At 15:40 on a Thursday, a competent person finishes the annual thorough examination of a six-tonne gantry crane and hands the site engineer a LOLER Regulation 10 report noting hairline cracking on a hook block cheek plate. The report reaches the EHS inbox that evening. Three weeks later it still lives there as a PDF. The equipment record in Maximo shows the crane as “inspected”, no defect, no work order, no failure code. Twelve months on, at the next thorough examination, the same crack is recorded again, now with a growth measurement, and the competent person asks, politely, why nothing was done.
This is what statutory inspection failure looks like in most asset-intensive operators. The examination is performed properly, the paperwork is legally sufficient, and yet none of it lands anywhere a reliability engineer, a maintenance planner or an asset director would notice. The asset management discipline is not the examination itself. It is the path the report takes into the asset record.
What the competent person actually leaves you with
Under LOLER 1998, a competent person performs a thorough examination of lifting equipment at intervals fixed by Regulation 9, typically every six or twelve months depending on the equipment class, and issues a written report under Regulation 10. Serious defects must be reported verbally to the dutyholder at once, then in writing to the enforcing authority. Under PSSR 2000, a pressure system in scope cannot be operated without a Written Scheme of Examination signed by a competent person, and Regulation 9 requires examinations to be carried out in accordance with the scheme. Under PUWER 1998, inspection intervals are set by risk and duty type, and each record must show the equipment, the person, the date, and any defects. Sector regimes sit alongside: COMAH, Ex-rated equipment, BS 7671 fixed electrical installations, statutory thermal imaging on switchboards, high voltage plant. Each produces the same artefact: a named competent person, a dated examination, defects, action required, a next due date.
Each of those records contains something a reliability programme cannot produce in-house: an independent, calibrated observation of the asset by a specialist working under a legal duty of care. Per examination, that observation is worth more than a corrective work order raised by the operator’s own crew, because it is scoped and reported to a fixed protocol rather than to shift pressure.
Why the findings rarely reach the failure history
The failure is procedural. The paper path was designed to satisfy the regulator, not the asset manager, and in most operators it runs outside the CMMS. Four patterns produce the disconnect.
- The examination bypasses the CMMS. In many estates the visit is arranged directly between the EHS function and the third-party competent person. The equipment record in Maximo never sees it. Nothing is scheduled, nothing is closed, no failure code is attached.
- The report is filed as a scan against a folder. A PDF lands in a shared drive. The asset record carries, at best, a hyperlink to that folder. The finding is not searchable, not reportable and not visible on the asset when a planner opens it.
- Defect rectification runs outside the maintenance backlog. A repairable defect is raised as a one-off through EHS or engineering, not through the planning cycle. Asset criticality never influences its priority.
- Scope drifts silently at reorganisation. When plant is reconfigured or equipment moves between operating locations, the equipment list under a PSSR Written Scheme diverges from the CMMS asset hierarchy. Next year’s examination is scoped from the old list. Items fall out. Nobody notices until an audit.
The result is compliance on paper and blindness in data. Findings from the most authoritative inspection performed on the estate never influence PM design, spares strategy, or asset criticality reassessment.
Statutory work belongs on the work management chain
The mechanism that closes the gap is to treat every statutory examination as a first-class work order in the CMMS, generated from a PM, executed by the competent person on site, and closed with a structured record. In IBM Maximo and MAS the routine is unremarkable.
- A statutory PM sits against the asset, with the correct frequency (six or twelve months for LOLER, the interval in the Written Scheme for PSSR, the duty-driven cadence for PUWER). The job plan carries the reference to the regime and scheme document.
- The work order is raised automatically, assigned to the competent person’s organisation, and used as the vehicle for their attendance on site. Closing the work order confirms the examination was performed against the scheme.
- Findings are recorded on the work order using the failure code hierarchy already in place for that equipment class, so statutory findings roll up alongside corrective and condition-driven ones. This depends on the failure code library being fit for statutory observation, not only for crew reporting.
- The examination report is attached to the work order as evidence. The report metadata (competent person, examination date, next due date, defects reported to an enforcing authority) is captured as work order fields, not buried inside the PDF.
- A repair identified in the examination is raised as a linked corrective work order, planned through the normal maintenance queue, and prioritised against the asset’s criticality rating.
Everything downstream, bad actor lists, PM strategy revisions, spares reviews, is built on the accuracy of that entry.
What the asset record must carry
For the record to be worth reading, the asset itself needs a small set of attributes, configured once and relied on for a decade.
- The statutory regime that applies (LOLER, PSSR, PUWER, COMAH, sector-specific), stored as an attribute, not implied by the equipment classification.
- A reference to the Written Scheme of Examination or equivalent regime document, held in the linked document library and versioned.
- The competent person’s organisation and, where the regime records this, the named examiner.
- The last examination date and the next due date, both as first-class fields on the asset, so an overdue examination can be reported without opening PDFs.
- A flag for defects reported to an enforcing authority under Regulation 10 style provisions, so the compliance lead sees those separately from ordinary findings.
- A history of examinations on the record, so a five-year defect trend on that asset is visible on the equipment page rather than in a compliance archive.
None of this is unusual configuration work. It gets skipped when statutory inspection is treated as an EHS system rather than an asset management artefact.
What stays hard
Competent person independence has to be protected. The examination’s evidential weight depends on the examiner sitting outside the operating and maintenance chain. Building the work order into the CMMS must preserve that line, and the workflow must keep the report intact and unedited.
Scope alignment at reorganisation is a rolling job. When plant is reconfigured, sold, decommissioned, or brought under new ownership, the Written Scheme of Examination must be reviewed by the competent person and the CMMS asset population updated in the same cycle. There is no automation that removes the review.
Rented and contractor-owned equipment sits in a grey zone. Where LOLER equipment is hired in for a short campaign, examination is usually the hire company’s responsibility, but the operational duty holder still needs the record visible in the receiving CMMS during the hire. This is worth a written pre-mobilisation handover with a copy of the current examination report attached.
Closing position
Statutory inspection is asset management work. The competent person’s examination is the highest-authority inspection record most operators will see this year, and in the majority of estates it is being left in inboxes because the CMMS was never asked to carry it. The design change is small: statutory PMs, structured findings against the failure library, evidence attached to the work order, next due dates on the asset record. Programmes that make the move stop being surprised by defect trends in year two. Programmes that leave the design untouched will spend the next audit cycle explaining why a hairline crack recorded last year appears again this year, larger.