Falls from height accounted for eight per cent of all workplace injuries in 2021 (source: hse.gov.uk/statistics) which equates to roughly 35,000 injured people in the workplace. Working at height is often a necessary part of carrying out work, but it also carries significant risk to the worker.
A fall from height can be fatal and even a fall from a low level can cause a serious injury. For these reasons, it is important to understand how to control working at height, comply with the legislative requirements and protect your workforce.
What is working at height?
This might seem like an obvious question to answer, but it covers a lot more than you might think. The HSE give a vague definition of working at height which is: “Work at height means work in any place where, if there were no precautions in place, a person could fall a distance liable to cause personal injury. (HSE Document INDG401 www.hse.gov.uk/pubns/indg401.pdf). This means that there are some obvious situations such as:
- Using a ladder as part of your work
- Working a cherry picket or Mobile Elevating Work Platform (MEWPS) / scissor lift
- Working on scaffolding
- Working on a roof
But there are also some less obvious situations where working at height applies like:
- Working next to a hole in the ground such as a well or an open excavation since this poses a risk of a fall
- Working on a kerb edge since there is a risk of spraining a joint or breaking an ankle
Having said this, the law does recognise situations where common sense does need to prevail – no one is expecting you to wear fall arrest equipment when working on a pavement in case you fall off a kerb!
Don’t forget that working at height is not only dangerous because of people falling from height. There is a risk posed to others from items being dropped when working at height or the failure or collapse of temporary structures. We need to make sure that we consider the whole work process and protect everyone involved, not just the workers who are “off the ground”.
Before work begins
It doesn’t matter which industry you are in, working at height presents a serious risk to the safety of the worker. This means that, if you employ five or more people, you are going to need to record the significant findings of your risk assessment. If you employ less than five people, you do not need to record the outcome of the assessment, but you still need to do it. With work at height, we always recommend recording the assessment regardless of the number of people that you employ.
When planning the work and assessing the risk we need to consider the hierarchy of controls. I have spoken about this in other articles, but as we are talking about risk assessment, let’s have a brief look at this again and think about how this might apply to working at height:
The best way to avoid falling from height, is to avoid working at height. This should always be written in your risk assessment as the first control. This is the easiest way of stopping incidents happening. Think about who is going to be carrying out work at height, are there other staff members or other people there? Can you restrict their access to working at height?
Think about the work processes involved with working at height. Is there any way you can remove working at height from the work process? Can the work be carried out at ground level and lifted (safely!) into position. If not, can work be carried out inside the structure rather than on temporary structures such as scaffolding? Essentially, you should, where possible, reduce the distance that a fall can occur from to reduce the severity of an incident should it occur.
“the best way to avoid falling from height is to avoid working at height”
Particularly where equipment or machinery is in place you should ensure that you have the certification required for it, that all the safety controls are in place, and that the machinery is defect free. You might also consider the use of lanyard for tools to stop them from being dropped, kickboards and debris netting on scaffolding or the use of hydraulic outriggers or stabilisers for access or lifting machinery.
As well as your risk assessment, don’t forget to write up a safe system of work (sometimes referred to as a method statement) which should give clear instructions to workers on the safest possible way to carry out the work. You should ensure that workers are trained to understand the risk that working at height poses, or to operate machinery or to use ladders.
PPE should be put in place to manage the residual risk that is posed if all other controls fail and need to be considered. We are going to explore PPE in detail, but don’t neglect PPE for everyone in the workplace. For example, if you have a construction site and have people working at height you might choose to enforce hard hats in case of items being dropped from working being carried out at height.
There are some other considerations which need to be made when planning the work such as:
- Taking into account the weather at the time of the work – high winds, rain, sleet, snow or poor visibility may increase the likelihood of a fall from height or incident where workers are working from height.
- Plan for emergencies – you should have Procedures for Serious and Imminent Danger and you should ensure that these make provision for dealing with incidents which are related to working at height including falls from height, dropped tools or materials, failure or collapse of temporary structures or the failure or overturning of equipment.
- Inspecting the workplace prior to work taking place to identify weaknesses in the structure and to assess the suitability of the working method.
- Safe storage of materials so that if they fall they will not cause injury or damage.
Controlling work at height
There are many ways to control working at height, and the right control for your workplace and the work being undertaken needs to be carefully considered and assessed. It is highly unlikely that any “off the shelf” solution will meet the specific requirements of your workplace and you should always make sure that your controls are specific to the type of work and location. Below we explore some of the controls that you should put into place when carrying out different types of work at height:
Ladders and stepladders
These are probably the most common items when it comes to working at height and are used across multiple trades and industries. Firstly, ensure that your ladders are not made of wood as this can warp and become easily damaged. All ladders (step or lean-to) should be checked before use and a record of this inspection should be made once a week regardless of the condition of the ladder. In the case of the ladder being damaged, it should be removed from the work area. You should also ensure that the ladders are used by competent workers only and the usage of these falls in line with industry guidelines. As a general rule the belt buckle of the user should remain inside the stiles at all times, you should not work off the top three rungs. You can find guidance for the safe use of ladders here: www.ladderassociation.org.uk/wp-content/uploads/2021/07/LA455-Safe-Use-of-Ladders-and-Stepladders-A-brief-guide.pdf.
“all access machinery should be inspected prior to use”
Access machinery (cherry pickers, scissor lifts etc.)
Access machinery is complex and wide ranging. Ensure that you have all of the correct certificates for the machine. You should expect to see an EU Declaration of Conformity if the machine is less than 12 months old. If the machine is older, request to see certificates which cover the Provision and Use of Work Equipment Regulations (PUWER) and the Lifting Operations and Lifting Equipment Regulations (LOLER) which should both be dated within the past 12 months. If this is in place, ensure that the operator has a competency certification and that this is in date. All access machinery should be inspected by this operator prior to use and any defects found should be noted and the machine stood down until rectified. Regardless of the defect condition of the machinery, this check must be recorded once per week, or following any event which may give rise to a defect (such as a plant strike, overturning etc.). There are many safety features on access equipment including anchor points for fall arrest (see PPE below), dead man pedals and switches, outriggers / stabilisers etc. Check the manufacturers guidance and ensure that all safety features are working. You should restrict the area underneath the access machinery and ensure that no one puts themselves under the elevated arm or platform. Finally, it is sensible to enforce the use of hard hats across the workplace and ensure that the movement of these items is banked at all times.
Lifting machinery (telehandlers, forklifts, cranes etc.)
Lifting machinery is different to access machinery in that loads are being lifted and not people. As we are dealing with heights and items falling this is a sensible thing to cover. The guidance are very much the same as access machinery.
Widely used across the construction industry for access at height, scaffolding is the number one thing I see on site audits that is neglected and not properly controlled.
You need to appoint a competent scaffolder to erect your scaffold, ensuring that it meets all of the industry guidance. Rather than list all of these, I have listed below the top things I see time and time again with scaffolding:
- Scaffolding must be checked every day for defects. This can be carried out by anyone. However, once every seven days the scaffold must be inspected by a competent person who holds a CISRS (Construction Industry Scaffolders Record Scheme) card. This weekly check must be recorded. Normally this is logged on a “scaff-tag” located at the access point for the scaffold.
- At the top of each elevation, ensure safety gates are in place and they are closed. This helps to prevent accidental falls through the access points.
- Access ladders must be replaced if defective and should be secured
- Kick or toe-boards should be erected around the whole of the scaffold to prevent items being knocked off, or people slipping
- Remember that the only person who should modify a scaffold, is a scaffolder!
- Any working platform (not just scaffolding!) used for construction work and from which a person could fall more than two metres must be inspected after assembly in any position, after any event liable to have affected its stability and at intervals not exceeding seven days.
Roof work is considered one of the most dangerous types of working at height. This means the most important part is ensuring that the roof is of a stable enough material and structure to support the weight of the workers. There may be a need for crawl boards or other temporary structure to prevent falls through the roof. Regardless of this, there should be additional controls in place. The temporary access structure should be secured in place, or even better, carry work out from the inside through access machinery. Roofing ladders are another option be aware that they follow all the same rules as other ladders and need to be secured into place. The HSE has some good guidance for working on roofs which you can read more about here: www.hse.gov.uk/construction/safetytopics/roofwork.htm).
“scaffolding is the number one thing I see on site audits that is neglected”
Working near openings in the ground (excavations, wells, open manholes etc.)
Excavations, wells, open manhole sand other ground level openings can cause serious injury, not only because of the distance you can fall but also because of the difficulty for emergency services to access the injured person. These types of working at height should be taken very seriously and there are some very basic controls which can be put into place. Firstly, erecting barriers around the opening can highlight its presence and steer people (and vehicles) away from the opening. This doesn’t need to be anything fancy, pedestrian barriers or even orange barrier fencing and pins is enough. Communication is also key, putting up signage to warn of open excavations or highlighting this on inductions to work areas can bring this to the forefront of people’s minds and help to minimise the chances of a fall. When working in or around an opening like this, never work “over the top” of the opening. I have seen it before on a site where workers had two scaffold boards over a well opening which plunged some 50ft – needless to say that work activity was stopped, and access machinery was used even though this was carried out at ground level. Lastly, consider the use of a “lookout” worker whose job it is to firstly raise the alarm in case of emergency but also to direct others away from opening. Hard hats for all are always a good idea with this kind of work too.
Competence to work at height
Competence is a combination of experience and qualification and is important in working at height to ensure that the most up to date safety protocols are used and that everyone gets to go home at the end of the day! Generally speaking we can categorise working at height as either “low risk short duration” and then everything else.
Low risk, short duration work is work which lasts no more than 30 minutes and is completed through the use of a lean-to or step ladder. The level of competence required here is very simplistic and only needs to be instruction from a manager or supervisor on how to complete the work, and an awareness of the outcomes and controls which have been identified from our risk assessment process. They should also receive some basic training around the use of ladder or any other job-specific information they might need (like COSHH, or electrical assessments for example). This training does not have been overly onerous though and can take place on the job. Just make sure that you have a record of the training so that you can evidence this if you are ever asked to.
For everything else, there will be a higher expectation placed upon the employer. Further consideration needs to be given to the use of access machinery, drawing up scaffolding plans or obtaining proper accreditation for the work being undertaken. Essentially, if the work can’t be done in under 30 minutes with a ladder or stepladder, you need to be thinking more about the work processes involved and the types of certification and accreditation you might need to complete the work.
Managing residual risk
Anyone who has read my previous articles will know what I mean when I talk about PPE and residual risk, but in case you haven’t read them, PPE is only in place when everything else fails. It is a last port of call for safety and should never be relied upon to ensure the safety of workers. With regards to PPE and working at height, I have covered some items which are worth having a look at. It should be noted that priority should be given to what are referred to as “collective protective measures” over “individual protective measures”. These collective measures are in place regardless of who falls from height and include things like guard rails, debris netting and airbags. Research the types of collective protective measures and pick ones that are appropriate for your own work.
While they may not necessarily protect against a fall from height, they should go hand in hand with working at height. If there is a chance a person can fall, there is a chance that tools or materials can fall too. Hard hats may help to protect people as they go about their work.
“If a person can fall chances are tools or materials can fall too”
Fall arrest systems
These are the most common type of PPE issued with working at height. A fall arrest system is made up of different parts included a body support element (such as a harness or waist belt), a connecting element (lanyard) a connector (similar to a karabiner) and an anchor point. All parts of this system must be tested and certificated, and the weight limits must be adhered to as per the manufacturers guidance. The system should be checked before use and not used if any defects are found whatsoever. Safety catches on the karabiner/s should be checked thoroughly and you should always use a proper anchor point. Do not attached yourself to scaffolding or aerials or balconies as these are not weight bearing anchor points for fall arrest.
Think fall arrest systems but for hammers, drills etc. This ensures that the tool cannot fall from working at height and cause injury to people below. A very simple but very effective piece of PPE.
Helmets should be issued to anyone using fall arrest. This should be impact rated and have a chin strap.
Eye protection may need to be worn and should be checked to ensure compatibility with the helmet.
When working at height, good quality footwear with a good quality sole is essential to reduce the chance of slips. This should also include ankle protection and protective toe caps.
This will help to ensure that items are not dropped, and will also protect the hands if a person does fall and they reach out to grab something like the fall arrest lanyard. There are many other controls and parts to working at height. Without a limitless word count on the article I wouldn’t be able to explore them all, however, check the HSE website and other industry bodies for guidance – it is all out there. Alternatively, whoever you employ to help manage your health and safety should be able to provide you with the guidance that you need to work safely at height.