Turning away from me to the job at hand, may I invite discussion around the difficulties of determining what an excavator or material handler is bound to have fitted if considered under LOLER and/or PUWER? This appears to be a minefield for an engineer surveyor completing an examination. With no harmonized build standard for material handlers until 1 June 2022, manufacturers were claiming compliance with the Machinery Directive by interpreting and addressing the essential health and safety requirements directly, while some adopted elements of the harmonized EN 474 standards for earthmovers. (Since then, material handlers have been included in EN 474 and designated under the excavator umbrella).
Still, excavators and material handlers are not the same. Excavators dig and move loose material. Material handlers pick up, carry, and sling loads. However, due to their versatility, excavators have also been adapted to lift too.
Is primary function still the determining factor between LOLER and PUWER? What are the issues surrounding load limiters, rated capacity indicators (RCI’s) and stability warning devices when lifting loads? How does a height-adjustable cab affect matters?
Every inspection company will have answers to these and other issues, but I wonder: are we all joined up and doing the same thing as an industry?
