The Power of PUWER
The food and drink industry is buried in PUWER issues.
The easiest and least expensive aspect of keeping equipment safe is ticking the “checklist” known as the “PUWER assessment”. The hardest and most expensive aspects are designing solutions to the problems, raising the money, finding the time and skills to implement the solutions and then maintaining their efficacy over the lifetime of the equipment.
Finch specialises in improving asset, process safety and health and safety management. As well as advising clients and helping develop industry standards, our people are often instructed as expert witnesses in complex litigation.
Over several decades, Finch has worked with many food and drink manufacturers globally to help successfully tackle the hardest and most expensive aspects of equipment safety within a good system of management, including a “design checklist” at the very first stages of equipment specification.
Unfortunately, we have also seen that a disproportionately high number have only just started or only completed the easiest and least expensive aspects. This is evidenced by the many tens of thousands of outstanding issues in thousands of PUWER assessments stored in the cloud.
It makes business sense to keep people safe. Employees’ sense of safety is linked to their productivity, loyalty to the brand and engagement in improving the business. The intention of health and safety laws and standards is not to make life difficult; it is to keep people safe. It is simply good business.
The Provision and Use of Work Equipment Regulations 1998 (“PUWER”) is a piece of health and safety legislation with which many food manufacturers in Britain will be familiar. In our many experiences from the shopfloor to the courtroom, Finch has seen equipment safety managed with various levels of maturity. At one extreme, “PUWER” will not feature in the food and drink manufacturer’s language or is seen as a box-ticking exercise. At the other extreme, keeping equipment safe is normal and central to the culture, and PUWER compliance is embedded and integrated into equipment buying and asset management systems. In these organisations, we often see this culture benefits other areas of the business.
The majority of food and drink manufacturers fall somewhere around the middle ground: trying hard to maintain equipment to keep it safe and carrying out many PUWER assessments to demonstrate compliance. It is in this middle ground that there is a potential problem.
A PUWER assessment is not the end of the process, it is a means to an end. The law does not require you to stop at a PUWER assessment, the law requires you to control the hazards and manage the risks. A PUWER assessment is only part of the Plan-Do-Check-Act (PDCA) cycle. It is perhaps the smallest and least expensive part of the job.
Often finding the problem – the PUWER assessment – is the easy part. Finding a range of solutions then prioritising, selecting and justifying the right one, progressively implementing fixes, and keeping them effective for life and learning from the experience is by far the hardest and most expensive part of the job.
In this middle ground, where there are many tens of thousands of outstanding issues and improvement actions across the sector, are there many pieces of unsafe equipment in use?
There are many reasons that food and drink manufacturers do not follow up on PUWER assessments. Even if they start solving the problems and issues, it is common that they don’t sustain the time, effort and investment needed. Unfortunately, this can result in expensive and low-value repetition of assessments every few years because confidence in the last ones done has waned or they have forgotten altogether.
We advocate that the first step in resolving this problem is to change the mindset before starting PUWER assessments and engaging a third party. The first thought should not be “We need to be PUWER compliant, and we need an assessment”, it should be to ask your people or your next PUWER consultant, “How are you going to help us manage the many simple and complex issues this PUWER assessment will reveal, and can and will you help us design the solutions and control the risks?”
In other words, plan your exit before you invest (but do invest and make sure it is sustainable for your business).
If you have any PUWER requirements or wider needs for asset management, please contact [email protected] 01530 412777.