PUWER Regulation 6 inspection records: what the regulation actually requires
Regulation 6 of PUWER 1998 prescribes no report contents and no inspection interval. What it does require, why a maintenance or service log does not discharge the duty, what suitable intervals means in practice, and why the retention rule only works if each item carries a next-due date.
By Hovermarks team
Quick answer. Regulation 6 of the Provision and Use of Work Equipment Regulations 1998 requires work equipment to be inspected after installation and before first use, after assembly at a new site or location, at suitable intervals where it is exposed to conditions causing deterioration, and after exceptional circumstances liable to jeopardise safety. The result must be recorded and kept until the next inspection under the regulation is recorded. The regulation prescribes no report contents and no interval. Any figure you use comes from the manufacturer's instructions or your own risk assessment, never from the regulation.
PUWER Regulation 6 is the inspection duty most often described wrongly, because people reach for the LOLER shape and assume it applies here too. It does not. LOLER enumerates eleven particulars a report must contain and sets 6 and 12-month intervals in the regulation itself. Regulation 6 does neither. What it gives you instead is a duty framed around outcomes, and a retention rule with a quiet dependency most systems fail to meet.
What Regulation 6 requires
Four triggers and one record duty:
- After installation, before first use (Reg 6(1)(a)), where safety depends on the installation conditions.
- After assembly at a new site or in a new location (Reg 6(1)(b)), to verify it has been installed correctly and is safe to operate.
- At suitable intervals (Reg 6(2)), where the equipment is exposed to conditions causing deterioration liable to result in dangerous situations, so that those conditions are detected in good time.
- After exceptional circumstances liable to jeopardise the safety of the work equipment (Reg 6(2) again).
Then Reg 6(3): the result of an inspection is recorded and kept until the next inspection under the regulation is recorded.
There is also a transfer duty at Reg 6(4): equipment leaving your undertaking, or arriving from someone else's, must be accompanied by physical evidence that the last inspection required under the regulation has been carried out.
And an exclusion at Reg 6(5) worth knowing. Regulation 6 itself does not apply to five things: power presses (covered by Regulations 32 to 35), the guards and protection devices on those presses, work equipment for lifting loads including persons, winding apparatus at mines, and work equipment covered by Regulation 29 of the Construction (Health, Safety and Welfare) Regulations 1996.
Read that carve-out precisely, because it is easy to overstate. Lifting equipment remains under PUWER as work equipment: the rest of the regulations, suitability, maintenance, training, guarding, all still apply to it. What is disapplied is this regulation, the Regulation 6 inspection duty, because LOLER's thorough examination is the inspection regime for that equipment instead.
The interval the regulation does not give you
"Suitable intervals" is the whole of it. There is no six months, no twelve months, no annual default hiding elsewhere in the regulation. Any specific number applied to work equipment comes from one of two places:
- The manufacturer's instructions, which are evidence of what the maker considers appropriate, or
- Your own risk assessment, weighing duty cycle, environment, consequence of failure, and history.
This matters more than it sounds. Stating an interval as though the regulation set it is a common error, and it is a poor position to be in when someone asks where the figure came from and the honest answer is "a template". The defensible record is the one that says what interval was chosen, and on what basis, so the reasoning survives the person who made it.
Why a service log does not discharge the duty
The most useful thing to know about Regulation 6, and the thing most often got wrong: HSE guidance is clear that a combined maintenance or service record does not satisfy the inspection duty. The safety inspection is a distinct activity from maintenance, and its result must be recorded as such.
The logic is straightforward once stated. Maintenance asks whether the equipment works. Inspection asks whether it is safe, which is a different question with a different scope and often a different person. A service sheet that mentions a guard in passing is not a record of an inspection; it is a record of a service that happened to notice something. When an inspector asks to see the Regulation 6 record and receives a maintenance history, the answer to the question asked is still missing.
Practically: keep the safety inspection as its own record, with its own date, its own outcome, and its own person attached, even where the same visit does both.
The retention rule and its quiet dependency
Reg 6(3) says the result is kept until the next inspection is recorded. Read that as a system requirement and something follows: the rule is unworkable unless each item carries a next-due date.
Without one, you cannot answer the only question retention exists to serve. Is the record I am holding still the current one, or has it been superseded by an inspection nobody filed? A stack of records with no forward date tells you what happened, not whether you are covered now. That is why an inspection regime built on "we inspect them when we get round to it" fails audit even when the inspections genuinely happened: nothing in the system distinguishes a current record from a stale one.
What a defensible PUWER record looks like
Since the regulation prescribes no contents, this is practice rather than statute, but it is what survives scrutiny:
- The equipment, identified individually
- The date of the inspection and the person who carried it out
- What was inspected and the outcome, including anything found
- Action taken on anything found, and by when
- The next-due date, and the basis for the interval
- Evidence attached to the record rather than filed elsewhere
None of that is exotic. It is simply the record being a record of an inspection rather than a note that one occurred.
What software can and cannot do here
It can hold the inspection as its own record type, distinct from maintenance; carry a next-due date per item so the retention rule works; keep the interval and its basis alongside the result; and keep the evidence attached to the record instead of on someone's phone.
It cannot decide what a suitable interval is. That judgement belongs to whoever assesses the risk, and it stays with them. Nor can it make an inspection competent: whether the right things were looked at, and whether the person looking knew what they were looking for, remains a professional responsibility no tool discharges.
Where Hovermarks fits
Hovermarks generates the PUWER Inspection Record as a distinct record type against the QR-tagged asset, with its own next-due date so the Regulation 6 retention rule has something to run against, and its own outcome and attribution rather than a line in a maintenance log. Statutory reporting is on every paid plan. The statutory reporting guide sets PUWER alongside LOLER and PSSR, and the statutory reporting page covers how the validator behaves.