Mastering maintenance

In the UK, LOLER (Lifting Operations and Lifting Equipment Regulations) and PUWER (Provision and Use of Work Equipment Regulations) spell out the requirements for ensuring lifting equipment for work is safe to use. Introduced in the late 1990s, the combination of these two sets of regulations establishes a high standard of safety for lifting equipment via three levels of checking: pre-use checks; routine inspection and maintenance; thorough examination. In addition, the initial selection of equipment has an important role to play. As a result, it is almost inevitable that a number of different personnel will be involved. Unfortunately, feedback received from LEEA members suggests there is a lack of understanding among some employers as to precisely who is responsible for doing what. In response, the association has published a new guidance note that aims to provide both clarity and practical advice.

The most commonly voiced concern is that some employers are failing to recognise where ultimate responsibility for the safety of lifting equipment lies. Yet, on this particular question, there is no room for doubt. The obligations imposed by LOLER and PUWER apply to the ‘duty holder’, i.e. the person responsible for the lifting equipment. Usually this is the employer or self-employed person. However, it should be stressed that this is not always the case. In certain circumstances it might be a building owner, the person in charge of the equipment, or a hire company.

Of course, processes such as the selection, inspection, maintenance and thorough examination of lifting equipment are specialist tasks requiring specialist skills. In many cases, the duty holder will not have the expertise necessary to fulfil all of their obligations. If this is the case, it is perfectly acceptable – indeed desirable – for them to delegate to suitably qualified personnel or organisations. But doing so does not absolve them of ultimate responsibility. It simply changes the nature of their accountability. A duty holder who delegates or sub-contracts their legal obligations becomes culpable for ensuring that those undertaking the tasks are suitably qualified, experienced, trained, equipped etc. In other words, that they are competent for the task. Where external organisations are involved, the duty holder must have the procedures in place to vet such competency.

LEEA’s new guidance note identifies five key roles that contribute to the on-going safety of lifting equipment at work. They are: 

Procurement personnel

Procurement personnel are responsible for selecting equipment best suited to the intended application. This will involve creating a specification that includes not just a full understanding of the equipment involved, but also other relevant factors, such as environmental conditions and the skills of those who will be using the equipment. They will need to identify the minimum performance requirements, reference appropriate safety standards, and choose equipment on its ability to perform safely under all foreseeable conditions, not just the price.

The lifting equipment examiner 

In the lifting equipment industry, the term ‘competent person’ is commonly associated with the individual responsible for the thorough examination of lifting equipment. The requirements for such examinations are set out in LOLER. The competent person is responsible for ensuring that any defects found are reported to the duty holder, with recommendations as to corrective actions required. In turn, the duty holder is then responsible for taking the appropriate action, investigating the root cause, and implementing measures to prevent reoccurrence. 

The inspector

The inspector is responsible for interim inspections between thorough examinations. These are determined by the risk assessment, which should identify the critical components and assemblies to be covered by the inspections. The inspector is responsible for monitoring them and ensuring they are replaced before they become dangerous. Records should be kept, and relevant findings reported to the duty holder and competent person. Once again, the duty holder is responsible for ensuring appropriate corrective action is taken. 

Maintenance personnel

Maintenance personnel should repair faults: as and when they occur; as requested by the inspector or duty holder; as required by the manufacturer’s literature; in accordance with a planned maintenance regime. Clearly they are responsible for ensuring all these repairs are done effectively, using suitable components. Furthermore, records should be kept in a maintenance log, and made available to the inspector and competent person. 

Operators

Operators are responsible for ensuring that they only use lifting equipment for which they have been trained – and do so in accordance with this training and the manufacturer’s literature. In addition, they should undertake pre-use checks of the equipment, and report to the inspection and/or maintenance personnel any obvious signs of damage or changes to the operation that might indicate a defect.

As with so many things in life, ensuring the safety of lifting equipment is almost invariably a matter of teamwork. Equally, when a variety of different people are involved, perhaps encompassing both internal staff and external agencies, there is always a danger of confusion in terms of where individual responsibilities lie. Establishing and maintaining clear lines of communication is therefore likely to require careful attention. Ultimately, even if they are not ‘hands on’ in terms of undertaking all the necessary tasks, it is the duty holder’s responsibility to ensure that everyone is absolutely clear as to their role, and all have the necessary skillset to fulfil it. In the UK, duty holders are fortunate to enjoy a well-established regulatory framework in the shape of LOLER and PUWER; these regulations also form a significant part of the LEEA technical requirements that members worldwide are required to adhere to. For all the relevant stakeholders, a number of helpful publications are available to help ensure compliance, including the approved code of practice (ACoP) that accompanies LOLER, and LEEA’s own COPSULE (Code of Practice for the Safe Use of Lifting Equipment). To this list can now be added the association’s new guidance note, ‘Roles and responsibilities for ensuring the continued safety of in-service lifting equipment’, copies of which can be downloaded from www.leeaint.com

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