Compliance Guide
Yes, racking inspections are a legal requirement. But the rules are spread across several pieces of legislation, two HSE documents, and an industry standard. Here’s exactly what applies to your warehouse and why.
Reading time: 9 minutes
If you operate pallet racking, cantilever racking or similar storage equipment in a UK workplace, you are legally required to:
Important
There is no single law that says ‘you must inspect your racking annually’. The requirement comes from how several pieces of legislation interact, with HSG76 and the SEMA Codes of Practice setting out what good compliance looks like in practice. The combined effect is unambiguous: you must inspect.
Racking inspection requirements come from four distinct sources, each adding a different layer of obligation:
The foundational piece of UK workplace safety law. It places a general duty on employers to ensure, so far as is reasonably practicable, the health, safety and welfare of employees and anyone else affected by the work. Damaged racking that could collapse on a person clearly falls under this duty.
Requires every employer to carry out a suitable and sufficient risk assessment. Pallet racking is a recognised workplace hazard, so any competent risk assessment must include it. Without regular inspection, you cannot reasonably claim to be assessing the risk.
This is the headline regulation. PUWER classifies pallet racking as work equipment, which means it must be inspected at suitable intervals by a person who is competent to do so. PUWER also requires that inspections be recorded.
Requires that workplaces, including the equipment within them, be maintained in an efficient state, in efficient working order and in good repair. Damaged racking is, by definition, not in good repair.
HSG76, titled Warehousing and Storage: A Guide to Health and Safety, is the HSE’s published guidance for warehouse operators. It is not a law in itself, but courts and HSE inspectors treat it as the benchmark for what reasonable practice looks like. Failure to follow HSG76 is, in practice, treated as evidence of non-compliance with the legislation above.
HSG76 makes three specific recommendations for racking:
Why This Matters
HSG76 is the document an HSE inspector or insurer will reference if anything goes wrong. If an incident occurs and you cannot produce evidence of regular internal checks plus an annual expert inspection, you are very likely to be found in breach of PUWER and the Management Regulations, irrespective of how the incident actually happened.
BS EN 15635 is the British and European standard titled Steel Static Storage Systems: Application and Maintenance of Storage Equipment. It is the technical document that defines what a competent inspection actually looks like.
BS EN 15635 sets out the inspection process, the criteria for damage classification, and the responsibilities of both the equipment owner and the inspector. The SEMA Codes of Practice are aligned with BS EN 15635, which is why a SEMA Approved Rack Inspector (SARI) inspection is automatically also a BS EN 15635 compliant inspection.
You don’t need to read BS EN 15635 to be compliant. You do need to ensure your inspector works to it, which any SARI will do by default.
PUWER and HSG76 both require that the annual inspection be carried out by a technically competent person. The legislation deliberately does not define this term, because competence is judged on a case-by-case basis. However, the HSE has stated repeatedly in guidance and in court cases that evidence of competence can include:
The SARI qualification (SEMA Approved Rack Inspector) is the only widely recognised UK qualification specifically for racking inspections. It involves a four-day course, a written exam, and a practical assessment, followed by ongoing CPD requirements. While other qualifications and forms of evidence can satisfy the ‘technically competent’ test, using a SARI is the simplest and most defensible way to demonstrate compliance.
In Plain Terms
If something goes wrong and you used a SARI inspector, you have a clear, well-recognised defence. If you used someone less qualified, you’ll be expected to demonstrate why you considered them competent for that specific task. That’s a much harder argument to make.
Non-compliance with racking inspection requirements has three categories of consequence, in increasing order of seriousness:
If an HSE inspector visits your site (whether routinely, after a complaint, or after an incident) and finds inadequate racking inspection arrangements, they can serve an Improvement Notice requiring you to fix the situation, or a Prohibition Notice forcing you to stop using the racking immediately.
Most public liability and employers’ liability insurance policies require you to comply with health and safety legislation. After an incident, an insurer who finds out you weren’t carrying out required inspections may reduce or decline a claim. This can leave the business personally exposed for the costs.
Breaches of PUWER and the Health and Safety at Work Act are criminal offences. Fines for serious cases regularly exceed six figures, and in cases involving serious injury or death, custodial sentences for directors are possible under the Corporate Manslaughter Act.
An enforced shutdown of part of your warehouse following a Prohibition Notice can be commercially devastating. So can the ripple effects of a serious incident: customer loss of confidence, supply chain disruption, recruitment difficulty, and the personal toll on staff.
Reading the legislation can make compliance sound complicated. In reality, a compliant warehouse needs four things in place:
If those four things are in place, working as intended, and documented, you are compliant. If any of them are missing or intermittent, you have a gap that will surface as soon as anything goes wrong.
Yes. Although no single piece of legislation uses the words ‘racking inspection’, the combined effect of PUWER, the Management Regulations, the Workplace Regulations and the Health and Safety at Work Act is that inspection is a clear legal duty. HSG76 and BS EN 15635 set out what good compliance looks like in practice.
It applies to any workplace with racking, regardless of size. There is no minimum threshold. A two-bay system in a small unit is just as much subject to PUWER as a multi-acre distribution centre, although the inspection itself will obviously be much shorter.
In principle, yes, if they meet the ‘technically competent’ test. In practice, this is hard to demonstrate without a recognised qualification, and creates an obvious independence problem (your staff inspecting equipment they themselves use). Almost every operator chooses an external SARI for the annual expert inspection and uses internal staff only for the weekly internal checks.
The legal requirements are exactly the same. In fact, second-hand racking often warrants extra attention because component history is less well known and mixed-manufacturer assemblies are more common. An inspection should be carried out before second-hand racking is first put into use.
The duty under PUWER falls on the employer, that is, the business operating the racking, not the building owner. If you rent a warehouse and your business uses the racking, the inspection duty is yours. Lease agreements sometimes shift this contractually but do not transfer the statutory duty.
PUWER requires records to be kept until the next inspection is carried out, but in practice you should keep them for considerably longer. Most operators keep at least six years of inspection records to align with limitation periods for personal injury claims, and many keep them indefinitely as part of their general H&S documentation.
The Health and Safety at Work Act, PUWER, the Management Regulations and the Workplace Regulations are all freely available on legislation.gov.uk. HSG76 is a free download from the HSE website. BS EN 15635 is published by BSI and is paid-for, although the relevant principles are summarised in HSG76 and the SEMA Codes of Practice for free.
This page is a plain-English overview written by SEMA Approved Rack Inspectors. It is not legal advice. If you have a specific question about your obligations, particularly in connection with an incident, an enforcement notice, or an insurance claim, consult a qualified health and safety lawyer.
Weekly checks, annual expert inspections, post-event triggers and high-throughput exceptions explained.
Who in your team should hold the role, what they actually do, and what training they need to be competent.
How damage is classified Red, Amber and Green, the criteria for each, and what each grade requires you to do.
