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Although the
Thorough Examination of lifting equipment, which includes fork
lift trucks, has been a requirement since 1998, there are still
some areas of confusion and misunderstanding.
This applies to all
fork lift trucks and pallet trucks but also to other types of
lifting equipment.
Any person who is
responsible for the safe and legal use of fork lift trucks
should have a sound understanding of the following information.
including....
-
the employers
managers of fork lift truck operators,
owners of fork lift trucks
maintenance engineers of fork lift trucks
drivers.
A Thorough
Examination
is a statutory
requirement for lifting equipment under the Lifting Operations
and Lifting Equipment Regulations 1998 (LOLER 98), Regulation 9.
It has the same purpose as an MOT inspection by providing a
report which identifies that the lifting equipment is safe to
use, and/or advice that needs to be followed to avoid risks in
use. It is just as important as an MOT
—
probably more so! There is a legal requirement for a Thorough
Examination to be carried out on fork lift trucks at least once
a year, and often more frequently depending on conditions of
use.
There are legal
requirements under the Provision and Use of Work Equipment
Regulations 1998 (PUWER 98), Regulation 6. They require all
safety aspects of the truck to be inspected, and actions
specified to remedy any defects found before they can create
risks in use. To avoid duplication of effort the inspection of
these other items would normally be carried out within the
Thorough Examination
A Chain Inspection
is the name often
used for inspections under old legislation. As a term it is out
of date. A Thorough Examination includes the inspection of
chains and forks, but much more besides
A LOLER
Inspection is sometimes used, incorrectly, to describe a
Thorough
Examination. It is used because LOLER is the shortened version
of “Lifting
Operations and Lifting Equipment Regulations 1998”. These
regulations, and the associated Approved Code of Practice,
prescribe the format to be used for the
Report of a Thorough Examination. It is safest to stick to the
term Thorough
Examination
A Safety Inspection
is
a term sometimes used to describe Thorough Examination under
LOLER 98 and other inspection requirements under PUWER 98. To
avoid confusion the FLTA embraces both requirements within the
term Thorough Examination.
A Thorough
Examination
is the inspection of
lifting equipment, as required by LOLER
98, and other safety related components or equipment, as
required by PUWER 98. A
Competent Person is required to examine these items, check them
for serviceability
and report accordingly. It is not a full maintenance inspection
of the truck. A Thorough Examination is substantially different
from a maintenance inspection and the Competent Person has
different duties to fulfil under the law.
Although A Thorough
Examination can cover both regulations, it is a single
examination.
|
LOLER 98 |
|
PUWER98 |
Chains
Forks
Mast
Carriage
Tilt Mechanism |
Breaks
Steering
Seat Restraint
Overhead Guard
Tyres |
| |
Through
Examination
This
is a legal requirement |
|
The employers
responsibility.
Under Health and
Safety legislation the employer has a duty of care
—
“It shall be the duty of
every
employer to ensure, as far as is reasonably practical, the
health, safety and we/fare at work of a/I his employees”.
The employer must ensure that the fork lift trucks that
his/her operators use are safe. This is achieved through the
implementation of a programme of Thorough
Examinations. (Remembering that Thorough Examinations run
alongside necessary maintenance procedures and checks. But not
in place of them.)
The
employer is the owner of the fork lift truck. His
duty is clear. The employer must make arrangements
for every fork lift truck to be Thoroughly
Examined on a regular basis, at least once per year. (The
actual frequency to be determined by a Competent Person.)
The
employer who is not the owner of the fork lift truck
but leases it, or rents it on a long term basis, usually 12
months or more, the responsibility is the same as though the
trucks were his own.
The employer who is
on short term lease or contract
of a fork lift truck
of say less than 12 months, then the owner of the truck, the
rental company, is responsible for arranging the
Thorough Examination.
However, the employer
must still satisfy himself that such an examination has been
conducted at an appropriate time. This can be achieved by
insisting that a copy of the current
Report of Thorough
Examination is
provided with other rental documentation. If there is not one
supplied then demand to see it before you let your employees use
the truck.
A Competent Person
for the purpose of
Thorough Examination is an
experienced service engineer or examiner who meets the general
criteria as explained in LOLER 98
•
An authorised fork lift truck service engineer.
• An insurance company lifting
equipment examiner.
• An examiner from a specialist
inspection company.
A Competent Persons
training
should fall into one
of the following categories bearing in mind that you probably
cannot carry out your own MOT inspections.
The important
considerations are....
•
An already competent person, must authorise the
engineer as a Competent Person
for the purpose of conducting Thorough
Examinations.
•
The engineer must have an appropriate level of
experience and training. A recommendation of a minimum of 5
years’ experience as a fork lift truck service engineer and
successful completion of a Thorough
Examination course may be reasonable. Along with
a revalidation every 5 years.
• A Competent Person validating for
his own company needs to be independent from the routine
maintenance of the lift trucks. This means that there needs
to be a number of suitably qualified engineers, and a
management system to properly
control them.
A
Thorough Examination on a periodic
basis. BITA GN28 recommendations on intervals for
periodic Thorough Examination which
are......
|
Minimum Intervals Between
Examinations |
Operating
Circumstances |
| 12
months |
Any truck
working up to 40 hours
per week, without attachments other
than side shift. (mandatory) |
6 Months |
Any truck used for lifting persons,
no matter how infrequent (mandatory) |
6 Months |
Any truck fitted with an attachment
other than a side shift. |
6 Months |
Any truck working between 40 and 80
hours per week. |
| 4
Months |
Any truck
working in excess of 80 hours
per week. |
| 4
Months |
Any truck working in arduous
conditions
Such as....
Marine
environments
Corrosive chemical environment
Metal manufacturing or processing
Cement/aggregate processing, or
abrasive partials are present
Brine Processing |
| Extracted
from BITA note GN28 |
|
These guidelines
have been issued to HSE Inspectors. There is also a requirement
to have a Thorough Examination if
the fork lift truck has been involved in a major incident or if
it has had significant repairs or renovation.
Seat
restraints may not always be required. For example
reach trucks and trucks with stand-on operators do not need to
have a seat belt fitted. Additionally in certain circumstances
older counterbalance trucks may still be used without a seat
belt, but such use should be backed up with a written risk
assessment. For further information see the HSE Information
Sheet MISC 241
If the Thorough
Examination fails
then the Competent Person will make
a report. On the report he/she will list any defects they have
found. If there are no defects then the fork lift truck can
continue in use. With defects that do not create imminent risk.
A timescale may be given within which the faults must be
rectified. It must within this period, but meanwhile the
equipment may continue in use. The equipment may also be taken
out of use until the faults have been rectified. The
Competent Person will then check
that the defects have been rectified within the given period.
Where there is a defect that could imminently be of danger to
persons, the Competent Person is
bound to recommend that the equipment cannot be used until the
fault has been rectified. In these circumstances the equipment
must be taken out of use immediately. It may not be used again
until the defect has been rectified and signed off by a
Competent Person.
The Competent person
reports
that the lift truck truck is fit for use.
However, he/she does have a duty to send a
copy of there report to the relevant enforcing authority in
certain situations. This applies where there is, in there
opinion, a defect in the equipment involving an existing or
imminent risk of serious personal injury. This requirement is
limited to those cases where there would be a risk of
serious personal injury arising
from failure of the equipment should anyone attempt to use it
further to the time of the examination. Examples would be a
broken link in a chain or a cracked
brake pipe.
The need for a
formal MOT
inspection does not apply to a fork lift truck, but it must have
a Thorough Examination instead.
This is a specific legal requirement and must be completed as
such. It may be that faults are found that the
Competent Person can fix, if they
are also a service engineer, before they leave your site. That’s
fine. That’s one of the benefits of using a
Competent Person from a fork lift
truck company. However, it should be remembered that the
Competent Person is legally obliged
to comment on safety related faults in the
Report of Thorough Examination. That way a true record of
the equipment is being kept. That’s in everyone’s best
interests, especially the employer.
The
Thorough Examination is an additional item
on your maintenance
contracts. It is a separate safety inspection. You may have a
contract that includes it, but it should be stated separately.
additional item.
The company's
competent person
can carry out a
Thorough Examination as you already
have cranes and hydraulic jacks and other lifting equipment.
Additionally deciding to maintain your fork lift trucks with a
fork lift truck company, but have all your lifting equipment
Thoroughly Examined by a specialist
inspection company
A fork lift truck
company has your maintenance agreement
then they will no doubt arrange and invoice the
Thorough Examination separately.
You should expect it to be carried out by a
different engineer to the
one who usually services and/or repairs the truck. This other
engineer may also be able to carry out the next due service, but
he will treat the Thorough Examination and the service as two
different events. This is because he is required to carry out,
and report on the Thorough Examination as a specific safety
inspection, just like an MOT
The
Thorough Examination is a specific legal requirement
and must be completed as such. It may be that faults are found
that the Competent Person can fix,
if they are also a service
engineer, before they leave your
site. That’s fine. That’s one of the benefits of using a
Competent Person from a fork lift
truck company. However, it should
be remembered that the
Competent Person is legally obliged
to comment on safety related faults in the
Report of Thorough Examination. That way a true record of
the equipment is being kept. That’s in everyone’s best
interests, especially the employer.
Infrequent use of a
fork lift
has the same requirements for Thorough Examination as any other
fork lift No exceptions.
The use of hand
pallets.
There is an argument that more accidents are caused by
hand-pallet trucks than by any other types of lifting equipment.
Hand pallet trucks come under LOLER 98 but the risks associated
with their use are relatively low compared to ride-on trucks.
With this in mind, they are not required to have formal safety
inspections. However, owners must be able to demonstrate that
they have procedures in place that check they are safe to use.
Routine maintenance inspections would need to be carried out.
The safe recommendation is that they are
Thoroughly Examined. It will not be a long or complex
task. Consider having them examined at the same time as other
equipment.
Further
information....
These
publications can be purchased from HSE Book (Tel: 01787
881165)
• Safe Use of
Work Equipment
Provision and Use of Work Equipment Regulations 1998
(PUWER 98)
Approved Code of Practice And Guidance
HSE Code L22
ISBN Code 0-7176-1626-6
•
Safe Use of Lifting Equipment
Lifting Operations and Lifting Equipment Regulations 1998
(LOLER 98)
Approved Code of Practice and Guidance
HSE Code L113
ISBN Code 0-7176-1828-2
This publication
can be purchased from British Industrial Truck Association (BITA)
(Tel: 01344 623800).
• Safety Inspections Of Industrial
Lift Trucks
GN28
This publication
can be purchased from Fork Lift Truck Association (FLTA)
(Tel: 01256 381441)
•
Technical Bulletin 05
No
Responsibility accepted for the accuracy of this article |