As an employer, you’re legally obligated to put “reasonably practicable” measures in place to protect your employees during manual handling tasks. But what this entails may not be immediately clear.

In this article, we explain exactly what employers are required to do under the Manual Handling Operations Regulations 1992 – and why, beyond fulfilling your duty of care, compliance is essential.

Manual Handling Operations Regulations 1992 – summary

The Manual Handling Operations Regulations 1992 (MHOR) were implemented to protect UK workers during work tasks involving manual handling:

• Lifting
• Lowering
• Carrying
• Pushing
• Pulling
• Otherwise moving a load by hand or bodily force

MHOR 1992 introduced a hierarchy of controls for manual handling tasks that should be followed in sequence to effectively mitigate risks and reduce injury rates:

1. Avoid manual handling where possible
2. Risk assess unavoidable manual handling
3. Take action to reduce the risk of injury based on risk assessment findings

Failure to comply with Manual Handling Operations Regulations 1992 may result in prosecution by the Health and Safety Executive (HSE). Penalties include fines and even jail time.

Learn about the different types of risk associated with manual handling.

Hierarchy of manual handling controls – in detail

The hierarchy of controls is one of the key points set out by the Manual Handling Operations Regulations 1992. These procedures focus on removing, identifying, and reducing the risks introduced by manual handling tasks.

Let’s discuss them in full to give you a complete picture of your responsibilities in practice under MHOR.

1. Avoid hazardous manual handling where reasonably practicable

The top control in the hierarchy states that any manual handling task that carries a risk should be avoided altogether where a practical alternative exists. This can be accomplished through redesigning the task or ‘by automating or mechanising the process.’

For example, instead of workers lifting and carrying heavy boxes of stock from the delivery area to the storeroom, a pallet truck or conveyor system could be used to eliminate the need for manual handling.

2. Where the hazardous manual handling task cannot be avoided, employers must assess the risk of injury employees face

The second MHOR control measure focuses on developing a comprehensive understanding of the risks at play when an employee carries out unavoidable manual handling tasks.

It acknowledges that some manual handling tasks cannot be cut from the workflow, particularly in industrial work environments or in emergency service professions, and guides employers in carrying out “suitable and sufficient” risk assessments.

The risk assessment of any manual handling task should consider:

• The task – frequency, duration, posture required (e.g., twisting, stooping, reaching, repetitive movements).
• The load – weight, size, shape, stability, and ease of grasp.
• The working environment – space constraints, floor condition, temperature, lighting, and ventilation.
• The individual’s capability – age, gender, level of training, fitness, pre-existing health conditions, and pregnancy.
• Other factors – use of personal protective equipment (PPE), time pressures, or unpredictable movements of the load (e.g., handling animals or unstable objects).

3. Employers must implement measures to reduce the risk of injury ‘so far as is reasonably practicable’

With the risk identified and dissected, the next step in the manual handling hierarchy of controls is to introduce safety measures that minimise hazards where reasonably practicable.

Again, this may involve changing the way employees approach the task or by providing support that makes the task safer. For example, you may break loads into smaller, more manageable units, and provide employees with manual handling training tailored to their tasks, helping them complete their work more sustainably and conscientiously.

What do the Manual Handling Operations Regulations 1992 cover?

The Manual Handling Operations Regulations 1992 define manual handling as follows:

‘The Regulations apply to manual handling activities involving the transporting or supporting of loads, including lifting, lowering, pushing, pulling, carrying, or moving loads. A load may be either inanimate, for example a box or a trolley, or animate, for example a person or an animal.’

The broadness of this definition ensures that the regulations apply to all workplaces where employers may face risks during manual handling tasks.

Employer responsibilities under the Manual Handling Operations Regulations 1992

Follow the manual handling hierarchy of controls

As the employer, your primary responsibility is to ensure the manual handling hierarchy of controls is effectively followed and implemented.

If there are any manual handling tasks in your workplace that pose a risk to employees, you must:

• Ask whether loads need to be lifted or if the task can be redesigned, automated or mechanised
• Carry out a risk assessment where hazardous manual handling is unavoidable
• Take reasonably practicable steps to minimise the risk – based on the findings of your risk assessment

Address new risks introduced by task modification

If you remove a manual handling task from the workflow, the solution may introduce a different set of risks. For instance, a mechanised solution, such as the use of lift trucks, can be dangerous in its own right.

The manual handling legislation reminds employees that these risks must also be minimised in accordance with the appropriate HSE guidance.

Carrying out risk assessments

If you conclude that there is no reasonably practicable way for your employee or employees to avoid a hazardous manual handling task, you must organise a risk assessment.

MHOR permits you to delegate this task, but reminds that, as you are responsible for health & safety in your business, ‘ultimately, you are responsible’. Let’s unpack that…

If you delegate the task to another employee, and they misjudge risk or carry out the risk assessment incorrectly, the buck stops with you.

Your delegate must:

• Be deemed competent to carry out the assessment
• Involve employees responsible for carrying out the task in the assessment process
• Understand their limitations as an assessor – and when specialist assistance is required

The MHOR 1992 also, of course, permit you to outsource professional risk assessment from experts like Cardinus.

Reviewing existing risk assessments

The Manual Handling Operations Regulations 1992 state that existing risk assessment reports should be reviewed by the employer if:

• You suspect they may no longer be valid
• The manual handling operations it assessed have changed significantly (i.e. the task now involves heavier loads, is performed more frequently, is carried out in a different location, or new equipment/layout changes affect how it is done)

Informing employees of risks

The MHOR 1992 state that employers must ensure employees understand the risks present during hazardous manual handling tasks.

You’re required to offer not just an outline of the greater risks, but also, where reasonably practicable, details that contribute to the risk, such as:

• Load weight
• Heaviest load side (if unbalanced)
• Special handling requirements

In short, any information that deepens your employees’ familiarity with the risks they’ll face ( and thus their ability to manage them) needs to be shared.

Protecting employees working outside business premises

The manual handling regs extend to work carried out on your business’s behalf on non-work premises.

Safe systems of work should be designed and taught to, for instance, employees who will be delivering goods or providing personal care off site.

As you have limited control over outside premises, you’re legally obligated to cooperate with those who do have control to make manual handling work safer on their premises:

‘… take all reasonable steps to co-ordinate and communicate with them to plan how the work can be done safely.’

Likewise, if an employee from another business visits your premises, you’re required to cooperate with them and their employer to make any manual handling tasks as safe as possible.

This might include joint risk assessments and a clear breakdown of who will provide which safety measures. In these cross-site scenarios, communication is key.

Protecting temporary, freelance, or agency workers

The Manual Handling Operations Regulations 1992 state that employers must apply the same health and safety protections to work whether it’s carried out by full-time employees or temporary, freelance, or agency workers.

Ensure safety measures have been implemented and are effective

Once manual handling safety measures have been decided upon, it’s the employer’s responsibility to ensure they are being implemented, and, importantly, that they are effectively reducing risk.

Manual handling laws require you to monitor safety measures in order to confirm they’re having the intended result. You can do so through open discussion with handlers and by regularly comparing current accident and ill-health data against pre-intervention data.

If the current measures are falling short, you’re obligated to adjust the approach until the task is provably safer.

Provide employees with manual handling training

The manual handling regs state that employers should provide manual handling-specific health and safety training to handlers. This is to supplement more general health and safety training rather than replace it. You also shouldn’t treat manual handling training as the whole solution. Your priority should always be to remove the task entirely or to make it safer through redesign.

Whether you appoint in-house personnel as trainers or outsource expert trainers, it’s the employer’s duty to check the competency of instructors.

The Manual Handling Operations Regulations 1992 recommend monitoring the efficacy of training as you do other risk reduction measures. They suggest:

• Keeping a record of who has been trained, when, and the content of the course taken
• Informing senior staff of the practices taught to workers
• Training new starters before or as soon as possible after they start their role
• Reviewing sickness, absence, or near-miss reporting before and after training

At Cardinus, we offer an interactive and customisable Manual Handling eLearning course backed by almost three decades’ experience in risk management and health & safety support.

Our training teaches employees best practices, sustainable working, and risk awareness – and includes a risk self-assessment tool that gives you a clear picture of the risk-levels of individual employees. Learn more about our Manual handling course.

What ‘reasonably practicable’ means in manual handling regulations

The term ‘reasonably practicable’ appears several times throughout the Manual Handling Operations Regulations 1992 and defines the degree to which employers need to act to safeguard employees from manual handling risks.

In essence, it means that risk reduction measures should be realistic and sustainable within the context of a task and your business. For example, if a risk solution is – in relation to the risk – disproportionately expensive, time-consuming, or otherwise disruptive, it’s not feasible.

This isn’t to say that you don’t have to do anything when a solution is determined appropriate; you simply have to seek more reasonable solutions, whether they be more affordable, more efficient, or less disruptive.

How do you know what is ‘reasonably practicable’?

Ultimately, what’s considered reasonably practicable is determined by the severity of the risk in question. The balance always tips in favour of health and safety rather than resources or operational factors.

In short, human safety always comes first.

The more severe the risk, the more resources you’re expected to invest to make a task safer. On the flip side, you won’t be expected to invest heavily in safety measures to combat a minor risk.

Use our RiskAI suite to assess the severity of manual handling risks.

Employee responsibilities under the Manual Handling Operations Regulations 1992

Even on your own business premises, you cannot be omnipresent and omniscient, which is why the Manual Handing Operations Regulations also place responsibilities on your employees:

• Make full and proper use of safe systems of work provided by the employer in compliance with the regulations
• Enable compliance with the regulations through cooperating with their employer
• Make use of equipment provided, in line with training, instruction, and safe systems of work
• Take reasonable care for their own health and the health of others in the area that may be impacted by their manual handling activities

All manual handling legislation employers need to know

• Manual Handling Operations Regulations 1992 (MHOR) – the cornerstone legislation setting out employers’ duties to avoid hazardous manual handling where possible, assess unavoidable tasks, and reduce risks of injury.
• Health and Safety (Miscellaneous Amendments) Regulations 2002 – updated aspects of the original manual handling rules but did not alter the fundamental responsibilities placed on employers.
• Health and Safety at Work etc. Act 1974 – the overarching law requiring all employers to safeguard the health, safety, and welfare of their employees. Compliance with manual handling regulations forms a crucial part of this general duty.
• Management of Health and Safety at Work Regulations 1999 – requires employers to conduct risk assessments, implement necessary control measures, appoint competent staff, and provide adequate information and training. These duties extend to manual handling activities as part of everyday workplace safety.

The business case for compliance with manual handling laws

Compliance with manual handling legislation may seem like a burden, but there’s strong evidence that it’s also a shrewd business move.

According to the Health and Safety Executive, from 2023-24, 17% of all non-fatal workplace injuries in the UK occurred because of manual handling. This equates to around 103,000 incidents.

Furthermore, musculoskeletal disorders (MSDs) are the most common injury type associate with manual handling), and HSE data suggests that MSDs account for 24% of all lost business days, costing UK businesses billions annually.

On average, manual handling injuries set employers back by roughly £8,500 per case, and potential non-compliance penalties can drive associated fees up dramatically.

When proper safety measures are implemented in accordance with the Manual Handling Operations Regulations 1992, you remove this loss centre from the equation while also boosting the health, wellbeing and productivity of your workforce.

In turn, businesses often:

• Save on recruitment drives, as staff members are more likely to remain loyal to the company
• Recruit the best talent when a vacancy does need filling
• See growth through higher capacity and quality delivery

Compliance with manual handling legislation made easy with Cardinus

We offer a range of industrial ergonomics solutions for non-office work environments designed to identify and reduce risks – and significantly lower injury rates related to manual handling and other ergonomic hazards.

From motion capture technology and AI-powered risk analysis to eLearning courses and our end-to-end industrial ergonomics platform, Healthy Working Pro, our solutions can fill crucial gaps in your ergonomics plan or serve as a comprehensive ergonomics programme in and of themselves.

Contact Cardinus today to learn more about our industrial ergonomics solutions and how they can support your compliance with the Manual Handling Operations Regulations 1992.