Search

The Provision and Use of Work Equipment Regulations 1998 (PUWER) in UK Aviation

The Provision and Use of Work Equipment Regulations 1998 (PUWER) in UK Aviation

The Provision and Use of Work Equipment Regulations 1998 (PUWER) is a UK regulation designed to ensure that work equipment is safe, suitable, and properly maintained. It applies to all employers, self-employed individuals, and anyone who has control over work equipment used in the workplace.

Posted

13.10.2025

Written by

Paul Cullinan

This article is designed to highlight the value of carrying out a full PUWER Assessment as soon as reasonably practicable to mitigate the risks involved with the operation of work equipment assets to reduce risks to as low as is reasonably practicable (ALARP), from design, to in use, for the continued use of operatives and ultimately disposal or refurbishment.

Finch Consulting has extensive expertise and experience in the field of Asset Management and will ensure the continuity of operations, safeguard employees and customers and preserve valuable business assets through the adoption of asset management principles.

PUWER Applications in Aviation

The Provision and Use of Work Equipment Regulations 1998 (PUWER) are applicable in a variety of applications in the aviation industry, such as:

  • Ground operations: Equipment like baggage handling systems, aircraft towing vehicles, refuelling rigs, and maintenance tools must comply with PUWER.
  • Maintenance and engineering: Tools and machinery used in aircraft maintenance (e.g., jacks, hoists, diagnostic equipment) are subject to PUWER.
  • Airside safety: Mobile equipment such as service vehicles and power presses used in hangars or on the apron must meet PUWER standards.
  • Training and inspection: Aviation employers must ensure that staff using equipment are trained and that equipment is regularly inspected and maintained.

Compliance within Aviation

Aircraft maintenance organisations (e.g. those holding Part 145 approval under UK CAA regulations) must comply with PUWER alongside aviation-specific rules. To comply, organisations must:

  • Conduct risk assessments for all equipment.
  • Ensure regular inspections by a competent person.
  • Maintain equipment logs and service records.
  • Provide training for all equipment users.
  • Integrate PUWER compliance into broader aviation safety management systems. For example:
  • Safety Management Systems (SMS)
  • CAA oversight and audits
  • Maintenance performance initiatives, like those outlined in CAA’s Safety Plan [caa.co.uk]

As well as the PUWER regulations, aircraft maintenance organisations must adhere to the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER), Control of Substances Hazardous to Health 2002 (COSHH), Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) and other regulations as applicable. These regulations, although separate relate to each other closely in the aviation sector. For example, an aircraft jack would be inspected under PUWER but as they are lifting equipment would also need to be inspected under LOLER. COSHH focuses on substance risk, while PUWER ensures the equipment handling those substances is safe. DSEAR mandates risk assessments and controls for explosive atmospheres; PUWER ensures the equipment used in those areas is maintained to prevent ignition sources.

Reducing Maintenance-Induced Errors

The UK Civil Aviation Authority (CAA) has identified maintenance errors as a key safety risk. PUWER helps mitigate this by:

  • Ensuring equipment is fit for purpose
  • Promoting safe working practices
  • Supporting human factors and fatigue risk management

Understanding the Difference Between a PUWER Assessment and a PUWER Inspection

Two key activities that support this duty are PUWER Assessments and PUWER Inspections, each serving distinct but complementary purposes.

Carrying out a PUWER Assessment is essential for several reasons, all rooted in ensuring the safe and compliant use of work equipment in the workplace. A PUWER Assessment carried out by Finch will review the requirements set out in PUWER Regulations 4 through to 24 ensuring a safe and compliant working environment.

PUWER Assessment

A PUWER Assessment is a comprehensive evaluation of work equipment to identify potential risks and determine appropriate control measures. It considers factors such as the equipment’s suitability for the task, its condition, how it is used, and the environment in which it operates.

A PUWER assessment is typically conducted:

  • Before introducing new equipment into the workplace.
  • When there are changes to processes or working conditions.
  • Periodically, as part of an organisation’s risk management strategy.

A PUWER Assessment covers the key risk factors:

1. Equipment Suitability

  • Is the equipment appropriate for the task and environment?
  • Can it operate safely under expected conditions (e.g. high speed, corrosive atmosphere)?
  • Is it adapted or constructed to perform its intended function without introducing hazards?

2. Mechanical and Operational Hazards

  • Moving parts that could cause injury (e.g. entanglement, crushing, cutting)
  • Poorly guarded machinery
  • Unexpected start-up or failure modes

3. Electrical Risks

  • Faulty wiring or insulation
  • Lack of proper grounding
  • Exposure to live components

4. Environmental Conditions

  • Excessive noise, vibration, heat, or cold
  • Risk of chemical exposure or corrosion
  • Poor lighting or ventilation

5. Human Factors

  • Operator competence and training
  • Misuse due to lack of understanding or fatigue
  • Ergonomic risks (e.g. repetitive strain, awkward postures)

6. Maintenance and Wear

  • Deterioration of safety-critical components
  • Lack of scheduled inspections or servicing
  • Inadequate record-keeping of maintenance history

7. Control Measures and Safeguards

  • Missing or ineffective guards, emergency stops, interlocks
  • Inadequate signage or warning systems
  • Absence of personal protective equipment (PPE)

8. Documentation and Compliance

  • Missing risk assessments or inspection records
  • Non-compliance with manufacturer’s safety instructions
  • Failure to meet industry-specific standards

Key Benefits of a PUWER Assessment

  • Legal Compliance: PUWER assessments are a legal requirement in the UK. Failure to comply can result in fines or enforcement action.
  • Risk Reduction: Helps prevent accidents and injuries by identifying and mitigating equipment-related risks.
  • Cost Savings: Preventive maintenance reduces repair costs
  • Operational Efficiency: Can highlight outdated or inefficient equipment, prompting upgrades.
  • Insurance Benefits: Lower premiums with strong safety records
  • Employee Morale: Safer environment boosts engagement
  • Reputation & Responsibility: Demonstrates a commitment to safety, which builds trust with employees and stakeholders.

The goal of a PUWER Assessment is to ensure that all foreseeable risks are addressed and that the equipment complies with PUWER requirements.

PUWER Inspection

A PUWER Inspection, which should be undertaken as part of a PUWER assessment, is a more focused activity aimed at verifying the initial or ongoing safety and integrity of work equipment and helps revalidate the PUWER Assessment. It involves checking for signs of wear, damage, or deterioration that could compromise safety. Inspections are required:

  • Purpose: To ensure that work equipment is safe to use and has not deteriorated in a way that could pose a risk.
  • Scope: Typically involves checking safety-critical components. Can be visual or involve testing and dismantling.
  • Timing:
    • Risk assessment, the primary determinant of inspection frequency.
    • After installation and before first use.
    • After reassembly at a new site.
    • At regular intervals, especially if exposed to conditions causing deterioration or if the equipment is used more frequently.
    • Inspection schedules should align with manufacturers guidance on maintenance and safety checks.
    • Industry requirements may dictate minimum inspection intervals.
    • After exceptional circumstances (e.g. major modifications or damage).
  • Legal Requirement: Mandated under Regulation 6 of PUWER.
  • Who Performs It: Must be done by a competent person who is sufficiently independent to the maintenance organisation.
  • Record Keeping: Inspection results must be recorded and retained until the next inspection.

The goal of a PUWER inspection is to ensure that work equipment remains safe, suitable, and properly maintained throughout its operational life.

Summary

While a PUWER Assessment is about the bigger picture of risk identification and control planning, a PUWER Inspection is more focused on ensuring continued safe operation. Both are essential for demonstrating and maintaining compliance and protecting workers from harm. By completing a thorough PUWER Assessment from the outset, subsequent PUWER inspections will be made more streamlined and efficient by setting a benchmark with a safe and compliant workplace from day one. By implementing PUWER into aviation safety management systems ensures that PUWER is not treated in isolation but as part of a holistic approach to aviation safety. By enforcing equipment standards and training, PUWER contributes to a safer, more reliable maintenance environment, maintainability is improved, and reduced maintenance-related failures are evident across the aviation sector.

Written by

The Provision and Use of Work Equipment Regulations 1998 (PUWER) in UK Aviation

Paul Cullinan

Consultant

View profile

Related insights

The Power of PUWER

03.05.2023 Multiple authors

Machinery manufacturers – Know your duties on producing low-noise machines

05.01.2021 Multiple authors
Further insights

We give you the confidence to be a better business.

Let's talk
Finch Consulting
Privacy Overview

This website uses cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful.