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Brown900431  
#1 Posted : 23 June 2017 11:15:03(UTC)
Rank: Forum user
Brown900431

Hi everyone, I'm having a discussion with one of our managers and he says straps/chains used for load security on a lorry/flat bed aren't lifting equipment under LOLER so don't need formal/documented inspections and/or maintenance. I've tried explaining about the requirements of PUWER but he says hes asked delivery drivers who come to us and they don't do it so therefore we don't either.

I need to do a risk assessment, can anyone give me any examples of inspection & maintenance regimes for ratchet straps/chains used for load security?

thanks!

Bigmac1  
#2 Posted : 23 June 2017 13:27:07(UTC)
Rank: Super forum user
Bigmac1

PUWER requires that: all work equipment be maintained in an efficient state, in efficient order and in good repair; where any machinery has a maintenance log, the log is kept up to date; and that maintenance operations on work equipment can be carried out safely.

What you must do

In order to ensure work equipment does not deteriorate to the extent that it may put people at risk, employers, the relevant self-employed and others in control of work equipment are required by PUWER to keep it 'maintained in an efficient state, in efficient order and in good repair'. If you are self-employed and your work poses no risk to the health and safety of others, then health and safety law may not apply to you.  HSE has guidance to help you understand if the law applies. Such effective maintenance can not only help in meeting PUWER requirements but can also serve other business objectives, such as improved productivity and reduced environmental impact.

The frequency and nature of maintenance should be determined through risk assessment, taking full account of:

  • the manufacturer's recommendations
  • the intensity of use
  • operating environment (eg the effect of temperature, corrosion, weathering)
  • user knowledge and experience
  • the risk to health and safety from any foreseeable failure or malfunction

Safety-critical parts of work equipment may need a higher and more frequent level of attention than other aspects, which can be reflected within any maintenance programme. Breakdown maintenance, undertaken only after faults or failures have occurred, will not be suitable where significant risk will arise from the continued use of the work equipment.

The manufacturer's instructions should describe what maintenance is required to keep the equipment safe and how this can be done safely. These instructions should always be followed, unless there are justifiable reasons for not doing so (eg where more frequent maintenance is necessary, due to intense use, adverse environmental conditions or when other experience shows this need). Maintenance on a less frequent basis than the manufacturer's recommendation should be subject to careful risk assessment and the reasons for doing so should be reviewed at appropriate intervals. For example, where there is already an inspection regime, perhaps for lightly used equipment, less frequent maintenance may be justified because of the condition monitoring already provided by the inspection programme.

There is no requirement for you to keep a maintenance log, although it is recommended for high-risk equipment. Maintenance logs can provide useful information for the future planning of maintenance, as well as informing maintenance personnel of previous action taken. However, if you have a maintenance log, you must keep it up to date.

Brown900431  
#3 Posted : 23 June 2017 13:44:40(UTC)
Rank: Forum user
Brown900431

ok, thanks, thats interesting.

In my opinion a securing strap is pretty safety critical, in that if it fails our load might go through a windscreen of a vehicle.

Or am I going OTT? does anyone record inspections on straps?

Thanks! :) 

AndyJB  
#4 Posted : 23 June 2017 13:45:53(UTC)
Rank: Forum user
AndyJB

Mr.Flibble2.0  
#5 Posted : 23 June 2017 13:54:56(UTC)
Rank: Forum user
Mr.Flibble2.0

I tend to break it down to:

If its primary function is to lift then its LOLER, for everything else it's PUWER.

Ask your insurance company who does you LOLER inspections, they tend to look at both if you ask them as part of their visits.

Brown900431  
#6 Posted : 23 June 2017 14:52:41(UTC)
Rank: Forum user
Brown900431

Thanks, information is helpful.

But I was really just looking for a show of hands; does anyone do a formal, recorded check/inspection on straps?

Many thanks!

chris42  
#7 Posted : 23 June 2017 15:03:34(UTC)
Rank: Super forum user
chris42

But some equipment could require both ie LOLER for lifting mechanism part and PUWER for rest of the equipment.

In this instance, the straps / chains etc are not lifting accessories, so LOLER does not apply. We used to get our chains formally inspected for holding down our product to the trailer.

PS. Love the way the Manager is willing to take the word of a truck driver over the company own H&S person.

Stuart Smiles  
#8 Posted : 23 June 2017 16:29:14(UTC)
Rank: Forum user
Stuart Smiles

Buy a copy of Nina Day's book from HSL and ask him to sign for it, have a look at comments on amazon as to what the reviewer though of it. 

https://www.amazon.co.uk/Load-Safe-Road-Professional-Transport/dp/0956122841/ref=sr_1_1?ie=UTF8&qid=1498234208&sr=8-1&keywords=nina+day+transport+load 

She was tasked with writing something to sort out load security so that vosa could regulate it, and relevant information on subjects related is covered. If you have a copy of the "load safety matrix" from dvsa you can reference that too - included in fta link below. 

The trade associations, RHA and FTA also sell guides/training via their websites to make more user friendly, and have some free downloads. 

https://www.rha.uk.net/policy-campaigning/compliance-guides/safe-loading-guide

http://www.fta.co.uk/export/sites/fta/_galleries/downloads/loading_of_vehicles/Enforcement_of_load_security.pdf 

Other info: 

https://www.gov.uk/government/publications/load-securing-vehicle-operator-guidance/load-securing-vehicle-operator-guidance

http://www.hse.gov.uk/workplacetransport/loadsafety/index.htm

http://www.healthandsafetyevents.co.uk/orgfiles/ZORGF000011/HSE/seminar-presentations/nina-day-health-safety-laboratory-health-safety-event-2017.pdf 

https://www.fors-online.org.uk/cms/wp-content/uploads/2016/04/V6-Safe-loading-1.pdf

https://www.gov.uk/government/publications/load-securing-vehicle-operator-guidance/load-securing-vehicle-operator-guidance 

the problems you are always going to have are about assessment of the strap and it's ability to do the job. Had a long chat with one of the guys at cargo-stop, suggest you have a discussion about suitability for your needs with the manufacturer and some sort of regieme for inspections by the users to comply with your needs, in addition to the regieme you come up with for formal inspection. I think they have a checklist for people to follow to check it's ok to use, perhaps you also want to ask ref extra straps in case when you decide you aren't happy with the one you have, you have a system for spares etc to hand and a way of managing inventory.

we wrote vehicle regs on straps to ensure stay with vehicle, & box/bag for them to live in with shackles, with paint dabs for colour coding as current inspected strap, on the back of label. 

whatever is simple and works for you is the system to adopt. 

Edited by user 23 June 2017 16:32:06(UTC)  | Reason: added load safety presentation found online

Brian Campbell  
#9 Posted : 24 June 2017 09:28:49(UTC)
Rank: Forum user
Brian Campbell

We use 5ton rated ratchet straps daily but dont have any sort of regime for regular inspections, however if the buckle is damaged or the strap is badly frayed then they are binned straight away and replaced.  Its never been brought up by our insurance inspectors either but yes under PUWER they should be considered as plant i suppose and therefore subject to PUWER regs requirements.

Brown900431  
#10 Posted : 26 June 2017 09:46:11(UTC)
Rank: Forum user
Brown900431

many thanks everyone, I'm going to look through the links and see what i can find, it seems to be a bit of a vague area. Most people I've spoken to acknowledge that they fall under PUWER but tend to rely on the person securing the load to visually inspect the strap. We don't have particularly big loads but they can be high value and it makes sense to make sure that we keep them safe.

Chris42 is the only person I've come across that says they have a formal inspection for their securing chains.

and yes its frustrating that they'll all listen to every tom, dick or harry that offers an (uninformed) opinion but someone who has studied and worked in a H&S role for over 10 years is told 'i don't know what I'm talking about', thats why I love ISO's, client and any other external audits I can justify! 

Cheers people, you're always a excellent source of good advice and practical help!!

chris42  
#11 Posted : 26 June 2017 09:59:30(UTC)
Rank: Super forum user
chris42

Sent PM which will explain.

Stuart Smiles  
#12 Posted : 29 June 2017 19:59:49(UTC)
Rank: Forum user
Stuart Smiles

Hi,

for us, (waste company with iso 18001 and iso 14001 and 9001 with lrqa auditors)

our chains, shackles, and straps & ratchets were inspected by a competent person every 6 months. (loler competent inspection) by someone with exam from lifting equipment engineers association. in addition we had a loler register so that we could confirm each and organise testing paperwork etc for audit etc. hardest bits were when things go missing when need to gather for testing and or quarantining and taking out of service/ recording their being destroyed. 

ask your insurers who they recommend for testing - we used plant inspection services, and ccs limited.

Others are available.

normally the same people as do forklifts and similar.

remeber what it's there to do, stop/restrain a load from falling off. if you don't know it's going to do the job then you will be accused that you aren't concerned if it is capable of the task asked of it, and won't have records of it being checked. 

In addition, On the HSL website is a training course for 6th July for safe transport, incorporating loading and pedestrians etc. it is listed as costing £450.00  

thanks

  

 

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