Guest Blog – David Tilsley-Curtis of 3JB Ltd
Helping Engineering Managers, Safety Managers and Duty Holders ensure work at height equipment is inspected, maintained and used safely in compliance with PUWER and the Work at Height Regulations.
What do PUWER and the Work at Height Regulations tell us?
Regulation 6 of the Provision and Use of Work Equipment Regulations 1998 (PUWER) places a duty on employers and those in control of work equipment to ensure that equipment exposed to conditions causing deterioration is inspected by a competent person at suitable intervals.
In addition, the Work at Height Regulations 2005 (WAHR) require that equipment used for working at height is suitable for its intended purpose, maintained in a safe condition and inspected at appropriate intervals.
Regulation 12 specifically requires that must be rigorously inspected by a competent person on a regular basis, especially after being exposed to conditions liable to cause deterioration which could result in dangerous situations is inspected by a competent person.
Neither PUWER nor WAHR provides a precise definition of a “competent person”, leaving employers responsible for ensuring the individual carrying out inspections has the appropriate knowledge, training and experience.
What is the purpose of a Work at Height Equipment Inspection?
The purpose of inspecting work at height equipment is to confirm that it remains safe for continued use, that deterioration can be identified before it presents a risk, and that appropriate remedial action is taken where defects are found.
Inspection is intended to determine whether equipment can continue to be used safely, rather than confirming that it is always being used safely. Safe use depends on many other factors, including planning, supervision, user competence and adherence to safe systems of work.
Equipment commonly requiring inspection includes:
• Podium steps
• Mobile access towers
• Portable Ladders and stepladders
• Mobile platforms /gantries
• Fixed Ladders
• Edge Handrailing
• Safety harnesses and lanyards
• Foxed access platforms and walkways
Regular inspections form one part of an effective work at height management system alongside maintenance, operator training, pre-use checks and suitable risk assessments.
How do you identify a Competent Person to carry out Work at Height Equipment Inspections?
Both PUWER and WAHR require inspections to be completed by a person with sufficient knowledge and experience to recognise defects, assess their significance and determine appropriate action.
For work at height equipment, this competence typically includes knowledge of:
• The manufacturer’s intended use, inspection criteria and maintenance requirements.
• Relevant legislation including PUWER and the Work at Height Regulations.
• Current industry guidance, British Standards and HSE publications relating to work at height equipment.
• Inspection methods appropriate to the type of equipment being examined.
• Risk assessment principles to determine whether defects require immediate withdrawal from service or controlled continued use.
Evidence of competence may include recognised qualifications, manufacturer training, IPAF, PASMA or Ladder Association training (where appropriate), engineering qualifications and documented experience in designing and certifying similar equipment.
Can inspections be carried out in-house?
Yes.
Many organisations successfully carry out inspections using competent in-house personnel, provided they have:
• Experience with the equipment being inspected.
• Knowledge of deterioration mechanisms and common failure points.
• Understanding of current legal requirements and industry best practice.
• Knowledge of the BS or EN standard appropriate to the equipment being inspected.
• The ability to identify defects and recommend appropriate corrective actions.
Where sufficient competence is not available internally, employers should appoint an independent third-party inspection provider with demonstrable expertise.
Although inspections may be outsourced, the legal duty to ensure inspections are completed remains with the employer or person in control of the equipment. This responsibility cannot be transferred.
What does “Necessary Experience” mean?
For straightforward equipment such as ladders or podium steps, experienced supervisors or maintenance personnel may possess sufficient knowledge to complete inspections, provided they understand the inspection criteria and manufacturer recommendations.
More complex equipment—including MEWPs, fall arrest systems, suspended access equipment or anchor points—often requires specialist knowledge and formal training and will most often come under the LOLER requirements.
Necessary experience includes understanding:
• How the equipment functions.
• Typical wear, fatigue and deterioration mechanisms.
• Manufacturer inspection requirements.
• Relevant British Standards and HSE guidance.
• Safe operating limitations.
• The consequences of defects or misuse.
This experience enables inspectors to distinguish between cosmetic issues, maintenance requirements and defects that make equipment unsafe.
Determining Inspection Requirements
The Health and Safety Executive recognises that determining what should be inspected, how inspections should be carried out, and how often inspections are required demands a different level of competence from carrying out the inspection itself.
Appointed Person for Determining Inspection Requirements
This individual should understand:
• Which equipment requires formal inspection.
• What each inspection should include.
• Whether functional testing is necessary.
• Inspection intervals based on manufacturer recommendations, frequency of use and operating conditions.
• Applicable legal and industry requirements.
Appointed Person for Carrying Out Inspections
The individual carrying out inspections should understand:
• The construction and operation of the equipment.
• Inspection techniques appropriate for that equipment.
• Common defects and deterioration mechanisms.
• Acceptance and rejection criteria.
• Appropriate reporting procedures.
• When equipment must be withdrawn from service immediately.
Inspection findings should be clearly documented, with defects prioritised according to risk and suitable corrective actions recommended.
How do I check the competence of Third-Party Inspection Companies?
Before appointing an external inspection provider, employers should verify that inspectors possess appropriate competence for the equipment being inspected.
Areas to consider include:
Relevant Technical Knowledge
Inspectors should have demonstrable engineering or technical competence relating to work at height equipment.
Examples include:
• Engineering qualifications
• Engineering knowledge of the design standards
• PASMA experience
• Ladder experience
• Manufacturer-specific inspection training
• Experience inspecting similar equipment
Equipment-Specific Experience
Inspectors should understand not only the equipment itself but also how it is used within your workplace, including environmental factors that may affect deterioration.
Health and Safety Competence
Inspectors should possess appropriate health and safety knowledge through recognised qualifications or significant practical experience.
Why is it important to verify inspector competence?
Both PUWER and the Work at Height Regulations require inspections to be carried out by competent persons.
Employers therefore have a legal duty to ensure that anyone carrying out inspections has the necessary training, knowledge and experience before inspections begin.
For in-house inspectors, competence can normally be demonstrated through:
• Training records.
• Qualifications.
• Experience.
• Job role descriptions.
• Supervised inspection history.
For external providers, competence should be assessed as part of supplier approval and procurement processes.
Simply requesting copies of qualifications is not sufficient. Employers should ensure qualifications remain current, are relevant to the equipment being inspected and are supported by appropriate practical experience.
Failure to verify competence could expose an organisation to enforcement action, increased liability and unnecessary risk should equipment fail or an accident occur.
Supporting Compliance
Effective inspection programmes help organisations demonstrate compliance with both PUWER and the Work at Height Regulations while reducing the risk of equipment failure and falls from height.
Whether inspections are completed internally or by an external specialist, employers should ensure inspections are planned, documented, risk-based and carried out by genuinely competent persons.
Professional inspection providers can also assist with inspection scheduling, written reports, defect prioritisation, compliance audits and training to help organisations maintain safe work at height equipment throughout its service life.
If you have any questions, contact us or Dave at 3JB Ltd.
Guest Blogging
If you feel that you could contribute to this blog then please feel free to send me a proposal of your guest blogging ideas and we can discuss these further info@walkersafety.co.uk . Please note any proposals must be of benefit to my readers from individuals with knowledge of their subject matter.
