Most PUWER checklists circulating online are generic equipment condition lists. They are useful, but they are not what Regulation 6 asks for. The regulation is narrower and more specific than a tick sheet, and businesses that treat the two as the same thing often hold a folder of completed forms that would not satisfy an inspector. This is what the regulation requires and how to build a checklist around it.
What a PUWER Inspection Is, and What It Is Not
A PUWER inspection checklist is a formal check under Regulation 6 of the Provision and Use of Work Equipment Regulations 1998, carried out by a competent person and recorded, to confirm that work equipment remains safe. It applies where safety depends on installation conditions or where the equipment deteriorates in ways that could become dangerous.
The scope of PUWER is very broad. It covers almost anything used at work: hand tools, office equipment, industrial machinery, mobile plant, and equipment that is hired in or brought from home rather than owned. The duty falls on employers, the self-employed, and anyone with control over work equipment, so there is no exemption for sole traders.
Where in-house competence does not extend to the equipment in question, businesses commonly appoint an external engineer surveyor to carry out the PUWER inspection checklist and issue the report.
Four Different Things That Get Confused
- Pre-use check. The operator’s look over the equipment before use. Sensible practice and referenced in guidance, but not an inspection under Regulation 6.
- Inspection (Regulation 6). A formal check by a competent person, recorded, with defects and remedial action noted.
- Thorough examination. A full functional check, usually involving testing. Lifting equipment falls under LOLER and pressure systems under PSSR, and those regimes run alongside PUWER rather than replacing it.
- Maintenance (Regulation 5). A separate duty entirely. Keeping equipment in efficient working order is not the same as inspecting it.
That last distinction causes more compliance failures than any other. A workshop with a detailed maintenance log and no separate inspection record does not comply with Regulation 6, however well maintained the machines are.
When Regulation 6 Requires an Inspection
The regulation is triggered in four situations:
- After installation and before first use, where safety depends on how the equipment was installed
- After assembly at a new site or in a new location, for the same reason
- At suitable intervals, where the equipment is exposed to conditions causing deterioration liable to result in dangerous situations
- After exceptional circumstances liable to have jeopardised the safety of the equipment
The fourth is the one that gets missed. An exceptional circumstance means a collision, an overload, a modification, a long period out of service, exposure to severe weather, or anything else outside normal use. The inspection is due at that point regardless of where the equipment sits in its normal cycle.
How Often: There Is No Fixed Interval
PUWER sets no statutory inspection frequency. Intervals are determined by risk assessment, taking account of the equipment type, how heavily it is used, and the environment it operates in. Equipment used outdoors generally deteriorates faster than the same equipment used indoors and warrants a shorter interval.
There is one exception. A power press working cold metal has a set statutory cycle, requiring thorough examination and test by a competent person at least every six months where it is fitted with automatic, interlocking or photo-electric guards, and at least every twelve months otherwise.
For everything else, more frequent is not automatically safer. Over-inspection wears out the safety devices being tested and encourages a tick-box culture where nobody is really looking. Inspection records should be used to adjust intervals in both directions: if a machine has produced no defects across several cycles, the interval may be too short, and if defects keep appearing, it is too long.
The PUWER Inspection Checklist
Build the PUWER inspection checklist around the regulations rather than around the equipment. The regulation numbers give the inspection its structure and make the record defensible.
Suitability and Conformity (Regulations 4 and 10)
- Equipment is suitable for the work it is being used for and the conditions it is used in
- UKCA or CE marking present where applicable, with a Declaration of Conformity available
- Second-hand equipment verified as meeting current standards, since conformity does not transfer automatically from a previous owner
- Hired-in equipment checked on arrival rather than assumed compliant
Dangerous Parts and Guarding (Regulation 11)
- Fixed guards secure and requiring a tool to remove
- Interlocks functioning, and not defeated, taped over or bypassed
- Guards in place on all rotating and reciprocating parts, which is where saws, grinders, drills and planers most often fail
- Trip devices, light curtains and pressure mats tested and working
- No accessible nip points, in-running rollers or exposed drive belts
Controls (Regulations 14 to 18)
- Starting controls require a deliberate action and cannot be operated accidentally
- Stop controls bring the equipment to a safe condition and take priority over start controls
- Emergency stops are accessible, clearly identified, and act as a backup rather than a primary stop
- Control systems fail to a safe state on loss of power or air
- Controls are visible and identifiable from the operating position
Isolation, Stability and Environment (Regulations 19 to 21)
- Means of isolating from every energy source, including stored energy
- Lock-off provision available and used during maintenance
- Equipment stabilised, bolted down or clamped where necessary
- Lighting adequate for the work being carried out
Specific Hazards and Condition (Regulations 12 and 13)
- Protection against ejection of parts, workpieces or material
- Protection against overheating, fire, explosion and the release of substances
- Hot and very cold surfaces guarded or insulated
- Cables, hoses, couplings and hydraulic lines free of damage
- Structural elements free from cracking, corrosion, distortion or wear
Markings, Warnings and Information (Regulations 8, 9, 23 and 24)
- Safety markings legible and correct
- Warning devices audible or visible in the working environment
- Manufacturer’s instructions available to operators
- Operators trained on that specific equipment, with training records held
What the Inspection Record Must Show
Records are a requirement, not good practice, and must be made available on request. A record that would stand up should identify:
- The equipment, uniquely, by serial or asset number
- The date of the inspection
- Who carried it out, and the basis of their competence
- What was inspected and what was found
- Any defects identified
- The remedial action required, who is responsible for it, and by when
- Confirmation that remedial action was completed and verified
- The date the next inspection is due
The close-out matters as much as the finding. Equipment taken out of service after a defect must stay out until the corrective action is completed and verified. Returning it without a documented close-out is where a paperwork problem becomes a safety one.
Where Businesses Usually Come Unstuck
Treating the maintenance log as the inspection record. They are different duties under different regulations and need separate evidence.
Assuming a fixed annual cycle. Nothing in PUWER specifies annual, and an interval that has never been reviewed against defect data is almost certainly wrong in one direction or the other.
Nobody defining competence. A competent person needs sufficient training, experience and knowledge for the specific equipment. Being the most experienced person in the building is not the same thing, and the record should show the basis of that competence.
Missing the exceptional circumstances trigger. A machine that has been struck, overloaded, moved or left standing for six months needs inspecting before it goes back into use, whatever the calendar says.
Ignoring hired and second-hand equipment. Both arrive without a verified history, and both sit squarely within the duty holder’s responsibility from the moment they are put into service.
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