The MHE is there to serve a purpose not become the subject of an administrative burden.

Your checks are an opportunity to identify potential issues prior to a days use.

It is not an effective use of employee time if every single user repeats the same task several times during a shift.

I also agree.

By that logic you would have to argue that if the same operator returned to the equipment, and no one else had used it in the interim, they should conduct a further check?

Forklifts are often used intermittently (not continuously).

I am trying to imagine explaining to forklift drivers that they have to do the daily checks every time they get on the truck during the day.

In my imaginings, it doesn't end nicely.

What's more, my sympathy is entirely with the operators.

My primary difficulty in this scenario is that I am unable to answer the question "Why??"

Edited by user 23 September 2022 19:10:27(UTC)  | Reason: can we have a spillchuck?

I work for a large international organisation who have multiple sites, many fork lifts, a fleet management team, a large H&S team, RTITB trained drivers (by several national providers).

Our pre-printed inspection log lists three shifts in a day, seven days on one page for one week of records.

Can't wait to announce they have all been getting it wrong for decades OR we could actually look at the specific regulated requirement rather than a hearsay interpretation.

Originally Posted by: Azza

a pre-use inspection must take place before the next operator

Must is an absolute legal obligation - quite interested to find out where in legislation this must appears 

Roundtuit - ME TOO!!

Azza.....

OK, so the RTITB guidance includes this comment:

"HOW OFTEN SHOULD A PRE-USE INSPECTION TAKE PLACE?

A pre-use inspection should be completed by the operator prior to any forklift operation; this could be either at the start of their shift or prior to a period of continuous use. Even if a forklift was already checked by another operator earlier that day, a pre-use inspection must take place before the next operator begins to use the truck." (My bold italics)

But the RTITB guidance does not attempt to explain what law might require this.

There are very few bits of UK health and safety legislation these days that say “you MUST do this” or “you MUST NOT do this”.

Whatever would be so explicitly prescriptive would be contained either in LOLER or PUWER on, in each case, in the Approved Code of Practice which supports the legislation, in effect quasi Regulations as you either have to do what it says in the ACOP or be able to do something equally effective to comply with the relevant legislation.

L113 the ACOP which supports LOLER is silent on pre-use inspections – it does say quite a lot about statutory examinations of forklift trucks.

In the guidance (NOT afforded ACOP status) supporting Reg 8 of LOLER which covers the planning and supervision of lifting operations L113 comments

“288 You should ensure that people who use lifting equipment have received appropriate training, information and instruction so that they can carry out pre-use checks on the lifting equipment. The user or operator is best placed to identify faults or damage to equipment. These pre-use checks are not the same as maintenance or thorough examination, but where defects are found they should be reported to the maintenance team so they can maintain a full record of identified faults for each piece of equipment.

289 The purpose of these pre-use checks is to identify faulty equipment. The operator of the equipment should act as the first line of defence in identifying any faults or damage. Such checks should be carried out before the lifting equipment is used during each working day or at the beginning of each shift. The aim of such checks is to pick up faults due to day-to-day wear and tear and malfunction of safety-related equipment. If any defects are found the operator should report and record the defect and not use the equipment unless authorised to do so or, if competent to do so, take appropriate action to record the fault and rectify it” (My bold italics)

So, no suggestion by HSE here that an FLT would need more than one pre-use check PER SHIFT.

In the ACOP that supports Regulation 6 of PUWER, L22 there is guidance in paragraph 100 (ACOP) and paragraph 101 (“Guidance” NOT afforded ACOP status) on the frequency of inspections:

Frequency of inspection

100 The frequency of inspections should be based on how quickly the work equipment or parts of it are likely to deteriorate and so give rise to a significant risk. This should take into account the type of equipment, how it is used and the conditions to which it is exposed.

101 The inspection frequency may be different for the same type of equipment because the rate of deterioration can vary in different situations. Where equipment is subject to frequent use in a harsh outdoor environment (for example at a coastal site or on a construction site), it is likely to need more frequent inspection than if it is used occasionally in an indoor environment such as a warehouse.

So, absolutely nothing set in stone here.

Regulation 6 of PUWER is fairly typical of modern UK H&S legislation that is based on a goal-setting approach:

Regulation 6 Inspection

(1) Every employer shall ensure that, where the safety of work equipment depends on the installation conditions, it is inspected—

       (a) after installation and before being put into service for the first time; or

       (b) after assembly at a new site or in a new location, to ensure that it has been installed correctly and is                   safe to operate.

(2) Every employer shall ensure that work equipment exposed to conditions causing deterioration which is liable to result in dangerous situations is inspected—

      (a) at suitable intervals; and

      (b) each time that exceptional circumstances which are liable to jeopardise the safety of the work                           equipment have occurred, to ensure that health and safety conditions are maintained and that any                     deterioration can be detected and remedied in good time [……CONTINUES……]

Now of course it can be convenient for some to translate goal-setting requirements into easy to understand DOs and DON’Ts and it may be tempting to dictate a conservative approach if in doubt, particularly if e.g. a health and safety consultant wants to consider numerous “What If?”s, in this case including “What if the operator at the start of the shift didn’t actually do the pre-start inspection, but just ticked the box on the inspection form to say that they had done it?”

However this is likely to result in lots of so-called “blue tape”, wherein duty holders are asked to do more than that which is appropriate. Doing a proper pre-use check on an FLT takes time. Is it really necessary to do this each and every time a FLT is handed over from one operator to another or is the tried and tested process of doing this at the beginning of each shift or the first use of the fork truck during a shift sufficient?

Perhaps time to go back to the advisers and ask what the legal basis for their specifications is?

Hopefully someone from RTITB will be along to clarify their position as to why they appear to be taking a higher stance than legally required.

Sorry mate I know you are in a hurry but go have a coffee, I can’t offload your truck until I have carried out an inspection ( don’t worry there will be no problem as I know someone else did it less than an hour ago).

One of the problems with organisations over egging what is required in all industries, breads distrust in people who are supposed to be experts.

Chris