Machine Guarding Under PUWER: What Employers Must Check

by admin | Aug 10, 2026 | Consultancy Services, Health and Safety, Risk Assessment, Safety Update

Could Someone Reach the Dangerous Parts of Your Machinery?

A machine may have been used without incident for years, but that does not make an exposed drive, belt, roller or blade acceptable. A new HSE prosecution in East Anglia is a timely reminder that machinery guarding must physically prevent access to dangerous parts — and that training or instructions are not substitutes for proper engineering controls.

Why this matters now

On 7 August 2026, the ⁠Health and Safety Executive reported the prosecution of a Thetford chemical manufacturer following an incident involving an unguarded powered conveyor.

An employee removed a cardboard box from a running conveyor and his hand became entangled in the machinery. He suffered a broken finger and bruising to three other fingers, required surgery and was unable to work for six weeks.

HSE found that the business had failed to prevent access to dangerous parts of the conveyor. Easy Cleaning Solutions Ltd pleaded guilty to breaching regulation 11(1) of the Provision and Use of Work Equipment Regulations 1998 and was fined £100,000 plus £6,468.18 in costs.

Although this incident occurred in manufacturing rather than construction, the underlying requirement applies to work equipment across construction workshops, fabrication facilities, plant yards and other workplaces. PUWER defines work equipment very widely, covering machinery, appliances, apparatus, tools and installations used at work.

What does PUWER actually require?

⁠Regulation 11 of PUWER 1998 requires employers to take effective measures to prevent access to dangerous parts of machinery or to stop the movement of dangerous parts before a person enters the danger zone.

Importantly, PUWER establishes a hierarchy of protective measures. Physical prevention comes before reliance on human behaviour.

The starting point is normally fixed guards or enclosures. Where those are not practicable, other guards or protection devices should be considered, followed where appropriate by jigs, holders or similar devices. Information, instruction, training and supervision sit further down that hierarchy rather than replacing the higher-order controls.

That distinction matters.

A warning sticker saying “keep hands clear” does not make an accessible roller safe. Neither does a toolbox talk, a trained operator or a written instruction telling people not to reach into the machinery.

If someone can foreseeably reach a dangerous moving part during normal operation, the first question should be how access can be physically prevented.

When should a fixed guard become an interlocked guard?

HSE guidance says fixed guarding will normally be the preferred method of preventing access to dangerous parts. A fixed guard should require a deliberate action, normally involving tools or secure fixings, before it can be removed.

However, some machines need regular access for loading, adjustment, inspection, cleaning or clearing material.

Where routine access is genuinely necessary, HSE advises that an interlocked guard may be more appropriate. The interlock should prevent the dangerous movement from operating while the guard is open and, where necessary, prevent the guard being opened until movement has stopped.

This is particularly relevant to:

• Conveyors and rollers.
• Workshop saws.
• Fabrication machinery.
• Cutting and forming equipment.
• Plant-processing equipment.
• Crushers and screening equipment.
• Machinery where blockages or offcuts require regular removal.

The correct safeguarding arrangement depends on the particular machine and risk. Simply replacing a missing fixed panel with an easily removable cover may not be sufficient if workers must repeatedly remove it during normal production.

What about clearing jams, cleaning and maintenance?

Some of the most dangerous interactions with machinery happen when the equipment is not performing normally.

A blockage develops. Material becomes trapped. Something sounds wrong. A worker reaches in to investigate.

PUWER applies not only to normal operation but also to activities including starting, stopping, repairing, maintaining, servicing and cleaning work equipment.

For maintenance, ⁠HSE guidance says plant and equipment should be made safe before work starts. In most cases that means stopping the machinery and isolating energy supplies. Where accidental reconnection is possible, locking off may be necessary. Stored hydraulic, pneumatic, gravitational or other energy may also need to be released or physically restrained.

PUWER regulation 19 separately requires suitable means of isolating work equipment from all sources of energy where appropriate, with the isolation means clearly identifiable and readily accessible.

A useful rule for supervisors is therefore:

If somebody needs to put part of their body into an area normally protected by a guard, normal operating controls should not automatically be treated as safe isolation.

The appropriate method should be determined through the machinery risk assessment and manufacturer’s instructions.

Why training cannot compensate for missing guards

Training remains important. Regulation 9 of PUWER requires people using work equipment to receive adequate training for health and safety purposes, including the methods to be used, risks arising from use and precautions to be taken.

Managers and supervisors also need enough knowledge to recognise unsafe machinery arrangements and challenge practices such as removed guards, defeated interlocks or inadequate isolation. ⁠IOSH Managing Safely provides practical training in risk assessment, hazard control, legal responsibilities and incident investigation for people responsible for managing or supervising others. For employees and operatives, ⁠IOSH Working Safely provides a broader introduction to identifying hazards and reducing workplace risks.

But training is not permission to operate fundamentally unsafe machinery.

A competent, experienced employee can still make an error, react instinctively to a blockage or become distracted. Machinery safeguarding is designed on the basis that foreseeable human interaction needs to be controlled.

This is why the hierarchy matters. Engineering controls should prevent the worker reaching the danger in the first place wherever reasonably practicable.

The same principle should inform supervision. If operators routinely defeat an interlock, remove a guard, prop open a cover or use an improvised method to clear material while machinery is running, simply reminding them of the rules is unlikely to resolve the underlying problem.

Managers should ask why the unsafe behaviour has become convenient or necessary.

It may reveal:

• A poorly designed access arrangement.
• Repeated blockages.
• Unrealistic production pressure.
• An unsuitable machine for the task.
• A damaged or unreliable interlock.
• Inadequate isolation arrangements.
• A maintenance problem that has become accepted as normal.

What should you do now?

Businesses using powered machinery should take the HSE prosecution as an opportunity to walk their workplace and look at the equipment as it is actually used — not simply as it appeared when the risk assessment was first written.

Start with machinery capable of drawing, trapping, crushing, cutting or entangling someone.

Check:

• Are all original guards present and secure?
• Can hands, fingers, clothing or tools reach belts, chains, rollers, blades, gears or drive components?
• Have guards been modified, removed or defeated?
• Do interlocks actually stop dangerous movement?
• Are emergency stops accessible and functioning?
• How are routine blockages cleared?
• How is machinery isolated before maintenance?
• Can stored energy cause unexpected movement?
• Are operators trained in the actual safe method?
• Are supervisors challenging shortcuts?
• Are recurring machinery faults being repaired rather than worked around?

Where a machine has been modified, refurbished or adapted, the safeguarding should also be reviewed. HSE confirms that refurbished and modified machinery must remain safe in use and meet PUWER requirements.

For higher-risk or unfamiliar machinery, specialist engineering input may be necessary. The objective is not simply to produce another PUWER checklist; it is to confirm that a person cannot foreseeably reach a dangerous moving part.

Frequently asked questions

Can a machine be used temporarily with a guard removed?

Not merely because the period is short. Where the guard is necessary to prevent access to dangerous parts, operating without it could breach PUWER. Any exceptional activity requiring access must be properly assessed and controlled using suitable safeguarding, isolation or another engineered method appropriate to the task.

Is an emergency stop a substitute for a guard?

No. Emergency stops are an additional protective measure. HSE’s machinery-safety hierarchy prioritises preventing access to dangerous parts through guards and safeguarding arrangements.

Can trained maintenance staff work on moving machinery?

Most maintenance should be carried out with machinery stopped and isolated. There are specialist circumstances where work cannot be undertaken completely de-energised, but these require specific assessment and additional controls rather than simply relying on experience or training.

Does PUWER apply to old machinery?

Yes. PUWER applies to work equipment used at work, including older equipment. Older machinery may in fact require particular attention where guarding standards, modifications or previous repairs have changed over time.

All Star Safety provides ⁠health and safety consultancy and workplace auditing across construction, engineering and industrial environments, including reviews of risk assessments, equipment controls and safe systems of work.

For businesses employing plant mechanics and maintenance technicians, our workplace-based ⁠Plant Maintenance NVQs assess competence through the inspection, servicing, fault diagnosis and repair activities people already undertake at work.