Duty holder guides

Making Sense of LOLER Defect Categories

Plain answers from independent engineer surveyors who write these reports every week.

Every defect on a thorough examination report carries a category, and the category is the instruction: A stops the equipment now, B sets a legal deadline, C goes on the watch list. This guide explains what each one means, what real defects look like in each, and the log that proves you acted.

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  • Competent engineer surveyors
  • Reports issued promptly
A B C
3 tiers
Category A, B and C cover every finding an examiner makes
A date
Every category B defect carries a repair by deadline
Recurring C
The same observation twice is heading for category B
11 items
Schedule 1 fixes what every report must contain

Reading your report

  • Find the defect wording and its category before anything else
  • Category A means the kit is already out of service, act accordingly
  • Diary every category B deadline the day the report arrives
  • Record category C items somewhere they will be seen next time
Findings and what they mean

What each category means, with real examples

The categories are how competent persons translate Regulations 9 and 10 of LOLER 1998 into instructions you can act on. The regulations themselves speak of defects which are, or could become, a danger to persons; the A, B, C labels are the industry's standard shorthand for how close that danger is.

The examples matter more than the definitions. A cracked load chain link, a hook that has opened beyond its throat measurement, a brake that creeps under load or wear beyond the manufacturer's limits are all category A: the safe working load can no longer be relied on. Worn but serviceable shackle pins, a chipped pulley flange or a hairline weld observation belong lower down the scale, and the examiner's judgement, not a table, places them.

FindingSeverityWhat you must doWho is told
Category A: existing or imminent dangerSeriousOut of service immediately, repair, then re examination before any liftYou verbally at once, written report, copy to the enforcing authority
Category B: will become dangerousTime boundRepair by the date on the report, which is a legal deadline, not adviceYou, in the written report
Category C: observationMonitorRecord it, watch it, and expect questions if it appears twiceYou, in the written report
Illegible markings on an accessorySeriousAn accessory whose identification cannot be read comes out of serviceYou, through the report

One nuance worth knowing: some examiners run a two tier system and record anything below a dated defect as an observation. The words on your report control, so read the defect text, not just the letter.

Getting back to work

The deadlines, the log and the escalation

Categories only work if something happens after the report is filed. Two disciplines turn the letters into a defence.

Category B deadlines are legal deadlines

A category B entry reads like advice and behaves like law: if the date passes without the repair, the equipment is non compliant and should be out of service until the work is done and verified. Diary the deadline the day the report lands, assign an owner, and keep the repair invoice with the report.

Watch category C items across consecutive reports too. An observation that appears twice is deterioration in progress, and a competent person seeing it progress will move it to category B, usually with a shorter deadline than you would have chosen yourself.

The defect log beside the report

The report proves a defect was found; it cannot prove the defect was fixed. The practical answer is a defect log kept beside the reports: the report date, the category, the action and deadline, who did the repair, when it closed, and whether a further examination was needed before return to service.

When an inspector wants to verify that category B defects were actually addressed in time, this is the document that answers in one page. Reports without a closure trail are the most common gap we see in otherwise compliant estates.

Part 1 of 9

Where the categories actually come from, because the law never says A, B or C

Open LOLER itself and you will not find Category A anywhere. Schedule 1 item 8 creates exactly two statutory tiers: a defect which is a danger to persons, for which the report must give the particulars of the repair, renewal or alteration required, and a defect which is not yet but could become a danger to persons, for which the report must state the time by which it could become one and the particulars of the work needed. Everything else, the letters, the numbers, the colours, is a labelling convention that examiners and inspection bodies lay over those two tiers, usually adding a third bucket for observations that meet neither test.

Schedule 1, item 8 is a danger could become a danger, time attached A 1 B 2 C observations labels are conventions on two statutory tiers
The statute defines two tiers, is a danger and could become a danger with a time attached; the familiar A, B and C labels are conventions built on top.

That distinction matters practically, not just academically. Because the categories are conventions, two providers can label the same finding differently while both being legally correct, and the words that carry legal force are the statutory ones on the report: is a danger, could become a danger, and the time attached. When you read any categorised report, translate the label back to the statutory tier before deciding anything, and treat the letter as a summary of the examiner's judgement rather than the judgement itself. Our guide to reading the report shows where the item 8 entries sit among the eleven required items.

The convention exists because it is useful: a fleet manager scanning forty reports needs the triage at a glance, and A, B, C does that well. Just never let the shorthand replace the sentence underneath it, because when a category and its wording seem to disagree, the wording wins.

Key pointThe letters are a filing system; the law is in the wording, and the wording has exactly two tiers: a danger now, or a danger by a stated time.
Part 2 of 9

Category A: the defect that is a danger today

A Category A entry, however your provider labels it, records the examiner's opinion that the defect is a danger to persons now. The consequences are the sharpest in the regime: the equipment comes out of service immediately, and where the defect involves an existing or imminent risk of serious personal injury, the examiner sends a copy of the report to the relevant enforcing authority as a legal duty they cannot waive.

What earns the top category is failure of something whose job is to prevent harm, present tense. A cracked hook or load chain link, brakes that will not hold the rated load, a limit switch that no longer stops travel, structural cracking in a boom or mast weld, an accessory with cuts or distortion past discard criteria, a missing safety catch on a hook lifting above people. The unifying logic is that continued use relies on luck rather than margin: the component has left its designed envelope, and the next overload, snatch or fatigue cycle is not guaranteed to be survived.

Read an A entry for three things. The component: it tells you what to isolate and what spares to source. The mechanism: cracked, corroded, distorted and worn point at different causes and different fleet checks. And the required work: item 8 obliges the examiner to state the repair, renewal or alteration required, which is your scope of work in the examiner's words, not the fitter's guess.

One discipline separates well run estates on A defects: they treat the verbal notification as the stop, not the paperwork's arrival. The examiner must tell you forthwith, and from that conversation every lift the equipment performs is use of equipment you know to be dangerous.

Key pointAn A category defect means the margin is already gone; isolate on the phone call, source against the examiner's required work, and never ask for the authority copy to be softened.
Worked example

Worked example: one chain, three categories

Take an identical grade 80 load chain on three hoists across one site, measured for elongation at the same examination. Hoist one measures 1.2 per cent against the commonly used discard benchmark of around 3 per cent for that chain type. Hoist two measures 2.4 per cent. Hoist three measures 4.1 per cent. Same component, same duty, three different report entries.

~3% 1.2% 2.4% 4.1% observationdated defectdanger now
The same chain at three wear states: an observation at 1.2 per cent, a dated defect at 2.4, and a danger now at 4.1; the category tracks the remaining margin, not the component.

Hoist three is the easy one: past discard, the chain is a danger to persons now, Category A, hoist out of service, chain replaced and the hoist re examined before use. Hoist one is the other easy one: comfortably inside the margin, recorded as an observation with the measurement noted, no action demanded, and the number banked for trending at the next visit.

Hoist two is where the examiner earns their fee. At 2.4 per cent the chain is not a danger today, but on this duty and this trend it could become one before the next scheduled examination, so it lands in the middle tier: a defect which is not yet but could become a danger, with a time by which the chain must be replaced. That date is the examiner's engineering estimate of when the margin runs out, discounted for safety, and it is a legal boundary rather than a suggestion.

Notice what the case shows about the categories themselves. They are not properties of components; they are statements about remaining margin. The same crack, wear figure or corrosion depth can sit in any tier depending on duty, environment and trend, which is why arguing a category by comparing two reports on different machines misses how the judgement works.

Key pointCategories measure the distance between today's condition and danger; the same finding can lawfully sit in any tier, and the examiner's date is the margin converted into a deadline.
Part 4 of 9

Category B: the deadline tier, and what the date legally is

The middle category is the one estates mishandle most, because it looks like a to do list and is actually a boundary. Schedule 1 item 8 requires the examiner, for a defect which is not yet but could become a danger, to state the time by which it could become such a danger and the work required. The date on a B entry is therefore not an admin convenience: it is the examiner's written opinion of when the defect stops being tomorrow's problem.

Run B defects on three rules. First, the date is the latest moment, not the target: plan the repair for comfortably inside it, because deadline day repairs leave no room for parts on back order or a fitter off sick. Second, the equipment may keep working up to the date only as reported: if the entry restricts duty, derates the load or excludes a function, those conditions are part of the opinion, and use outside them is use outside the report. Third, when the date will be missed, decide before it arrives: stop the equipment, or get the examiner's revised opinion in writing. Letting a B date lapse in silence quietly converts the entry into a Category A situation with a paper trail proving you were told the date.

found B date danger, per the report repair planned here margin for parts, access and bad luck
The B date is the examiner's estimate of when the margin runs out: plan the repair comfortably inside it, because past the date the entry reads as a danger you were warned about.

Track B defects as their own list with owners and evidence of closure: the invoice, the fitted part, and where the report or good practice asks for it, the re examination of the affected component. At the next thorough examination the examiner will look for exactly this closure, and an estate that closes B entries visibly earns categories argued in its favour when judgements are marginal.

Key pointA B category date is the examiner's opinion of when danger arrives; repair inside it, honour any conditions attached, and never let the date pass without a written decision.
Part 5 of 9

Observations and Category C: the entries that are cheap now and expensive to ignore

The third bucket carries no statutory force, which is exactly why it is so useful. Observations, monitor entries, Category C, advisory items: these record deterioration or conditions that meet neither statutory test, and asking nothing today, they are the examiner giving you the trend for free. Wear at 40 per cent of discard, surface corrosion on a non critical member, a decal fading, drain holes blocking, a duty creeping toward the equipment's limits.

Their value is almost entirely in the series. One observation is a note; the same observation across three reports with a rising measurement is a forecast, and a forecast with a date on it is a budget line you got years in advance. Estates that harvest observations replace components in planned windows at parts cost; estates that discard them meet the same components later as B dates in busy seasons or A defects at worse moments.

Handle them with a light but real process: log them against the asset, glance at the trend when planning maintenance, and tell the examiner what you did about last year's notes. That last habit changes the examination itself, because an examiner who sees observations acted on writes better, earlier, franker observations, and one who sees them ignored eventually stops writing them, which is the quiet death of your early warning system.

One caution: an observation is only cheap while its facts hold. If duty, environment or condition change, the entry does not wait politely for the next examination. The observation that noted mast wear on a single shift truck becomes a different conversation when the truck moves to three shifts in a cold store, and exceptional circumstances exist for exactly that case.

Key pointObservations are the regime's free intelligence: logged and trended they become planned maintenance at parts cost, ignored they come back wearing a category and a deadline.
Part 6 of 9

Category patterns that should make you challenge a report

Every defect on every report is Category B, year after year: a provider avoiding the confrontation of an A and the honesty of observations
A category with no defect description or component identified, leaving you unable to plan the work item 8 requires the examiner to state
B entries whose date is always exactly the next examination date, which is a diary entry pretending to be an engineering judgement
An A category delivered with an offer to soften it if the work is booked with the same provider's repair arm
Categories that swing with the season: the same finding graded A in a quiet month and B in your busy period
Vague required work such as attend to chain, when the statute demands particulars of the repair, renewal or alteration
No observations, ever, on ageing equipment: margins do not stay perfect for a decade, silence means they are not being recorded
Category language that changes provider to provider with no key on the report explaining which statutory tier each label maps to
Key pointA category system is trustworthy when its letters map cleanly to the two statutory tiers and its dates read like engineering; drift from either is your cue to ask questions.
Part 7 of 9

Different providers, different labels: translating the conventions

Move between inspection providers and the labels change under you. One issues Category A, B and C. Another writes immediate, serious and other. A third numbers them 1 and 2, a fourth colours entries red, amber and green, and insurer linked bodies each have a house style. None of this variation is a compliance problem, because none of the labels are statutory; every scheme is a wrapper around the same Schedule 1 wording.

Build yourself a translation habit rather than a preferred vocabulary. Whatever the label, ask which statutory position the entry takes: is this a defect which is a danger now, a defect which could become one by a stated time, or a comment meeting neither test. The first always means out of service and, where the risk of serious personal injury is existing or imminent, an authority copy. The second always means a legal deadline with required work. The third always means information. Once your defect log records that translation alongside the provider's label, reports from any body drop into one consistent system.

Where this bites hardest is mixed estates and provider changes. A fleet with hire equipment inspected by one body, owned plant by another and accessories by a third can hold three labelling schemes at once, and a defect log sorted by provider label will mis sort them. Sort by statutory tier and the log reads true across every report. It also future proofs a provider switch: your history stays comparable because you recorded the law's categories, not the letterhead's.

If a report's key does not say which labels map to which statutory tier, ask the provider to state it in writing once. Good ones answer in a sentence.

Key pointLabels are dialects and the statute is the language; log every defect by its statutory tier and any provider's report drops into the same system.
Part 8 of 9

Who decides the category, and how to challenge one properly

The category is the competent person's opinion, and LOLER is built so that opinion, not yours, governs. That is deliberate: the examiner is required to be sufficiently independent and impartial precisely so the judgement cannot be leaned on. But opinion does not mean beyond conversation, and there is a proper way to challenge a category you believe is wrong in either direction.

Challenge with engineering, not commercial pressure. If you think an A is harsh, the questions are technical: what mechanism, what measurement, what criteria, and would the examiner walk you through the finding at the machine. Examiners will happily show a crack indication or a wear reading, and seeing it usually ends the argument one way or the other. If the disagreement survives the walkthrough, a second competent person's examination is legitimate; quietly shopping until a friendlier letter arrives is not, because the first report does not evaporate, and a paper trail of category shopping reads terribly beside an incident.

Challenge upward too. A duty holder who believes a B is generous, because they know the duty is harsher than the examiner assumed, should say so: the examination is only as good as the information it was given, and examiners revise judgements when the facts improve. Telling the examiner the hoist actually runs three shifts in a washdown area is not undermining their opinion, it is completing it.

Two things are never negotiable, whatever the conversation: the equipment stays out of service while an A category stands, and the enforcing authority copy, where the statutory trigger is met, is the examiner's duty to send. Any provider offering flexibility on either is offering to break the law with you as the witness.

Key pointChallenge categories with measurements and duty facts at the machine, accept the answer or commission a second competent opinion openly, and never touch the stop or the authority copy while you argue.
Part 9 of 9

What each category should trigger in your wider system

A category is only worth what it changes, and a defect log that records letters without consequences is a filing exercise. Map each tier to a fixed set of downstream actions and the categories start running the estate for you.

An A entry triggers the stop, the isolation evidence, the fleet question on sibling components, the spares order against the examiner's required work, and the re examination booking, in that order. It should also trigger one look backwards: what would have caught this earlier, and does the pre use check or maintenance schedule gain a line. A B entry triggers a dated task with an owner, a decision point set before the deadline, any use conditions written into the equipment's instructions, and closure evidence filed with the report. An observation triggers a log line and a trend glance at the next maintenance planning cycle, nothing more, which is precisely its virtue.

Let the categories also drive the conversations beyond the workshop. Hire desks should hear about A and B entries on hired plant the same day in writing. Whoever manages the examination scheme should see any cluster of B entries on one equipment family, because clusters are the scheme asking to be tightened. And the person who buys equipment should see the observation trends, because a fleet whose observations all point at one component or one supplier is telling you what to specify differently next time.

Close the loop annually: one hour with the defect log, counting entries by tier, by equipment family and by cause. That distribution is the health of the estate in three columns, and it is the summary an insurer or inspector is most impressed to be handed unasked.

Key pointWire each category to a fixed response and the report stops being paperwork: A runs the emergency, B runs the plan, observations run the budget, and the annual distribution runs the strategy.
Related pages
Common questions

LOLER Defect Categories: your questions answered

Are the A, B and C categories written into LOLER itself?

No. The regulations speak of defects which are or could become a danger to persons, and Schedule 1 requires each defect and the action needed to be recorded. The letters are standard competent person practice for expressing how urgent that danger is, which is why wording can vary slightly between providers.

Who decides the category, us or the examiner?

The examiner, and only the examiner. The category is the competent person's professional judgement about danger, made independently. You can discuss a finding and provide context, but a duty holder cannot negotiate a category down, and an examiner who trades categories is not one to keep.

What are typical category A defects?

A cracked or deformed load chain link, a hook opened beyond its throat dimension, a brake that will not hold the load, wear beyond the manufacturer's discard limits, structural cracking, or a lifting accessory whose identification markings cannot be read. The common thread: the safe working load can no longer be relied upon.

How long do we get for a category B repair?

Whatever the report says, and nothing more. The examiner sets a date they judge the defect can safely tolerate, commonly weeks rather than months. If the date passes, treat the equipment as non compliant and stand it down until the repair is done and verified. See HSE's guidance on thorough examinations for the duties behind the deadline.

Can we ignore category C observations?

You can, and it is a mistake. Nothing forces action on a category C, but observations are early photographs of deterioration. The same item recurring across reports is progressive wear, and acting while it is still category C is always cheaper than the category B repair it becomes.

Which categories reach HSE?

Only defects involving an existing or imminent risk of serious personal injury, which in practice means category A findings. The examiner sends the copy; it is their statutory duty, not yours, and it is not an accusation against you unless the danger is then ignored.

Does a category B defect affect using the equipment meanwhile?

The report tells you. Some category B entries permit normal use until the deadline; others carry conditions, a reduced duty or a restriction on configuration. The conditions are part of the legal finding, so treat any use outside them as use of defective equipment. Our LOLER regulations guide covers duties in full.

Do the same categories apply to hired equipment?

Yes. The examination follows the equipment, and the category follows the examination. Tell the hire company immediately, take the item out of use for category A, and do not repair hired kit yourself; the owner arranges the repair and the fresh examination.

Talk it through with an independent engineer surveyor today