If you own, hire out or simply use stillages, cages, post pallets or trolleys anywhere in Great Britain, one set of rules sits underneath everything you do with them: the Provision and Use of Work Equipment Regulations 1998, universally shortened to PUWER. It is not a niche or optional standard. PUWER applies to almost every piece of equipment used at work, and a loaded steel stillage being lifted, stacked, wheeled or transported is very much work equipment in the eyes of the law.
The trouble is that most guidance on PUWER is written for machinery with guards and moving parts, leaving the people responsible for storage and handling equipment to work out how it maps onto a welded steel frame. This guide closes that gap. It explains what PUWER actually requires, how it differs from LOLER, where UKCA marking fits in, and — crucially — the practical steps for selecting, assessing, inspecting and maintaining stillages so that you can demonstrate compliance rather than just hope for it.
What PUWER Is (and Isn’t)
PUWER places duties on any employer or self-employed person who provides or uses work equipment. In plain terms, it requires that equipment is:
- Suitable for the task and the conditions in which it will be used;
- Maintained in a safe condition and, where relevant, inspected to keep it that way;
- Used only by people who have received adequate information, instruction and training;
- Accompanied by appropriate safeguards against the specific risks it creates.
Two points routinely catch businesses out. First, PUWER duties do not stop at the point of purchase — they run for the entire working life of the equipment, so a stillage that was perfectly compliant on day one can drift out of compliance through wear, damage or misuse. Second, “work equipment” is defined broadly. A humble collapsible metal pallet, a bulk bag holder or a warehouse trolley all fall within scope, not just the obvious lifting kit.
It is also worth being clear about what PUWER is not. It is not a product certification scheme, and it does not, on its own, cover the mechanics of lifting a load. Those responsibilities sit with UKCA marking and LOLER respectively, and understanding how the three interlock is the foundation of getting compliance right.
PUWER, LOLER and UKCA: How They Fit Together
These three frameworks are frequently confused, yet each answers a different question about the same piece of equipment.
PUWER — the general duty
PUWER is the baseline. It governs whether a stillage or cage is suitable, maintained, inspected and used safely across the whole of its life. Every stillage in your operation is caught by PUWER, whether or not it is ever lifted.
LOLER — the lifting overlay
The Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) sit on top of PUWER and apply specifically when equipment is used for lifting or lowering loads. The moment a stillage is designed to be craned, hoisted or lifted with a load inside it — rather than simply forked at ground level — it becomes lifting equipment and attracts LOLER duties, including thorough examination at defined intervals. This is why a stillage intended for overhead lifting is a fundamentally different product from a standard storage unit and should be sourced as a certified lifting stillage with documented load testing, not adapted after the fact.
UKCA — the product mark
Since Great Britain introduced its own conformity regime, the relevant product marking for equipment placed on the GB market is UKCA (UK Conformity Assessed). For structural steel fabrications such as stillages, UKCA marking is underpinned by the harmonised welding and execution standard BS EN 1090, giving assurance that the item has been designed, welded and manufactured to a controlled specification. Buying UKCA-marked equipment does not discharge your PUWER duties — you still have to use and maintain it correctly — but it gives you a defensible starting point and removes a whole category of doubt about the equipment’s structural integrity.
A simple way to hold the three in mind: UKCA tells you the equipment was built right, PUWER tells you it is being used and kept right, and LOLER tells you the lift itself is right.
Selecting Suitable Stillages
The first and most substantive PUWER duty is suitability. Choosing the wrong stillage is not just inefficient — it is a compliance failure the moment the equipment goes into service. A structured selection process should cover the following.
- Task and load profile. Define what you are storing or moving: weight, dimensions, shape, fragility and whether the load is static, dynamic or concentrated in one area. A point load behaves very differently from an evenly spread one.
- Load capacity with a margin. Match the manufacturer’s rated capacity to your heaviest realistic load, and never treat the rating as a target to run up against. Overloading is one of the most common causes of structural failure.
- Material compatibility. Consider chemical, corrosive or reactive interactions between the stored goods and the steel. Aggressive substances, moisture or outdoor exposure may call for specific coatings or finishes.
- Format and access. Solid sheeted metal stillages contain fine or loose materials and offer security; mesh stillages give visibility, drainage and airflow. Drop fronts, removable panels and fork guides all affect how safely and quickly the unit can be loaded.
- Environment. Temperature, humidity, floor condition and whether the unit lives indoors or on site all bear on both suitability and durability.
- Specialist hazards. Some contents demand a purpose-built solution — compressed cylinders, for example, belong in a properly ventilated gas bottle cage rather than a general storage unit.
Where no standard product fits the task cleanly, the compliant answer is engineered design rather than improvisation. A bespoke stillage built to your exact load and dimensional requirements is almost always safer — and cheaper over its life — than forcing an off-the-shelf unit to do a job it was not designed for.
Risk Assessment: The Engine of Compliance
PUWER expects the risks associated with work equipment to be identified and controlled, and a documented risk assessment is how you evidence that. It does not need to be elaborate, but it does need to be genuine and specific to your operation. A workable structure is:
- Identify hazards. Sharp edges, unstable or badly stacked loads, trapping points on drop fronts and hinges, manual handling strain, interaction with forklifts and other traffic, and slip hazards from spills or debris around the unit.
- Assess the risk. Weigh the likely severity of harm, how often it could occur and how many people are exposed. This lets you prioritise rather than treat every hazard as equal.
- Apply the hierarchy of control. Eliminate or engineer out the hazard first (for example, a stillage designed to nest and stack safely), then use administrative controls such as safe systems of work and stacking limits, and only then rely on personal protective equipment.
- Record your findings. Set down the hazards, the risks and the controls you have put in place.
- Review and update. Revisit the assessment whenever the equipment, the load, the process or the workplace changes — and periodically even when they do not.
PPE sits deliberately at the bottom of that hierarchy: it is the last line of defence, not the first. Where it is needed for stillage handling — cut-resistant gloves for sharp edges, safety footwear against dropped loads, high-visibility clothing in trafficked areas — it must be selected against the identified hazards, correctly fitted, and backed by training and routine inspection.
Inspection and Maintenance
Suitability at the point of purchase means nothing if the equipment degrades unnoticed. PUWER’s maintenance and inspection duties are where day-one compliance is either sustained or quietly lost.
Routine inspection
Set an inspection frequency proportionate to how hard the equipment is worked and how harsh its environment is — daily pre-use checks for heavily used units, longer intervals for lightly used stock. Each visual inspection should cover:
- Frames, welds and joints for cracks, distortion or corrosion;
- Base plates, feet and load-bearing surfaces for damage or deflection;
- Fasteners for looseness or absence;
- Moving parts — hinges, locking pins, latches and drop-front mechanisms — for smooth, secure operation;
- Stacking behaviour: correct alignment, even stacking and adherence to stated stacking limits.
Remember that stillages used for lifting attract a separate, more formal regime under LOLER — thorough examination by a competent person — over and above these routine PUWER checks.
Planned maintenance
Back inspection with a maintenance schedule: prompt repair or replacement of damaged components, cleaning to remove debris and contaminants, and lubrication of moving parts to the manufacturer’s guidance. Keep frequently damaged wear items — shoot bolts, pallet feet, end caps and label holders — in stock so that a minor defect can be fixed the same day rather than left to worsen. Complex structural repairs, particularly to welds, should go to qualified personnel rather than being patched on the floor.
Documentation
Record what you inspected, what you found, what you did and who did it. This paper trail is not bureaucracy for its own sake: it is the single most useful thing you can produce if an incident occurs or an inspector asks how you manage your equipment. It also reveals recurring faults that point to a deeper problem with the equipment or the way it is used.
Training and Competence
PUWER is explicit that people who use work equipment must have adequate information, instruction and training. For stillages that means operators understand the rated load and never exceed it, know the correct stacking and nesting limits, can safely operate drop fronts and locking mechanisms, and understand how the unit interacts with forklifts and lifting equipment. Just as importantly, foster a culture where staff report a bent frame, a failing latch or a cracked weld the moment they spot it — early reporting is what turns a near miss into a prevented accident.
A Practical PUWER Checklist for Stillages
- Is each stillage suitable for its actual load and environment, with a sensible capacity margin?
- Is it UKCA marked and built to a recognised standard such as BS EN 1090?
- If it is lifted, is it a certified lifting stillage under a LOLER thorough-examination regime?
- Is there a documented risk assessment, reviewed when things change?
- Are inspections and maintenance scheduled, carried out and recorded?
- Are operators trained and encouraged to report defects?
- Are spare consumables on hand so defects are fixed quickly?
Work through that list honestly and you will have a defensible, practical PUWER position — not a folder of paperwork, but equipment that is genuinely fit, safe and well looked after.
Get Compliant Equipment, Built in the UK
Compliance is far easier when it is designed in from the outset. As a UK manufacturer, Lowe Stillages & Cages builds steel stillages, cages, post pallets, collapsible metal pallets, trolleys and gas-bottle handling equipment to controlled specifications, with load testing and certification available where your application demands it. If you are unsure which format, capacity or certification your operation needs, our team can help you specify equipment that meets PUWER, LOLER and UKCA requirements from day one.
Get a quote for standard or bespoke equipment, or contact our team to talk through your compliance requirements.