PUWER Regulations

PUWER rules are the Provision and Use of Work Equipment Regulations 1998. UK law setting out duties for equipment used at work. They apply to almost anything from hand tools to industrial machinery.

Lifts are treated as work equipment for this purpose, alongside any lifting-specific rules under LOLER.

The core idea behind PUWER rules is straightforward:

• Equipment provided for work must be suitable for the task
• Properly maintained
• Used only by people who have been given the right details
• Instruction and training

Safety and UK rules

For lifts, this sits on top of the more specific needs in LOLER, rather than replacing them.

If you are trying to place PUWER against LOLER for the first time, our difference between LOLER and PUWER guide walks through the distinction with worked examples specific to lifts.

PUWER rules were introduced to bring a consistent standard across all kinds of workplace equipment, rather than relying on separate rules for every category of machinery.

That is why the language of the rules is deliberately general, leaving it to guidance and case-by-case judgement to apply it sensibly to something like a lift.

PUWER rules apply to work equipment mostly. This means any machinery, appliance or tool used by an employee at work.

Because a lift is equipment provided in a workplace, it falls under PUWER whether or not it also happens to be lifting equipment covered separately by LOLER.

The key duties are that equipment must be suitable for the purpose and conditions in which it is used, properly maintained in an efficient state, and accompanied by adequate details, instruction and.

Here, needed, training for anyone who runs or interacts with it. Controls need to be clearly identifiable, and dangerous parts need appropriate guarding.

For a lift, this translates into practical questions:

• Is the lift suitable for the loads and traffic it actually carries
• Is there a maintenance regime in place
• Do staff who run goods lifts or override systems know what they are doing and why

Safety and UK rules

PUWER rules also expect equipment to be used in conditions it was designed for.

A lift specified for occasional passenger use that ends up carrying heavy trolleys daily is a suitability issue under PUWER, quite separate from whether it happens to be passing its LOLER examinations.

PUWER needs equipment to be inspected where there is a risk of deterioration leading to danger.

While LOLER goes further for lifting equipment specially, requiring a formal thorough examination by a competent person at set intervals. Our LOLER thorough examinations guide covers those intervals in full.

In practice, a LOLER thorough examination will often satisfy the equivalent PUWER inspection duty for a lift. Because it is more careful and covers the relevant risks.

But PUWER's wider duties — suitability, maintenance, training, guarding. Still apply and are not automatically ticked off by the LOLER paperwork alone. Our PUWER inspection guide sets this relationship out in more detail.

The practical takeaway is that a duty holder should not treat a passed LOLER examination as proof of full PUWER compliance. It is strong evidence for one part of the picture.

However, the wider PUWER duties need their own separate attention.

PUWER rules mainly place duties on employers for equipment used by their employees. However, the scope is wider than that phrase suggests. Self-employed people using equipment for their own work.

Anyone with control over how equipment is used at a workplace, can also carry PUWER duties.

For a lift, this can mean overlapping duty holders in the same building: the employer whose staff use a goods lift. The landlord or managing agent who controls the equipment more broadly.

Safety and UK rules

As with LOLER, the practical answer is whoever has real control of the lift day-to-day. This needs to be agreed and documented rather than assumed.

In practice, agreeing this in writing at the start of a lease or upkeep agreement avoids the awkward situation where an incident occurs and two parties each assume the other was responsible for PUWER compliance on the lift.

Where an upkeep company sits between the landlord and the firms using the building.

Costs and timescales

That company can also become the practical duty holder for day-to-day PUWER compliance, even if the underlying lease places ultimate responsibility elsewhere.

Clarifying this chain of responsibility in writing removes the ambiguity that otherwise only surfaces once something has already gone wrong.

The most common gap is treating a passed LOLER thorough examination as the whole of the compliance picture and forgetting the separate PUWER duties around training and details.

Staff who run goods lifts, use fireman's override keys, or manage passenger flow onto a lift during an evacuation often have no documented training at all.

Another common gap is suitability. A lift installed years ago for a different pattern of use — lighter loads, fewer daily cycles.

Safety and UK rules

May no longer be suitable for how the building actually uses it now. This is itself a PUWER issue rather than purely a maintenance one.

Keeping simple, dated records of training given.

Costs and timescales

Instructions issued and suitability reviews done goes a long way toward closing these gaps, and costs far less than dealing with an enforcement visit that finds none of it exists.

A further gap appears when a lift is shared between several tenants under one landlord. Each tenant assumes training is somebody else's responsibility.

Without a written agreement setting out who covers which PUWER duty, this kind of gap can persist for years without anyone noticing, until an inspection or an incident forces the question to be answered.

A simple record set is usually enough:

• Who has been trained on which equipment and when
• Any suitability reviews done after a change of use
• A note of maintenance actions taken outside the standard servicing schedule

These records do not need to be elaborate. However, they do need to exist and be dated. So that if an inspector or insurer asks the question.

The duty holder can show the reasoning rather than simply asserting that all is fine.

It also helps to note the date and outcome of each suitability review alongside the training records.

So a duty holder can show a consistent history rather than a single snapshot produced just before an inspection. A simple shared spreadsheet is usually enough.

The discipline of keeping it current matters far more than the format chosen for it.

Picture a small retail unit where staff now and then use the passenger lift to move stock trolleys between floors outside opening hours. Even though the lift was specified for client use only.

Under PUWER rules, this is a suitability question: is the lift being used in a way it was designed for. Have staff been told how to use it safely for that purpose?

If the lift's manual states it is not designed for trolley loads, continuing to use it that way is a PUWER compliance gap regardless of whether the lift is still passing its LOLER thorough examinations.

The fix might be as simple as reviewing suitability, updating instructions, or giving a different route for stock.

This scenario is common precisely because it develops gradually — a lift used slightly outside its original purpose, with nobody deciding that formally.

A short annual review of how equipment is actually being used, compared with what it was designed for, catches this kind of drift before it becomes a bigger problem.

A duty holder should be able to answer a handful of questions at any time:

• Is the lift suitable for how it is actually used
• Is there a current maintenance arrangement in place
• Are LOLER thorough examinations up to date
• Can training records be produced for anyone with special access such as override keys

Where control of a lift is shared — a landlord and several tenant firms, for example. The duty-holder checklist should be reviewed by all parties together rather than each assuming somebody else holds it.

A written agreement on who checks what, and how often, avoids gaps opening up between separate responsibilities.

It is also worth keeping a simple log of any change in how the lift is used, such as a new tenant bringing in heavier stock or more frequent deliveries.

Since these changes are exactly what PUWER's suitability duty is designed to catch.

"Suitable" under PUWER does not mean the equipment merely works. It means the equipment is appropriate for the actual conditions and loads it experiences.

This can change over a building's life even if the lift itself has not been altered.

A "competent person" for a LOLER thorough examination is a specific, accredited role. Distinct from the general PUWER duty to give staff adequate "details, instruction and training" to use equipment safely.

The two terms sound similar but describe different duties. Confusing them is a common source of compliance gaps.

"Maintained" under PUWER means kept in an efficient working order and in good repair. This is a slightly broader idea than simply having a maintenance contract in place.

The contract needs to actually be giving that standard, not just existing on paper.

PUWER rules do not need a lift to be replaced simply because it is old.

However, the suitability duty does become harder to satisfy as components age and the equipment's original design assumptions drift further from how the building actually uses it today.

What it involves

Where a lift is heading toward upgrade work for other reasons — out of date parts. Rising breakdown rates — it is worth reviewing suitability at the same time.

Since an upgrade work project is a natural point to correct any drift between the lift's design and its actual duty, rather than simply replacing like for like.

A duty holder who has already documented a suitability review, even an informal one.

Is in a much stronger position if an inspector or insurer later questions why an older lift is still in service.

Because it shows the equipment's continued use has been actively considered rather than assumed.

When a building changes hands, or a maintenance contract moves to a new provider, PUWER-relevant records should transfer with it:

• Training logs
• Suitability reviews
• Any notes on how the lift is actually used day to day

Without this, a new duty holder effectively starts from zero and may unknowingly repeat old mistakes.

A clean handover pack for PUWER purposes does not need to be wide — a short suitability statement, a training record template, and a note of any known limitations on the lift's use is usually enough to give a new duty holder a working starting point rather than a blank page.

This matters especially at lease renewal or change of tenant, where responsibility for day-to-day use of the lift often shifts even though the equipment itself does not change.

Treating this as a formal handover point, rather than an informal conversation, closes a common gap in PUWER compliance.

"Details and instruction" under PUWER rules means staff need to be told how to use equipment safely, in a form they can actually understand.

Before they use it — not simply given a manual to read at their own convenience whenever they get around to it.

What it involves

"Efficient state" is the phrase PUWER uses for maintenance. It means the equipment performs as intended without too much wear or risk.

This is a slightly different bar than simply being working on any given day. A lift can technically run while still failing this standard.

Safety and UK rules

"Dangerous parts" refers to components that could cause injury if accessed inappropriately, such as exposed mechanisms in a machine room. PUWER expects these to be guarded or otherwise controlled.

This for a lift usually means restricted access to plant rooms rather than physical guards on the lift car itself.

What to check and report

It is also worth distinguishing "inspection" from "thorough examination" in PUWER language. An inspection can be a simpler visual or functional check done by a trained person on site.

Whereas a thorough examination under LOLER must be done by an independent competent person and follows a defined legal format.