Shortwave radio transmisson antenna, typically consists of a large copper wire mesh suspended between two masts. To date, whilst we undertake annual visual inspections of the masts, halyard, shackles etc,  we have not completed a LOLER inspection, although we have been recently advised by a 3rd party that the halyard, blok and shackle components would be subject to LOLER when lowering an antenna for maintenance.   I went away and had a look at the L113, the HSE’s Safe Use of Lifting Equipment (LOLER Regulations 1998), and came upon the following excerpt:

 2.31. In most cases LOLER will not apply to work equipment which does not have as its principal function a use for lifting or lowering.

Whilst raising and lowering an antenna is certainly a use case of the halyard, block, and shackle etc., it’s not the principal, ongoing function.  I see the principal function of this equipment to maintain mechanical tension and support in the antenna system, ensuring stable positioning and alignment, with the capability of lowering the antenna when damaged, i.e. by exception, and certainly not its principal function.  For example, an antenna may remain static (under suspension) for >99% of the time (signifying that this would be its principal function).

 Due to this, I would challenge that LOLER applies but would welcome any thoughts. Thanks in advance