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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 As a term it is out of date.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 |