to its design or construction.

An employer meets their obligation under PUWER by specifying UKCA/CE marked equipment and using it according to the manufacturer’s instructions but if the equipment is not UKCA/CE marked or the equipment is being used for some other purpose than the manufacturer intended then the employer must take responsibility for compliance with the EHSR’s themselves.

10.2 In-House Specialist Research Equipment/Rigs

• Work Equipment specially designed and constructed ‘in-house’ for use ‘in house’ should be designed and constructed in accordance with relevant legislation and comply to Essential Health and Safety Requirements and the requirements of the Supply of Machinery (Safety) Regulations 2008. In the absence of UKCA/CE Marking (which is not required due to the fact it is not being ‘placed on the market’) PUWER sets out these minimum safety requirements which must be adhered to by the employer and these are retrospective so that the equipment must meet certain minimum safety requirements no matter how old it is. Therefore, people making equipment must apply the same standards as they would if they were UKCA/CE marking it. (equipment/system must be safe). Whether or not the UKCA/CE mark is put on the equipment makes very little difference to the design measures which ought to be applied to ensure its safe.
• The design stage of the research equipment/rig should consider all risks and evaluate and implement ways to mitigate them. At this stage the designer should liaise with their School/Department Safety Officer/lead to help with this process to ensure compliance to the machinery directive with regards to the parts purchased. How you show compliance goes back to the risk assessment. Any residual risks must be communicated to those who will be using the equipment. Inherently safe design measures are the first and most important step in the risk reduction process.
• The Health and Safety at work act places a duty on any person who designs, manufactures, imports or supplies any article for use at work to ensure so far as reasonably practicable that the article is designed and constructed that it will be safe and without risks to health.
• The production of a ‘Technical Compliance File or Technical File’ for the equipment is encouraged. Technical files for research rigs in the University setting can take a variety of forms as this equipment is not usually being placed on the market. However, they  should include a description of the equipment, functions, safety related devices ( stop controls) , test reports, circuit diagrams, identification of the ESHRs associated with the machinery, description of the critical operating parameters (temperatures, speeds), records of risk assessments against specific standards, quality control, training documents, software information , flow charts  and commissioning procedures.
• Ensure suitable instructions and training for use are  provided and Standard Operating Procedures written for the system.
• The maintenance of the equipment will depend on the equipment purpose and frequency of use and the complexities of the research equipment. Any Modifications to the research equipment which effects the integrity of the system requires notification to the competent person for approval.
• Some Specialist equipment assemblies will contain sub systems that are UKCA/CE marked and such sub systems must be considered as PUWER equipment separately.

What do you need to consider when starting the design stage for a Research Rig?

• Consider the size & location of the rig.
• Consider the materials & equipment you want to use as some are not compatible.
• Do you need access to electricity, water supply, compressed air, temperature management, use of lasers?
• Will there be toxic fumes produced? Do you need extraction? How will you do that? Do you need help from FM or external contractor?
• Do you need to use gases? Consider safety, storage, PPE, training.
• What parts do you need?
• Do you have the approved COSHH in place for chemicals/materials/gases you want to use?
• What are the risks & how can you design them out
• What safety systems & engineering controls might you need in place ( interlocks, Lock Out Tag Out ,stop controls)?
• Is there an inspection schedule in place ? Are there recorded pre-checks ?
• Does the rig need to be housed/contained inside a cabinet/cell ?
• Is it set up so that it will not work if a safety element has been compromised?
• What access Restrictions might be required to the area around the Research Rig?
• What PPE is required?
• Are there clear warnings signs ?
• Ensure there is a Risk Assessment & operating procedure as part of the technical file for the research rig . What is the process for updating Risk Assessments with modifications?
• Ensure there is a management of change system in place so substantial changes to processes are identified and risk assessed . Ensure approved users are added to Risk Assessment.
• Has recorded training been provided for all those who will use it including the use of any safety control measures?

Please see Appendix 9: Checklist to ensure the safety of ‘in-house’ constructed Equipment to help assess compliance for in house constructed equipment.
Please see Examples of Technical Files on Work Equipment Provision & use Guidance & Training LEARN page. 

10.3 Safe Working in the proximity of Robots and complex Machinery

The guarding requirements of robots and other complex equipment need to be properly assessed. Particular attention needs to be paid to any changes of use or change of circumstance over time and the guarding assessment should be reviewed on a regular basis.

Operators of robots and complex or higher risk machinery must be properly trained (and that training documented). Operators should also be periodically reminded of the safe operating practices to be used around robots and other complex equipment.

In terms of robot safety in particular, schools are advised to identify and assess where teaching mode is used and ensure that appropriate precautions are in place and the risk is minimised in that mode.

It is good practice to schedule safety focused walk arounds looking at the work practices in high-risk areas, specifically checking that routine operations and checks are being conducted as defined.

Pre-start safety checks should be a part of normal operation for high-risk equipment and the completion of these checks should be recorded.

10.4 Scientific and Laboratory Equipment

Special considerations need to be made when considering the safe use of equipment in a laboratory due to the nature of the work, the environment and materials used. To ensure safety of those working or maintaining this equipment you must ensure strict cleaning, and decontamination procedures of equipment to minimise exposure to biological or chemical agents. In addition, certain laboratory work equipment presents specific hazards and risks that need to be risk assessed and managed.

Guidance Points for Scientific and Laboratory Equipment

Things to consider:

• Spark free Fridges/Freezers for storage of flammable chemicals.

• Equipment containing compressed gases, pressure vessel, low or high temperatures. Think about the hazards, regulators, labelling, pre- checks, PPE, handling and storage.
• Centrifuges – Failure/deterioration due to lack of maintenance of rotors or improper balancing can cause a number of hazards.
• Ultra-sonicators or other rotating equipment – Exposure to high volumes of audible sounds can cause health issues.
• Use of lasers, electromagnetic radiation – Consider PPE and signage.
• Electrically powered equipment – hot plates, vacuum pumps.
• High voltage and high- powered equipment
• Ensure equipment is installed correctly and maintained appropriately.
• Placement of equipment to reduce trip hazards, allow maintenance and space for guarding.
• Minimise the use of disposable sharp puncturing devices where possible, use safe techniques and ensure safe disposal.
• Use Microwaves specially designed for laboratory use – Built in safety features.
• Humidity – Condensation can enter electrical equipment placed in a cold room
• Refer to the University Chemical and Biological Safety Policies and refer to HSE Management and Operation of Microbiological Laboratories guidance.

For the purposes of PUWER mobile work equipment is any work equipment that travels between places where it works or that works as it travels. Examples include fork-lift trucks & tractors. Equipment might be moved on wheels, tracks, rollers and could be self-propelled, towed or remote controlled. Steps must be taken to ensure stability. You must ensure risks to the operator and other workers is controlled.

Workers should be protected from:

• • Falling out of the equipment or unexpected movement. Consider seating requirements, restraining devices, speed limits, use of guard rails, good braking systems. Passengers must not be carried unless equipment designed to do so.
• Risk of falling objects ( Need for Falling Object Protective Structures ( FOPS) like protective cages. )
• Being hit from moving parts or ejected material. Guards should be fitted to prevent contact with wheels or tracks.
• Sharp edges or crushing
• • Risk of overturning. ( Need for Roll over Protective Structures ( ROPS) ) Insufficient Visibility to ensure they can manoeuvre safely. If vision is impaired CCTV or mirrors could be used.
• Unstable mobile equipment. Where ballasting or counterbalancing is used the stabilising method should be reviewed each time it is repositioned.
• Exposure to fumes by ensuring work equipment using internal combustion engine is not used in confined spaces. Controls must be put in place to capture exhaust fumes.

Every employer must ensure that mobile work equipment is suitable for carrying persons and incorporates features for reducing risks to safety this includes considering the risks of the mobile equipment rolling over. Consideration should be given to the diversity of the people using the equipment & take into account differences in human shape/size & disabilities.

NOTE: The use of restraining devices and protective structures must be closely evaluated as part of the risk assessment to ensure there is not an increase to risk injury due to these devises.

11.1 Motor Vehicles

Motor vehicles being used for work activities which are not privately-owned fall under PUWER. When these vehicles are used in public roads the road traffic legislation takes precedence. Drivers should have a valid driving licence and the vehicles should be maintained to normal standards for the public highway and have a valid MOT certificate.

The Scope of PUWER is very wide and the risks of work equipment varies. However, within the confines of this University PUWER Policy some equipment will likely be exempt from PUWER regulations. Exemptions usually occur when there are more specific requirements.

These are:

• Domestic white goods appliances (Fridges, Freezers, heaters, microwaves). However, specialist freezers/microwaves for laboratory or catering use are in scope.
• Shelving /Racking/Cabinets with no moving parts.
• Extension Leads
• PC’s and Paper Printers
• Private Cars

Please see Appendix 1 Work Equipment in Scope and Exemption Listings

12.1 Medical Devices

Where a medical device is also a machine it is excluded from the scope of the Machinery Directive although it still must meet the relevant Essential Health and Safety requirements. Enforcement for this equipment falls to Medicines and Healthcare Products Regulatory Agency (MHRA).

According to the Medical Device Directive (MDD) a medical device is described as any instrument, apparatus, appliance, software, material or other article used alone or combined for humans to:

•  Diagnose, prevent, monitor, treat or alleviate disease
• Diagnose, monitor, treat, alleviate or compensate for injury or handicap
• Investigate, replace or modify the anatomy or physiological process
• Control conception

Not all work equipment needs formal inspection to ensure safety but a visual check before use is required. However, inspection is necessary for equipment with significant risks to health and safety.

The result of the inspection should be recorded. These records should be held securely and be made available on request of enforcing authority.

Work equipment should not be used unless you know the inspection has taken place.

Guidance Points for Inspections

Inspections can be:

• ‘In-House’ Pre-Planned - Schedule and content of inspection decided by those responsible for the safety of the equipment. Regular ‘walk around’ recorded inspections are encouraged.
• ‘In-house’ Un-Planned – This can be a member of the University Health and Safety Team or Departmental Safety Officer performing a spot check of a department to check for compliance
• External Pre-planned– These are ‘thorough Examinations’ that are carried out by external insurance inspector (organised through Facilities Management) due to regulations to look at a certain aspect/type of equipment (e.g. lifting equipment/pressure vessel inspection). The frequency of these will depend on the equipment so you need to contact your DAP for advice.
• External Un-planned – This is a visit from an external organisation who announce their visit with limited notice to check on compliance of the organisation they are visiting. (e.g. Health and Safety Executive).

When are inspections required?

Equipment should be checked to ensure that safety related features are functioning correctly Inspections will normally be required where the safe operation of the equipment is dependent on its condition in use and deterioration could lead to significant risks. Examples of such conditions include: Rapid wear from use in an arduous environment.

•  Failure through repeated operation.
• Before use – informal pre-checks.
• Malfunction.
• To check safety control systems
• Tampering with safety devices.
• Installation or incorrect installation /re-installation. (Where the safety of the work equipment depends on the installation conditions. It should be inspected after installation, before first use and after reassembly at a new location).
• Following exceptional circumstances, following modification, change of use, long period without use or serious damage to the equipment.
• Some work equipment will need inspection due to regulation e.g. Pressure Vessels.

Extent of Inspection schedule:

• Depends on the potential risks

• Depends on the Risk Assessment which will take into account how the equipment is used, who is using it and the environment it is operating.
• Depends on the equipment manufacturer's information – This will contain instructions for routine maintenance and inspection and frequency to reduce deterioration.
• Depends on your own experience and previous history the equipment.

What Should an Inspection Include?

• Inspections will include visual checks & sometimes functional checks and testing.
• It should always include safety related parts necessary for the operation of the equipment (controls). A functional or other test may be required to test safety related parts ( interlocks) .Not always required for all types of equipment.
• Records of Inspection made and kept.

Frequency of Inspection

This is based on the type of equipment, frequency of use and environment in which it is used.

Who Should do the inspection?

Any person carrying out elements of the inspection schedule, e.g. the operator, user or supervisor, must have an appropriate level of competence to do so. They should have the necessary knowledge and experience. They should know what to look at, what to look for and what to do if there is a problem.

Internal Inspection Schedule (In-House)

Experienced in-house employees such as a departmental manager/supervisor may be able to do this if they have the correct experience and knowledge. They decide what the inspection should include, how it should be done and how often it should be done.

External Examination and Inspection

Sometimes the level of expertise to perform an inspection requires help from an outside organisation either due specialist equipment being required, a critical component needing replacing, level of skill required or due to a statutory examination (e.g. Pressure vessel). Ensure these inspections have been arranged in advance, have been completed correctly and records kept.

Legally, some inspections need to be done annually and therefore planning is crucial to ensure the inspection is completed within the specified timeframe. Ensure Equipment is made available for the inspection.

13.1 Audit

Schools/Departments/Services should consider in areas of PUWER high risk to undertake audits as best practice. The audit should be designed to check compliance with this policy and accuracy of records and registers. Findings should be discussed at Health and Safety Review Meetings. Ensure there is equality & diversity of staff who undertake audits if qualified to do so to aid personal development.

At the end of a machines (work equipment) life the instructions need to be consulted and a risk assessment conducted prior to decommissioning and disposal. The removal of any guards as part of the dis-mantling of equipment process can present a hazard which is why a risk assessment is required.

Disposal of work equipment no longer required needs consideration for the following aspects:

• Decontamination
• Prevention of unauthorised re-use
• Removal of labels
• WEEE ( Waste Electrical & Electronic Equipment) Regulations
• Re-use
• Recycling
• Refrigerators/gases
• Radioactive sources
• Removal of records

For more information with regards to decontamination of equipment please refer to the University ‘Biological Safety Policy’ and ‘Chemical Safety Policy’.

WEEE

It is illegal to dispose of WEEE in general waste and therefore this process must be used for the disposal of all redundant electrical equipment including mobile phones & computers. For more information on WEEE procedures please refer to the Sustainability section of the Facilities Management page on the University website. 

WARPit

WARPit is an online portal and reuse network which makes it easy for Schools and Departments to share surplus resources on our two campuses. Often items are thrown away in one part of the organisation when another part is in need, so if you have an item you no longer require and it is still fit for use please advertise it on WARPit. This supports the University’s procurement procedures as well as the Environmental Policy and specifically the Waste Management Strategy. Anything electrical may only be promoted internally and must be in good and safe working order.

Kit Catalogue

A catalogue of all the equipment and facilities available for use at Loughborough University, and containing hundreds of supporting manuals, case studies and other resources Loughborough University's Equipment Database (lboro.ac.uk). All Equipment should be compliant with PUWER.

For more information refer to Environmental Policy and Sustainability Charter. When considering disposal, you are encouraged to adopt the waste management hierarchy of Prevention, Re-use, Recycling and Recovery in order to reduce waste and landfill.

The re-use of equipment is actively encouraged from a sustainability perspective but we also need to ensure we meet our obligations under PUWER to ensure what might be shared or donated to other areas within the University meets certain standards. For more information please see the PUWER LEARN page or contact the PUWER DAP