Whilst we are all currently living and working through an ever-changing pandemic it is important to remember that existing H&S legislation still applies and this includes your statutory inspections of equipment and systems. This includes:
- Fire alarm systems, fire extinguishers, emergency lighting and other fire protection systems
- Lifting equipment such as forklift trucks, passenger lifts and lifting platforms
- Pressure systems
- Gas appliances
- Electrical systems
- General work equipment
It may be that your usual contractors are unable to fulfil your usual servicing and inspection regime due to staff availability and implementation of the government social distancing guidelines. If this is the case, how do you then fulfil your statutory requirements?
Some key points:
- Ensure that you have an up to date list of your equipment and systems and the dates of the last and next inspection
- Identify if you need to continue to use this equipment during this time. If not, then you could take it out of use and delay the inspection until needed. Make sure that you communicate any changes to equipment use to those affected and restrict access by locking off or removing keys from circulation where necessary
- Speak to your suppliers. Can they still deliver the planned schedule of inspections within this current time?
- If they can deliver the schedule of inspections do you need to change the way that they access site? Are there other measures that need to be considered to allow the inspection to go ahead safely in line with social distancing guidelines? Make sure you clearly communicate any changes in your procedures in relation to COVID-19; they may need to complete an updated induction
- Speak to your insurance company if you are unable to complete the statutory inspections. Your policy may become invalid if you fail to comply with the required regulations on inspections, servicing and testing
- Check other inspectors and suppliers; there may be company specific reasons for your existing supplier not providing the inspections (i.e. lack of workforce) and therefore others may still be available to help. Before using another company ensure that your due diligence is in place; check for qualifications, safety paperwork and insurance as a minimum
- Use your supplier’s knowledge if they are unable to provide the planned inspection; remember they are likely to be the experts in their specific area of compliance, so will be able to assist with ways to keep equipment operational and also compliant
- Document everything. Keep email trails from suppliers, contractors, experts and colleagues as evidence of your planning and risk assessment process. Update your risk assessments for any change in procedure as a result of equipment being out of action
- Make sure your internal checks and inspections are being completed as normal, where safe to do so
- Don’t forget about planning in inspections for once you are ready to use the equipment again. It is likely that a lot of businesses will be in the same boat and suppliers will be very busy catching up so plan ahead and have a plan for booking equipment in when restrictions have lessened or suppliers are back to work (obviously this will be subject to change based on the development of the pandemic)
We definitely recommend speaking to your supplier teams about specific arrangements for your business in relation to statutory requirements, these include fire risk assessor, legionella management company, thorough examination professionals and, of course, your health and safety adviser.
There has been an extension put into place for MOT examinations from 30th March 2020 onwards, six months for cars and 3 months for lorries, buses and trailers, however you still have to ensure that vehicles are in a safe roadworthy condition. To help comply with this ensure that your drivers are completing documented checks on a regular basis and keep the records of these checks. A risk assessment on this extension in relation to your business will assist you to identify any hazards and control measures that you need to put into place to maintain the safety of your company vehicles and employees. For more information on this specific adjustment please see https://www.gov.uk/guidance/coronavirus-covid-19-mots-for-cars-vans-and-motorcycles-due-from-30-march-2020
Remember, as business owners, the duty rests with you under the Health & Safety at Work Act 1974 to provide a safe workplace and safe equipment; this has not changed in light of the current pandemic and therefore it is essential that you ensure you have reasonably practicable arrangements in place to continue to manage the risks.