LOLER, PUWER and the Forklift Examination

Walk into most UK warehouses and you will find a LOLER thorough examination certificate fixed to the forklift mast with a cable tie. Walk back six months later and a fair few of those certificates have quietly expired. Nobody noticed, or nobody acted. That gap between what the law requires and what actually happens on the ground is where the risk sits.

What LOLER Requires for Forklifts

The Lifting Operations and Lifting Equipment Regulations 1998 cover any equipment used at work to lift loads, and a counterbalance or reach truck fits that definition squarely. Under LOLER, a forklift must be thoroughly examined:

• Before it is first used, unless the manufacturer has already provided written evidence that an examination has been carried out
• After installation or assembly in a new location
• At regular intervals thereafter
• Following any exceptional circumstances, such as a collision, an overload incident, or anything else that may have affected the integrity of the mast or lifting mechanism

The standard interval for a forklift lifting loads is every 12 months. That catches some operators by surprise. The six-month interval, which gets mentioned more often, applies when lifting equipment is used to lift people. If your site ever attaches a working platform or man-riding cage to a forklift, those operations sit in the six-month category, even if the truck itself only requires annual examination in its normal load-lifting role.

What PUWER Adds on Top

PUWER, the Provision and Use of Work Equipment Regulations 1998, sits alongside LOLER rather than replacing it. Where LOLER focuses on lifting operations specifically, PUWER covers the condition and suitability of all work equipment, forklifts included.

Under PUWER you are required to keep the truck in efficient working order and good repair, carry out inspections at appropriate intervals, maintain records of those inspections, and ensure operators are properly trained and authorised to use the equipment.

A PUWER inspection is not the same as a LOLER thorough examination. The thorough examination must be carried out by a competent person who is sufficiently independent and impartial, typically an examiner from an engineering inspection body or your insurer’s technical arm. A PUWER inspection can be performed by a competent in-house engineer, provided they have the knowledge and experience to identify relevant deterioration and risk.

Many sites combine a manufacturer’s annual service with the LOLER thorough examination, which is practical enough. Just make sure the examination report is a separate, properly documented output rather than a line item buried in the service paperwork.

What a Thorough Examination Actually Covers

A thorough examination is not a walk-round with a clipboard. The competent person is expected to inspect all load-bearing structural components, including the mast, forks, carriage, and any attachments fitted to the truck. They will check hydraulic systems, brakes, tyres, and steering, and test safety-critical functions under controlled conditions.

Any defect that creates a risk must be reported, with the examiner specifying whether it needs immediate remediation or can be addressed within a defined timescale. If a defect presents an immediate danger and the employer does not rectify it, the examiner is legally required to notify the enforcing authority, which in most manufacturing settings means the HSE. This is not a procedural formality.

Keeping Your Records Straight

The written report produced after each thorough examination should be kept until it is superseded by the next report. In practice, most sites retain examination records for at least two years, and that is generally sound advice.

Keep the records somewhere accessible. If an inspector arrives, or worse, if there is an incident, you want to produce the documentation without a search through filing cabinets. A simple spreadsheet showing each truck’s identification number, last examination date, next due date, and where the current report is held will do the job.

Gaps Worth Checking Now

Sites that drift into non-compliance tend to have the same problems. A truck is added to the fleet without being registered for examination. A certificate expires during a busy production run and nobody chases it. An attachment is fitted without checking whether it changes the examination requirements.

Attachments are worth particular attention. Under LOLER, an attachment that affects the lifting capacity or method of the truck may need its own thorough examination, separate from the examination of the truck itself. Confirm this with your examiner whenever a new attachment is fitted.

The administrative side of all this is not complicated, but it does need someone to own it. If responsibility sits between the maintenance supervisor and the fleet manager with neither taking the lead, the gaps will open. Assign it, record it, and review it on a fixed cycle.

If you want a structured way to identify where compliance and operational gaps are costing you before they become incidents, losses.cadencestandard.com helps put a number to those losses. For teams working through a broader maintenance improvement programme, the resources in the Cadence toolkit are worth a look once the compliance baseline is sorted.