Here at Sunrise Tools we are often asked about LOLER, the Lifting Operations and Lifting Equipment Regulations most notably in relation to our Manhole Buddy manhole and drain cover lifting range. In this blog we will be taking you through what LOLER is and how it might apply when using manhole cover lifting products.
The Health and Safety Executive (HSE) is the UK statutory authority for work-related health and safety matters. The HSE develops strategy and policy, provides advice and guidance and undertakes inspection and enforcement where appropriate. From the Health and Safety Executive (HSE) website:
“These Regulations (often abbreviated to LOLER) place duties on people and companies who own, operate or have control over lifting equipment. This includes all businesses and organisations whose employees use lifting equipment, whether owned by them or not. In most cases, lifting equipment is also work equipment so the Provision and Use of Work Equipment Regulations (PUWER) will also apply (including inspection & maintenance). and All lifting operations involving lifting equipment must be properly planned by a competent person, appropriately supervised and carried out in a safe manner.”
In our opinion, a good place to start is HSE publication INDG422 - Thorough Examination of Lifting Equipment - an excellent resource and not a long read. We feel it weaves together key aspects of the Lifting Operations and Lifting Equipment Regulations (LOLER) and the over-arching Provision and Use of Work Equipment Regulations (PUWER). So if you are new to this subject, we recommend you start by reading the above publication.
With regards to Manhole Cover Lifting equipment, pictured below are three examples, including a Manhole Buddy magnetic manhole cover lifter. All three designs permit a cover to be raised and moved. The majority of Manhole Cover Lifters will embrace one of these concepts.
A typical manhole cover will be 8 to 12 cm deep; 16 cm will be an exceptionally deep cover. To raise even a 16 cm cover using these equipment types, the cover (the ‘load’ in the regulations) need not be suspended a significant height above the surrounding ground level, typically 20 cm maximum.
This equipment type is not specifically referenced within LOLER which is probably the reason we receive questions on the subject. Having considered the nature of the load, how it is attached to the lifting equipment and the level at which it is suspended, we think it appropriate to highlight how LOLER views handling a loaded pallet of goods, depending upon the lifting method used.
A typical forklift truck that could be raising the load to height and moving it some distance at notable speeds, falls within the remit of LOLER. By contrast, a pallet truck moving the same loaded pallet is specifically exempted from LOLER because “the consequence of the load falling off are very low”. We assume (as the reasoning is not given) the exemption applies primarily because the load is not being raised a significant height but additionally, the pallet truck is limited to pedestrian speeds, even if it has battery assistance.
The consequences of our load (the manhole cover) falling off are very low; the ability to move the load at speed is even more limited. In the absence of another equivalent, we advise manhole cover lifting equipment be categorised as per the exempted pallet truck, for the purposes of applying LOLER.
Activities where cover lifting is required will invariably be subject to some form of Risk Assessment. In general, this will take account of the tasks to be undertaken, the consequences of the process and measures to mitigate risk. The work process associated with lifting a manhole or drain cover will typically include:
· Securing the work area before operations commence
· Assessing the weight of the cover including any requirement to ‘free up’ the cover before attempting to lift
· Selecting appropriate equipment and checking it is in suitable condition before use
· Using the equipment as advised in User Guides and/or Training
· Cleaning and inspection of equipment after use
· Where appropriate, reporting faults on the equipment and withdrawing from use if unsafe.
LOLER states all lifting operations should be properly planned and supervised (by a Competent Person). Latitude is required (and given) for situations where a lifting activity is regular and commonplace such that planning and supervision is not required on each occasion. If we consider the afore-mentioned forklift, it would be inappropriate to require each pallet movement to be planned and supervised but it is expected that the operator has been trained in all aspects of the activity and the equipment is inspected at the beginning of each shift, its condition formally recorded and defects dealt with in a timely manner.
So it will be with the cover lifting equipment, where it is expected the operator will have previously been trained in its use and inspection before and after deployment will be the norm. These in-service practices should be supported by periodic “thorough examination” outside of the work environment.
We referenced HSE publication INDG422 - Thorough Examination of Lifting Equipment Competent Person (according to the LOLER Approved Code of Practice and guidance) is someone who “has such appropriate practical and theoretical knowledge and experience of the lifting equipment to be thoroughly examined as will enable them to detect defects or weaknesses and to assess their importance in relation to the safety and continued use of the lifting equipment”.
In this instance, the Competent Person may be tasked to oversee the lifetime deployment of the equipment, to include:
· Inspecting new equipment and adding to a register before first use (or as soon as practical thereafter)
· Determining an inspection schedule/timetable and where appropriate, instructing operatives about in-use inspection
· Recording any faults, repairs or retirement of products on the register and communicating actions required to appropriate persons.
Although the three Manhole Cover Lifters pictured earlier in this article perform the same basic function, attributes of their construction and use will probably influence the guidance issued by the Competent Person for their in-service operation and the chosen “thorough examination” schedule:
1. The Hydraulic Manhole Lifter (centre picture)
This equipment has the largest lifting capacity of the three types shown. It also requires more assembly at the point of use. In the period between examinations, parts could be fitted and dismantled many times, creating more opportunities for wear, damage or even loss. So relative to the other designs, a shorter examination interval could be appropriate as would more attention to User Instructions and/or training.
2. The Manhole Buddy Cover Lifting Set (left-hand picture)
The key element in a Manhole Buddy cover lifting set is the folding trolley. In common with many pieces of equipment, if it has been damaged in storage or transit, the defects might be apparent as it is being deployed. Similarly, if it is significantly damaged during use, it will probably fail to fold away properly, indicated by a pin not engaging or a carry strap not securing. The Competent Person may deem such in-use inspection, allied to the design of the product, supports a longer period between inspections.
LOLER places the primary responsibility on “people and companies who own, operate or have control over lifting equipment” such entities often referred to as the “duty holder”. We are happy to offer advice and guidance for consideration by interested parties and have expressed our view that Manhole Buddy Cover Lifting Products could be categorised alongside what we see as the closest identifiable equivalent referenced within LOLER, the pallet truck.
The Provision and Use of Work Equipment Regulations (PUWER) will in most instances have precedence over LOLER; conversely, LOLER is the mechanism through which the specific requirements of Lifting Operations are addressed. LOLER identifies the Competent Person as being central to the management of all lifting equipment and its deployment. Depending on the size of an organisation, there may be other roles or persons that encompass the broader aspects of Health and Safety and will contribute to determining which regulations will apply or prevail in a given situation.
Understanding any regulation and its relevance to a given situation is the first step in determining what action might be required. The plethora of advice and guidance heaped upon us from many sources, sometimes conflicting, invariably makes the task more daunting. In many instances, there is value in drawing upon the resources of a professional adviser, who is expert in that field, to plot a course through the minefield.
· Further information on the Manhole Buddy drain cover lifter can be found in the online User Guide.
· A short video exhibiting the main functions of the Manhole Buddy can be accessed here