Risk Assessments · Mandatory · Pre-Construction

RAMS — Plant and Machinery Operation

This RAMS covers the operation of construction plant and machinery including excavators, dumpers, compactors, and power tools under PUWER 1998. It addresses operator competence (CPCS/NPORS cards), daily pre-use checks, maintenance regimes, segregation of pedestrians and vehicles, and noise and vibration exposure limits.

Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. PUWER 1998 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.

Legal basis	Provision and Use of Work Equipment Regulations 1998 (PUWER) + Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) + CDM 2015 Regulation 27 (traffic routes)
Vibration	Control of Vibration at Work Regulations 2005 (HAV and WBV exposure limits)
Who	Principal Contractor, plant operators, site supervisors, lift supervisors, appointed persons
CPCS / NPORS	Industry card schemes confirming operator competence for specific plant categories
LOLER applies to	All lifting plant including cranes, MEWPs used as lifting equipment, telehandlers, hoists, and excavators used for lifting
Pre-use checks	Required daily before first use under PUWER Regulation 6 and manufacturer instructions
Thorough examination	LOLER Regulation 9 requires thorough examination at prescribed intervals (6 months lifting persons, 12 months lifting loads)
Enforcing authority	Health and Safety Executive (HSE)

1. What It Covers

Plant and machinery RAMS address every item of mobile or static plant used on a construction site — from excavators, dumpers and telehandlers to tower cranes, piling rigs and road planers. Plant is involved in a disproportionate number of construction fatalities. The HSE’s data consistently shows that ‘struck by moving vehicle’ and ‘contact with moving machinery’ are among the top five causes of death on UK construction sites in any given year.

The legal framework is layered. PUWER 1998 applies to all work equipment and requires that plant is suitable, maintained, inspected and operated only by competent persons. LOLER 1998 applies specifically to lifting operations and lifting equipment, imposing additional duties around planning, supervision and thorough examination. CDM 2015 Regulation 27 requires that traffic routes on construction sites are organised to prevent danger from vehicles to pedestrians and vice versa. The Control of Vibration at Work Regulations 2005 set exposure action and limit values for both hand-arm vibration (HAV) and whole-body vibration (WBV), both of which are directly relevant to plant operation.

“Every employer shall ensure that work equipment is so constructed or adapted as to be suitable for the purpose for which it is used or provided.”— PUWER 1998 Regulation 4(1)

Plant is involved in around a quarter of all construction deaths

Being struck by moving plant remains one of the most common causes of fatal injury on construction sites. The risk is highest where pedestrian and vehicle routes are not segregated, where reversing manoeuvres are carried out without banksmen, and where operators lack adequate visibility. Every plant RAMS must address pedestrian-vehicle segregation as a primary control measure.

2. Common Plant Types

The table below sets out the most common categories of plant encountered on construction sites, together with the corresponding CPCS card category, the applicable regulations, and the key competence requirements for operators.

Plant type	CPCS category	Applicable regulations	Key competence requirements
Excavator (tracked / wheeled)	A59 (360) / A58 (180)	PUWER, LOLER (if lifting), CDM Reg 27	CPCS or NPORS card; LOLER appointed person where lifting with excavator
Telehandler	A17	PUWER, LOLER	CPCS or NPORS card; familiarisation on specific model; LOLER lift plan for lifting operations
Tower crane	A04	PUWER, LOLER, BS 7121	CPCS card; appointed person (A61); lift supervisor (A62); slinger/signaller (A40)
Mobile crane	A60	PUWER, LOLER, BS 7121	CPCS card for crane category; appointed person and lift supervisor for all lifts
Forward tipping dumper	A09	PUWER, CDM Reg 27	CPCS or NPORS card; site-specific familiarisation on routes and tipping areas
Ride-on roller	A31	PUWER, Vibration Regs 2005	CPCS or NPORS card; WBV exposure assessment for prolonged operation
Piling rig	A37 (driven) / A38 (bored)	PUWER, LOLER (for crane element), Vibration Regs 2005	CPCS card for specific piling type; noise and vibration monitoring

Excavators used for lifting are lifting equipment under LOLER

Any excavator used to lift loads — including suspending skips, sheet piles, or trench boxes — becomes lifting equipment for that operation and the full requirements of LOLER apply. This includes the need for a lift plan, an appointed person, a lift supervisor, a slinger/signaller, and a current thorough examination report covering the lifting configuration.

3. Vibration — HAV and WBV

The Control of Vibration at Work Regulations 2005 set exposure action values (EAV) and exposure limit values (ELV) for both hand-arm vibration (HAV) and whole-body vibration (WBV). Plant operators are exposed to WBV through the seat of the machine, while workers using hand-held powered tools such as breakers, compactors, and vibrating pokers are exposed to HAV. Prolonged exposure to HAV causes Hand-Arm Vibration Syndrome (HAVS), a painful and irreversible condition affecting the blood vessels, nerves, and joints of the hand and arm. WBV exposure is linked to lower back pain and spinal disorders.

Vibration type	Exposure Action Value (EAV)	Exposure Limit Value (ELV)	Action required
Hand-arm vibration (HAV)	2.5 m/s² A(8)	5 m/s² A(8)	At EAV: health surveillance, reduce exposure, provide information. At ELV: exposure must not be exceeded under any circumstances.
Whole-body vibration (WBV)	0.5 m/s² A(8)	1.15 m/s² A(8)	At EAV: assess and reduce exposure, maintain seats and suspension. At ELV: must not be exceeded; remove operator or change equipment.

HAVS is irreversible — prevention is the only remedy

Once Hand-Arm Vibration Syndrome develops, the damage cannot be undone. Symptoms include blanching of the fingers (vibration white finger), loss of grip strength, tingling and numbness, and pain in the hands and wrists. The RAMS must identify which tools and plant exceed the EAV, calculate daily exposure durations, rotate operators to stay within limits, and ensure health surveillance is in place for all exposed workers. The HSE’s online vibration exposure calculator should be used to determine safe trigger times for each item of equipment.

4. Key Hazards

Plant operations generate a range of hazards that must be addressed in the RAMS. The following table identifies the principal hazards, who is at risk, the key risk factors, and the controls required.

Hazard	Who at risk	Risk factors	Controls
Pedestrian struck by plant	All site workers, visitors	Poor segregation, blind spots, reversing manoeuvres, no banksman	Segregated pedestrian routes (CDM Reg 27), banksmen for reversing, proximity warning systems, high-visibility PPE, one-way traffic systems
Plant overturning	Operator, nearby workers	Soft ground, slopes, overloading, uneven surfaces, wind (cranes)	Ground condition assessment, outrigger pads on firm ground, rated capacity indicator, wind speed monitoring for cranes, operator training
Underground service strike	Operator, nearby workers	Inadequate service location, no CAT/Genny survey, mechanical excavation near services	PAS 128 survey, CAT and Genny scan before excavation, hand dig within 500mm of services, service plans reviewed and marked on ground
Whole-body vibration (WBV)	Plant operators	Prolonged operation on rough terrain, poor seat suspension, old plant	WBV exposure assessment, seat maintenance and replacement, task rotation, EAV and ELV monitoring, health surveillance
Hand-arm vibration (HAV)	Operatives using handheld tools	Breakers, vibrating pokers, compactors, cut-off saws used for extended periods	Vibration exposure calculator, trigger time limits, low-vibration tool selection, task rotation, health surveillance, anti-vibration gloves as last resort
Plant-to-plant collision	Multiple operators	Congested site, poor traffic management, no one-way system	Traffic management plan, designated routes, speed limits, one-way systems, proximity warning systems, radio communication
Pre-use check failure	Operator, all site workers	Defective brakes, hydraulics, steering, lights, or guards not identified	Daily pre-use inspection checklist, defect reporting system, plant taken out of service until defects rectified, PUWER Regulation 6 compliance
Unauthorised operation	Untrained person and nearby workers	Keys left in plant, no card check process, agency workers not verified	Isolator key removal when unattended, CPCS/NPORS card check on every operator before first use, plant register with named operators, key safe system

5. Common Mistakes

No pedestrian-vehicle segregation plan

CDM 2015 Regulation 27 requires that construction sites are organised so that pedestrians and vehicles can move without risks to health or safety. Relying solely on high-visibility clothing without physical segregation, designated crossing points, and banksmen is insufficient. The traffic management plan must be documented in the RAMS and enforced on site.

Operating plant without a current thorough examination

LOLER Regulation 9 requires that lifting equipment undergoes thorough examination at prescribed intervals — every 6 months for equipment lifting persons, and every 12 months for equipment lifting loads only. Operating lifting plant without a current thorough examination report is a criminal offence and one of the most common LOLER breaches identified by HSE inspectors.

No vibration exposure assessment for hand-held tools

The Vibration Regulations 2005 require a suitable and sufficient assessment of HAV exposure wherever workers use vibrating hand-held tools. Many sites fail to calculate trigger times, monitor cumulative exposure, or provide health surveillance. HAVS claims are among the most common industrial disease claims in construction, and the absence of a vibration assessment is difficult to defend.

Failing to check operator competence cards daily

Checking CPCS or NPORS cards at induction is not enough. Cards expire, operators switch between sites, and agency workers may not hold the correct category. A robust system checks operator cards against the specific plant category each day before work commences. The CPCS card-check hotline and online verification service should be used to confirm validity.

Using excavators for lifting without a lift plan

Excavators are routinely used for lifting operations — suspending trench boxes, sheet piles, or skips. The moment an excavator suspends a load, it becomes lifting equipment under LOLER and requires a lift plan, an appointed person, a lift supervisor, a slinger/signaller, and a current thorough examination report covering the lifting configuration. Treating excavator lifting as an informal activity is a serious compliance failure.

6. Frequently Asked Questions

Is a CPCS card legally required to operate plant on a construction site?▾

CPCS is not a legal requirement in itself, but PUWER Regulation 9 requires that only competent persons operate work equipment where there is a specific risk. In practice, CPCS (or the equivalent NPORS scheme) is the industry-accepted evidence of operator competence. Most principal contractors require it as a site condition, and the HSE expects to see a recognised competence card for any operator involved in an incident.

How often must lifting equipment undergo thorough examination?▾

Under LOLER Regulation 9, lifting equipment must be thoroughly examined every 12 months for equipment used to lift loads only, and every 6 months for equipment used to lift persons (such as a MEWP or passenger hoist). Accessories for lifting (chains, slings, shackles) must be examined every 6 months. An insurance engineer or competent person independent of the user must carry out the examination, and the report must be available on site.

What is the difference between a pre-use check and a thorough examination?▾

A pre-use check is a visual and functional inspection carried out by the operator each day before first use, typically using a manufacturer-provided checklist. It covers obvious defects such as fluid leaks, damaged guards, worn tyres, and faulty controls. A thorough examination under LOLER is a detailed engineering inspection carried out by a competent person (usually an insurance engineer) at prescribed intervals to verify structural integrity and safe working condition. Both are required — one does not replace the other.

Do the Vibration Regulations apply to all plant operators or only those using hand-held tools?▾

Both types of vibration are covered. Hand-arm vibration (HAV) applies to workers using hand-held vibrating tools such as breakers, compactors, and vibrating pokers. Whole-body vibration (WBV) applies to operators of mobile plant who are exposed to vibration transmitted through the seat — particularly on rough terrain or when using older machines with inadequate seat suspension. The employer must assess and control both types of exposure.

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