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One site, three regimes: what LOLER, PUWER and PSSR each want from you

A worked walk through a single site's equipment, deciding which of LOLER, PUWER and PSSR applies to each item and what record each one leaves behind. For duty holders with mixed equipment who need to know what they should be holding, not which regulation is more interesting.

By Hovermarks team

Quick answer. Most sites run equipment under all three regimes at once. Lifting equipment and accessories are LOLER, and LOLER's thorough examination is the inspection duty for them because PUWER Regulation 6 is expressly disapplied there. Work equipment that does not lift is PUWER Regulation 6. Pressure systems are PSSR, examined against a written scheme. The regimes differ in what the report must contain, whether the regulation sets an interval, and how long records are kept, so a single site needs three different record shapes rather than one.

This is the walk a new duty holder actually needs: not a comparison of regulations in the abstract, but a tour of one ordinary site, deciding item by item which regime applies and what you should have in the file for each.

The site: a light-engineering unit with a workshop, a small yard, and a mezzanine store.

The overhead crane, and everything hanging off it

LOLER. The crane is lifting equipment. Thorough examination at least every 12 months, or 6 months if it is ever used to lift people, or on the intervals in an examination scheme drawn up by a competent person. Also after installation, after assembly at a new location, and after exceptional circumstances.

Everything below the hook is a lifting accessory: slings, shackles, chains, eyebolts, the lifting beam in the corner. All on the 6-month cycle, each needing its own identity and its own record. This is where mixed sites fail most often, because accessories are numerous, cheap, and mobile.

What you hold: a report of thorough examination per item containing all eleven Schedule 1 particulars, retained under Regulation 11 by record type, plus the examination scheme if the equipment runs on one. The eleven are set out in the Schedule 1 guide.

The pillar drill, the bandsaw, the mezzanine racking

PUWER Regulation 6. None of these lift, so LOLER does not reach them. Inspection is required after installation and before first use where safety depends on the installation conditions, after assembly at a new location, at suitable intervals where the equipment is exposed to conditions causing deterioration, and after exceptional circumstances.

The interval is yours to justify. Regulation 6 sets none. Whatever cycle you run comes from the manufacturer's instructions or your risk assessment, and the reasoning is worth recording alongside the result.

What you hold: a recorded result of inspection per item, kept until the next inspection is recorded, and recorded as a safety inspection in its own right. A service sheet that mentions a guard is not that record. Detail in the Regulation 6 guide.

The air receiver behind the compressor

PSSR. A pressure system, governed by its written scheme of examination: the scheme decides which parts are examined and at what intervals, and Regulation 9 requires examination by a competent person within those intervals.

What you hold: the written scheme itself, and a report of examination against it stating the four Regulation 9(5) items. The report must arrive within 28 days of completion or before the date specified under 9(5)(b), whichever is sooner, and Regulation 10 adds separate duties where the system would give rise to imminent danger. Detail in the PSSR guide.

The awkward ones

A telehandler. Lifting equipment when it lifts, which is most days, so LOLER at 12 months, and 6 months if a man basket is fitted because it is then lifting people. Its forks and attachments are accessories at 6 months. As work equipment it also sits under PUWER generally, though Regulation 6's inspection duty is disapplied because LOLER covers it.

A vehicle lift in the workshop. Lifting equipment, and a useful test of where the 6-month interval actually comes from. Regulation 9(3) sets 6 months for equipment for lifting persons and for lifting accessories, 12 months for other lifting equipment. A two-post vehicle lift lifts a vehicle, not a person, so on the face of Reg 9(3) it is 12-monthly. In practice many duty holders and insurers place vehicle lifts on a 6-month cycle through a written examination scheme, which Reg 9(3) expressly permits as the third route. That is a scheme-driven or contractual decision, not a statutory interval, and it is worth knowing which of the two you are relying on when someone asks why the equipment is on the cycle it is on.

A steam boiler. PSSR, and the scheme will be more demanding than the air receiver's. Do not assume one scheme covers both because both hold pressure.

Ladders and access equipment. PUWER Regulation 6. Not lifting equipment, frequently the least-recorded items on any site, and the easiest to bring into a system because the inspection is quick.

What differs, in one place

LOLERPUWER Reg 6PSSR
Report contents in the regulationYes, eleven Schedule 1 particularsNoYes, four items in Reg 9(5)
Interval in the regulationYes: 6 or 12 months, or per schemeNo, suitable intervalsPer the written scheme
RetentionBy record type, Reg 11Until next inspection recordedPer scheme and next-examination date
Delivery timingForthwith for defect notification; as soon as practicable for the reportNone stated28 days or the 9(5)(b) date, whichever is sooner

What this means for how you keep records

Three observations that follow from the table rather than from any product:

  1. One record shape will not serve. A single "inspections" list with a date and a tick cannot satisfy three regimes that ask for different things.
  2. Every item needs a next-due date, whichever regime it sits under. PUWER's retention rule depends on it, LOLER's intervals depend on it, and PSSR's 9(5)(c) date is the equivalent.
  3. Attribution is not optional anywhere. All three regimes want to know who did this, and a record that cannot say is weak under every one of them.

And the line that runs through all of it

Each regime distinguishes the record from the judgement behind it. A record can be complete: every particular present, attributed, retained, internally consistent. Whether the examination was adequate, and whether the person carrying it out was competent to do it, is a professional judgement the regulations place on the competent person and the duty holder. Software can guarantee the first. Nothing guarantees the second, and a duty holder should be suspicious of anyone who suggests otherwise.

Where Hovermarks fits

Hovermarks holds each item as a QR-tagged asset carrying its own regime, its own interval, its own next-due date and its own record history, and generates the LOLER, PUWER and PSSR report formats against them, refusing to issue one that is missing a required particular. Statutory reporting is on every paid plan. The statutory reporting guide is the reference version of this walk-through, and the statutory reporting page covers the validator.

Related reading

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