Compliance Gaps Hiding in Plain Sight

Test 1: Can you prove the population is complete?

Before asking whether inspections are current, ask whether every relevant asset, system and location is known.

Reconcile the compliance register against several independent sources:

• purchase and lease records;
• fixed-asset and insurance schedules;
• planned maintenance systems;
• site surveys and floor walks;
• contractor reports;
• disposal and transfer records; and
• local inventories held by departments.

Differences are valuable. They expose equipment that has been moved, renamed, replaced or acquired outside the usual route. Pay particular attention to mobile equipment, low-value purchases, tenant-provided assets, inherited systems after acquisition and equipment used infrequently.

A unique identifier should remain with the asset throughout its life. Descriptions such as “compressor in plant room” are not strong enough where several similar items exist or locations change.

Test 2: Is the correct regime applied?

Inspection, maintenance, servicing and statutory thorough examination are related but not interchangeable.

For example:

• PUWER requires work equipment exposed to deterioration that could create danger to be inspected at suitable intervals and after exceptional circumstances;
• lifting equipment may require thorough examination under LOLER by a competent person at prescribed or scheme-based intervals;
• qualifying pressure systems require a suitable written scheme of examination before use and examinations in accordance with that scheme; and
• local exhaust ventilation used to control substances hazardous to health normally requires thorough examination and testing at defined intervals, alongside routine checks and maintenance.

The label on a contractor visit does not determine legal compliance. The scope, competence, method, frequency and resulting report must satisfy the applicable requirement.

Create a simple obligation profile for each asset class: relevant legislation or standard, required activity, trigger or interval, competent-person criteria, records and escalation rules. This prevents the planned-maintenance schedule from becoming the organisation’s only interpretation of the law.

Test 3: Are intervals based on the right trigger?

Calendar dates can conceal incorrect start points or missed events. A schedule should consider:

• first use or installation;
• the previous examination date and specified due date;
• deterioration and manufacturer information;
• exceptional circumstances, damage, modification or relocation;
• changes in use, environment or loading;
• recommendations in the written scheme or competent-person report; and
• periods of non-use followed by recommissioning.

An automatically recurring annual task may be too frequent for one activity and dangerously late for another. It may also fail to recognise an examination scheme based on use, condition or a different statutory interval.

Test 4: Does a defect change what happens next?

The assurance value of an examination lies partly in the response to what it finds. Reports should be triaged promptly, not filed first and interpreted later.

For each defect, the organisation needs clarity on:

• whether continued use is permitted;
• any immediate isolation, restriction or interim control;
• the person authorised to make that decision;
• the repair owner and target date;
• whether the competent person or regulator must be notified;
• what evidence is required to close the action; and
• whether similar assets may share the same weakness.

“Completed” should mean that the defect has been resolved and verified, not merely that a work order has been raised or passed to a supplier.

Test 5: Can leadership see exposure, not just completion?

A headline percentage of inspections completed on time can be misleading. Ninety-nine per cent completion may hide one overdue safety-critical asset. Conversely, a small volume of overdue low-risk activity can dominate an undifferentiated dashboard.

Useful management information separates:

• safety-critical and statutory activities from routine tasks;
• overdue, booked, completed and report-awaited status;
• assets unavailable or restricted because of defects;
• high-priority corrective actions and ageing;
• recurring defects and poor-performing asset classes;
• supplier performance and report quality; and
• sites or departments with reconciliation gaps.

The board does not need every certificate. It does need to understand where the system is uncertain, where a critical control is unavailable and whether management action is reducing exposure.