The Health and Safety Executive (HSE) has released an update in relation to Thorough Examinations of plant and equipment, which are required by law, including under the Lifting Operations and Lifting Equipment Regulations (LOLER), the Pressure Systems Safety Regulations (PSSR), the Control of Substances Hazardous to Health Regulations (COSHH) and the Provision and Use of Work Equipment Regulations (PUWER).
Whilst the HSE acknowledge that critical industries may be rightly prioritised by inspection companies, especially if they themselves have reduced numbers of staff due to the ongoing coronavirus outbreak, the statutory obligation to have equipment Thoroughly Examined remains with employers/duty holders, i.e. you should ensure that all equipment has in date testing reports available.
In practical terms, this may mean contacting other inspection providers if your current supplier cannot service your requirements or rescheduling appointment dates to fit around your existing supplier. Businesses that have furloughed workers should make every effort to accommodate an Inspection Engineer’s visit, by having one of your workers available to open up and provide access to the equipment that needs an examination.
From an operational point of view, we recommend that upcoming inspections are accommodated wherever possible, to ensure that equipment is safe for continued use and is not taken out of service for an extended period beyond the re-test date. Bear in mind that there may be a backlog of work building up for inspection companies if re-test dates are missed and you may have to keep equipment out of service for longer until it can be Thoroughly Examined.
It would be prudent to discuss inspection arrangements with your current supplier in advance of any scheduled inspections, to plan alternatives or change your processes to accommodate equipment being out of service until a Thorough Examination has been completed.
Inspection Engineers must be able to complete their work whilst observing Social Distancing guidelines and remaining safe, which may involve:
- Pausing your processes that use the equipment and observing any cool down periods
- Working 2m apart from your workers throughout the inspection process, in an isolated area or with physical barriers marking a 2m distance
- Access to hand washing facilities in your workplace
- Cleaning equipment that requires inspection with disinfectant or leaving it untouched for a 72-hour period.
Inspection companies may also ask for formal confirmation that your workplace does not contain any workers showing symptoms of COVID-19 or from households where someone else has symptoms, in accordance with Government advice.
The HSE do offer scope for the continued use of work equipment beyond its Thorough Examination re-test date, subject to a rigorous risk assessment driven decision process which must record:
- how alternative inspection suppliers were sought
- justification for the equipment being used in support of essential work
- the consideration of alternative processes which do not use the equipment
- the consideration of the use of alternative equipment
- an assessment of the increased risk of immediate danger from a failure of equipment
- an assessment of the ability of a failure of equipment to cause wider harm
- a review of the written scheme and past inspection reports to identify likely damage or defects in the equipment
- advice from your inspection company about potential causes for concern and any additional checks required
- the consideration of the working environment and any corrosion factors it presents
- the additional arrangements you have introduced to manage the increased risk and mitigate harm to an appropriate level
- your access to competent engineers to carry out additional checks and maintenance of equipment
- when you will review the risk assessment
Of course, if your conclusion is that the equipment cannot be used safely then it must be taken out of use.