There's a ring binder on the shelf in the maintenance office. "Risk Assessments" on the spine. Forty pages inside, most of them about slips, trips and manual handling. Every new starter signed the back page on day one.
It's 3am. The case erector has jammed, and the fitter on shift is already reaching for the guard. Nobody has opened the binder since the auditor came round. Nobody's going to open it now.
The binder ticks a box. It does nothing for the person with an arm in the machine.
Most maintenance risk assessments fail because they were written for the audit. The fitter was never the reader.
What the law asks for
The Management Regulations ask every employer for a "suitable and sufficient" assessment of the risks to their own people and to anyone else their work affects (regulation 3). You review it if you suspect it's out of date or something significant has changed. If you employ five or more people*, you record the significant findings.
So the law wants the thinking done and the main findings written down. It doesn't ask for 40 pages.
HSE's own steps for managing risk tell you to take account of "non-routine operations, such as maintenance". They also say "Do not rely purely on paperwork" (HSE, managing risk). And your people are owed "comprehensible and relevant information" on the risks you found (regulation 10). A binder in the office, written in legal English, struggles on both counts.
Maintenance is the odd one out
Your production risk assessment covers the machine running, guards on, operator at the HMI. Maintenance is the same machine with the guards off and someone inside it.
HSE says maintenance "always involves non-routine activities" and may have to happen at short notice after a breakdown. It also says unsafe maintenance "has caused many fatalities and serious injuries" (HSE, maintenance). The hazards are different. Air left in the receiver. A lift table that's up. A knife bar that can drop. A gearbox that's still hot.
A generic sheet that says "isolate machine before work" misses all of that.
One task, one page
Here's our view. Write them per task, per machine, at the machine, with the fitter who does the job. One page each. Start with your common breakdowns, because those are the jobs done in a hurry.
Each page needs:
- the task in the fitter's words: "clear a jam in the case erector magazine"
- every energy source and where it's isolated, with the isolator number
- what stays live or loaded after isolation, and how you dump it
- anything that can fall or move under gravity, and how you prop it
- who is competent to do the job
- who else is nearby, and how you keep them out
- what makes you stop and call for help
HSE's list of what to do before work starts is a good prompt. It includes "release any stored energy, such as compressed air or hydraulic pressure". It also says to support parts that could fall and let hot parts cool (HSE, maintenance). Our guide to safe isolation, lock-off and prove dead goes through it step by step.
Sometimes the page shows a job that can only be done with the machine running. Treat that as a design question. PUWER asks for kit to be built or adapted so maintenance can be done shut down, so far as is reasonably practicable (regulation 22). The code of practice says to consider this when you do your risk assessment. Where the kit must run, it suggests temporary guards or "crawl speed operated by hold-to-run controls" (L22, paragraphs 218 and 221).
The breakdown nobody wrote up
You can't write a page for every fault. Some breakdowns will be new.
HSE accepts this. Maintenance workers "may need to undertake significant on-the-job risk assessment", because the job can change in ways nobody could foresee (HSE, maintenance). So give the shift a short card for the job with no page. Four questions. What's stopped? What's still live or loaded? Who else is here? Am I the right person for this?
That last question is where it goes wrong. The same HSE page says maintenance should only be done by people "competent to do the work". It also tells you to "decide if the work should be done by specialist contractors". Most risk assessments write "competent person" on every line and never say who that is.
At 3am on a servo fault, that gap shows. A good mechanical fitter has a go because nobody else is there. An hour later the call goes out anyway, and the line has been stood the whole time. If you want to see what that hour cost, work it out with our guide to the true cost of an hour of downtime. Then put a name, or a phone number, next to each task.
When a page isn't enough
Some jobs need more than one page. HSE says formal systems such as a permit to work "are required in some cases" for high-risk maintenance (HSE, maintenance). Confined spaces, hot work and work near high voltage are the usual ones. See permits to work: when you need one.
For a long or tricky job, the risk assessment tells you what can hurt you. A method statement for breakdown work sets out the order you do it in.
Contractors need the same page. You must give their employer comprehensible information on the risks on your site and what you do about them (regulation 12). A one-page task sheet does that better than the induction video.
Keep it alive
A risk assessment goes stale the day the machine changes. The law says review it when there's a significant change. HSE adds a review if "your workers have spotted any problems" or there have been accidents or near misses (HSE, managing risk).
The best time is straight after a breakdown. Ask the fitter one question. Did the page match what you found? If it didn't, fix it that week, while everyone still remembers.
What to do on Monday
- Pick your three worst machines. Walk each one with the fitter who knows it best, and write one page per common breakdown task.
- Put each page at the machine, in a sleeve by the isolator.
- Next to every task, name who is competent to do it, and who to call when they're not on shift.
- After the next breakdown, check the page against what you found and fix it that week.
* The five-employee threshold for recording significant findings correct as of 16 September 2026. Check HSE's guidance on managing risk for the latest. Paragraph numbers refer to L22, fourth edition (2014, amended 2018).