I would like to fully endorse the important message regarding the importance of inspecting all elements of a fork lift truck, and not limiting this to the lifting function. However, the article while not wholly inaccurate, uses misleading language, suggesting that unless the duty holder/owner employs a CFTS approved supplier they will not get a thorough examination of their fork lift truck as only LOLER is considered.
In fact, the LOLER ACOP does consider these elements. The ACOP to the regulations at section 340 states: Some parts of the equipment may need inspection to meet the requirements of PUWER, for example a forklift truck must be thoroughly examined under LOLER and must be inspected under PUWER. Where the person doing the work is a competent person under both sets of Regulations, these examinations and inspections can be conducted together.
Another important point to consider, which is not mentioned in the article, is the importance of competence, independence and impartiality. Again, the ACOP to the regulations states the following, some key points for owners and duty holders are picked out in bold text:
296 You should ensure that the person carrying out a thorough examination has such appropriate practical and theoretical knowledge and experience of the lifting equipment to be thoroughly examined as will enable them to detect defects or weaknesses and to assess their importance in relation to the safety and continued use of the lifting equipment298 It is the employer’s duty to ensure that they employ a suitably qualified competent person to carry out the thorough examination. LOLER does not expressly preclude the person carrying out the maintenance from also conducting the thorough examination. However, the competent person who carries out the thorough examination should not normally be the same person who performs routine maintenance operations on the equipment except where the risk of injury to others is low. This is to ensure that there is independence between the thorough examination and the maintenance and to avoid an individual examining their own work. When these functions are carried out by different people, the additional safety aspect of having a second person checking the equipment makes it more likely that defects will be identified and rectified.
299 Where the thorough examination is undertaken by the same person who has maintained the equipment, your risk assessment should show you have considered all the options, how you reached your decision about who should carry out these functions, and also show that the person is suitably qualified and independent to the extent that would be required for another competent person. In these circumstances any maintenance should be carried out after the thorough examination has been undertaken (see paragraph 362 on reporting defects where repairs are carried out immediately).
I would like to point out that the Safety Assessment Federation (SAFed) being the main trade association for inspection bodies in the UK, also provide guidance to their members on the inspection and examination of fork lift trucks, which, in line with the LOLER ACOP also includes the non LOLER elements. SAFed has circa 50 full members, which include all the major independent inspection bodies in the UK, and around the same number of associate members.
All SAFed full members are required to have accreditation through UKAS to ISO 17020 Requirements for the operation of various types of bodies performing inspection. This accreditation demonstrates, amongst other things, competence, independence and impartiality. Associate members are required to demonstrate these qualities to gain membership in lieu of ISO accreditation.
There are also a growing number of independent inspection companies, and many are members of the Independent National Inspection and Testing Association (INITA) who also demand demonstration of the above qualities, which are so important to delivering a credible inspection service.
SAFed and INITA along with the main inspection bodies in the UK are corporate partners of the SOE, and represented on the professional sector committee the Bureaux of Engineer Surveyors (BES). This professional body strives to influence industry for the betterment of the inspection sector, and to share information amongst members driving up quality and competence.
Therefore, when selecting a provider for inspection tasks it is important to look further than just the comprehensiveness of the physical examination and inspection, but how is competence, independence and impartiality demonstrated by the inspection body – especially if that body also completes the maintenance.
SAFed, INITA and SOE members are suitably independent and will provide a competent and compliant inspection and examination of the equipment.