Making machinery and equipment — machining, fabrication, welding, heat treatment, assembly and testing — is metalworking- and process-intensive. The duties in this guide apply to running the factory and employing people, whatever you make. Get this spine in place first, then layer the product-conformity rules on top.
Health and safety law here is largely devolved. The Health and Safety Executive (HSE) is the regulator in Great Britain and the Health and Safety Executive for Northern Ireland (HSENI) in Northern Ireland; the underlying duties are equivalent across the UK. Work through the sections below in order.
A. Meet your general health and safety duty
The Health and Safety at Work etc. Act 1974 is the foundation. You must ensure, so far as is reasonably practicable, the health, safety and welfare of your employees and of anyone else affected by your work. In a machinery factory that means risk-assessing machine tools, welding and cutting, lifting and assembly, noise and vibration and material handling, providing safe systems of work, and training and supervising your people.
B. Control exposure to hazardous substances (COSHH)
The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require you to assess, then prevent or adequately control, exposure to hazardous substances. In machinery manufacturing that means metalworking fluids and mists, welding fume, solvents and degreasers, paints and surface coatings, and any dust from grinding and machining. Provide engineering controls — local exhaust ventilation — and health surveillance where the regulations require it. In Northern Ireland the equivalent COSHH (Northern Ireland) Regulations 2003 apply.
C. Keep your work equipment safe (PUWER)
Your machinery — machine tools, presses, welding and cutting plant, test rigs and assembly equipment — must be suitable, properly maintained, inspected and adequately safeguarded under the Provision and Use of Work Equipment Regulations 1998. Guarding of machine tools and presses, and safe isolation for setting, maintenance and testing, are recurring enforcement themes. Lifting plant reads across to LOLER 1998.
D. Manage manual handling
Moving castings, fabrications, components, sub-assemblies and finished machines is routine and often heavy, so the Manual Handling Operations Regulations 1992 apply. Avoid hazardous manual handling so far as is reasonably practicable; where you cannot, assess the risk and reduce it — through lifting equipment, better layout and safe systems of work.
E. Manage fire safety
Hot work, solvents, oils and combustible packaging give machinery manufacturing a real fire load. The responsible person must carry out a fire risk assessment and maintain fire-safety arrangements, including hot-work permits and safe storage of flammables. The duty is devolved: the Regulatory Reform (Fire Safety) Order 2005 in England and Wales; the Fire (Scotland) Act 2005 and Fire Safety (Scotland) Regulations 2006 in Scotland; and the Fire and Rescue Services (Northern Ireland) Order 2006 in Northern Ireland.
F. Hold employers' liability insurance
As soon as you employ anyone, you must hold employers' liability compulsory insurance — normally at least £5 million of cover — and display or make available the certificate. This is a legal requirement across Great Britain, with an equivalent duty in Northern Ireland.
G. Meet your equality duties
As an employer you must not discriminate against, harass or victimise people because of a protected characteristic. In Great Britain this is governed by the Equality Act 2010; in Northern Ireland separate equality legislation applies, enforced by the Equality Commission for Northern Ireland.
H. Handle personal data lawfully
If you process personal data — about staff, customers or suppliers — you must comply with the UK GDPR and the Data Protection Act 2018, and in most cases pay the data protection fee to the Information Commissioner's Office (ICO). This applies UK-wide.
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1. Write your health and safety risk assessments
Assess machining, welding, assembly, lifting, noise and vibration, and put safe systems of work, training and supervision in place under HASAWA 1974.
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2. Put COSHH controls in for fluids, fume and coatings
Assess metalworking fluids and mists, welding fume, solvents and paints; fit local exhaust ventilation and arrange health surveillance where COSHH requires it.
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3. Bring work equipment into a PUWER regime
Make sure machine tools, presses and welding plant are guarded, maintained, inspected and safely isolated for setting, maintenance and testing.
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4. Control manual handling and carry out your fire risk assessment
Reduce hazardous handling of castings, components and finished machines; assess fire risk from hot work, oils and flammables under the regime for your nation.
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5. Take out employers' liability insurance and register with the ICO
Arrange at least £5 million of cover before anyone starts work, and pay the data protection fee unless you are exempt.
What to do next
This spine covers the duties of running the factory and employing people. On top of it sit the product-conformity and type-approval rules for what you make:
- Follow Place machinery and equipment on the market for machinery safety, EMC, pressure equipment, lifts, vehicle and engine type approval, and general product safety.
- Confirm you have covered everything with the machinery and equipment manufacturer compliance checklist.
Official sources
Authoritative health and safety and data-protection guidance.