Guarding: PUWER regulation 11 and the order of guards

It's 1am. The head drum bearing on the main take-away conveyor has collapsed. Your fitter gets the mesh guard off, swaps the bearing and lines up the drum. It's taken two hours. Despatch wants it running.

Two of the guard bolts have gone down the back of the frame. So the guard goes back on with cable ties, "just for tonight". Three weeks later, it's still on cable ties. An operator leans on it to clear a jam at the tail.

Sites rarely set out to run without guards. They lose them a bit at a time, at the end of a breakdown, when the guard is the last job and everyone's tired.

What regulation 11 asks for

PUWER regulation 11 sets two aims. Either stop people reaching dangerous parts of machinery, or stop the movement of those parts "before any part of a person enters a danger zone" (regulation 11).

A dangerous part has a wide meaning. The code of practice, L22, says that if a part "could cause injury, while being used in a foreseeable way", it can be considered dangerous (L22, paragraph 141).

The order of guards

Regulation 11(2) gives a strict order. You move down a level only where the one above isn't practicable:

1. fixed guards enclosing every dangerous part
2. other guards or protection devices, such as interlocked guards, light curtains and pressure mats
3. jigs, holders, push-sticks and similar protection appliances
4. information, instruction, training and supervision

L22 says the measures "are ranked in the order they should be implemented". It also says information, instruction, training and supervision are needed whatever level you use (L22, paragraph 145). You start at the top and keep working down until the risk is low enough (L22, paragraph 147).

So a sign saying "keep hands clear" doesn't stand in for a guard. It sits under one.

What counts as a fixed guard

L22 is precise. Fixed guards have no moving parts. They're held in place by welding or by fasteners, "making removal/opening impossible without using tools" (L22, Appendix 1, paragraph 1).

By that definition, a panel held on with cable ties or bungees doesn't meet the first level. Nor does one that lifts off by hand. Wing nuts are worth a hard look too.

Guards that don't fully enclose come lower down. L22 says fixed distance guards and adjustable guards should only be used where enclosing guards or protection devices aren't practicable (L22, Appendix 1, paragraph 8). Where a guard has gaps or mesh, the openings must stop people reaching the danger zone. Safe reach distances are set out in BS EN ISO 13857* (L22, Appendix 1, paragraph 22).

Where people need frequent access, L22 says you may need to choose between an interlocked movable guard and a protection device (L22, Appendix 1, paragraph 7). Our post on interlocked guards and how they get defeated covers the next level down.

The rules every guard must meet

Regulation 11(3) lists what every guard and protection device must do. Among them, guards must be:

• suitable, well built and strong enough
• "maintained in an efficient state, in efficient working order and in good repair"
• not a hazard themselves
• "not be easily bypassed or disabled"
• far enough from the danger zone
• built so that parts can be fitted and maintenance done, ideally without taking the guard off

(regulation 11(3))

L22 doesn't soften the maintenance point. It says "many accidents have occurred when guards have not been maintained" (L22, Appendix 1, paragraph 13).

Breakdowns are where guarding slips

L22 makes a point that matters on every breakdown. Your risk assessment should cover setting, maintenance, cleaning and repair, as well as normal running. Parts that aren't dangerous in normal use "may become accessible and therefore dangerous" during that work (L22, paragraph 149).

L22 also explains why it prefers guards that don't have to come off. After reassembly, the guard "may not work to its original performance standard" (L22, Appendix 1, paragraph 34). So every guard that comes off on a breakdown is a guard that might go back on wrong.

PUWER regulation 22 adds that kit should be built or adapted so that risky maintenance can be done while it's shut down, so far as reasonably practicable (regulation 22).

Take the conveyor. L22 uses it as an example. There's a risk of entanglement on the shafts, and of being trapped "by the intake between drum and moving belt" (L22, paragraph 148). That's exactly the guard that went back on with cable ties.

Our view

Here's what we think. Guards go back on properly before the line restarts. No exceptions for "just tonight". If bolts are lost, the job isn't finished, and the restart waits. Put the guard check on the sign-off, as set out in who signs off the restart.

The fix is mostly kit and planning. Keep spare guard fasteners in the breakdown bag. Keep a captive-fastener kit in the stores. A temporary guard repair is one of the temporary fixes that quietly become permanent, so log it as an open job with a date.

And watch the cost. A fitter on their own at 1am, two hours into a job, will cut corners to get the line back. A second pair of hands, or someone who can fabricate a proper guard bracket, often costs less than the hour of downtime you lose arguing about it. If your fitters are always on their own, that's a cover problem as much as a guarding one.

What to do on Monday

1. Walk your lines. Look for guards held with cable ties, bungees or missing bolts, and log each one as a job.
2. Add "guards refitted with all fasteners" to your breakdown restart sign-off.
3. Put spare guard fasteners in every breakdown kit.
4. Pick the guard that comes off most often. Ask whether an interlocked or hinged guard would stop it coming off at all.

* The reference to BS EN ISO 13857 for safe reach distances correct as of 19 October 2026. Check PUWER on legislation.gov.uk and L22 on HSE's website for the latest. Paragraph numbers refer to L22, fourth edition (2014, amended 2018).