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Thorough Examination FAQ

Below is a list of frequently asked questions on PUWER 98, LOLER 98 and Thorough Examination. If you can't find what you are looking for then please contact us.

1. 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 question 12.)

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.

2. What is a Chain & Forks Inspection?

This is the name often used for inspections under old legislation. As a term it is out of date. A Thorough Examination includes the inspection of chains and forks, but much more besides.

and an equally short test answer

3. What is a LOLER Inspection?

The term LOLER Inspection is sometimes used, incorrectly, to describe a Thorough Examination. It is used because LOLER is the shortened version of “Lifting Operations and Lifting Equipment Regulations 1998”. These regulations, and the associated Approved Code of Practice, prescribe the format to be used for the Report of a Thorough Examination. It is safest to stick to the term Thorough Examination.

4. What is a Safety Inspection?

Safety Inspection is a term sometimes used to describe Thorough Examination under LOLER 98 and other inspection requirements under PUWER 98. To avoid confusion the FLTA embraces both requirements within the term Thorough Examination.

5. What does a Thorough Examination involve? What is examined?

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 fulfil under the law.

Although a Thorough Examination covers both regulations, it is a single examination. The relationship to the regulations is shown below. (This is an explanation, not an exhaustive list.)

LOLER 98		PUWER 98
examine		examine

Chains		Brakes
Forks		Steering
Mast		Seat Restraints
Carriage		Overhead Guard
Tilt Mechanism		Tyres

6. Is a Thorough Examination a legal requirement?

Yes

7. 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.

8. How do I know that a hired fork lift truck has a current Report of Thorough Examination?

Demand to see a copy of the report.

9. 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.

10. Can my own engineer carry out a Thorough Examination?

(This is a question asked by a variety of companies that own their own fork lift trucks and use their own engineers to service them, along with other plant, lorries, vans etc. The answer below is not directed at fork lift truck companies.)

The safest answer is probably not, in the same way that you probably cannot carry out your own MOT inspections. There are a number of important issues here.

• Someone, who is competent to do so, must authorise the engineer as a Competent Person for the purpose of conducting Thorough Examinations.

• The engineer must have an appropriate level of experience and training. In the FLTA we recommend a minimum of 5 years’ experience as a fork lift truck service engineer and successful completion of a Thorough Examination course. Further, we recommend revalidation every 5 years.

• The Competent Person needs to be independent from the routine maintenance of the fork lift truck. This means that there needs to be a number of suitably qualified engineers, and a management system to properly control them.

11. If the fork lift truck does not have a seat belt will it fail the 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.

12. 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 in Table 1 on the following page. 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 truck 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

13. What about sideshifts?

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.

14. What happens if the fork lift truck fails the Thorough 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.

15. Will 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.

16. Our van has an MOT certificate, should we have one for our fork lift truck?

No. The MOT inspection does not apply to a fork lift truck, but it must have a Thorough Examination instead.

Regardless of who carries out the Thorough Examination you should receive a “Report of Thorough Examination”, signed by the Competent Person. You are required to keep this safe, so it is perhaps best to keep it on the truck file, or somewhere similar. When the next Thorough Examination is due the person who carries it out will ask to see the last report. Safety inspectors and enforcement officers may ask to see it too.

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

Probably not. Thorough Examination is not part of the maintenance schedule, it is a separate safety inspection. You may have a contract that includes it, but it should be stated separately and agreed as an additional item.

If you look at the answer to question 9 you will see that different types of people can carry out a Thorough Examination. Your company may own cranes and hydraulic jacks and other lifting equipment. You may decide to maintain your fork lift trucks with a fork lift truck company, but have all your lifting equipment Thoroughly Examined by a specialist inspection company.

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.

18. Can't the Thorough Examination and service be done all together? It would be quicker and cheaper!

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.

19. I only use my fork lift truck for 10 minutes each week to offload a delivery truck. Surely all this doesn't apply?

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

20. Is there a fixed price, like there is for an MOT?

No. Prices will vary. Some fork lift trucks are more complex than others and may have more to examine. In addition there will be travel costs for the Competent Person as he would normally go to the fork lift truck. Like everything else, check the price before confirming the task – but ignoring a Thorough Examination is not an option! Like an MOT the price quoted will be for the examination and associated documentation, not any repairs that may be necessary.

21. We have some hand-pallet trucks. This can't apply to them - can it?

Hand pallet trucks and low lift trucks (i.e. non-stacking powered trucks with forks or a load platform that lifts up to 500mm from the ground, including those with an operator platform that elevates up to 900mm from the ground) do not require Thorough Examination. However, in order to comply with PUWER 98, these types of equipment still require a formal safety inspection at least once per year. The results of such inspections should be recorded and records retained for future reference. There is no set format for such records and the standard inspection sheet used by a fork truck maintenance company should be quite adequate. It would not be wrong to use a Report of Thorough Examination if nothing else suitable was available.

22. If I want to read more about this subject what should I read?

The following publications can be purchased from HSE Books (Tel: 01787 881165) or through the catalogue section of this website.

• Safe Use of Work Equipment
Provision and Use of Work Equipment Regulations 1998
(PUWER 98)
Approved Code of Practice And Guidance
HSE Code L22
ISBN Code 0-7176-1626-6

• Safe Use of Lifting Equipment
Lifting Operations and Lifting Equipment Regulations 1998
(LOLER 98)
Approved Code of Practice and Guidance
HSE Code L113
ISBN Code 0-7176-1828-2

The following publication can be purchased from the British Industrial Truck Association (BITA) (Tel: 01344 623800).

• Safety Inspections Of Industrial Lift Trucks
GN 28

23. What is CFTS?

CFTS is the abbreviation for Consolidated Fork Truck Services Ltd. CFTS provides a Quality Assurance Procedural Code for the conduct of Thorough Examinations and a distinctive, comprehensive set of Thorough Examination documents.

You can find your nearest FLTA Member Company that is also accredited to CFTS by clicking here.

Further information on CFTS is available here.

mail@fork-truck.org.uk fax:01256 381735 tel:01256 381441

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