The Pressure Systems Safety Regulations 2000 (PSSR) and the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) require certain items of equipment to be subject to thorough examination and testing (TE&T) at prescribed frequencies.
With the outbreak of Covid-19, there has been concern that a shortage of engineers and the closure of many premises may result in a failure to ensure all equipment is examined within the statutory time limits.
The HSE has recently released a statement which can be viewed here.
The main points are:
- The law for LOLER and PSSR remain in place
- The overarching legal obligation remains, i.e. ensure that equipment is safe to use
- For businesses that are currently closed (i.e. they have either elected or been required to do so to meet Covid-19 related Government advice or restrictions), you should still give access to visiting inspectors to undertake TE&T
- If you experience problems in undertaking scheduled thorough examinations as you can’t access inspection services, you should adopt a risk-based process to determine whether there are steps you can take to safely continue to use equipment (that has not had its scheduled TE&T) or decide to stop using the equipment
- Equipment should only be used outside of its test regime if you can demonstrate that it is critical for essential work and that it can still be operated safely
- You must be able to demonstrate that you have made all reasonable attempts to have the TE&T carried out, made a thorough assessment of the increased risk, and taken appropriate action to manage it
- Inspectors have been instructed to focus their resource/expertise on equipment in premises where the most vulnerable are located such as hospitals, care homes and infrastructure which is essential to the running of the country
- Companies and inspectors must cooperate to ensure compliance with Public Health England advice regarding good hygiene practices and separation distances.
Due to this potential shortage of inspectors and engineers during and after lockdown, it is recommended that companies are proactive.
You should make yourself fully aware of what TE&T fall due in the next 3-4 months and start planning works with your engineering inspection companies. It may be better to try and have equipment inspected prior to its renewal date rather than risk no inspection at all and the equipment being put out of operation.
Contractors’ safety on site
To help protect inspectors and other contractors who are required to come to site, companies should consider the following guidance:
- Ensure arrival times have been agreed with the engineer. Do they know where to report to and who they are meeting?
- Ensure the engineer is aware of all new site rules before they attend the site. What segregation measures have been introduced? Do you have new PPE requirements? Are there now areas that the contractor will not be permitted to enter (i.e. canteens)?
- Ensure the engineer has the relevant PPE and cleaning materials with them before allowing them to start work
- Ensure the site induction is recorded in some way
- Ensure your staff are made aware of the presence of a contractor on site
- Where possible, limit the area the contractor can work in, or segregate them from your workforce
- Where possible, clean the work area and equipment before and after the engineer has undertaken work
Remember, inspectors will be instructed by their employers to carry out a dynamic risk assessment when they reach your premises. If they feel that you have not undertaken sufficient measures to protect their health, they may refuse to carry out the work.
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