Escalators, or moving walkways, don’t fall under the LOLER regulations. But while they still need to undergo regular inspections, they may not necessarily go under the name of a LOLER inspection in the strict sense of the term. However, they are still strictly regulated and controlled by a similar regime of maintenance, inspection and examination to that required for LOLER equipment.
The risks posed by escalators and moving walkways are no less real than any other lifting equipment. Therefore, ensuring safety and compliance with guidance is essential in order to meet your obligations as a duty holder under Section 3 of the Health and Safety at Work Act.
This blog lays out the reasons why you need to manage the safety of escalators, what regulations this type of equipment falls under and the specifics of what is required of you as a duty holder.
Why you need to manage escalators
There are a range of risks that escalators and moving walkways pose to users. They, therefore, require an adequate management plan in place to ensure that those risks are minimised and avoided.
The growing complexity of escalators and moving walkways, as well as the fact that their use is becoming more prevalent, are only a couple of the factors that make risk management important. What’s more, escalators are often the subject of abuse, misuse and negligence, especially those available to the general public in areas with little supervision.
In some cases, escalators are used as the primary emergency exit in a building, making their maintenance and reliability even more vital. In the light of incidents such as the King’s Cross fire in 1987, when 31 people died and 150 were injured due to a fire that began under one of the escalators, the need for guidance on escalator maintenance regimes, cleaning, communication and public safety has been firmly established.
What regulations do escalators in the workplace fall under?
While escalators may not fall under the LOLER Regulations, as a responsible person, you still have an obligation to maintain them to a safe working standard under the following regulations:
- Management of Health & Safety at Work Regulations 1999 – SI 1999/3242
- Workplace (Health, Safety & Welfare) Regulations 1992 – SI 1992/3004
- Provision & Use of Work Equipment Regulations 1998/2008 – SI 1998/2306
- Supply of Machinery (Safety) Regulations 2008 SI 2008/1597*
- Work at Height Regulations 2005 SI 2005/735; and
- Health & Safety (Safety Signs and Signals) Regulations 1996 SI 1996/341.
*In the UK the Supply of Machinery (Safety) Regulations 2008 implemented the requirements of the Machinery Directive 2006/42/EC. Escalators and similar machines must meet the requirements for safety and conformity of the Directive in their design, construction and installation when first brought into use.
In consultation with the Health & Safety Executive (HSE), the Safety Assessment Federation (SAFed) has prepared a document that provides considerable guidance on the duties and responsibilities of those who:
- manufacture, supply and install escalators and moving walkways
- design premises where they are to be installed
- own or manage premises in which they are installed; and
- inspect and examine escalators and moving walkways.
Under these detailed guidelines, even though escalators are not subject to LOLER, a thorough examination is still recommended and should normally be completed at six-monthly intervals.
SAFed guidelines support the legislation and replace the HSE Plant and Machinery guidance notes PM34: Safety in the use of escalators, and PM45: Escalators: periodic thorough examination, which are now withdrawn.
What do the guidelines require of you?
Under the guidelines, all duty holders, such as owners and managers who control premises, need to ensure that:
- all new escalators and moving walkways bear the CE marking and have a Declaration of Conformity, which must be kept for as long as the equipment is in operation
- escalators are properly maintained in efficient working order and in a good state of repair
- periodic thorough examinations are completed by a 'Competent Person' to ensure that escalators are safe to use
- reports of safety defects are actioned appropriately
- any supplementary tests are executed in a timely manner
- recommendations noted on the report are attended to as soon as reasonably practicable
- risk assessments are suitable and sufficient
- actions are taken to manage and reduce the risks uncovered by the risk assessment
- employees are adequately trained
- all accidents are recorded; and
- records and documentation are kept.
Who should carry out my escalator’s thorough examination?
The person carrying out the thorough examination of your escalator needs to have a sufficient level of knowledge, experience and expertise to do so. They need to conduct an examination that is comprehensive enough to assess the condition of the equipment and detect any defects which may pose a risk to people’s health and safety.
Following the inspection, they will need to provide you with a report that notifies you of any defects and advise on the urgency of actions needed to resolve them, as well as any temporary arrangements that need to be made. This 'Competent Person' also needs to identify any supplementary tests that are necessary to ensure the escalator (or moving walkway) is safe.
At British Engineering Services, our credentials are extensive. We’re the first business to receive UKAS accreditation to ISO/IEC 17020 and a founding member of SAFed. From of our knowledge and years of experience, we decided to create the following guide to help you better understand your obligations.
To ensure that you fully understand your obligations when it comes to your work equipment inspection duties, please download our ‘Essential guide to fulfilling your PUWER work equipment inspection obligations’.