Partner with an independent inspection body to cover your clients’ statutory obligations. One point of contact across all four regimes, with verified written reports and nationwide, multi-site cover for every plant type.
Independent advice on compliance, written schemes of examination and inspection strategy, from competent engineer surveyors with no equipment to sell you.
Plain answers from independent engineer surveyors who write these reports every week.
PUWER produces a record of inspection, not a certificate, and the difference is the whole document. Regulation 6 requires the result of every inspection to be recorded; what a good record contains, how long it lives, and how it should drive your inspection intervals is this guide's territory.
The statutory output of Regulation 6, never a certificate
No fixed form
The law prescribes the duty to record, not the layout
Until superseded
Keep each record at least until the next one exists
The exception
Power presses carry their own statutory reports
Reading your record
Check the record identifies the equipment, the date and the inspector
Read the findings with their grades and the reasoning behind each
Confirm every action has an owner, a date and closure evidence
Use the run of records to judge whether the interval is still right
Findings and what they mean
What the record must show, and what a good one adds
Regulation 6 requires inspection where safety depends on installation conditions or where deterioration can lead to danger, and requires the result to be recorded. It stops there: no schedule of contents, no prescribed form, no statutory signature block. The legal minimum is a record of the result that can be produced when asked.
A defensible record goes further, and the pattern is consistent across well run estates: identification of the equipment, the date, who inspected and their competence for that class of equipment, what the inspection covered, each finding with the grade given and a sentence of reasoning, the action required with its owner and date, and the closure evidence when the work is done. None of that is prescribed; all of it is what an inspector, an insurer or a court reads the record for.
Finding
Severity
What you must do
Who is told
Equipment, date and inspector
The identity block
Check the record could only describe this item and this visit
The minimum any record needs to be evidence
Findings with grades and reasoning
The judgement block
Read the reasoning line, it shows grading was a decision
Where thin records fail scrutiny
Actions, owners, dates and closure
The action block
Chase every open item; an unclosed action is a live finding
What HSE reads after any incident
The run of records over time
The trend
Shorten intervals after serious finds, relax after clean runs
Regulation 6 intervals are risk based
Where the equipment also lifts, the lifting function produces a separate Report of Thorough Examination under LOLER with its own Schedule 1 contents; the PUWER record covers the rest of the machine and the inspections between.
Getting back to work
The record as a working document
The record only earns its keep if it does two jobs beyond existing: proving compliance and steering the regime.
Why there is no certificate, and why that is fine
Anyone offering a PUWER certificate is selling a layout, not a legal status: the regulations recognise a record of inspection, and no certificate framing changes what the document is. That is not a weakness. A certificate implies a pass; a record captures a judgement, its reasoning and its follow through, which is far stronger evidence that equipment is actually managed.
Judge any inspection paperwork by whether it would satisfy the question an investigator actually asks: what did you know about this machine, when, and what did you do about it.
Let the records set the intervals
Because Regulation 6 intervals are risk based, the run of records is the evidence that your intervals are honest. A serious finding says the interval was too long: shorten it and note why in the next record. A long clean run supports the interval you have, or a considered extension.
This loop only works if records are kept together per machine and actually read. A record per visit filed and forgotten proves inspections happened; a series read as a trend proves the equipment is managed, and the second is what the regulation was written to achieve.
Part 1 of 9
What Regulation 6 actually requires, and when inspection bites
PUWER Regulation 6 does not put every machine on an inspection cycle. It requires inspection in two situations: where the safety of work equipment depends on the installation conditions, inspection after installation and before first use, and after assembly at a new site or location; and where work equipment is exposed to conditions causing deterioration liable to result in dangerous situations, inspection at suitable intervals, and after every exceptional circumstance liable to jeopardise its safety.
Both limbs end the same way: the result of the inspection is recorded, and the record can be produced. The extent of the inspection is proportionate to the risk, which is the regulation's quiet strength and the reason there is no prescribed form. A visual check of a bench grinder and a strip inspection of a guillotine clutch are both Regulation 6 inspections done properly, provided each is the right depth for the danger, done by someone competent, and recorded.
The line worth drawing on your own estate is between maintenance under Regulation 5 and inspection under Regulation 6. Maintenance keeps the equipment in efficient working order; the inspection is the deliberate check that safety related parts are in place and functioning. One engineer can do both on one visit, but the record must show the inspection happened as its own exercise, because after an incident that distinction is exactly what an investigator tests.
Key pointPUWER inspection bites where a safety component can deteriorate or fail; the duty is risk based, and only power presses carry a fixed statutory cycle.
Part 2 of 9
Anatomy of a defensible record
Because the law prescribes no layout, the standard is set by what the record must survive: an HSE inspector after an incident, an insurer's engineer, or a court. Across well run estates the same eight blocks appear, and a record carrying all eight has nothing to fear.
The eight blocks of a defensible inspection record, in the order an investigator reads them.
1
Identity. The equipment, uniquely: asset number, serial, location. A record that could describe two machines protects neither.
2
The visit. Date of inspection, and the trigger: routine interval, post installation, or after an exceptional circumstance such as a collision, a modification or a return from long storage.
3
Scope. What the inspection covered, and its depth: visual, functional, strip down, measurement. Scope is what makes a clean result meaningful.
4
Findings, graded, with reasons. Each finding carries the grade given and a sentence of reasoning. The reasoning line is what shows grading was a judgement rather than a habit.
5
Actions. What must happen for each finding, who owns it, and by when. An action without an owner and a date is a wish.
6
Closure. Evidence the actions happened: the works order, the invoice, the re check. An open action at the next inspection is a live finding aging in public.
7
Competence. Who inspected and why they were entitled to judge this class of equipment. On high consequence machines that is normally someone independent of the maintenance.
8
The next date. When this equipment is due again, so the record drives the diary rather than describing the past.
Key pointEight blocks make a record defensible: identity, date, scope, findings, actions, deadlines, the inspector and the next due date; drop one and the record stops proving control.
Worked example
Worked example: a guillotine record, read as an investigator would
A hydraulic guillotine is inspected on its routine cycle. The record identifies the machine by asset and serial, notes the trigger as a scheduled interval inspection, and scopes the visit as guarding, controls, stopping performance and hydraulics.
A guillotine inspection: light curtain proven, blade held, and the clamp hose flagged amber with a 30 day deadline.
The findings read: rear guard interlock functioning, stopping time measured within specification, light curtain aligned and tested with the test piece, hydraulic hose to the clamp showing outer sheath cracking with no leakage, graded for planned replacement with a 30 day date, and the foot pedal guard found loose, refixed on the day and closed in the record with the fitter's initials. One finding stops nothing, one is timed, one is closed at the visit: three grades of response, each with a reason attached.
Now run the investigator's questions against it. Was the machine identified? Yes, uniquely. Was the inspection at a defensible interval? The record shows the last date and the next. Was the inspector competent? Named, with their competence for guillotines stated. Were findings judged and actioned? Graded with reasons, owned and dated. Did the actions close? The hose replacement invoice is stapled behind. That record does in five minutes what no certificate could do at all: it proves the machine was managed.
Key pointAn investigator reads the record backwards, from the incident to the last entry that should have caught it.
Part 4 of 9
The power press exception: where PUWER writes its own reports
One family of equipment inside PUWER behaves like LOLER: power presses and their guards, governed by Part IV of the regulations. There the regime is prescriptive: thorough examination by a competent person on fixed statutory cycles, 12 months where the press has fixed guards only and 6 months in every other case, plus examination after the installation of guards or protection devices, in shift inspection and testing of the guards by an appointed person after setting and within the working period, and prescribed written reports with serious defects notified to the enforcing authority.
If you run presses, two filing consequences follow. The press paperwork sits alongside your ordinary Regulation 6 records, not inside them, because the statutory reports have their own required contents and their own retention. And the rest of the press cell, the feeding equipment, the tooling handling, the surrounding machines, still lives in the ordinary Regulation 6 world, so a press shop carries both regimes side by side. Treat any provider who quotes one document covering both with caution.
Key pointPower presses are PUWER's one statutory cycle: 12 months with fixed guards, 6 months otherwise, plus the in shift check by an appointed person.
Part 5 of 9
Digital records, and producing them on demand
Nothing in PUWER requires paper. The legal tests are that the result of the inspection is recorded, that the record can be produced when an inspector asks, and in practice that it is attributable to the person who inspected. Digital systems tend to clear those tests better than binders: dates and authorship are automatic, closure trails are timestamped, photos attach to findings, and the next due date can drive the diary directly.
Two disciplines keep a digital regime defensible. First, exportability: the system must produce a readable copy of any record on demand, on site, without a subscription renewal standing between you and your own evidence. Second, continuity: when equipment travels between sites, or the business changes software, the historical records travel too, because the series is the value. Estates that lose their history at every system change are permanently on record one.
Key pointA digital record is compliant if you can produce it on demand at the place of use; an inaccessible system is the same as no record.
Part 6 of 9
The interval loop, and what an inspector reads after an incident
Regulation 6 intervals are risk based, which means they are yours to set and yours to defend, and the run of records is the defence. The loop is simple: a serious finding says the interval was too long, so it shortens, with the reasoning noted in the next record; a long clean run on stable equipment supports the interval, or a considered extension, recorded the same way. An interval that only ever lengthens, or that never changes whatever the findings say, is a loop nobody is running.
Regulation 6 intervals are a loop, not a calendar: findings shorten the cycle and clean runs can relax it, with reasons recorded.
After an incident, the questions come in a fixed order, and the records answer all of them or none.
Was this equipment identified as needing Regulation 6 inspection, and on what reasoning
Was the interval defensible against the conditions and the findings history
Was the last inspection done, in time, by someone competent for this class of machine
Were the findings graded with reasons, and did the grading match what the machine was actually doing
Did every action close with evidence before the machine carried on working
Does the series show the estate reacting to what its own inspections found
A duty holder whose records walk that list has a defence built over years. One whose records are a drawer of undated tick sheets has a certificate shaped hole where their evidence should be, which is the final argument for treating the record, not any certificate, as the product you are buying.
Key pointYour intervals must respond to findings: a serious defect with an unchanged interval is the contradiction inspectors quote back.
Part 7 of 9
Who inspects what: competence without a certificate scheme
PUWER never defines the competent inspector by qualification, so the estate has to, and the working rule is that competence scales with consequence. Pre use checks belong to trained operators. Routine Regulation 6 inspections of general workshop equipment sit comfortably with a maintenance engineer who knows the machine class and has been given the time and the checklist to inspect rather than fix. High consequence equipment, guillotines, presses brakes, injection moulders, racking under heavy traffic, woodworking machinery, justifies a specialist, and on that tier independence starts to matter: the person judging the guarding should not be the person whose work the guarding depends on.
Whatever the tier, the record carries the competence: name, role, and why this person was entitled to judge this machine. That line is not bureaucracy, it is the answer to the second question every investigator asks. In house inspectors need their competence evidenced somewhere producible, training records, machine class experience, manufacturer courses, and estates using external inspectors should hold the same evidence about them. A record signed by someone whose competence nobody can describe is a record with its foundation missing.
Key pointPUWER names no certification scheme, so competence is evidenced by training, experience and the quality of the records themselves.
Part 8 of 9
One estate, four regimes: where the PUWER record fits
Most sites do not run PUWER in isolation, and the record only makes sense inside the family of statutory documents around it. A telehandler illustrates the whole map: its lifting function produces a Report of Thorough Examination under LOLER with Schedule 1 contents; the rest of the machine, brakes, steering, guarding, visibility aids, lives in the PUWER world of Regulation 6 inspections and records; the compressor in the workshop that services it runs under PSSR with a Written Scheme and examination reports; and the extraction bench where its parts are cleaned carries LEV TExT reports under COSHH.
The filing rule that keeps the map navigable is one file per asset, whatever the regime: everything the law says about that machine, in date order, in one place. The trap to avoid is the opposite habit of one file per provider, which scatters a single machine's story across whoever happened to hold the contract each year. When a hire desk, an insurer or an inspector asks about a machine, the answer should be one folder, and the PUWER records are usually the connective tissue in it, because they are the documents that cover everything the specialist regimes do not.
Key pointOne machine can carry LOLER, PSSR and LEV certificates and still need its PUWER record; the record covers what the certificates do not.
Part 9 of 9
Building the record system from a standing start
An estate that has never run Regulation 6 properly does not fix it by buying forms, it fixes it in a sequence. First, the inventory: every piece of work equipment listed, because the record system can only cover what the estate knows it owns. Second, the sort: against each item, does safety depend on installation, and is it exposed to deterioration liable to cause danger. Items with neither answer yes need maintenance but not the Regulation 6 regime, and writing that reasoning down is itself part of the defence. Third, intervals: set an honest first interval per item from the manufacturer's guidance, the conditions and the consequence of failure, knowing the findings loop will correct it.
Fourth, the first pass: inspect everything once to the eight block standard, and expect it to be the worst set of findings the estate ever produces, because a first inspection harvests years of drift. Fifth, the rhythm: closures chased weekly, the diary driven by next due dates, and the interval loop run at each visit. Six months of that sequence produces something no certificate supplier can sell: a set of records that shows an estate finding its own problems and fixing them, which is precisely the behaviour the regulation was written to create.
Key pointInventory first, risk ranking second, intervals third, then one file per asset: a defensible system is four steps, not a software purchase.
Why does PUWER produce a record when LOLER produces a report with fixed contents?
Different machinery of trust. LOLER routes safety through a statutory document with eleven prescribed items and authority notification; PUWER routes it through your risk assessment, so the record's job is to evidence your judgement rather than complete a form. The duty to record the result is statutory; the layout is yours.
Is there any legally required content at all?
The result of the inspection must be recorded and producible, and that is the statutory core. Everything else, identification, findings, grades, actions, signatures, is what makes the record defensible rather than what makes it legal. A record too thin to show what was inspected and found fails in practice even though no schedule of contents exists.
Who should sign the record?
Whoever carried out the inspection, with enough stated competence for that class of equipment that the judgement carries weight. For high consequence machines, presses, guillotines, racking under heavy traffic, that is usually a specialist rather than the maintainer, because the inspector should not be assessing their own work. See HSE's PUWER guidance.
How long do we keep PUWER records?
Keep each record at least until the next inspection is recorded, and in practice keep the series: the run of records per machine is your interval evidence and your deterioration story. Storage is cheap and the trend is the value, so discarding superseded records is saving pennies to burn proof.
Can the record be digital?
Yes. Nothing in the regulations requires paper; the tests are that the result is recorded, retrievable and attributable. Digital records tend to survive scrutiny better because dates, authorship and closure trails are automatic, provided the system can produce a readable copy on demand.
What is the power press exception?
Power presses and their guarding carry their own statutory examination and reporting regime inside PUWER, with prescribed reports and defect notification to the enforcing authority, behaving much like LOLER. If you run presses, that paperwork sits alongside, not inside, the ordinary Regulation 6 records described here.
What does an HSE inspector actually look for in our records after an incident?
The thread: that the machine was identified, inspected at defensible intervals by someone competent, that findings were graded with reasons, and that actions closed with evidence before the next visit. Gaps in that thread, especially open actions with no closure, do more damage than any individual finding. Our PUWER regulations guide covers the duties in full.
Does a clean record run mean we can extend the interval?
It is evidence for it, used honestly. Regulation 6 intervals follow risk, so a long clean series on stable equipment supports a considered extension, recorded with the reasoning. The same logic runs the other way after any serious finding, and an interval that only ever lengthens is a sign the loop is not being run honestly.
Talk it through with an independent engineer surveyor today
Partner with an independent inspection body to cover your clients’ statutory obligations. One point of contact across all four regimes, with verified written reports and nationwide, multi-site cover for every plant type.
Independent advice on compliance, written schemes of examination and inspection strategy, from competent engineer surveyors with no equipment to sell you.
