Industry urges HSE to retract emergency stop statements

The International Powered Access Federation (IPAF) has been joined by other industry associations to urge the UK’s Health and Safety Executive (HSE) to retract its letter sent to manufacturers regarding the use of emergency stop solutions on MEWPs.

The letter, issued in January, has sparked concern in the industry, with IPAF alongside the European Materials Handling Federation (FEM) and the Association of Equipment Manufacturers (AEM), stating that HSE’s interpretation of the rules around emergency stops does not adhere to the MEWP sector’s view on the subject.

IPAF CEO Peter Douglas introduces the annual IPAF Elevation event. (Photo: IPAF).

In their response the trio of associations said they were surprised at the sudden release of the letter, published by the HSE’s Product Safety and Market Surveillance Unit (PSMSU), came without the industry being warned and despite an ongoing consultation between IPAF and HSE on the subject.

“We are concerned that the HSE have not fully considered the consequences of the proposed action based on the HSE’s interpretation, and there is the potential for safety and commercial implications associated with the actions on the back of the interpretations within the letter,” said IPAF.

Points of concern 

IPAF said it was aligned in principle with the position, (based on BS EN ISO 13850:2015) that activating the Emergency Stop function shall not ‘impair the effectiveness of other safety functions’.

However, it was HSE’s additions to this principle in its letter to MEWP manufacturers that has concerned IPAF, FEM and AEM.

The HSE states in its letter, “Activating the emergency stop on a MEWP must not disable the safety related parts of the machine’s control system such as overload monitoring, inclination monitoring, stabiliser/outrigger monitoring, and associated alarms.’’

This says the association represents a clear misinterpretation of the requirements. “We agree that Emergency Stops shall not impair the effectiveness of safety functions. However, HSE’s interpretation of the requirements has extrapolated the requirement from BS EN ISO 13850 to include, for example, alarms which are not safety functions.”

“Each safety function on the MEWP creates a safe action by preventing movement. Currently, alarms and certain monitoring systems serve only to provide additional operational awareness.”

IPAF added that the HSE PSMSU, “Have formed a unique interpretation of the current requirements and expect this to be applied to relevant certified machines.”

“We are concerned with HSE’s apparent change of position in this regard and that the subtle expansion in language between the published standards and the HSE interpretation from ‘safety function’ to ‘safety related parts of the control system’ and ‘associated alarms’ would create new requirements, [not already included in the BS EN 280-1 or BS EN ISO 13850].”

IPAF, along with FEM and AEM, is now seeking ‘constructive dialogue’ with the HSE to clarify these differences in interpretation.

“We…believe that any proposal for the introduction of additional safety functions and alarm behaviours should be presented to the CEN Technical Committee developing EN 280-1 for inclusion based on a risk-based approach within the industry.”

Industry proposals

The Feration, with the FEM and AEM, have propose an “alternative and collaborative way forward”, involving three steps. 

• A review of the HSE’s letter: The industry has requested that the HSE consider revising its communication to ensure clarity, particularly regarding the interpretation of safety functions and alarms.
• Urgent technical discussions: IPAF MTC, alongside other representatives, seeks to engage with the HSE and PSMSU in technical discussions during February 2025 to establish a shared understanding of emergency stop requirements.
• Alignment with existing standards: The industry welcomes collaboration with the HSE to ensure consistency with BS EN 280-1:2022 and ongoing work within the CEN Technical Committee TC98/WG1. This would help ensure alignment with broader regulatory developments, including the Machinery Regulation 2023/1230/EU and relevant safety standards such as BS EN ISO 13849 and BS EN ISO 13850.

History of communications 

IPAF first addressed this issue In November 2022, providing initial guidance on the safe use of emergency stops on MEWPs. Further clarification was issued in December 2022, and most recently, IPAF published additional guidance on safe methods of isolation for platform controls on MEWPs.

On 23 January 2025, the HSE’s PSMSU issued a letter outlining its interpretation of emergency stop requirements. IPAF, alongside the European Materials Handling Federation (FEM) and the Association of Equipment Manufacturers (AEM), has responded, seeking constructive discussions.

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