Manufacturing and logistics environments are among the highest-risk settings for work equipment hazards. These are industries characterised by heavy machinery, repetitive operations, high production pressures, shift patterns, and constantly moving vehicles and materials. They are also the industries where PUWER compliance failures are most frequently prosecuted.
In 2023/24, manufacturing accounted for a significant proportion of workplace fatalities in Great Britain, and the construction, agriculture, and manufacturing sectors together were responsible for around two-thirds of all work-related deaths. Logistics operations face similar risks, particularly around conveyor systems, loading equipment, warehouse machinery, and vehicle movements.
Through years of experience working with businesses in these sectors, Safety Management Ltd has identified recurring patterns of non-compliance. These are not unusual or obscure failures. They are common, predictable, and entirely preventable.
Mistake 1: Treating PUWER as an Engineering Problem Only
Many manufacturing businesses delegate PUWER entirely to the engineering or maintenance department. While these teams have a critical role, PUWER compliance is a management responsibility that requires coordination across engineering, operations, health and safety, training, and procurement.
When PUWER sits exclusively with engineering, risk assessments tend to focus on technical specifications rather than how equipment is actually used on the shop floor. Operational pressures — such as guards being removed to speed up production — go unaddressed because engineering is not present during every shift.
Mistake 2: Removing Guards for Cleaning or Changeover
This is the single most common compliance failure we encounter. Guards are removed to facilitate cleaning, changeover, or minor adjustments, and either not replaced at all or replaced incorrectly. In fast-paced production environments, the temptation to “just quickly” access a machine without replacing the guard is enormous.
Every PUWER prosecution for guarding failures tells the same story: the guard was removed for a legitimate reason and never put back. The solution is not simply to tell people to replace guards. It requires a safe system of work that accounts for the need to access the machine and provides appropriate protection during those activities.
Mistake 3: Ignoring Warehouse and Logistics Equipment
In many operations, attention to PUWER is focused on the production line, while warehouse and logistics equipment is overlooked. Conveyor systems, pallet wrapping machines, baling machines, goods lifts, and loading bay equipment are all work equipment under PUWER and require the same rigour of assessment, maintenance, and inspection.
Some of the most serious PUWER prosecutions in recent years have involved logistics and warehouse equipment. A Liverpool-based waste and recycling company was fined £700,000 and its director sentenced to eight months in prison after an employee died clearing a blockage in a baling machine. The company continued to operate the machine unsafely for five years after the fatality.
Mistake 4: Incomplete Training Records
Manufacturing and logistics businesses often rely on informal, on-the-job training for equipment operation. While practical training is essential, it must be documented. The HSE expects to see formal training records that demonstrate each operator has been trained on the specific equipment they use, assessed as competent, and provided with refresher training at appropriate intervals.
If you cannot prove that a worker was trained, you cannot defend a prosecution claim that training was inadequate.
Mistake 5: Not Reviewing Risk Assessments After Changes
Equipment is modified. Production processes change. New materials are introduced. Staff turnover brings new operators who may use equipment differently. Each of these changes can introduce new hazards or alter existing risks, and each should trigger a review of the relevant PUWER risk assessments.
Too often, risk assessments are written once and filed away. They become historical documents rather than living management tools. When an incident occurs, the HSE will check whether the risk assessment reflected the actual conditions at the time of the incident. If it did not, that is a significant failing.
Mistake 6: Relying on Manufacturer Documentation Alone
The manufacturer’s manual is a starting point, not an endpoint. It tells you how the machine was designed to be used. It does not account for the specific way it is used in your operation, the environment it operates in, the competence of your operators, or the interactions with other equipment and processes.
Your PUWER risk assessment must consider all of these factors. Relying solely on manufacturer documentation is a common defence that the HSE has repeatedly rejected in prosecutions.
How Safety Management Ltd Works with Manufacturing and Logistics Businesses
We understand these industries because we work in them every day. Safety Management Ltd provides practical, proportionate PUWER compliance support that recognises the realities of production environments. We help you identify and address these common mistakes before they lead to injuries, enforcement action, or worse.
Our approach is collaborative. We work with your engineering, operations, and management teams to build compliance systems that are realistic, sustainable, and genuinely effective.
