Can I rely on risk assessments for doors, gates, and barriers?

The Door & Hardware Federation (DHF) technical team are often asked whether carrying out a risk assessment is enough to demonstrate compliance for powered doors, gates, and barrier systems. With several sets of UK regulations referencing risk assessment, it can be unclear where legal responsibilities begin and end. In this article, DHF’s technical experts explain how the regulations apply and why recognised safety standards remain central to ensuring compliance and protecting users.

When looking at the safety of doors, gates, and barrier systems, three sets of UK regulations are often referred to, The Supply of Machinery Safety Regulations 2008, The Provision and Use of Work Equipment Regulations 1998, and The Lifting Operations and Lifting Equipment Regulations 1998. 

All three place importance on risk assessment as a method of identifying hazards and protecting people. Because of this, it is sometimes assumed that completing a general risk assessment is enough to demonstrate legal compliance for entrance systems. 

 In practice however, the position is more specific and depends on which regulations apply and how they interact with recognised safety standards. This article explains how each set of regulations applies to doors, gates, and barriers, and whether risk assessment alone can be relied upon.

Supply of Machinery Safety Regulations 2008

The Supply of Machinery Safety Regulations applies to powered doors, gates, and barriers that are placed on the market or put into service. These regulations implement the requirements of the Machinery Directive into UK law and require manufacturers and installers to ensure that machinery is safe. Risk assessment forms part of these regulations. Manufacturers are required to identify hazards and reduce risks so far as possible. 

However, powered entrance systems are also covered by harmonised European standards and UK designated standards, which describe specific safety measures and performance requirements. These standards represent what is commonly referred to as the ‘state-of-the-art’, and define the minimum level of safety expected for compliance. Where a harmonised standard exists, any risk assessment used as an alternative approach must achieve a level of safety that is equal to or better than that provided by the standard. 

In theory, this allows for alternative solutions. In practice, the standards already provide detailed, well-established methods for addressing known risks such as crushing, impact, and trapping. Because of this, it is difficult to see how a different risk assessment approach could realistically offer the same level of protection without following the standards themselves. For this reason, compliance with the appropriate standard remains the normal and most reliable route to meeting the requirements of these regulations.

Provision and Use of Work Equipment Regulations 1998 (PUWER)

The Provision and Use of Work Equipment Regulations (PUWER) apply to a wide range of equipment used at work. This often leads to the assumption that they apply to all powered doors, gates, and barriers in workplaces. However, for entrance doors, gates, and barriers that are part of the building structure, the Workplace Health, Safety and Welfare Regulations take precedence. 

 PUWER specifically address the safety of workplace doors and traffic routes. As a result, normal entrance systems in and around workplaces do not fall under the Provision and Use of Work Equipment Regulations. Their safety is instead assessed by reference to relevant standards, which define what is reasonably practicable. Enforcement authorities and courts have previously accepted that where a recognised standard exists, it is reasonable to expect it to be followed. This means that risk assessments under PUWER are not required for entrance systems. 

 There is an important exception, however. Where a door, gate, or barrier forms part of a machine, production line, or industrial process, and not a building entrance, it may fall within the scope of these regulations. In such cases, risk assessment would be required.

Lifting Operations and Lifting Equipment Regulations 1998 (LOLER)

The Lifting Operations and Lifting Equipment Regulations (LOLER) apply to equipment used for lifting or lowering loads. Doors, gates, and barriers do not lift loads but simply move their own structure between open and closed positions. Because of this, these regulations do not apply to entrance systems. 

This position is supported by HSE guidance, which explains that equipment which only moves itself is outside the scope of LOLER. As with the Provision and Use of Work Equipment Regulations, entrance systems in workplaces are instead covered by the Workplace Regulations and the relevant safety standards. Risk assessments under these regulations are therefore not required for doors, gates, and barriers.

The role of standards and risk assessment

Recognised standards for powered doors, gates, and barriers describe known hazards and the measures needed to control them. They are based on many years of technical development, accident data, and industry experience. Risk assessment can play a supporting role, particularly where site conditions are unusual or where additional control measures are needed. 

However, a risk assessment cannot be used to justify safety measures that fall below the level set out in the standards. In simple terms, risk assessment does not replace the standards. It must work alongside them and cannot reduce the level of protection they require.

Summary

In summary, the Provision and Use of Work Equipment Regulations and the Lifting Operations and Lifting Equipment Regulations do not apply to entrance doors, gates, and barrier systems used as part of buildings. The Supply of Machinery Safety Regulations do apply to powered entrance systems, but any risk assessment carried out under these regulations must deliver a level of safety that is at least equal to that set out in the recognised standards. Because the standards already define current good practice and minimum safety levels, they remain the primary reference for legal compliance and for protecting people using doors, gates, and barriers.

www.dhfonline.org.uk

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