LOLER vs PUWER: Which Applies to Warehouse Equipment?

LOLER and PUWER are the two sets of regulations that decide how the equipment in your warehouse must be maintained, inspected and recorded — and the most common mistake is treating them as alternatives. They are not. Nearly every piece of equipment on a UK site is covered by PUWER; a smaller subset is also covered by LOLER. Getting the boundary wrong in either direction costs money: apply LOLER to everything and you are paying for statutory examinations you do not need, apply it to nothing and you have equipment in service without the thorough examination the law requires.

This guide is written from a handling and storage equipment supplier's point of view — pallet trucks, stackers, lift tables, cages, racking, steps and platforms — and it sets out which regulation catches what, what each one actually requires of you, and where the boundary is genuinely contested rather than merely misunderstood. It is general guidance, not a legal opinion or a risk assessment. Where a decision matters, establish it with a competent person for your specific equipment and your specific use.

The short answer

• PUWER 1998 — the Provision and Use of Work Equipment Regulations — applies to all work equipment. If your business provides it and someone uses it at work, PUWER applies. A pallet truck, a workbench, a set of steps, a racking run, a trolley, a drill.
• LOLER 1998 — the Lifting Operations and Lifting Equipment Regulations — applies to lifting equipment and lifting accessories, and it sits on top of PUWER rather than instead of it.
• All lifting equipment is work equipment. So anything caught by LOLER is caught by PUWER as well. Nothing is "LOLER instead of PUWER".
• The headline practical difference is thorough examination: LOLER imposes statutory examination intervals by a competent person. PUWER requires suitable inspection and maintenance, but does not set a fixed statutory interval in the same way.

What PUWER 1998 actually requires

PUWER is the broad one, and the duties are deliberately general because they have to cover everything from a stepladder to a press brake. In practice it requires an employer to make sure work equipment is:

• Suitable for the work it is used for, and for the conditions and place it is used in — which is why a standard hand pallet truck is the wrong equipment for a gravel yard and a rough-terrain pallet truck is the right one.
• Maintained in efficient working order and good repair, with a maintenance log where one is kept.
• Inspected where safety depends on the installation conditions or where it deteriorates in use, at suitable intervals, by a competent person, with the results recorded.
• Used only by people who have had adequate information, instruction and training — including anyone who supervises or manages its use.
• Fitted with appropriate guards, controls, isolation, stability, lighting and markings where those apply.

Two things follow from this that people routinely get wrong. First, "no statutory interval" does not mean "no inspection" — PUWER asks you to determine a suitable interval and to be able to justify it. Second, PUWER covers storage equipment: a racking run is work equipment, which is why a damaged upright is a PUWER matter even though nothing about racking is a lifting operation. Our guide to warehouse racking inspection under HSG76 and SEMA covers that in detail.

What LOLER 1998 adds on top

LOLER applies where work equipment is used for lifting or lowering loads, and to lifting accessories — slings, chains, eyebolts, shackles, spreader beams. Where it applies it adds requirements that PUWER does not contain:

• The equipment must be of adequate strength and stability for each load, and positioned or installed to reduce the risk of the load striking someone or drifting.
• It must be clearly marked with its safe working load (SWL), and where the SWL depends on the configuration, marked for each configuration. Accessories must be marked so their safe use can be identified.
• Equipment for lifting persons carries extra duties — preventing the carrier falling or tipping, preventing anyone being crushed or trapped, and providing a means of escape.
• Every lifting operation must be planned by a competent person, appropriately supervised and carried out safely.
• The equipment must undergo thorough examination by a competent person at statutory intervals, and the report must be kept.

The examination intervals

That 6-versus-12 split is the single most asked question about LOLER, and the answer is that it depends on what is being lifted, not on how big the machine is. A forklift man cage is lifting a person, so it sits in the six-month column even though the truck carrying it does not.

Which regulation covers the equipment we sell

This table is how each category is usually treated in a UK warehouse. Treat it as a starting point for a conversation with your competent person, not as a determination — the duty to establish what applies to your equipment in your use sits with you, not with a supplier.

The contested boundary: do hand pallet trucks need a LOLER thorough examination?

This is the question a handling equipment supplier gets asked more than any other, and anyone who gives you a flat yes or no is overstating the position. The boundary is genuinely disputed, and it turns on whether raising the forks counts as a lifting operation or as something incidental to transporting the load.

The argument that LOLER does not apply: a hand pallet truck raises a pallet a few centimetres purely so it can be wheeled. The load is never lifted to height, never suspended, and never carried over anyone. On that reading the lifting is incidental to the transport function, and PUWER alone is the right frame.

The argument that LOLER does apply: the regulations catch work equipment used for lifting or lowering loads, and a hydraulic pump raising a pallet on forks is doing exactly that. On that reading a twelve-month thorough examination is required.

What to do with that, practically. First, note that the argument only affects the statutory examination question — PUWER applies either way, so the truck must be maintained, inspected at a suitable interval, marked with its capacity, and used by trained people regardless of which side of the line it falls. Second, if the honest answer is that you cannot say which applies, the cheaper and safer course is usually to bring the trucks into a twelve-month competent-person examination cycle anyway: the cost of a periodic examination on a pallet truck is small against the cost of arguing the point after an incident. Third, get it decided once, in writing, by your competent person or insurer, and record the reasoning — an inspector's question is much easier to answer with a documented decision than with an opinion. Our pallet truck maintenance and servicing guide covers what a sensible inspection actually looks at.

What is not covered by LOLER

A short list, because "what is not covered by LOLER regulations?" is one of the questions Google shows on this search:

• Equipment that does not lift or lower a load. Racking, shelving, benches, cabinets, trolleys, conveyors that only convey, and access equipment you climb rather than ride.
• Escalators and passenger lifts in buildings are generally dealt with under their own regimes rather than as warehouse lifting equipment — check which applies to your building.
• Equipment not used at work — LOLER is a workplace regime.
• Pressure systems, vehicles on the public highway and electrical safety have their own regulations; LOLER does not displace them.

Note what is not on that list: nothing escapes PUWER by being outside LOLER. Falling outside LOLER narrows what you must do; it never removes the duty entirely.

A practical compliance checklist

If you are trying to get a warehouse in order rather than to study the law, this is the order to work in:

1. List the equipment. Everything provided for use at work, including things nobody thinks of as equipment — steps, benches, racking, bins.
2. Split the list. Does it lift or lower a load? If clearly yes, it is LOLER as well as PUWER. If clearly no, PUWER only. Put the genuinely arguable items — hand and powered pallet trucks above all — in a third pile and get them decided.
3. Check the markings. Every LOLER item needs its safe working load visible and legible. While you are there, check racking has a current load notice that matches how the bays are actually configured — changing beam levels changes the rated capacity, so the notice must change too.
4. Set the intervals. Six months for persons and accessories, twelve for other lifting equipment, or an examination scheme. For PUWER-only items, decide an interval you can justify and write down why.
5. Book the competent person and keep the reports. A thorough examination is not the same thing as a service, and a service record is not a substitute for an examination report.
6. Record the training. No licence is required to operate a manual pallet truck in the UK, but PUWER still requires adequate instruction and training, and you need to be able to show it.
7. Act on defects. A report that identifies a defect requiring immediate attention takes the equipment out of service until it is put right — the report is not a filing exercise.

Where we can and cannot help

We supply equipment. We do not carry out LOLER thorough examinations, PUWER inspections or racking inspections, and we do not provide training. For those you need an independent competent person, and there is a good argument for that person being independent of whoever sold you the kit. What we can do is supply equipment that is correctly marked and specified for the job, and tell you plainly what the product data does and does not state — including when it does not state a plated capacity, which is a question worth asking before you buy rather than at the point of examination.

See the pallet trucks, stackers, lifters and loaders, storage cages and access platforms and steps ranges, or read our guides to load ratings, UDL and SWL and using a pallet truck safely.