Comment: ‘I am independent’02 November 2023

LOLER ACOP Reg 9 maintenance inspection

How independent must inspectors be? LOLER ACOP Reg 9, paragraph 295, states: “it is essential that the competent person is sufficiently independent and impartial to allow objective decisions to be made.” Does that mean they cannot be an employee of the same company that carries out the maintenance? Not necessarily, it goes on to add.

But this is a difficult balance to strike in practice. If the maintainer, for example, is the same person doing the inspection, my fear is that urgent defects are unlikely to be reported for fear of reflecting a poor level of maintenance. Reporting is important because a thorough examination not only helps to ensure that equipment is safe, but when viewed over time also indicates how effective is the level of maintenance. If issues are repaired and not reported, the inefficiency of the maintenance programme is masked.

In my view, the maintainer and inspector should be different people. There has got to be a gap; they must be independent and impartial. However, they should maintain a relationship. Neither should be afraid to challenge each other, so long as it is done in a professional and respectful manner.

Managing this relationship is down to the equipment owner. The owner needs someone coordinating and making sense of the issues. Otherwise, inspection reports go in one drawer, and maintenance reports go in another. Facilities managers often act as the crucial go-between.

How to demonstrate sufficient separation of inspection and repair? The obvious route is via accreditation to ISO 17020 for inspection bodies. The categorisation of inspection bodies as type A, B or C under this standard is essentially a measure of their independence.

One of the best ways for an individual to demonstrate their own competence is through professional registration rather than purely by qualification. SAFed document SS01 suggests a category 2 engineer surveyor should be working at IEng level.

Dominic Dawson, chair, Bureau of Engineering Surveyors

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