Hi HoweD
I don't have any strong thoughts as to whether LOLER would apply but it would be necessary to get a better understanding of what each component is there for.
However, if you don't deal with it as being subject to LOLER what are you going to do to comply with the maintenance etc requirements of PUWER?
Which to me translates as evaluating the risk and deciding how to mitigate that. So, what could you reasonably envisage being the outcome should these components fail? Could you reasaonably expect that a heavy weight will come crashing down and, if so, is someone relatively liable to be harmed - WITHOUT taking the "worst case scenario". [The comet COULD fall out of the sky but it's unlikely in most scenarios that there will be anyone in the way!]
Many years ago I investigated the accident when a rope failed and a large component (+ part of the rope) fell about 30m from the top of a piling rig. At the time LOLER didn't exist and the predecessor legislation gave me not doubt that the piling rig was "lifting apparatus". There would be and were people working in an area below and one of them got struck on the helmet (which probably saved his life).
In your secnario, perhaps it MAY be that if there is a failure there is something that stops the assembly or part of it from crashing down. MAY be it's not realistic to expect that a person might be in the drop zone below. MAY be other parameters apply.
Lots of MAY bes but when it comes to the crunch in a Court as soon as anything comes down to working out what is or is not reasonably practicable the onus lies on the duty holder to prove that they have done all that is reasonably practicable on the balance of probabilities.
I am not sure that L113 helps you that much.
In the Approved Code of Practice part so quasi legislation it says (in bold to remind us that this is ACOP rather than just guidance):
30 A three-point linkage on a tractor is not considered to be lifting equipment.
If you can persuade a Court that your assembly is comparable to a three-point linkage, then NOT lifting equipment but STILL subject to PUWER.
In the guidance in L113, the text continues:
32 Other examples of equipment and operations not covered by LOLER include:
(a) a conveyor belt;
(b) winching a load where the load does not leave the ground;
(c) roller shutter doors;
(d) tipper trucks;
(e) eyebolts permanently fixed in the load (these form part of the load);
(f) dentist chairs; and
(g) fall arrest equipment, including eyebolts fastened to a structure to secure such fall arrest equipment, which are considered part of the fabric of the building.
Is your assembly comparable to any of these examples?
Even if it is, does it actually matter? - when the guidance in L113 continues:
33 However, a similar level of safety is required by PUWER in respect of the work equipment being used.....