Regulation 6 of PUWER 1998 requires work equipment to be inspected after installation and after assembly at a new site. Relocated mobile shelving meets that trigger exactly — here is what the inspection covers.
The regulation that applies
The Provision and Use of Work Equipment Regulations 1998 (PUWER) apply to mobile shelving because it is work equipment provided for use at work. Most dutyholders are familiar with Regulation 6 as the source of the annual inspection cycle, but the regulation actually contains two separate triggers.
The first is inspection where safety depends on installation conditions: equipment must be inspected after installation and before being put into service for the first time, and after assembly at a new site or in a new location. The second is periodic inspection at suitable intervals for equipment exposed to conditions causing deterioration liable to result in a dangerous situation.
A relocated mobile shelving system meets the first trigger unambiguously. It has been dismantled, transported and reassembled at a new site, and its safety depends absolutely on installation conditions — rail level, rail fixing, floor capacity, anti-tip engagement and end-stop position. The inspection is therefore not a matter of good practice or supplier upselling; it is the express requirement of the regulation.
Two further regulations sit alongside it. Regulation 5 requires work equipment to be maintained in an efficient state, in efficient working order and in good repair. Regulation 8 requires adequate health and safety information and, where appropriate, written instructions for users — which at a new site usually means new users. Regulation 9 requires that those users are adequately trained. Mobile systems should also comply with BS EN 15095, the standard covering power-operated and manually operated mobile racking and shelving.
Why a new location resets the compliance position
A system that was safe in its old room is not automatically safe in its new one, and the reasons are the reasons PUWER names installation conditions explicitly.
Structurally, the destination floor may be different. The applied load of mobile shelving is roughly double that of static shelving because the aisles are removed, and a slab that was adequate on the ground floor may not be on the first. Rail level and flatness at the new site also has to be verified against tolerance. Our floor loading guide covers the structural side in detail.
Mechanically, safety-critical components must be confirmed present and functioning at the new site: anti-tip devices, end-stops, brakes, and on powered systems photocells, floor sweeps and emergency stops. A safety device that has been reconnected but not function-tested is worse than no safety device at all, because it is trusted.
Procedurally, the people change. Staff at the new site may never have used mobile shelving before, and the written instructions and load labelling that were on the wall of the old room rarely make the journey — which engages Regulations 8 and 9 independently of the equipment's condition.
This article deals with the inspection and compliance duties only. The relocation process itself — surveys, dismantling sequence, transport, storage and reinstallation — is covered by our specialist relocation business at https://www.mobileshelvingrelocation.co.uk
What the post-relocation inspection covers
The inspection is carried out by a competent person — someone with the training, knowledge and experience to identify defects and assess their significance — and covers the reinstalled system as a whole rather than sampling it.
Floor and rails: floor condition and suitability at the new location, rail level along the full run and across the run, straightness, correct shimming, fixing type and torque appropriate to the floor construction, rail joints and infill, and end-stop presence and security.
Carriages and running gear: wheel and bearing condition, free and square running of every carriage, absence of drift or creep, drive chain or shaft alignment on manual systems, and handle and gearbox operation through the full travel of each aisle.
Safety devices: anti-tip mechanisms engaging correctly on every carriage, brake or locking devices functioning, aisle-entry protection, and on electric systems individual function-testing of photocells, floor sweeps, emergency stops, aisle-safe indicators and controlled stopping, together with electrical safety of the reconnected installation.
Structure and loading: upright and bay frame condition and plumb, shelf security and level, bracing, fascia and end panels, verification of the destination floor loading position, and safe working load labelling reinstated and legible.
The output is a written report identifying defects with a risk-based priority, a statement of whether the system is fit to be put into service, and a dated certificate naming the competent person. That date starts the annual periodic inspection cycle at the new site.
Findings that should stop a system entering service
Certain findings are safety-critical and mean the system should not be loaded or used until rectified: missing or wrongly positioned end-stops, anti-tip devices absent or engaging on only some carriages, rail fixings inadequate for the floor construction, and rails outside the level tolerance the carriages require.
On powered systems the equivalent findings concern the safety devices themselves — photocells at the wrong height, floor sweeps not reconnected, emergency stops that do not stop the system, or a control panel re-terminated without commissioning. Under BS EN 15095 and PUWER these are not deferrable items.
The other frequent finding is administrative rather than mechanical: no load labelling, no written operating instructions, and no record that staff at the new site have been trained. Those are breaches of Regulations 8 and 9 even where the steel is perfect.
Who is responsible
The dutyholder under PUWER is the employer or the person who has control of the work equipment — in practice, the organisation occupying the building where the system is installed. That duty does not transfer to the contractor who moved it. If a relocation is completed without inspection and someone is subsequently injured, the enforcement question is directed at the dutyholder.
This is why the inspection should be specified in the relocation contract from the outset, with the certificate a defined deliverable at handover. Where the same organisation dismantles, reinstalls and inspects, accountability is straightforward. Where a removals firm has moved the system, arrange an independent competent-person inspection before the system is loaded and used.
Our planned maintenance and PUWER inspection service carries out post-relocation inspections on all major makes, whoever carried out the move, and maintenance packages then keep the annual cycle in place.
Records to retain
Regulation 6 requires that the result of an inspection is recorded and kept until the next inspection is recorded. In practice, keep more than the minimum: the post-relocation inspection report and certificate, the pre-move condition survey, details of any parts replaced during the move, the destination floor loading position, commissioning results for powered safety devices, the operator training record for staff at the new site, and the written operating instructions issued.
That set of documents is what allows an estates or health and safety manager to demonstrate compliance quickly, whether to an internal audit, an insurer or an HSE inspector. For the wider annual regime, see our guide to PUWER inspections for mobile shelving, and for the move itself the relocation guide.
Arranging an inspection
If you have recently moved mobile shelving — or inherited a system in a building you have taken over, which raises exactly the same questions — a competent-person inspection is a short, inexpensive piece of work that closes a genuine legal gap.
Rackstor UK Ltd carries out PUWER inspections on mobile shelving, roller racking and Compactus systems across every UK postcode, on all major makes including Bruynzeel, Rackline, Forster, Dexion and legacy systems. Call 0800 654 6955 or use the contact form.
Frequently asked questions
- Does PUWER actually require an inspection after relocation?
- Yes. Regulation 6 of PUWER 1998 requires that where the safety of work equipment depends on the installation conditions, it is inspected after installation and before first use, and after assembly at a new site or in a new location. Relocated mobile shelving meets that trigger because its safety depends directly on rail level, fixing, floor capacity, anti-tip engagement and end-stops.
- Who is legally responsible for arranging it?
- The dutyholder — the employer or organisation with control of the equipment at the new premises. The duty does not pass to the removals or installation contractor, which is why the inspection and certificate should be written into the relocation contract as a deliverable.
- Who can carry out the inspection?
- A competent person: someone with sufficient training, knowledge and practical experience of mobile shelving to identify defects and judge their significance. In practice that means a specialist mobile shelving engineer rather than a general maintenance operative, particularly for powered systems where photocells, floor sweeps and emergency stops must be function-tested individually.
- What happens if defects are found?
- The report should categorise defects by risk. Safety-critical findings — missing end-stops or anti-tips, non-functioning safety devices on powered systems, unsafe rail fixing — mean the system should not be put into service until rectified. Lower-priority findings such as wear or labelling gaps are scheduled. Many defects can be corrected on the day by the attending engineer.
- Does the annual inspection cycle restart after a move?
- Effectively yes. The post-relocation inspection date becomes the baseline at the new site, and the next periodic inspection is due a year later for typical office and archive use, or more frequently for heavily used, powered or harsh-environment installations.
- We inherited a system when we took over a building. Do the same rules apply?
- Yes. Once you have control of the equipment you are the dutyholder, and you need to know its condition and inspection history. Where no records exist, commission a baseline competent-person inspection, reinstate load labelling and written operating instructions, and train your users. That establishes compliance with Regulations 5, 6, 8 and 9 from a known starting point.