Hi All,

I am new to the forum and looking for a bit of advice on PUWER and in particular on how to carry out a site survey to identify equipment in the workplace that would require PUWER assessment (conformity assessment). I would like to understand how to make a decision on which equipment would need a further assessment. This has come up in an audit and it refers to the PUWER regulations. I have found some PUWER assessment checklists that are inline with the current regulations but I'm just looking for a set of questions/points that need to be met which would allow me to identify the equipment first before carrying out an PUWER assessment.

Many Thanks

What does that audit actually say?

It says that there was no evidence of assessment of equipment being used on site (as mentioned above pallet wrapper, trolleys..), especially that pre-dating PUWER and/or does not carry a CE mark. A site survey should be carried out to identify equipment requiring conformity assessment.

Hi Martin.

Welcome to the forum. Just to help us understand what is driving this, can you tell us who instructed this audit? Was it internal or did it come from your insurers?

I'm with Jane. Conformity assessment (essential safety requirements) is not retrospective provided the equipment stays where it is.

Something a bit iffy about that finding/recommendation.

Can you pls expand upon the audit finding. Is the finding about PUWER Regulation 11 or about overall lack of PUWER linked risk assessments ?

Re-location of for example, pre MD, non CE marked equipment does not require it to be retrospectively CE marked, unless it is being placed on the market in the EU for the first time, e.g. importing used equipment from outside the EU which pre-dates the CE requirement.


CE marking is only required for equipment that falls under one of the directives that require it, MD, LVD, PED etc. for example.

CE marking is required for ALL equipment that falls under it's scope regardless of who makes it and who uses it, even if you design & build equipment for your own use.

As has been suggested all equipment, must, comply with PUWER.

JohnW, the "person" signing the DoC would also need to be able to generate a technical file, not easy if you're not the OEM, unless, you reverse engineer the equipment.
Which you might not be able to do retrospectively after CE marking the machine IYKWIM.

If you as an end user are going to CE mark equipment then you really need to generate the TF as part of the process.

Martin.
Go around and look at the machinery, it will ALL need assessing in some way or form.
Take the highest risk, equipment, such as that which can cause death, and look at the user exposure etc., and then do a full assessment on that first, as you go you will get quicker, and you will begin to see what is important, that way you can then more easily identify what does and what does not need a full assessment.