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Information

What is a Thorough examination

 A Thorough Examination is a statutory requirement for lifting equipment under the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER 98), Regulation 9. It has the same purpose as an MOT inspection by providing a report which identifies whether or not the lifting equipment is safe to use, and/or advice that needs to be followed to avoid risks in use. It is just as important as an MOT – probably more so! There is a legal requirement for a Thorough  Examination  to  be  carried  out on fork  lift trucks at least once a year,  and often more frequently depending on conditions of use. (See below).

There are legal requirements under the Provision and Use of Work Equipment Regulations 1998 (PUWER 98), Regulation 6. They require all safety aspects of the truck to be inspected, and actions specified to remedy any defects found before they can create risks in use.  To avoid  duplication  of  effort  the inspection  of these other items would normally be carried out within the Thorough Examination.

What does a Thorough examination involve?

A Thorough Examination is the inspection of lifting equipment, as required by LOLER 98, and other safety related components or equipment, as required by PUWER 98. A Competent Person is required to examine these items, check them for serviceability and report accordingly. It is not a full maintenance inspection of the truck. A Thorough Examination is substantially different from a maintenance inspection and the Competent Person has different duties to fulfill under the law.

Although a Thorough Examination covers both regulations, it is a single examination.

Is a Thorough Examination a legal requirement

Yes

Who is responsible for making sure that a fork lift truck has a current Report of Thorough Examination?

In simple terms it is the employer of the operator who has this responsibility. Under Health and Safety legislation the employer has a duty of care – “It shall be the duty of every employer to ensure, as far as is reasonably practical, the health, safety and welfare at work of all his employees”. The employer must ensure that the fork lift trucks that his/her operators use are safe. This is achieved through the implementation of a programme of Thorough Examinations. (It should be remembered that Thorough Examinations run alongside necessary maintenance procedures and checks, not in place of them.)

Where the employer is the owner of the fork lift truck this duty is clear. The employer must make arrangements for every fork lift truck to be Thoroughly Examined on a regular basis, at least once per year. (The actual frequency will be determined by the Competent Person.)

If the employer is not the owner of the truck but leases the truck, or rents it on a long term basis, usually 12 months or more, the responsibility is the same as though the trucks were owned by the employer.

If a fork lift truck is provided on a short term contract, a contract of less than 12 months, then the owner of the truck, the rental company, is responsible for arranging the Thorough Examination. However, the employer must still satisfy himself that such an examination has been conducted at an appropriate time. This can be achieved by insisting that a copy of the current Report of Thorough Examination is provided with other rental documentation.

Does a short term hire truck need a Thorough Examination

Yes – this should come with the fork lift truck when delivered to your site….if not, ask for one

Who can carry out a Thorough Examination

The legislation refers to a Competent Person. For the purpose of Thorough Examination a Competent Person is an experienced service engineer or examiner who meets the general criteria explained in LOLER 98.

For all practical purposes there are 3 types of person who may carry out a Thorough Examination. (Their titles may vary.)

• An authorised fork lift truck service engineer.

• An insurance company lifting equipment examiner.

• An examiner from a specialist inspection company.

The FLTA firmly believes that an experienced fork lift truck service engineer is best placed to conduct Thorough Examinations provided his/her company has a management system that ensures adequate training, instruction, supervision, quality control, independence, impartiality and integrity.

If the fork lift truck does not have a seat belt, will it fail a Thorough Examination?

Not necessarily. For example reach trucks and trucks with stand-on operators do not need to have a seat belt fitted, so it does not apply. In certain circumstances older counterbalance trucks may still be used without a seat belt, but such use should be backed up with a written risk assessment. For further information read the HSE Information Sheet MISC 241.

How often is a Thorough Examination required?

The regulations require routine Thorough Examination on a periodic basis. The FLTA agrees with the BITA GN28 recommendations on intervals for periodic Thorough Examination which are shown in detail below. These guidelines have been issued to HSE Inspectors. There is also a requirement to have a Thorough Examination if the fork lift truck has been involved in a major incident or if it has had significant repairs or renovation. 

Minimum Interval Between Examinations

Operating Circumstances

12 months

Any truck working up to 40 hours per week, without attachments other than a sideshift. (Mandatory)

6 months

Any truck used for elevating persons, no matter how infrequent. (Mandatory)

6 months

Any truck working between 40 and 80 hours per week

6 months

Any attachment not permanently fitted to a truck

4 months

Any truck working in excess of 80 hours per week.

4 months

Any truck working in arduous conditions such as:
Marine environments
Corrosive chemical environments
Metal manufacturing or processing
Cement/aggregate processing, or
where abrasive particles are present
Brine processes
Note: When an attachment is permanently fitted to a truck the attachment will be Thoroughly Examined as though it were part of that truck, at the same time interval as that truck.
Table 1 - Information Extracted from GN 28

What about attachments?

Permanently Attached Sideshifts

If the sideshift is permanently attached to the lift truck, then it can be treated as though it is part of the machine. This means that the frequency of Thorough Examination should be the same as for the truck to which it is attached.

The frequency of Thorough Examination may be varied if there is an examination scheme which determines otherwise or a Competent Person has set a different period, for example, due to its condition, or a design weakness that has come to light during use.

A sideshift may be considered permanently attached if the bottom hangers are bolted in position and it would be usual to expect that an engineer would be required to remove and refit the equipment.

Unattached Sideshifts

If the sideshift is not permanently attached to the lift truck, then it should be treated as a lifting accessory and have a Thorough Examination every six months, or in accordance with an examination scheme.

Visual Inspection of attachments

It is important that the operator of the truck does a visual inspection of the attachment prior to use on EACH occasion. This covers the possibility of someone else having damaged the attachment prior to them using it……remember that the daily inspection will need recording and maybe the easiest way may be to make a note on the daily inspection/pre-shift check sheets.

What if a fork lift truck fails an examination?

Fail is not really the right word. At the time of the Thorough Examination the Competent Person will make a report. On the report he will list any defects he has found.

If there are no defects then the fork lift truck can continue in use.

With defects that do not create imminent risk a timescale may be given within which the faults must be rectified. The defects must be rectified within this period, but meanwhile the equipment may continue in use. Alternatively, the equipment may be taken out of use until the faults have been rectified. The Competent Person will check that the defects have been rectified, within the given period, at the time of the next Thorough Examination.

Where there is a defect that could imminently be of danger to persons, the Competent Person may recommend that the equipment cannot be used until the fault has been rectified. In these circumstances the equipment must be taken out of use immediately. It may not be used again until the defect has been rectified.

Would the competent person report us to the health & safety people?

Not normally. However, he does have a duty to send a copy of his report to the relevant enforcing authority in certain situations. This applies where there is, in his opinion, a defect in the equipment involving an existing or imminent risk of serious personal injury. This requirement is limited to those cases where there would be a risk of serious personal injury arising from failure of the equipment should anyone attempt to use it. Examples would be a broken link in a chain or a cracked brake pipe.

We have a maintenance contract with a local fork lift truck company, will this include the Thorough Examination?

No. Thorough Examination is not part of the maintenance schedule, it is a separate safety inspection.

If the Thorough Examination is arranged with the same fork lift truck company with which you have a maintenance agreement then they will no doubt arrange and invoice the Thorough Examination separately. You should expect it to be carried out by a different engineer to the one who usually services and/or repairs the truck. This other engineer may also be able to carry out the next due service, but he will treat the Thorough Examination and the service as two different events. This is because he is required to carry out, and report on the Thorough Examination as a specific safety inspection, just like an MOT.

Can the service and thorough examination be done together to save on costs?

No. The Thorough Examination is a specific legal requirement and must be completed as such. It may be that faults are found that the Competent Person can fix, if they are also a service engineer, before they leave your site. That’s fine. That’s one of the benefits of using a Competent Person from a fork lift truck company. However, it should be remembered that the Competent Person is legally obliged to comment on safety related faults in the Report of Thorough Examination. That way a true record of the equipment is being kept. That’s in everyone’s best interests, especially the employer.

I only use the truck 10 mins per week, so I don’t need it doing.

You are wrong. The requirements for Thorough Examination apply to all fork lift trucks, no matter how infrequently they are used.