SiteThe palletiser cell went back into service on Friday night. New light curtain, fitted by your shift sparky after the old one took a hit from a forklift. It tested fine. Everyone went home.
On Monday the insurer's surveyor asks to see the inspection record for it. There's a job card that says "LC replaced, tested OK". No date. No name. No list of what was checked.
Most sites do inspect. Where they fall down is the record. And under PUWER, a record that doesn't show what was looked at is close to no record at all.
What regulation 6 asks for
PUWER regulation 6 covers three cases (regulation 6).
Kit whose safety depends on how it's installed must be inspected after installation and before first use. The same applies after it's assembled at a new site or location.
Kit exposed to conditions that cause deterioration "liable to result in dangerous situations" must be inspected at suitable intervals.
The same kit must also be inspected each time "exceptional circumstances" have put its safety at risk.
The result must be recorded and kept until the next inspection is recorded. And kit that leaves your site, or comes in from someone else's, must carry physical evidence that its last inspection was done.
Lifting equipment sits outside regulation 6. It has its own thorough examination regime under LOLER. Our post on LOLER thorough examinations covers that, and forklifts need both.
Does this machine need one?
Not everything does. The test in the code of practice is significant risk. That means a risk that could result in an imminent failure leading to a major injury, from bad installation, deterioration or exceptional circumstances (L22, paragraph 83).
The code of practice lists the kind of kit that may need inspecting. It includes machines where people approach the danger zone in normal running, "complex automated equipment" and "integrated production lines" (L22, paragraph 98). Hand tools, office furniture and non-powered machinery are unlikely to need one (L22, paragraph 99).
On a typical site, that puts your case packers, palletisers, robot cells and anything guarded by a light curtain or mat on the list.
Pre-use checks don't count
The operator's walk-round before start-up is useful. But for regulation 6, inspection "does not include a pre-use check" by the operator, and pre-use checks don't need recording (L22, paragraph 81).
Inspection is also separate from maintenance, though some checks overlap. So a PPM job card that says "greased, belts checked" isn't an inspection record for the guards and interlocks on that machine.
What to look at, and how often
The inspection should include visual checks, functional checks and testing where needed (L22, paragraph 86). It should always cover the safety-related parts, "for example overload warning devices and limit switches" (L22, paragraph 87). On most lines we'd add interlocks, light curtains, e-stops and two-hand controls. Our post on testing emergency stops has more.
There's no fixed interval in the law. Frequency should be based on how fast the kit deteriorates, how it's used and where (L22, paragraph 100). HSE's inspection page adds that gaps can be stretched if the history shows "negligible deterioration", or shortened if experience says so (HSE, inspection of work equipment). That's why the record matters. Without it, you can't justify either change.
After a breakdown, inspect before restart
Exceptional circumstances include "major modifications, refurbishment or repair work", known or suspected serious damage, and a long spell out of use (L22, paragraph 102).
Read that list with the palletiser cell in mind. A forklift strike on a light curtain is serious damage. Replacing it is a safety-critical repair. So an inspection is due before it goes back into production, and the person who fitted it has to be competent to do it and record it.
This is where not having the right engineer costs you. If your fitter can swap the part but can't inspect and sign off the safety function, the machine sits idle until someone who can turns up. Or it runs without the check. Neither is a good night.
The same goes for the restart after a long shut. Our post on the January restart looks at why lines fail after a break.
Who can inspect
The person must be competent, with "the necessary knowledge and experience" (L22, paragraph 91). Two jobs are split here. Someone decides what the inspection includes, how and when. Someone else can carry it out. Both can be in-house (L22, paragraphs 92 and 93).
The person carrying it out needs to know what to look at, what to look for, and what to do when they find a problem. That last part counts: reporting faults, making a record, and who to report to.
The nine things to write down
Records can be on paper or electronic, "from a pre-printed form to an entry in a diary" (L22, paragraph 103). There's no legal format. But the code of practice suggests nine items:
- Type and model of the equipment
- Any identification mark or number
- Its normal location
- The date of the inspection
- Who carried it out
- Any faults
- Any action taken
- Who the faults were reported to
- The date repairs or other action were done
Go back to Friday's job card. It has none of the first seven, and the last two weren't needed. A one-page form on the machine fixes that.
HSE also warns against overdoing it. Asking for too much detail too often risks "a superficial 'tick box' approach" (HSE, inspection of work equipment). Keep the form short and specific to the machine.
Physical evidence on the kit
For large kit, a copy of the last record will do. For smaller items, a tag, colour code or label works. Either way, a user should be able to see whether an inspection has been done, whether it's current, and link back to the record (L22, paragraph 105).
Anything hired in should arrive with that evidence. Check it at goods in.
Our view
Inspections that live in someone's head don't survive a sick day, a resignation or a surveyor. Write them down, keep them with the machine's history, and make the post-repair inspection part of the repair. If the person fixing it can't do that bit, you've found a skills gap worth closing. The record also feeds your breakdown log, so you can see which machines keep coming back.
What to do on Monday
- List every machine on site with a light curtain, mat, interlock or robot cell. Mark which ones have a current inspection record.
- Make a one-page inspection form with the nine items above, and pin one to each of those machines.
- Add a line to your breakdown procedure: safety-related repair means inspect and record before restart.
- Check who on each shift is competent to inspect and sign off. Note the shifts with nobody.
* Regulation text and HSE guidance correct as of 1 September 2026. Check PUWER regulation 6 on legislation.gov.uk and HSE's inspection page for the latest. Paragraph numbers refer to L22, fourth edition (2014, amended 2018).