How do you carry out the suitability examination of a lifting appliance?

What the order of 1 March 2004 says

Article 5-I of the order of 1 March 2004 (arrêté du 1er mars 2004) defines the suitability examination of a lifting appliance as “the examination that consists of checking that it is appropriate for the work the user plans to carry out and for the risks to which workers are exposed, and that the planned operations are compatible with the conditions of use of the appliance defined by the manufacturer”.

So, three questions: can the machine do this job (load, reach, height)? Is it suited to the risks of the site? Do the operations stay within the limits of the manual? Lifting accessories (slings, spreader beams…) have their own suitability examination (article 7).

Circular DRT no. 2005-04, which comments on the order, sums it up: checking that the appliance, once on site, can be used there under the planned conditions, given its capabilities, its location and the operating conditions.

When is the suitability examination required?

There is no fixed interval: it is part of the checks at commissioning (mise en service) and recommissioning (remise en service), not of the periodic inspection (VGP, vérification générale périodique), which is limited to the state of preservation and tests (article 22).

Who carries it out, and with what information?

The checks in the order are “the responsibility of the head of the establishment” that commissions or uses the appliance (article 1). Commissioning and recommissioning checks are carried out under the same conditions as the VGP (articles R4323-22 and R4323-28 of the French Labour Code): by qualified persons, in-house or external, who are competent and know the regulations (article R4323-24).

According to INRS (the French national research and safety institute, brochure ED 6339), the suitability examination may be entrusted to a third party appointed by the employer, provided the relevant information is passed on. Prévention BTP (the construction industry’s prevention body) rather advises an in-house person who knows the site and the equipment. In all cases, the head of the establishment gives the person in charge of the examination written information on the planned work (article 3).

For hired equipment, the examination remains the responsibility of the user company, which checks with the hire company that the inspections have been carried out. The manual, copies of the first commissioning report and of the latest VGP report, and the VGP history must be kept on the appliance or nearby (article 15).

The method, step by step

Example: a company hires an aerial work platform for a façade in town. The site manager notes the height, outreach, weight of two workers and their tools, a sloping pavement and a nearby overhead line, and compares them with the working envelope of the proposed model. On delivery, he checks it is the right model, that the documents are on board, and has the functional tests carried out. If the slope exceeds what the manual allows, the machine or the method changes. The pre-use inspection of the aerial work platform then takes over at every shift start.

Prévention BTP offers templates (tower cranes, aerial work platform, forklift) and asks for a written document, dated and signed by the works manager.

1. Describe the operation in writing: loads (weight, dimensions, centre of gravity, wind exposure), height, reach or outreach, people and tools for an aerial work platform.
2. Describe the site: ground, slopes and cross-falls, access and clearances, obstacles, overhead power lines, co-activity, wind.
3. Compare with the manual in the actual configuration: load chart, safe working load, permitted slope and wind, interchangeable equipment.
4. Check that the lifting accessories suit the load, the appliance and the environment.
5. Conclude: suitable, suitable under conditions (packing, cordoning off, set configuration) or unsuitable.
6. Date, sign and file the document with the appliance’s reports.

Suitability, assembly, load tests, VGP: do not mix them up

An up-to-date VGP says nothing about suitability for your site. INRS adds that a recommissioning check without a suitability examination is partial: it is up to the user to have it completed.

Where should the suitability examination be recorded?

The head of the establishment enters the results of the checks without delay in the safety register (registre de sécurité, article 3 of the order); a report from an external person is appended to it (article R4323-26). The register and reports may be digital (article R4323-27). Inspection documents are kept for five years and, in any event, those of the last two checks (article D4711-3).

The maintenance logbook has another purpose: servicing, repairs, modifications. Keep the suitability examination with the appliance’s manual and reports, linked to the site concerned: it is the document you will be asked for after an incident.

What Trackary does, and what it does not do

Trackary stores on each machine’s record its documents (manual, VGP reports, signed suitability examination), its intervention history and its inspection due dates, with alerts. The tests done on delivery can be logged as an intervention, with checkpoints and signature, from the app on the phone. Trackary costs €14 excl. VAT per active machine per month (€11 above 50 machines), unlimited users, with a 30-day free trial, no credit card required.

Trackary does not carry out the suitability examination and does not judge whether a machine suits your site. It certifies nothing and replaces neither the qualified person nor the employer’s responsibility.