Details really do matter09 June 2023

Dominic Dawson, chief engineer, Zurich Engineering

Dominic Dawson, chief engineer, Zurich Engineering, the new chair of SOE subsidiary BES, discusses the safety and compliance issues raised in last month‘s article ‘Details Matter’

I would like to fully endorse the important message regarding the importance of inspecting all elements of a fork lift truck, and not limiting this to the lifting function. However, the article – while not wholly inaccurate – uses misleading language, suggesting that unless the duty holder/owner employs a CFTS-approved supplier it will not get a thorough examination of a forklift truck, as only LOLER is considered. In fact, the LOLER ACOP does consider these elements. Section 340 states: “Some parts of the equipment may need inspection to meet the requirements of PUWER for example a forklift truck must be thoroughly examined under LOLER and must be inspected under PUWER. Where the person doing the work is a competent person under both sets of Regulations, these examinations and inspections can be conducted together.”

Another important point to consider, which is not mentioned in the article, is the importance of competence, independence and impartiality. Some key points for owners and duty holders are picked out from the ACOP below.

Section 296 says: “You should ensure that the person carrying out a thorough examination has such appropriate practical and theoretical knowledge and experience of the lifting equipment to be thoroughly examined as will enable them to detect defects or weaknesses and to assess their importance in relation to the safety and continued use of the lifting equipment.”

Section 298 says: “It is the employer’s duty to ensure that they employ a suitably qualified competent person to carry out the thorough examination. LOLER does not expressly preclude the person carrying out the maintenance from also conducting the thorough examination. However, the competent person who carries out the thorough examination should not normally be the same person who performs routine maintenance operations on the equipment except where the risk of injury to others is low. This is to ensure that there is independence between the thorough examination and the maintenance and to avoid an individual examining their own work.”

Section 299 says: “Where the thorough examination is undertaken by the same person who has maintained the equipment, your risk assessment should show you have considered all the options, how you reached your decision about who should carry out these functions, and also show that the person is suitably qualified and independent to the extent that would be required for another competent person. In these circumstances any maintenance should be carried out after the thorough examination has been undertaken.”

The Safety Assessment Federation (SAFed), the main trade association for inspection bodies in the UK, also provides guidance to members on the inspection and examination of fork lift trucks, which, in line with the LOLER ACOP, also includes the non LOLER elements. All SAFed full members are required to have accreditation through UKAS to ISO 17020 requirements. Among other things, this demonstrates competence, independence and impartiality.

There are also a growing number of independent inspection companies; many are members of the Independent National Inspection and Testing Association (INITA) which also demands demonstration of the above qualities, which are so important to delivering a credible inspection service. SAFed and INITA, along with the main inspection bodies in the UK, are corporate partners of the SOE, and represented within its professional sector group Bureau of Engineer Surveyors (BES).

Therefore, when selecting a provider for inspection tasks, it is important to look further than just the comprehensiveness of the physical examination and inspection, but how is competence, independence and impartiality demonstrated by the inspection body – especially if that body also completes the maintenance.

Dominic Dawson

Related Companies
Zurich Engineering

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