If Your Machines Could Talk, They'd Probably Ask for a Risk Assessment

If you employ people who use equipment to do their jobs — and that's virtually every employer in the country — then PUWER applies to you. The Provision and Use of Work Equipment Regulations 1998 might sound like something written by committee (because it was), but the principle behind it is straightforward: work equipment must be safe, and employers must make sure it stays that way.

The tricky part is that "work equipment" doesn't just mean the big, obvious machinery. It means everything.

What Counts as Work Equipment Under PUWER?

This is where PUWER catches people off guard. When you hear "work equipment," you probably picture a lathe, a press brake or a forklift. And those certainly count. But PUWER's definition is considerably broader than that.

Work equipment includes any machinery, appliance, apparatus, tool or installation used at work. That means CNC machines and hand drills. Conveyor belts and office shredders. Circular saws and the company microwave. If it's used by employees as part of their work, it's covered.

Second-hand equipment? Covered. Hired equipment? Covered. Equipment provided by someone else on a shared site? Still your responsibility if your employees are using it.

The HSE isn't interested in whether you bought the equipment new from a dealer or found it on Marketplace. Once it's in your workplace and your employees are using it, PUWER applies.

What PUWER Actually Requires

PUWER places several duties on employers. These aren't suggestions — they're legal requirements:

Suitability — Equipment must be suitable for its intended purpose and the conditions in which it's used. A domestic drill used in an industrial setting might not cut it (pun intended).

Maintenance — Equipment must be maintained in an efficient state, in efficient working order and in good repair. Where maintenance logs are required, they must be kept up to date.

Inspection — Where the safety of equipment depends on the conditions in which it's installed or used, it must be inspected at suitable intervals and after exceptional circumstances.

Information and instructions — Anyone using, supervising or managing work equipment must have adequate health and safety information and, where appropriate, written instructions.

Training — Employees must receive adequate training for the purposes of health and safety, including the methods of use, risks and precautions.

Guarding — Dangerous parts of machinery must be guarded. This is probably the most commonly breached requirement and the one that leads to the most serious injuries.

Controls — Equipment must have appropriate controls for starting, stopping and emergency stop functions.

The Guarding Problem

Let's talk about guards for a moment, because this is where most injuries happen. PUWER sets out a clear hierarchy for guarding dangerous parts of machinery:

First preference: fixed guards — permanently attached, requiring tools to remove. Second: interlocking guards — if the guard is opened, the machine stops. Third: adjustable guards — where fixed or interlocking guards aren't practical. Fourth: information, instruction, training and supervision — only where physical guarding isn't possible.

The reality in many workshops is that guards get removed because they "slow things down" or "get in the way." Some machines arrive from the second-hand market with guards missing entirely. This is a serious breach and one of the most common causes of serious workplace injuries in the UK.

If a machine has a dangerous part that's exposed, it needs guarding. Full stop.

The Common Mistakes

After conducting hundreds of PUWER assessments across different industries, these are the issues that come up again and again:

No risk assessments — The equipment is in use, people are operating it daily, but nobody has ever sat down and assessed the specific risks. Not for the equipment itself, not for the process, not for the people using it.

Missing or removed guards — Either the guards were never there, or they've been taken off for "convenience" and never put back.

No training records — Employees use equipment they've never been formally trained on. They learned by watching a colleague. There's no documentation.

Maintenance by memory — Equipment gets maintained when someone remembers, or when it breaks down. There's no planned preventive maintenance schedule and no records.

Hired equipment not assessed — A machine arrives on hire, it gets plugged in, and people start using it. Nobody checks whether it's suitable, whether guards are in place, or whether operators need training on that specific model.

What a PUWER Assessment Looks Like

A PUWER risk assessment examines every piece of work equipment in your operation. The assessor identifies each item, evaluates its condition, checks that guarding is in place and effective, reviews maintenance arrangements and records, and assesses whether operators have received adequate training.

The output is a practical report that tells you what's compliant, what needs attention, and what needs urgent action. It's not about passing or failing — it's about giving you a clear picture of where you stand and what needs to happen next.

Who Needs a PUWER Assessment?

Any employer whose workers use equipment. But some sectors are higher risk than others: manufacturing, engineering, construction, food production, agriculture, logistics and vehicle repair all tend to have more complex equipment profiles and higher-risk processes.

If your employees operate anything more complex than a stapler, a PUWER assessment is worth having. And legally, it's not optional.

Ready to get your equipment assessed? Book a PUWER Assessment →

York Green Safety Partners provides expert PUWER risk assessments for employers across the UK. Based in Cheshire, covering the whole country.