PUWER for maintenance managers: what the regulations actually ask

It's Tuesday afternoon. The case packer has been running for three weeks with a cable tie holding the door switch in. Everyone knows. The new switch is on order, the line is busy, and nobody's been hurt.

Your night fitter is a good mechanical hand. Last week they swapped a servo drive on the same machine because nobody else was on. It worked. Nobody asked whether they'd done one before.

Ask most managers what PUWER covers and they'll say guards. Guards matter. But read the regulations with a maintenance hat on and most of them are about your team. Who is allowed to work on which machine. What "maintained" means. Whether the kit lets you work on it safely at all.

Maintenance counts as use

Start with one definition, because everything else hangs off it. In PUWER, "use" of work equipment means any activity involving it. That includes "repairing, modifying, maintaining, servicing and cleaning" (regulation 2).

So when PUWER talks about the people who use a machine, it means your fitters as much as your operators. The training duty, the information duty and the specific risk duty all apply to the person with the spanners.

"Efficient" means safe, not fast

Regulation 5 says work equipment must be kept "in an efficient state, in efficient working order and in good repair" (regulation 5). Production hears "efficient" and thinks output. The code of practice says the word is about health and safety and "not concerned with productivity" (L22, paragraph 70).

That changes the conversation. The cable-tied door switch is a maintenance failure under PUWER even if the packer is hitting its numbers.

The code of practice makes a sharp point about why. A fault that hits production shows up fast. A fault in a safety system "could remain undetected" unless your maintenance includes safety checks (L22, paragraph 71). Where safety-critical parts could fail and leave a hidden risk, you need a formal system of planned or condition-based maintenance (L22, paragraph 75). If your PPM sheets only cover the bits that stop the line, that's the gap. Our guide to building a PPM schedule from the manual shows how to pull the safety checks in.

One myth to clear up. You don't have to keep a maintenance log. But if a machine has one, it must be kept up to date (regulation 5). A log with a two-year gap is worse than no log, because it shows you started and stopped.

The right person on the right kit

This is the part that bites at 2am.

Where a machine carries a specific risk, regulation 7 limits repairs, maintenance and servicing to people "specifically designated" for that work. Those people must have had adequate training for it (regulation 7). The code of practice adds that maintenance should only be done by people competent to do the work (L22, paragraph 79).

Think about the servo drive again. If your fitter wasn't trained on it, the swap was a gamble with their safety, and with your name on it. And when the one person who is competent on that machine is on leave, the law doesn't let you hand the job to whoever's free. You either have a second competent person, or you get one in. Our post on what to do when the only person who knows the machine is on holiday covers the cover side.

Here's the cost nobody budgets for. Without the right engineer, the choice at 2am is a stopped line or an unsafe fix. Both cost money. Only one gets written up when it goes wrong.

Training applies to you too. Regulation 9 covers anyone who "supervises or manages the use of work equipment" (regulation 9). If you sign off the work, you need to know enough to judge it. Keep the evidence. Our post on training records has what to keep.

Can the kit be worked on safely?

Two regulations deal with the machine itself.

Regulation 19 says equipment must have suitable means to isolate it from all its sources of energy, and those means must be "clearly identifiable and readily accessible" (regulation 19). The code of practice is clear that interlocked guards and e-stops "are not suitable as a means of isolation" (L22, paragraph 195). If the only isolator for the palletiser is behind a stack of pallets, or nobody can tell which one it is, that's a PUWER problem before anyone picks up a tool. Our guide to safe isolation goes through the steps.

Regulation 22 asks for equipment built or adapted so that, so far as is reasonably practicable, risky maintenance can be done "while the work equipment is shut down" (regulation 22). Where it has to run, the code of practice gives examples of what to add: temporary guards, limited movement controls, and crawl speed on hold-to-run controls (L22, paragraph 221).

So if your fitters can only set up the wrapper with a guard open and the machine at full speed, the fix is a design change, not a reminder to be careful.

Guards still matter

Regulation 11 sets an order for guarding. Fixed guards first where practicable. Then other guards or protection devices. Then jigs and push-sticks. Information, training and supervision come last (regulation 11). Guards must also not be "easily bypassed or disabled".

A cable tie in a door switch is exactly that. Our post on guarding and the order of guards goes further.

Hired kit and shared kit

If the kit is hired, agree in writing who does the safety-related maintenance. The code of practice says both the hire firm and the hirer should "agree exactly what they are responsible for" (L22, paragraph 77). Do it when the kit arrives, not when it breaks.

Our view

Read as a whole, PUWER is a maintenance standard with guarding inside it. It asks four things of you: keep the safety parts working, let only competent people work on risky kit, make the kit safe to work on, and keep the records honest.

The one that costs most when it's missing is the second. You can buy a switch overnight. A competent engineer for that machine, at that hour, takes planning.

What to do on Monday

1. Walk the floor and list every bodge on a safety device: cable ties, taped switches, bridged interlocks. Give each one an owner and a date.
2. For your five most critical machines, write down who is competent to repair them. If the answer is one name, plan the cover now.
3. Check your PPM sheets include safety checks as well as production checks.
4. Find every isolator on those five machines. Can a stranger find and identify each one in under a minute?

* Regulation text and HSE guidance correct as of 29 August 2026. Check PUWER on legislation.gov.uk and HSE's PUWER pages for the latest. Paragraph numbers refer to L22, fourth edition (2014, amended 2018).