In the opening meeting, I asked them a series of questions so that I could better understand their issues and see where they thought they were regarding compliance with legislation.
The General Manager said that they’d had a big push on PUWER for the last few months. I asked how that was going.
“The H&S advisor said we needed to do PUWER assessments of all the work equipment…” I nodded. And waited. “So, we commenced a programme of PUWER assessments and started with the office equipment.”
That isn’t where I’d have started, and my poker face isn’t great, but I did my best not to let my thoughts show.
We went out and performed the sample audit. Halfway around we entered the small workshop. Let’s just say that there was a plethora (I like that word) of issues with regards to the machinery and equipment being non-compliant with PUWER.
So, there was definitely an issue with PUWER.
However, the immediate challenge was to get the team on side because they had just invested time and effort into performing PUWER assessments on non-priority equipment.
There’s a mentality we use at Universal with regards to our audits and assessments:
Is our advice proportionate? Is it pragmatic?
If not, nobody will care and we, as a company, have not added value.
But what about PUWER?
The PUWER Regs (1998) – Provision and Use of Work Equipment Regulations is obviously an important issue for any company. Whether an attraction or factory.
Is this definitely relevant to amusement rides?
Yes, and it’s mentioned in HS(G)175. Appendix 1 lists relevant legislation to be followed by fairgrounds and amusement parks, including PUWER. But as HS(G)175 says, “at first glance these [pieces of legislation] can appear daunting”. Hopefully this newsletter will help to make it less daunting.
Before we look at the legislation in detail, let’s just shuffle back a second.
The Health and Safety at Work Act (1974) gives us a general responsibility for keeping our staff safe. It also gives us a broad framework for doing it (I probably don’t need to tell you that it involves managing risk).
But this is a very broad concept. This is why there are several other pieces of legislation, to give us more specific guidance on managing particular types of hazard.
These pieces of legislation support the Health and Safety at Work Act. They’re not instead of it.
The Act is the ‘mother law’, or ‘primary law’.
Legislation is designed to support the Act. All the legislation that falls under the Health and Safety at Work Act is also built around the premise of ‘managing risk’.
This ‘secondary legislation’ often focuses on keeping employees safe from particular types of hazard. And you’ve guessed it, one of those pieces of secondary legislation is PUWER (1998).
If you have the delights of a HSE visit, and their inspectors find you’re not working in accordance with health and safety laws, then the action they take – based on the severity of the non-compliance – is either:
Remember those general responsibilities I just mentioned? Well, if HSE find an issue, they typically raise it under the Health and Safety at Work Act Section 2(1). This states:
“It shall be the duty of every employer to ensure, as far as reasonably practicable, the health, safety and welfare at work of all his employees.”
It’s a catch-all.
Technically, PUWER applies to any piece of work equipment that’s used by staff – for example the tools and pieces of machinery used by maintenance technicians.
And let’s not forget that a ride or amusement device is an extremely complex piece of machinery!
So why would you start with office equipment?
Because PUWER falls under the Health and Safety at Work Act, it’s underpinned by the concept of managing risk. In other words, the control measures need to be proportionate to the amount of risk that each piece of equipment poses.
According to PUWER, equipment should be:
A key word in PUWER is ‘proportionate’.
Let’s focus on machinery.
Machinery needs to have adequate risk assessments. You should consider how the machine might malfunction, and any guidance from the manufacturer of the machine.
Apply the hierarchy of controls. Guards that prevent access to dangerous machinery are ideal, but they aren’t always practical. Other control measures might include: interlocks, trip switches, jigs, and push sticks.
Like the controls on our rides, machinery should follow recognised standards to make it easier to operate. This includes labelling controls – remember, operating machinery isn’t meant to be a memory test.
When using hazardous equipment, there must be adequate control measures. Things we’ve seen on our audits include:
Some questions for you.
You need to be proportionate AND pragmatic.
What does this mean? Essentially, it means that you should take a look at the range of equipment at your workplace and make a considered judgement on where to start with your PUWER assessments. If all staff are fully office-based, then it will make sense to focus on office equipment. If you have workshops or operate potentially hazardous machinery, then it’s likely that you should be starting there.
Instruction and training:
You should have a Safe System of Work (SSOW) for managing each machine. Don’t just assume that because someone’s a trained technician, they’ll know how to use each piece of equipment safely. Some hazards, or modes of failure, might not be obvious.
At Universal Verification, we often train staff using the SKATE model of competence: Skills, Knowledge, Attitude, Training, Experience.
How do you make sure your team is competent to use the equipment they’re using?
Remember section 2(1) above? Well, the catch-all Regulations in PUWER are typically:
At Universal Verification Ltd we’re passionate about safety.
Whilst guest safety often comes under the spotlight, your technicians also have families, loved ones, hopes and dreams. We want to keep them safe too.
Our consultants understand the legislation. We understand the industry. We understand being Proportionate and Pragmatic.
Our range of audits and consultancy services are bespoke and tailored to your requirements and your attraction.
ContactNeil Wilson or Marcus Brian for more information or to book in a visit.
