Duty holder guides

Defects Found in Your PUWER Inspection

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

PUWER handles defects differently from every other regime: no certificate, no fixed statutory cycle, and no report to the authority except for power presses. What you get is a record of inspection and a risk based duty to act on it. Here is what stops, what waits and what you keep.

  • Independent & impartial
  • Competent engineer surveyors
  • Reports issued promptly
A record
PUWER produces a record of inspection, never a certificate
Risk based
Regulation 6 sets intervals by risk, not fixed dates
Power presses
The one PUWER regime with statutory reports
No HSE copy
Ordinary PUWER defects are not sent to the authority

Do this first

  • Stand down any machine where guarding or interlocks failed
  • Walk the finding back to your risk assessment, not the calendar
  • Fix a repair date the risk actually supports
  • File the record of inspection where an auditor can find it
Findings and what they mean

Which defects stop the machine

A PUWER inspection under Regulation 6 checks that work equipment is safe where its safety depends on how it is installed and can deteriorate: guards, interlocks, emergency stops, controls, hydraulics, structure. There is no statutory defect grading, so the inspector's judgement and your risk assessment do the sorting between what stops now and what is planned in.

The honest dividing line is whether the defect removes a protective measure. A machine whose interlock no longer stops the wheel is running without the safeguard your risk assessment relies on, and using it is the offence, not the defect itself.

FindingSeverityWhat you must doWho is told
Protective measure defeated: guards, interlocks, stopsSeriousTake the equipment out of use until it is made safe and recheckedYour own people; there is no authority notification
Deterioration that will become dangerousTime boundPlan the repair inside the window your risk assessment supportsYour own people, through the record
Wear worth watchingMonitorNote it on the record and check again at the next inspectionYour own people, through the record
Power press defectsStatutoryFollow the power press regime, including its examination reports and notification rulesThe enforcing authority, for power presses only

If the equipment also lifts, the lifting function sits under LOLER with its own thorough examination and defect rules; PUWER inspections cover the rest of the machine and the checks between thorough examinations.

Getting back to work

Making it safe and proving you did

PUWER compliance after a defect is repair plus record. The regime trusts your judgement on timing and then holds you to the evidence of it.

Repair, recheck, return to service

Repairs follow the finding: a guard remade, an interlock replaced, a stop circuit rewired. Where the defect defeated a protective measure, have a competent person recheck the equipment before it returns to use, because the recheck is what turns a repair into evidence.

Interval discipline matters afterwards. Regulation 6 intervals are risk based, so a machine that produced a serious defect has just told you its interval was too long. Shortening it is the response an inspector expects to see, and the record is where that decision lives.

There is no PUWER certificate, and that matters

Nothing in PUWER creates a certificate, and a provider selling PUWER certification is describing something the regulations do not contain. The compliance evidence is the record of inspection: what was inspected, when, what was found and what was done about it.

Keep each record at least until the next inspection is recorded, and in practice keep the run of them, because the sequence is what demonstrates a working regime to an auditor, an insurer or an HSE inspector. The exception is power presses, which carry their own statutory examination, reports and authority notification, the only place in PUWER where the paperwork resembles LOLER.

Part 1 of 9

What a defect on a PUWER inspection actually changes

A defect found at a PUWER inspection changes your legal position the moment it is written down, and understanding that is the difference between managing the finding and merely filing it. There is no certificate to void: PUWER produces a record of inspection, and a defect entry in that record is a written statement that a safety related part of your work equipment has deteriorated or failed. From that entry onward, you are an employer with documented knowledge.

STOP NOW guard gap at nip FIX BY DATE hose abrasion, 30 days WATCH belt edge wear, reasons noted
A defect entry commits the equipment to one of three managed states: stopped now, repaired by a date, or monitored with reasons recorded.

Regulation 6 exists precisely for this moment: inspection is required where equipment safety depends on installation conditions or where deterioration can lead to danger, and the inspection's whole purpose is to find that deterioration while it is a finding rather than an incident. A defect is therefore the system working. What inspectors judge is not the existence of defects but the traffic between finding and fixing: whether the graded severity produced a proportionate response, on a defensible timescale, evidenced in the record.

Grade every defect explicitly, because an ungraded defect defaults in an investigator's mind to the most serious reading. The practical grades mirror the other statutory regimes: a defect creating immediate danger stops the equipment now; a defect that will become dangerous carries a repair by date; a deterioration worth tracking is recorded with reasons and watched. The grade belongs in the record next to the finding, with the reasoning in one sentence, and our guide to the inspection record shows where each element sits.

Key pointA PUWER defect converts general duties into specific knowledge; grade it in writing, respond to the grade, and the record proves control instead of documenting neglect.
Part 2 of 9

The immediate danger finding: stopping equipment without a certificate to revoke

When an inspection finds a defect creating immediate danger, PUWER gives you no examiner's grounding notice to lean on: the stop is your decision, made under your general duty, and made now. That absence of ceremony is exactly why the discipline matters more, because the only thing standing between the finding and the next operator is what you do in the following hour.

1
Stop the equipment and make the stop physical: isolate, lock off, remove the means of starting where the design allows. A guard missing from a running machine is not resolved by an email.
2
Tag it with the reason and the authority: taken out of service, guard interlock defective, by order of the engineering manager, date. The tag is for the person who arrives at the machine knowing nothing.
3
Tell the planning chain before the shift plan does: the supervisor allocating work, the team leader of the next shift, the maintenance planner who might otherwise schedule the machine.
4
Record the stop in the inspection record itself: defect found, graded immediate danger, equipment isolated at time and date, by whom. This entry is the one an investigator would look for first, and it takes ninety seconds.
5
Look sideways before you relax: if the defect is a failed interlock on machine three, machines one, two and four with the same interlock deserve a check today, because a component that failed in service on one unit is a fleet question, not a machine question.
Key pointWith no statutory examiner to ground the machine, the grounding is yours to order and evidence; a lock, a tag and a ninety second record entry are what done looks like.
Worked example

Worked example: a conveyor guard defect read as an investigator would

An internal PUWER inspection of a packing line finds the fixed guard over the conveyor's tail drum has a bent corner leaving a gap at the in running nip, wide enough for fingers, on a machine cleaned daily by hand. The inspector grades it immediate danger, and the line stops at 14:10 with the drive isolated and tagged.

gap at the nip section replaced, refitted rechecked, released
A gap at an in running nip on a hand cleaned conveyor is the classic PUWER immediate danger: obvious in hindsight, invisible in routine.

Walk the closure as an investigator later would, backwards from the record. The record shows the finding, the grade, the isolation time and the fix: guard removed, corner section replaced rather than bent back, refitted with all fixings, and a functional check that the gap is closed at every point an operator can reach during cleaning. It shows a recheck entry by the inspector the next morning confirming the repair, and the line released at 09:40. It also shows cause: the corner was bent by a pallet strike from the adjacent aisle, so a barrier rail is raised against the guard and the weekly checklist gains a line for guard condition on the aisle side.

Now notice what the investigator cannot find, because it never happened: no gap between finding and isolation while the shift finished, no bent back into shape repair that fails again at the next pallet strike, no verbal only handover that leaves the night shift restarting a tagged machine. The whole file is five entries long and took less effort than the argument it prevents.

The line lost nineteen working hours. The same nip, found by an accident investigation instead of an inspection, costs a finger, a prohibition notice and a prosecution built on the question we started with: when did you know.

Key pointInvestigators read records backwards, from the harm to the last entry that should have prevented it; build every defect closure so that backwards read finds isolation, repair, recheck and cause, in that order.
Part 4 of 9

Repair, recheck and returning equipment to service on your own authority

Returning defective equipment to service under PUWER carries a trap symmetrical to the stop: with no external examiner mandated, the temptation is to let the repair itself be the authorisation. Resist it. The finding was made by a competent inspection; the closure should be too, and the record should show a named, competent person confirmed the repair before the equipment ran.

Match the repair to the safety function, not to the symptom. A guard defect is closed when the guard again performs its function at every accessible point, which is a test, not a glance. An interlock defect is closed when the interlock demonstrably stops the machine in every mode it protects, including the inching and setting modes where interlock defeats live. A brake, a stop, an emergency cable: each has a functional test, and the record entry that says tested and proven is worth ten that say fitted.

Where the defect had a repair by date rather than an immediate stop, the date is a boundary, not a target. Plan the work inside it, and if the date will be missed, make a positive decision before it passes: either stop the equipment until the repair, or have your competent person record why continued use remains justified and what compensating measures apply. A date that slides past in silence converts a managed defect into documented use of equipment you had declared would become dangerous.

Recheck ruthlessly after third party repairs. The contractor who serviced the press does excellent work and also left the guard fence panel off; the record's recheck entry is where that gets caught, and the inspection regime that assumes competence without verification will eventually document its own blind spot.

Key pointEquipment returns to service on a named person's tested confirmation, not on the arrival of an invoice; the recheck entry is the closure, everything before it is progress.
Part 5 of 9

The defect handling mistakes that inspectors quote back

The finished the shift gap: a timestamped finding followed by hours of production before the isolation entry
The bent back repair: restoring the shape of a guard without restoring its function, discoverable at the next pallet strike
Grading by production pressure, where the same defect is immediate danger in January and monitor in the busy season
The silent slipped date: a repair by entry with no closure and no decision recorded when the date passed
Recording the defect but not the recheck, leaving the file unable to say who confirmed the machine safe or when
Fixing unit three and never checking units one, two and four with the identical component
Verbal only handovers, so the night shift restarts what the day shift tagged
Letting operators normalise the defeat: the interlock bridged for cleaning that stays bridged, with the inspection recording it as a finding every year and nobody closing it
Deleting or rewriting record entries after an incident, which converts a defect case into a dishonesty case
Key pointEach of these mistakes shares one shape: the record shows you knew, and the machine shows you carried on; never let those two facts coexist in your file.
Part 6 of 9

Defects found between inspections: the operator's finding is still a finding

The inspection interval is a maximum, not a schedule for noticing. Most equipment defects announce themselves between inspections, to the operator who hears the change, sees the crack or finds the guard loose, and an employer's defect system is judged by what happens to those findings just as much as the formal ones. PUWER's information and training duties exist so operators can recognise danger; the reporting route is what makes that recognition worth anything.

Make the route shorter than the shift. A defect book at the machine, a supervisor empowered to stop the line, a maintenance number that answers: the mechanics matter less than the latency. An operator report that takes three days to reach a decision maker is a system designed to lose the race against the failure it describes.

Treat operator findings with the same grading discipline as inspection findings: graded, recorded, closed with a recheck. The stakes are identical, and the record of an operator report handled well is powerful evidence of a living system rather than an annual ritual. Conversely, the pattern investigators feast on is the defect reported twice by operators, absent from the inspection records, and present in the incident file.

Feed the between inspection findings back into the inspection itself. If operators keep reporting the same guard working loose, the inspection checklist gains that guard, the interval for that machine shortens, and the fixings get engineering attention rather than repeated tightening. Regulation 6 asks for inspection where deterioration can lead to danger; the operators are telling you, in real time, exactly where that is.

Key pointA defect does not care who found it; run one graded, recorded, rechecked route for the fitter's finding and the operator's, and make it faster than the shift that raised it.
Part 7 of 9

When defects change the interval: the loop that proves your system thinks

A defect should never leave your inspection intervals exactly as it found them without somebody deciding so. Regulation 6 intervals are risk based, which cuts both ways: findings of deterioration are evidence the interval is too long for the conditions, and a clean run of inspections is evidence it might responsibly relax. The interval that never moves in either direction is the signature of a system on autopilot.

serious finding intervals tighten after the finding clean runs relax them, with reasons
Findings tighten the loop and clean runs can relax it; either way, the record shows the interval was a decision, not an inheritance.

Work the loop explicitly after any significant defect. Ask what the deterioration rate implies: a guard fixing that works loose in four months makes a six month inspection a coin toss, and the record should show the interval halved with the reason. Ask whether the conditions changed: the machine moved outdoors, the shift pattern doubled, the material got more abrasive. And ask whether the inspection scope caught the defect or the defect found itself: a failure mode the checklist never examined is a checklist finding, not just an equipment one.

Record the decision even when the decision is no change. One line, defect reviewed, isolated cause, interval retained, converts silence into judgement. This is also where the power press exception earns a mention in any defect conversation: presses run on fixed statutory cycles that you cannot relax, and defects there change the maintenance and the in shift checks instead.

Reviewed intervals are also the cheapest credibility you can buy. An inspection record whose intervals visibly respond to findings tells an inspector the system is alive, and that impression colours how every other page of the file is read.

Key pointAfter every significant defect, the interval question gets asked and the answer gets written down; a loop that visibly tightens on findings is the strongest single page in a PUWER file.
Part 8 of 9

One estate, four regimes: where the PUWER defect sits among the certificates

A defect rarely respects regulatory boundaries, and the estates that handle defects worst are usually the ones that assume the certificate regimes have it covered. A fork lift carries a LOLER report for its lifting function; its brakes, steering, lights and seat interlock are PUWER matters that no thorough examination certifies. A compressor's receiver sits under PSSR; the drive guard and emergency stop are PUWER. The spray booth's airflow is the LEV test's business; the booth's door interlocks are yours.

Route each defect to its own regime and let each regime's machinery run. A brake defect on the truck is graded and closed in the PUWER record even though the truck's LOLER report is current and clean, because that report never looked at the brakes. A guard defect on the compressor does not wait for the next PSSR examination, which would not record it anyway. Cross regime confusion runs the other way too: a chain defect found during a PUWER walk round belongs to the LOLER world, wants the competent person's opinion, and may trigger an examination out of cycle.

The practical tool is a one page split per machine: which regime owns which system, who inspects it, on what cycle, and where the records live. Ten minutes per asset ends the this is covered by the certificate conversation permanently, and it is exactly the map an inspector asks for when a defect on a multi regime machine comes up.

Above all, never read a current certificate as evidence the whole machine is sound. The certificates certify their own scope; the PUWER record is where everything else lives, which is why the machine with four clean certificates can still be carrying the defect that stops it.

Key pointCertificates cover their scope and nothing else; map each machine's systems to their regimes once, and route every defect to the record that actually owns it.
Part 9 of 9

Building the defect system from a standing start

If defects on your site currently live in memory, verbal handovers and the fitter's notebook, building the system is a fortnight's work, not a transformation programme, and the defect handling improves the day the first page exists. The sequence matters more than the software.

1
Start one record per machine, today, however basic: identity, its inspection interval with a reason, and a defects section with four columns, finding, grade, action, recheck. Paper in a binder beats software next quarter.
2
Grade with three levels and plain definitions: stop now, fix by date, watch. Write the definitions on the record template so every inspector and supervisor grades from the same words.
3
Empower the stop. Name who can take equipment out of service, and make clear it includes supervisors on nights, because a defect system that waits for office hours has an eight hour hole in it.
4
Set the recheck rule: nothing returns to service without a named person's tested confirmation in the record. One rule, no exceptions, including for contractors' repairs.
5
Open the operator route: a defect book at the machine or a number that answers, and a standing item on the shift handover.
6
Review monthly for the first quarter: are findings getting grades, are dates being met, are intervals responding. The review is where the system starts thinking instead of just recording.

The whole structure exists to answer four questions quickly: what did you know, when, what did you do, and who confirmed it. Every element above is one of those answers, prepared in advance.

Key pointA defect system is four columns and three rules, and it can start this afternoon; what it buys is the ability to answer when did you know with a page instead of a pause.
Related pages
Common questions

PUWER Inspection: your questions answered

Is there such a thing as a PUWER certificate?

No. PUWER produces a record of inspection, and no certificate exists anywhere in the regulations. A provider offering PUWER certification is repackaging the record, which is harmless until the wording overclaims what the document legally is. Judge providers on the quality of the record.

Do PUWER defects get reported to HSE?

Ordinary defects do not; the record stays in your own system. The exception is power presses, which have their own statutory examination and reporting regime including authority notification, closer in shape to LOLER than to the rest of PUWER.

How long do we have to fix a defect?

As long as your risk assessment honestly supports and no longer. Where a protective measure has failed, the answer is before the machine is used again. For deterioration that is heading toward dangerous, the inspector's recommendation and your own assessment set the window, and the record should show the reasoning.

Can operators keep using the machine if the guard is the problem?

No. Running equipment without the safeguard your risk assessment relies on is the classic PUWER prosecution, and it needs no accident to prosecute. Stand the machine down, fix the guard or interlock, recheck, and record all three steps.

Who counts as competent to inspect under PUWER?

Someone with the knowledge and experience to know what to look at and what failure looks like on that class of equipment. Independence helps for the same reason it does everywhere: an inspector with no stake in the repair bill reports what is there. See HSE's PUWER guidance for the duty in full.

Our machine also lifts. Which rules apply to the defect?

Both regimes, split by function. The lifting function has its thorough examination and defect rules under LOLER, while PUWER covers the guarding, controls and the inspections between those examinations. One visit can cover both, but the paperwork stays distinct; our PUWER guide explains the split.

What should a good record of inspection contain?

The equipment identity, the date, what was inspected, the defects found, the action taken and who carried it out. Vague records are the commonest weakness we see, because a record that just says checked, OK proves nothing when the question is asked two years later.

Does racking or a roller shutter door really sit under PUWER?

Yes. Work equipment is anything used at work, and racking struck by trucks or a door that can fall are exactly the deteriorating, safety critical equipment Regulation 6 inspections exist for. The interval follows the punishment the equipment takes, not a calendar habit.

Talk it through with an independent engineer surveyor today