What is PUWER Machinery Guarding?

PUWER establishes what employers must do to ensure work equipment safety in their workplace. It’s one of the UK’s most comprehensive health and safety regulations, with the PUWER definition of work equipment covering all tools, machinery, apparatus and appliances used professionally.

To comply with PUWER, all equipment used in your workplace must be:

• Suitable for its intended use
• Risk assessed
• Maintained in efficient working order
• Inspected regularly to confirm it’s safe for use
• Used only by workers given adequate information, instruction and training

The requirement to implement adequate machine guarding comes from Regulation 11 of PUWER. It states that all employers must ensure measures are implemented to:

• Prevent access to machinery’s dangerous parts
• Stop the movement of any dangerous part when a person enters a danger zone

For more general advice on complying with PUWER, see our previous guides. The Health and Safety Executive (HSE) also provide an Approved Code of Practice on PUWER compliance.

Regulation 11 refers to dangerous parts of machinery. Under the law, this means any equipment part that may foreseeably cause injury. To prevent harm, dangerous parts must be isolated from workers through the use of safeguards.

There’s no complete list of dangerous parts. It’s up to you to risk assess your work equipment to identify them and implement adequate safeguards. You should generally look out for:

• Moving parts that may hit workers
• Moving parts that may crush workers, either within the machinery itself or against a fixed surface
• Moving parts that may cause shearing
• Rollers, belts or pulleys that may draw in or trap workers
• Sharp edges that can cause lacerations
• Rough surfaces that can cause abrasions
• Parts that become dangerously hot or cold during operation
• Parts that expel steam or other hazardous substances
• Parts that may cause electrical shocks or burns

It’s important to note that any part may become dangerous due to faults or wear and tear. Regular inspections (another PUWER duty) are necessary to flag these issues and ensure they’re fixed before anyone is injured.

Machinery guarding describes the protective devices for work equipment that shield workers from its dangerous parts. The term is used interchangeably with safeguarding and covers a wide range of measures, including:

• Fixed guards
• Different control set-ups that reduce risk (such as two-hand controls)
• Sensors that detect a person or body part in a danger zone

You must use your risk assessment to determine adequate safeguards. As in general workplace risk assessments, there’s an established hierarchy of control measures. Certain safeguards are considered more effective than others. Determining the safest, most suitable guards for your machinery is up to you. This process should be straightforward for new machinery as manufacturers hold a number of equipment safety duties.

Alongside PUWER, equipment safety is legislated by the Supply of Machinery (Safety) Regulations 2008 (SMSR).

PUWER sets out duties for equipment end users, while SMSR establishes what manufacturers must do to make work equipment safe. A key duty under SMSR is to build in guards and safety devices to control unavoidable risks

If you purchase machinery that complies with SMSR, the manufacturer should have installed the necessary safeguards in line with their design risk assessment.

Design risk assessments mirror the PUWER risk assessments you must conduct as the end user. However, they do not render your risk assessments unnecessary.

You must still conduct a risk assessment after introducing equipment to your workplace. This on-site risk assessment is required to review work equipment hazards and controls in the environment in which it’s used.

There are also scenarios when you, as the end user, must complete the design risk assessment as well as the PUWER version.

If you modify machinery, you legally become the manufacturer and must fulfil their duties. These duties include conducting the design risk assessment and installing adequate machine guards.

Any machinery in your workplace that predates SMSR or comes from outside the UK will also need a design risk assessment.

Even if equipment complies with SMSR, you still have duties when it comes to PUWER machinery guarding.

First, it’s still necessary to confirm all safeguards are in place and free from defects for any new equipment.

Then, you must also conduct a risk assessment to confirm that the equipment is:

• Suitable for the intended use
• In safe condition and in a suitable location for use
• Is fitted with appropriate guards

This on-site risk assessment is always necessary. Although SMSR sets high expectations for manufacturers, equipment can be damaged during transit, delivered with missing parts or installed incorrectly.

So, conducting your own risk assessment is necessary to confirm safeguards are present and correct.

Below, we’ve explained different guard types and their advantages and limitations to help you complete your own design or on-site risk assessment.

Under PUWER, all safeguards must:

• Prevent contact with the dangerous part
• Be secure and well-constructed
• Prevent objects from falling into moving parts
• Create no new hazards (e.g. a fixed guard forcing an operator to adopt an uncomfortable work position that may cause discomfort or injury)
• Create no interference (e.g. a fixed guard obscuring the operator’s view)
• Allow for essential cleaning and maintenance

There are different levels of safeguards, ranked by the HSE from most to least effective:

1. Fixed guards
2. Other guards, including interlocked, adjustable and self-adjusting guards
3. Protection devices that shut machinery down if tripped
4. Positioning operators to use the machinery from a safer position

Selecting sufficient safeguards depends on the risk level and intended use of machinery.

Safeguards must also be balanced between practicality and effectiveness. Safety is always the priority but guards can’t make work unreasonable. Staff will likely find risky workarounds for safeguards that get in their way.

It’s up to you to consider these factors during the risk assessment process.

We’ve gone through the general advantages and disadvantages of these safeguards to help you determine which are most suitable for your equipment and workplace.

Fixed guards are permanent barriers to a machine’s dangerous parts. They provide the maximum protection and should be the first safeguard considered.

Despite the name, they’re also flexible, in the sense they can be built and designed for various types of machinery.

The main drawback is they require removal before cleaning or maintenance, which can complicate procedures. They also have the potential to interfere with visibility during operation.

Interlocked guards use tripping mechanisms to automatically shut off or disengage a machine when opened or removed during operation. To add to this protection, a machine cannot be restarted until any interlocked guards are reset.

Interlocked guards are something of a compromise compared to fixed guards. They offer less (but still decent) protection while allowing greater access to the machinery for repair or cleaning.

Because interlocked guards are more complicated, they require careful adjustment and maintenance. They’re also not as foolproof as their fixed counterparts. Equipment users can usually circumvent interlocked guards if they find them impractical.

Adjustable guards provide a moveable barrier to dangerous parts based on the task or size of stock entering machinery.

They can be made specifically for different applications. The equipment user can also make adjustments depending on the task at hand.

Giving equipment users control over the guard also has disadvantages. Workers may adjust the guard incorrectly or misuse it. And, even when used effectively, adjustable guards offer less protection than fixed or interlocked alternatives.

Self-adjusting guards are similar to adjustable guards but require no user input.

They adjust automatically depending on the size of stock entering the machine. This reduces the risk of user error.

Despite this advantage, self-adjusting guards only offer limited protection. They also often require more frequent maintenance.

In addition to machinery guards, you may find other protection devices are necessary.

Presence-sensing devices shut machinery down if a person enters a danger zone. They allow freer operator movement and offer protection to anyone around the machine.

These devices are also simple to use, requiring zero input from the operator.

However, presence-sensing devices cannot protect against mechanical failure and are only suitable for machines that can actually be stopped.

Safety tripwires work much the same way as presence-sensing devices but they form a physical boundary around dangerous areas. If a worker passes this boundary, machinery shuts down.

These measures only protect the worker who trips the wire. They also require manual activation.

You may also be able to further reduce risk by changing how an operator uses the machinery. There are usually three methods for this:

• Moving controls away from the dangerous parts so workers can operate the machinery in a safe position
• Designing controls so operators must always use two hands. This method reduces the risk of workers reaching into dangerous areas
• Providing holding tools such as jigs or push sticks so workers can maintain a safe distance from dangerous parts

Failure to comply with PUWER can lead to significant consequences. The regulations ensure that work equipment is suitable for its intended use, properly maintained and regularly inspected. Non-compliance not only poses serious risks to employee safety but also subjects your organisation to legal penalties.

Businesses found in breach of PUWER may face hefty fines and criminal prosecution in severe cases. Serious breaches can also result in duty holders or employers being held personally liable, leading to further legal repercussions.

This guide has covered just one aspect of PUWER work equipment safety. Full compliance involves a holistic approach, encompassing regular inspections, diligent maintenance and thorough risk assessments to ensure all work equipment is safe and fit for purpose.

Managing these aspects can be complex and requires a deep understanding of the regulations. That’s why we offer a PUWER Compliance Management course. This course is designed to equip you with the knowledge and skills needed to manage all PUWER duties.

It covers everything duty holders need to know, from conducting detailed risk assessments to overseeing inspections and maintenance.