Plant Hire Statutory Thorough Examinations: Which Machines Need What, and When
A telehandler, a towable compressor and a set of chains can leave a hire yard on the same lorry. Each one answers to a different set of regulations on a different clock, and the machines change hands every week. We carry out statutory thorough examinations for hire fleets. Below, each regime is set out with its interval, the events that bring an examination forward, and who holds the duty once a machine is out on hire.
What Statutory Thorough Examinations Does a Plant Hire Company Need?
A plant hire company needs LOLER thorough examinations for anything that lifts, PUWER inspections for other plant, PSSR examinations for compressors and air receivers, and Work at Height inspections for harnesses and towers. Dust extraction units add a COSHH test. Each runs on its own clock, and most need proof of the last check travelling with the machine.
Depending on what is in the fleet, that means:
LOLER thorough examination for telehandlers, cranes, lorry loaders, MEWPs, hoists and excavators used for lifting
LOLER accessory examination for chains, slings, shackles and hooks
PUWER inspection for non-lifting plant such as dumpers, rollers, crushers and saws
PSSR examination under a written scheme for compressors and air receivers above the size threshold
Work at Height inspection for harnesses, lanyards and mobile access towers
COSHH thorough examination and test for dust extraction units
Who Holds the Duty When a Machine Is on Hire?
Both of you do. HSE's equipment hire guidance treats a hire company as a supplier under section 6 of the Health and Safety at Work Act, which covers pre-hire testing and inspection and passing on safety information. You also carry PUWER and LOLER duties to the extent you control the equipment, including making sure thorough examinations and inspections happen at the required intervals.
The customer has duties too. HSE's position on hired lifting equipment is that the user always has a duty to comply with the thorough examination requirements, and should check at the outset that a current report exists. HSE also notes that, in practice, those examinations are usually carried out by or for the hire company. Daily pre-use checks sit with the user unless the hire agreement says otherwise.
In our experience this shared duty is the single biggest misunderstanding around hire, and it cuts both ways. It is not limited to lifting equipment either, because PUWER applies to hire equipment in the same way it applies to owned kit.
Proof of the Last Examination Goes Out With the Machine
LOLER regulation 9(4), PUWER regulation 6(4) and regulation 12(5) of the Work at Height Regulations all say the same thing. Equipment cannot leave your business, or be used by the customer's business, unless it is accompanied by physical evidence that the last required examination or inspection was carried out.
Sending a copy of the current report with the delivery paperwork is the simplest way to meet that. It also covers the customer's own check before first use.
LOLER Thorough Examinations for Hired Lifting Equipment
Anything in the fleet that lifts or lowers a load needs LOLER thorough examinations, and under LOLER a load includes a person. Regulation 9(3) sets the maximum gaps:
Every 6 months for equipment that lifts people
Every 6 months for every lifting accessory
Every 12 months for all other lifting equipment
A competent person can set different intervals under a written examination scheme. HSE gives heavy use and corrosive conditions as reasons to examine more often, and very slow deterioration, such as kit that is rarely used and stored dry, as a reason to stretch the gap. Each examination ends in a written report, often called the LOLER certificate, which has to carry the particulars listed in Schedule 1 to LOLER, including the latest date for the next examination.
Some events bring an examination forward. HSE lists accidents and dangerous occurrences, a major change in conditions of use, replacement of parts that are subject to examination, and long periods out of use. That last one matters for yard stock, because a machine that has sat unhired for months may need examining before it goes back out. Kit whose safety depends on how it is installed, such as a goods hoist built up on site, also needs examining after assembly and before use at each new location.
Telehandlers, Cranes and Lorry Loaders
Lifting loads only, these sit on the 12 month interval. Fit a man-riding platform to a telehandler or crane and the combination is lifting people, which moves it to 6 months.
MEWPs, Boom Lifts and Scissor Lifts
Every MEWP lifts people, so every MEWP in a hire fleet is on the 6 month interval, whether the hire sheet calls it a boom lift, a scissor lift or a cherry picker. Hoists that carry passengers are on the same interval.
Excavators Used for Lifting
An excavator that only digs is work equipment under PUWER. Once it lifts, it is lifting equipment, and HSE sets out the conditions: the manufacturer must permit lifting, the machine needs dedicated lifting points marked with a safe working load, it has to be used in line with the manufacturer's instructions, and it must have had a thorough examination. Above one tonne lifting capacity, it should also have a rated capacity indicator and boom check valves.
If a customer plans to lift with the machine, send it out with an excavator LOLER examination already in place rather than a PUWER inspection record alone.
Chains, Slings and Shackles
Lifting accessories run on their own 6 month interval, item by item. A crane's report covers the crane, not the chains and shackles that go out with it, so loose gear needs its own record travelling with it.
Examinations That Fall Due Mid-Hire
On a long hire, the next examination date can land while the machine is on the customer's site. HSE accepts that it may suit the user to organise periodic thorough examinations, but says this should be by written agreement, particularly on long-term hire. Whoever books it, you still see the outcome. LOLER regulation 10 requires the examiner to send the report to the employer and to anyone the equipment was hired from.
The fix is to agree in writing, at the start of any hire likely to outlast the current report, who books the next examination and where the machine will be when it falls due.
PUWER Inspections for Dumpers, Rollers and Other Plant
Plant that does not lift falls under PUWER regulation 6 instead, and the regulation sets no fixed interval. Equipment exposed to conditions that cause deterioration liable to result in danger must be inspected by a competent person at suitable intervals, and again after any exceptional circumstances that could affect its safety. On a hire fleet that usually covers dumpers, rollers, crushers, screeners, mixers and saws.
You set the interval. It should reflect how hard each machine works and what the manufacturer recommends, so a dumper rotating through groundworks sites may need checking more often than kit that spends most of its time on the shelf. The result of each inspection has to be recorded and kept until the next one is recorded.
PSSR Examinations for Compressors and Air Receivers
Pressure plant works differently. Under the Pressure Systems Safety Regulations, a system that can be readily moved between and used in different locations is a mobile system, and for mobile systems the core duties fall on the owner rather than the user. A towable site compressor is the obvious example, which puts the duty squarely on the hire company.
Under Part II of the Pressure Systems Safety Regulations, the owner of a mobile system must:
Have a written scheme of examination, drawn up or certified by a competent person, before the system is operated
Have it examined within the intervals the scheme sets, with the written report arriving within 28 days at the latest
Mark the next examination date on the system, legibly, durably and clearly visible
Give the user the safe operating limits in writing, or mark them on the system
Provide instructions for safe operation and for emergencies
Keep the records at the premises the system is deployed from
Once the date for the next examination has passed, nobody may supply a mobile system for operation until it has been examined again.
The written scheme, examination and record duties fall away where every pressure vessel in a compressed air system is under 250 bar litres, meaning pressure in bar multiplied by internal volume in litres. Pressure systems that form part of a vehicle's braking, control or suspension system are outside PSSR altogether. For everything else, check each model against the threshold rather than assuming, as set out in our guide on whether air compressors need inspecting.
Work at Height Equipment: Harnesses, Lanyards and Access Towers
Harnesses, lanyards and other personal fall protection, along with mobile access towers, come under regulation 12 of the Work at Height Regulations. Kit exposed to conditions that cause deterioration must be inspected at suitable intervals and after exceptional circumstances, with the result recorded and kept until the next inspection. The physical evidence rule applies here too, so none of it should go out on hire without proof of its last inspection.
Towers bring duties that land on the customer. Anything whose safety depends on how it is assembled must be inspected in position after assembly, and a working platform used for construction work, where someone could fall 2 metres or more, must have been inspected within the previous 7 days.
Dust Extraction Units and LEV Testing
If the range includes dust extraction units for cutting, chasing or drilling, HSE treats on-tool extraction as a type of local exhaust ventilation. LEV needs a statutory thorough examination and test by a competent person at least every 14 months. Testing units at the depot on the same programme as the rest of the fleet means the record is in place when a customer asks for it.
Keeping a Hire Fleet Examination Programme on Track
With up to six regimes running on different clocks, the programme matters as much as the examinations. A workable programme covers six things:
A register of every machine and accessory, with its regime and next due date
Examinations booked between hires at the depot, before dates fall due on a customer's site
A check on yard stock that has sat idle for a long period before it goes back out
A copy of the current report sent out with every machine
Written agreement on who books the next examination for any hire likely to outlast the report
An examiner who does not also service the equipment
The last point comes from HSE guidance rather than preference. The competent person carrying out a thorough examination should not be the person who services or maintains the equipment, because they would be assessing their own work.
Our Engineer Surveyors are independent and fully qualified, and larger fleets can be examined over several days at the yard. One fleet we look after runs to 166 pieces of plant, and reports are typically issued within three days of the visit.
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