Start with responsibility and intended use
PUWER duties apply to organisations that own, operate or control work equipment. Machinery must be suitable, maintained, inspected where required and used by trained people with effective controls for dangerous parts. Define who supplies, integrates, installs, owns and uses the equipment, and record the final product, packaging, environment, operator tasks and maintenance interventions. A generic certificate or checklist cannot replace that project-specific scope.
Questions for the project team
- Is the machine suitable for the actual product, pack, environment and foreseeable use?
- Can normal operation, setting, cleaning, blockage clearing and maintenance be carried out safely?
- Are guards, interlocks, emergency stops and control functions effective for the installed line?
- Are inspection, maintenance, training and safe-isolation arrangements documented?
Documents and evidence to plan
The exact records depend on the project, but the following deliverables provide a practical starting structure:
- site-specific machinery risk assessment
- inspection and maintenance schedule
- training and competence records
- safe system for cleaning, setting and intervention
- record of modifications and validation
Apply the controls across the machinery lifecycle
Review the requirement during specification, supplier selection, design review, factory testing, installation, site acceptance, training, routine operation, cleaning, maintenance and modification. A change that appears small—such as a new solvent, bottle size, cap, guarding opening, extraction system or line speed—can alter the original risk or conformity basis.
Current official sources
Use the official sources below as the starting point and check their update dates when the project is reviewed.
Common questions
What is the starting point for puwer planning for packaging machinery?
PUWER duties apply to organisations that own, operate or control work equipment. Machinery must be suitable, maintained, inspected where required and used by trained people with effective controls for dangerous parts.
Does a conformity mark replace the user risk assessment?
No. Supply obligations and duties for safe installation, use, inspection, maintenance and workplace risk control are related but distinct.
Who should confirm the legal interpretation?
Use current official guidance and competent legal, safety, engineering, metrology or food-safety advice appropriate to the project and jurisdiction.
When should the assessment be reviewed?
Review it when equipment, product, packaging, formulation, process, controls, room layout, use or official requirements change, and after relevant incidents or findings.