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PSSR: the written scheme, the 28-day report, and the imminent-danger duty

Under PSSR 2000 the written scheme of examination decides what is examined and when. Regulation 9(5) sets the four things the report must state, Regulation 9(3) sets the 28-day delivery duty with a whichever-is-sooner clause, and Regulation 10 carries the separate forthwith and 14-day enforcing-authority duties.

By Hovermarks team

Quick answer. The Pressure Systems Safety Regulations 2000 hang everything on the written scheme of examination: it decides which parts are examined and at what intervals, and Regulation 9 requires the competent person to examine in accordance with it. Regulation 9(5) sets the four things the report must state or specify. Regulation 9(3) requires the report to arrive within 28 days of completion, or before the date specified under 9(5)(b), whichever is sooner. Regulation 10 carries separate duties where the system would give rise to imminent danger: a report forthwith, and notification to the enforcing authority within 14 days.

PSSR is not LOLER for pressure systems. LOLER enumerates the report contents in a Schedule and puts intervals in the regulation. PSSR does neither: the scheme sets the intervals and the scope, and the report is written against the scheme. Get the scheme wrong and everything downstream inherits the error.

The written scheme is the spine

Before any examination happens, a suitable written scheme must exist, drawn up or certified by a competent person, covering the parts of the pressure system it applies to and the intervals at which they are examined. Regulation 9 then requires the user of an installed system, or the owner of a mobile system, to ensure those parts are examined by a competent person within the intervals the scheme specifies.

Two consequences people miss:

  • Scope is the scheme's, not the regulation's. If a part is outside the scheme it is not examined under Regulation 9, which makes the scheme's coverage a safety decision rather than paperwork.
  • The interval question has no general answer. "How often must a pressure system be examined" has only one honest response: as the scheme says. There is no statutory default equivalent to LOLER's 6 and 12 months.

What the report must state: Regulation 9(5)

Four items, and each is a distinct obligation:

  • 9(5)(a) which parts of the pressure system have been examined, the condition of those parts, and the results of the examination
  • 9(5)(b) any repairs or modifications to, or changes in the established safe operating limits of, the parts examined which are necessary to prevent danger, and the date by which any such repairs or modifications must be completed
  • 9(5)(c) the date, within the limits set by the scheme, after which the system may not be operated without a further examination
  • 9(5)(d) whether in the competent person's opinion the scheme of examination is suitable, or should be modified, and if the latter, the reasons

9(5)(d) is the one that surprises people. The report is not only a statement about the system; it is also a professional opinion about the scheme the examination ran under. A scheme that has drifted out of step with the plant is exactly the failure this item exists to catch.

The delivery duty: Regulation 9(3), and its sooner clause

The report must be sent as soon as is practicable after completing the examination, and in any event to arrive:

  • within 28 days of completion (or, for integrated installed systems examined as a series, within 28 days of the last examination in that series), or
  • before the date specified in the report under 9(5)(b),

whichever is sooner.

That last clause is the part worth internalising. If the competent person specifies that a repair must be completed by a date fourteen days out, the report has to arrive before that date, not at day 28. The 28-day figure is a ceiling, not an allowance, and a report that lands inside 28 days can still be late.

Imminent danger: Regulation 10

Regulation 10 is a different duty to a different recipient, and merging it with the 28-day rule is a common error. Where the competent person is of the opinion that the pressure system will give rise to imminent danger unless repairs, modifications or changes to operating conditions are made, they must forthwith make a written report identifying the system and specifying the repairs, modifications or changes concerned, and then within 14 days of completing the examination send a written report containing the same particulars to the enforcing authority.

So there are two clocks, and they measure different things:

DutyRegulationRecipientTiming
Ordinary report of examination9(3)User or owner28 days, or the 9(5)(b) date, whichever is sooner
Imminent-danger report10User or ownerForthwith
Enforcing-authority notification10Enforcing authorityWithin 14 days of completing the examination

What software does here, and what it does not

Worth being precise, because this is where inspection tools tend to imply more than they do.

Hovermarks produces the PSSR Report of Examination and refuses to issue an incomplete one. Against 9(5) that means the parts examined with their condition and results are carried from the examination record; a danger-classified defect cannot be issued without both its remedial action and its remedy-by date, which is 9(5)(b); and the next-examination date under 9(5)(c) is required before issue. The 9(5)(d) opinion on scheme suitability is not captured today: there is no field for it, so a competent person recording that opinion does so outside the app. That is a gap, and naming it is more useful than working around it.

What the software does not do, at all:

  • It does not track, manage or remind on the 28-day duty, and it does not compute or watch the whichever-is-sooner date.
  • It has no Regulation 10 route: no imminent-danger report distinct from the ordinary one, and nothing covering the 14-day enforcing-authority notification.
  • It holds no record that a report was sent, to whom, or when.

Those are duties on the competent person, and they stay there. A tool that produced a compliant document and then implied it had discharged the delivery obligation would be worse than one that stayed quiet, because the person carrying the duty would think it was handled.

That distinction runs through all of this. Software can guarantee a report is complete against the regulation and internally consistent. It cannot make an examination competent, and it cannot deliver a report on your behalf.

Where Hovermarks fits

Hovermarks generates the PSSR Report of Examination against the QR-tagged system, tied to the written scheme it runs under, and blocks issue where a required particular is missing. Statutory reporting is on every paid plan. The statutory reporting guide sets PSSR alongside LOLER and PUWER, and the statutory reporting page covers the validator.

Related reading

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