I ask a simple question when I audit machinery compliance: who is your GMR 2.1 appointee, and when did they last physically inspect the machinery they are responsible for?
The first part is answered instantly. Someone produces a letter. The second part produces a pause, and often the discovery that the appointee is a group engineering manager based four hundred kilometres away who visits quarterly.
That is the gap. Not the paperwork — the daily reality of what the General Machinery Regulations actually require.
The appointment is personal and it is supervisory
GMR 2.1 requires the user of machinery to appoint a competent person to supervise the machinery. The word doing the work is supervise. It implies presence, knowledge of condition, and authority to act.
Two consequences follow that people routinely miss. First, the appointee carries personal liability — this is not a corporate obligation discharged by a company. Second, the appointment must be accepted in writing by someone who understands the scope, and the scope must be defined. "All machinery at the Rustenburg operation" is not a scope; it is an aspiration.
Where an operation is large or geographically spread, GMR 2.2 assistants exist for exactly this reason. Appointing them is not an admission of weakness. Failing to appoint them, and pretending one person supervises seven sites, is the exposure.
What supervision means week to week
In the operations where I consider this genuinely under control, the appointee's routine looks roughly like this:
- A documented physical inspection cycle covering all listed machinery, with findings recorded and dated — not delegated wholesale to the maintenance planner
- Sight of and sign-off on the pressure equipment register, including hydrostatic and non-destructive test due dates on vessels and boilers
- Review of machinery-related incidents and near-misses, personally, with the authority to stop a machine
- Verification that the people operating and maintaining listed machinery are competent and appointed — lifting machine operators, boiler attendants, driven machinery operators
- A standing item in the site engineering meeting where machinery condition and outstanding statutory tests are tabled
None of that is exotic. It is mostly a discipline of records and presence. But the volume of it is why the appointment fails when it is given to someone whose actual job is something else entirely.
The registers that get audited
When an inspector arrives, the documents that get pulled first are predictable: the appointment letters with acceptance signatures and current dates, the pressure vessel register with test certificates, the lifting machinery register with load test records, the machinery inspection records, and the record of competency for operators of listed machinery.
The most common finding is not absence. It is a register that stopped being maintained eleven months ago, usually at the point the previous appointee left and nobody formally transferred the role. An appointment does not survive a resignation. It has to be reissued and re-accepted, and the gap between the two is a period during which the operation had no appointee at all.
Where operations get caught out
Contractor machinery is the sharpest one. A contractor brings a mobile crane onto your site. Whose GMR 2.1 scope does it fall under? The answer depends on the contractual arrangement and who is the user of the machinery, and it needs to be settled in writing before the crane arrives, not after it drops something.
The second is modification. Plant is modified under a small works budget, nobody notifies the appointee, and the machinery he is supervising no longer matches the register or the original design assumptions. A simple rule — no machinery modification without appointee sign-off — closes it, but it requires the engineering change process to actually route through him.
The third is the competent person definition itself. Competence under the regulations means qualification, training and experience relevant to the machinery in question. A qualified mechanical engineer with no boiler experience is not automatically competent to supervise a fired pressure vessel installation, and I have seen that argument lost.
If you are being asked to accept an appointment
Read the scope. Walk the plant before you sign. Ask what the outstanding statutory test position is, ask what your budget authority is, and ask in writing what happens if you refuse to operate a machine.
If those questions produce discomfort, you have learned something important about the appointment before your name is on it rather than after.