Rank: Forum user 
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Should a pallet inverter be included on a company's LOLER register?
I'm sure someone has a short and sweet answer to this short question!
Thanks for your help.
Lucy
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Rank: Super forum user 
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I think not, as the machine is not itself concerned with lifting and lowering of the load.
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Sorry Ron, I have to disagree. Pallet inverters lift the pallet in order to turn them over so in my opinion they are covered by LOLER
Phil W
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Hi Lucy.
I'd say yes too.
Andy
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I may be displaying ignorance and limited understanding of the mode of operation. I had assumed that all of these machines just rotated the load on a fixed axis, with the FLT doing the on/off 'lifting' bit.
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Rank: Super forum user
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I was intrigued by this post as I have not dealt with pallet inverters so I used a well known search engine to view them. From what I have just seen I would say it depends. The equipment I have seen looks to be of two designs.
In one you load the pallet into the inverter with a fork lift and the unit turns over. There does not appear to be any lifting involved and so LOLAR would not apply.
The other form appear to allow you to load at low level (with a pallet truck?) and then lift the load to give sufficient clearance to turn it - hence LOLAR would apply.
I admit I have not seen these in operation and that my assumption is base on looking at these on the web, I would be interested if I have misinterpreted their operation.
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Similar questions have arisen in the past. If the purpose of lifting is only to gain ground clearance then the equipment does not fall under LOLER, that's not what LOLER was written for.
Hence pump trucks do not qualify under LOLER and nor do multi-point linkages on the back of tractors.
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Safety
yes I here what you are saying and I agree totally about pallet trucks, the amount of clearance needed to turn a pallet appears to be much greater and I am not sure you would apply the same logic. I think this is a very interesting one.
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Interesting in terms or interpretation. The HSE (for example) tell us that the lifting boom on a lorry tipper truck is not to be considered as lifting equipment.
http://www.hse.gov.uk/lau/lacs/90-4.htm#para28
Applying that logic, this suggests that where the pallet inverter lifts as well as turns, LOLER isn't to be applied?
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I get the impression that people generally believe that LOLER places a higher standard than PUWER. The manner in which the equipment is managed should be based on the risk assessment. LOLER was written for equipment of which the main purose is to achieve a different height such as; MEWPS, cranes, passenger lifts, goods lifts, FLTs, etc. What is this obsession with trying to Apply LOLER where it isn't necessary?
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Rank: Super forum user
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Safety
Once again I agree with you, the only additional thing would be the thorough examination. As I stated I was basing my comment's on looking at the Internet and not viewing the equipment in the flesh. For me there are some units which clearly do no lifting but just turn the pallet. For the others I canno0t say how much lifting is involved but I can clearly see that your argument carries great merit and could easily be the case.
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The inverter I dealt with a few years ago lifted the pallet a good 2 foot off of the deck, and then spun it.
I'm happy to be proved wrong, but I would consider this to come under LOLER.
At my current employer- pallet trucks and dock levellers are inspected under LOLER, as required by our insurers.
Andy
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Motorhead wrote: as required by our insurers.
Andy
That is the bit that really matters. And that any control measures are relevent to the risk. PUWER is not LOLER's poorer cousin.
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No there's the lack of understanding from insurance companies!
LOLAR requires a COMPETENT person to draw up a scheme of thorough examination. As a pallet truck does not need such a thorough examination, how does the COMPETENT persons do that?
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Rank: Super forum user 
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I have looked as well and I could not call this decision. It lifts, ergo, it is lifting equipment. If in doubt, it is safer to add it and pay whatever it costs than to leave it off and pay the consequences. Bit of a no brainer really.
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I would suggest it is a lifting accessory therefore under LOLER.
Ta
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hilary wrote:I have looked as well and I could not call this decision. It lifts, ergo, it is lifting equipment. If in doubt, it is safer to add it and pay whatever it costs than to leave it off and pay the consequences. Bit of a no brainer really.
Using that logic, do you subject the jack in the boot of your car to LOLER inspections?
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What Safety Smurf is saying is that just because a machine has a bit of lifting associated with it, that doesn't automatically attract LOLER. I'm absolutely with him on this. Consider again the lowly pallet truck. It lifts the load a couple of inches but could you then use it to put the load anywhere else but back down on the floor? No. Could you use it to lift a load out of racking? No.
For those who try to read otherwise, I invite you to go back to the Regs and particularly the ACOP (paras 28 to 33). LOLER is about equipment that enables you to fundamentally change the location of an article or person (get to the third floor of your offices without using the stairs, lifting a new chiller onto the roof, allowing the window cleaner to get up and down the facade etc. etc.). Don't clog up the system with dubious applications please; just because there's incidental lifting does not, repeat not attract LOLER per se.
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Where do you draw the line? I have 70 bay doors, motors lift the doors up via wires, would these fall under LOLER as they are being lifted? or docklevellers which have rams which lift up the dock to the height of the vehicle?....what about the system inside the photocopier which lifts the paper in position?..I agree with Smurf and Jim, just because it something lifts something does not automatically full under LOLER!
We had 4 pallet inverters at my last site, quite a large company and they were not inlcuded on the insurance inspections!..Put it this way, if part of the lifting mechanisim failed, what could happen? baring in mind the inverter is in a caged area (normally), the operator is a safe distance from the equipment, and the lift is about 2-3 foot of the floor?
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Lucy d This is a question which is very difficult to answer I completely disagree with Mr Flibble /Jim /Safety Smurf (Sorry folks). Yes you have to draw a line somewhere as this is turning into peoples opinions as the regs are difficult to decipher. Ask your insurers and see what they say. I use these things frequently they are a lifting accessory we do have them on the LOLER register as I would rather they were inspected that way. The only other way is if you have a serious accident with one and then you can ask the HSE investigation team what they think?
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alexmccreadie13 wrote:Lucy d This is a question which is very difficult to answer I completely disagree with Mr Flibble /Jim /Safety Smurf (Sorry folks). Yes you have to draw a line somewhere as this is turning into peoples opinions as the regs are difficult to decipher. Ask your insurers and see what they say. I use these things frequently they are a lifting accessory we do have them on the LOLER register as I would rather they were inspected that way. The only other way is if you have a serious accident with one and then you can ask the HSE investigation team what they think?
I'd be inclined to agree with Mr Fibble / Jim / Safety Smurf. I wouldn't however base this on the fact we have to draw a line, I'd base it on the regs, acop, guidance and industry practice. LOLER is applicable to equipment who's principal aim is to lift / lower. If the principal use of the equipment is something other than lifting, e.g. in this case the rotating and wrapping of a pallet, statutory inspection should be under PUWER.
It's also important to remember that thorough examinations don't by default cover all items a PUWER inspection covers (which the LOLER acop states). Even with a LOLER inspection non-lifting aspects of the machine may still need to be inspected under PUWER! There is a risk that if the pallet inverter is placed under LOLER, not all safety aspects would be tested. Regardless I believe PUWER to be the most appropriate reg for pallet inverter.
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I urge the doubters to study the information at the link I gave at post #9.
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When I first posted on this thread I said I thought some inverters would be LOLAR and some not depending on the way they work, but stated that was from little knowledge of these units. Safety Smurf and others have very correctly pointed out the guidance that where the lifting is incidental to the actual work activity LOLAR does not apply. Many people who use these equipment state that this is the case so I bow to there practical knowledge and add my support to the not LOLAR side.
As for asking your insurance company they may say its covered but who says they are right? I knew a car recover company who had to get their winch on the flatbed examined even though it dragged the car up the ramp and do no lifting what so ever. This type of winch is quite clearly covered in HSE guidance as not being LOLAR
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ron hunter wrote:I urge the doubters to study the information at the link I gave at post #9.
A good link Ron, para 28 in particular as you have stated previously. Para 28 is directly applicable to the original question.
Para 17 of your link is also important to be aware of to ensure all safety aspects of equipment are statutory inspected as required (be that under under PUWER, LOLER or LOLER and PUWER).
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Safety Smurf wrote:hilary wrote:I have looked as well and I could not call this decision. It lifts, ergo, it is lifting equipment. If in doubt, it is safer to add it and pay whatever it costs than to leave it off and pay the consequences. Bit of a no brainer really.
Using that logic, do you subject the jack in the boot of your car to LOLER inspections?
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hilary wrote:Safety Smurf wrote:hilary wrote:I have looked as well and I could not call this decision. It lifts, ergo, it is lifting equipment. If in doubt, it is safer to add it and pay whatever it costs than to leave it off and pay the consequences. Bit of a no brainer really.
Using that logic, do you subject the jack in the boot of your car to LOLER inspections?
Errm, this is lifted from the HSE Local Authority Circular:
"8 The Regulations should not be applied where risks are low, for example raising someone in a barber's chair, (which, in any case, may be considered as a 'height adjustment' rather than a 'lifting operation'). Other equipment, such as a vehicle jack, which may seem similar to this example, is more likely to involve risk and LOLER should be applied."
To be fair, it quantifies that personal jacks may possibly be excluded, but clearly the HSE do regard this as Lifting Equipment under the regulations.
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hilary wrote:hilary wrote:Safety Smurf wrote:hilary wrote:I have looked as well and I could not call this decision. It lifts, ergo, it is lifting equipment. If in doubt, it is safer to add it and pay whatever it costs than to leave it off and pay the consequences. Bit of a no brainer really.
Using that logic, do you subject the jack in the boot of your car to LOLER inspections?
Errm, this is lifted from the HSE Local Authority Circular:
"8 The Regulations should not be applied where risks are low, for example raising someone in a barber's chair, (which, in any case, may be considered as a 'height adjustment' rather than a 'lifting operation'). Other equipment, such as a vehicle jack, which may seem similar to this example, is more likely to involve risk and LOLER should be applied."
To be fair, it quantifies that personal jacks may possibly be excluded, but clearly the HSE do regard this as Lifting Equipment under the regulations.
The principal aim of a vehicle jack is to lift, using this logic, and dependant on the associated risk, it would come under LOLER. The nonsense situation comes when its cheaper to buy a new jack than pay for an inspection regime under LOLER!!
Within our maintenance departments, personal jacks are LOLER inspected (this also makes commercial sense, but for a person / company who owns 1 or 2 jacks, it may be cheaper to buy a new jack each year, is that really going to happen?!).
As an aside, I read the above circular as meaning personal jacks should probably be included within LOLER (rather than may possibly be excluded)?
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Thank you all for your contributions.
I appreciate the comments highlighting the requirement for maintenance and inspection under both PUWER and LOLER, however I do think it makes a difference to categorise which is appropriate to a specific piece of equipment since this may affect the nature of the inspection.
Again thank you for taking time to provide the information.
Lucy
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Brian Hagyard wrote:No there's the lack of understanding from insurance companies!
LOLAR requires a COMPETENT person to draw up a scheme of thorough examination. As a pallet truck does not need such a thorough examination, how does the COMPETENT persons do that?
Totally agree, why o why are insurance companies insistant in requiring hand pallet truck fall under LOLER is beyond me. PUWER yes, not LOLER.
'While LOLER applies to most work equipment used for lifting, in practice the risk assessment may result in there being few (if any) measures necessary to comply with the Regulations. Examples include a pallet truck (which raises the load a small distance) and small storage and retrieval systems with trays on a continuous chain'
http://www.hse.gov.uk/lau/lacs/90-4.htm
'
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Brian Hagyard wrote:No there's the lack of understanding from insurance companies!
LOLAR requires a COMPETENT person to draw up a scheme of thorough examination. As a pallet truck does not need such a thorough examination, how does the COMPETENT persons do that?
Brian,
A examination scheme is not required in LOLER unless you wish to extend the statutory periods of examination for an item of lifting equipment or part therof. In the absence of an examination scheme examinations needs to be carried out in accordance with the other stipulations in LOLER.
L113 states "In most cases LOLER will not apply to work equipment which does not have the principal function a use for lifting or lowering" As a pallet truck is intended to move pallets around and the raising of them to clear the floor to permit movement is ancilliary then LOLER is not applicable.
If you visit the plant guides on most of the major insurance industry owned inspection companies web sites you will see that they state that applicable legislation for a pallet truck is PUWER
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good morning everybody
few thoughts,
Vehicle jacks are only covered by LOLER for the garage mechanic who is at work. the jack in the boot of your car is not used for work activities therefore not covered by LOLER. The motor mechanic or road side assistant will use his own jack because he is at work and his jack is quicker, stronger etc.
The pallet lifter carries our lifting as an incidental part of its operation, similar to a fairground ride, its primary function is inversion of a pallet by rotation, therefore not covered by LOLER but definately by PUWER.
LOLER requires a written scheme by a competent person first, in the absence of a written scheme then the 6 and 12 months minimums apply. Lots of companies, insurance included, apply the 6 and 12 month periods almost verbatum as they are the legal minimums, however the written scheme by the competent person may require more frequent, or less frequent inspection depending on the condition, usage, likelyhood of deterioration, exposure to advers eather etc
hope this helps
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Rank: Super forum user
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up north wrote:good morning everybody
few thoughts,
Vehicle jacks are only covered by LOLER for the garage mechanic who is at work. the jack in the boot of your car is not used for work activities therefore not covered by LOLER. The motor mechanic or road side assistant will use his own jack because he is at work and his jack is quicker, stronger etc.
*flame proof jacket on*
Unless you are driving a company car, on company business when you get a flat tyre and change your own tyre using the jack in the boot of your car?
*flame proof jacket off*
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