Compliance

The inspection records you have to keep — and where they go missing

Almost nobody fails an inspection audit because the kit was unsafe. They fail because the paperwork proving it was safe is in a van.

· 6 min read

There are two separate duties here and they get conflated constantly. One is to make sure work equipment is safe. The other is to be able to demonstrate it — to an inspector, to an insurer, or to a coroner. The first is about the kit. The second is about the record, and it is the second that people fail.

The pattern is remarkably consistent. The examination happened. A competent person did it properly. A report was issued. And eighteen months later nobody can produce it, because it was emailed to someone who has left, or it is in a lever-arch file at a depot the company no longer rents.

What the two regulations actually ask for

PUWER covers work equipment generally. Where safety depends on how something was installed or on conditions that deteriorate, it must be inspected at suitable intervals, and you must keep a record of the result of the last inspection.

LOLER covers lifting equipment specifically and is stricter, because the failure mode is worse. Lifting equipment needs thorough examination by a competent person, and the intervals are prescribed rather than left to your judgement.

EquipmentThorough examinationUnder
Anything used to lift peopleAt least every 6 monthsLOLER reg 9
Lifting accessories — slings, shackles, eyeboltsAt least every 6 monthsLOLER reg 9
Other lifting equipmentAt least every 12 monthsLOLER reg 9
Any of the above on a written examination schemeAs the scheme specifiesLOLER reg 9
Work equipment where safety depends on installationSuitable intervals; record the last onePUWER reg 6

Two things people get wrong about that table. The intervals are maxima, not targets — a scheme drawn up by a competent person can require more frequent examination and often should. And a thorough examination is not the same as the pre-use check an operative does at the start of a shift; both are required, and only one of them produces a report.

The duty follows use, not ownership

This one causes real trouble. If you hire in a telehandler or a chain block, the examination duty does not stay with the hire company just because they own it. As the person with control of the equipment you need to be satisfied it has been examined, and you need the report to prove it.

Which means hired kit needs to be on your register too, with its report attached and its off-hire date recorded — not treated as somebody else’s problem because it has somebody else’s asset tag on it.

Where the record actually breaks

In roughly the order we see them:

  • The report is a PDF in an inbox. It exists, it is valid, and it is findable only by a person who knows to search for it. When that person is on holiday it does not exist.
  • The register lists an item once and the reports pile up separately. Nothing joins "Chain block, 1t, serial CB-4471" to the three reports issued against it, so proving continuous compliance means reading all of them.
  • Serial numbers are recorded inconsistently — CB4471, CB-4471, cb 4471 — so the same item appears three times and each copy looks overdue.
  • The due date is calculated from when the last examination was booked rather than when it was done, which drifts by a few weeks each cycle until an item is quietly out of date.
  • Something goes to a site and never comes back onto the register, so it stops appearing on the report of what is due.
  • An item fails examination, gets quarantined, and there is no state for that — so it either stays "available" and someone uses it, or it vanishes from the register entirely.
An item that failed examination and was never marked as failed is more dangerous than one that was never examined at all, because the record says it is fine.

What a register has to do to be worth keeping

Five things, and most spreadsheets do three of them.

  1. Identify each physical item uniquely and permanently. One row per serial number, not one row per type with a quantity — you cannot examine "4 chain blocks", you examine a specific one.
  2. Hold the next-due date as a fact derived from the last examination date, so it cannot drift.
  3. Tell you what is due before it is due, unprompted. A register you have to remember to look at is a register that will be looked at after the deadline.
  4. Record state, including the unhappy states: quarantined, failed, awaiting repair, off-hire. If the only options are available and issued, everything else becomes a note nobody reads.
  5. Keep the history rather than overwriting it. The question at an audit is not what the status is today, it is whether it was in date on 14 March when the accident happened.

That last point is the one that separates a register from a list. A list tells you the current state. An audit asks about a past state, and a spreadsheet that has been edited in place cannot answer it — the previous value is simply gone.

A reasonable Monday morning

If you are starting from a filing cabinet, do not attempt to digitise the history. Nobody has ever finished that project. Instead:

  1. List every item that is subject to examination, by serial number. Include hired kit. This is usually a shorter list than people fear — a few hundred items at most.
  2. For each one, record the date of the most recent examination you can evidence, and attach or reference that report.
  3. Let the next-due date be calculated from it. Anything with no evidence gets flagged as unknown rather than assumed compliant, because assuming is the failure mode.
  4. Deal with the unknowns as a batch — that is your actual exposure, and it is better to see it as a number on Monday than to discover it item by item over a year.
  5. From then on, every new report updates the item rather than being filed alongside it.

Step three is uncomfortable, which is the point. Most organisations doing this for the first time find somewhere between five and fifteen percent of their register has no evidence they can lay hands on. Finding that out deliberately is much cheaper than finding it out during an investigation.

Nilstock holds each item as a distinct asset with its own history rather than as a quantity, records inspection dates and the state an item is in — including quarantined and failed — and chases what is coming due without being asked. The equipment tracking side of the product explains how custody and due dates work; sector detail is on the construction and maintenance stores pages. If your balances are already drifting, cycle counting is the counting discipline that keeps a register honest.

Nilstock does this bit for you.

Scan a badge, scan the item, confirm. Fourteen days free, no card.

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