There is still a vital need to protect workers
Although the total number of personnel being killed at work is on the decline, there are certain activities which are still of concern. Working at height, according to the HSE, remains the most common kind of accident in the workplace with falls from height accounting for nearly twenty five percent of deaths among workers across all industries.
Latest figures from the HSE show that something needs to be done to ensure that people are aware of the dangers involved with working at height and what methods can be implemented in order to make this type of work safer. Between the years 2004/2005, fifty three people were killed by falling from height and nearly three thousand eight hundred people sustained major injuries. Although the figures that are shown are across all types of industry, construction work has the highest numbers of deaths and serious injuries, with falls from height accounting for up to fifty percent of all construction fatalities.
Directives and regulations
In 2001 the European Union adopted the Temporary Work at Height Directive (2001/45/EC) which was the second amendment to the Use of Work Equipment Directive (1989/655/EEC) and set out minimum health and safety requirements for the safe use of work equipment, when working at height.
The Work at Height Regulations (WAHR) 2005 were introduced and came into force in April of last year. The Regulations place duties on all people to ensure that first of all any task which may require a person to work at height is first assessed by a competent person, after which a suitable system of work which takes into account all activities to be carried out is put into place and then adhered to.
The Regulations are relevant to most areas of industry within the United Kingdom, although there are some exceptions such as shipping, offshore installations and docks. The Health and Safety Commission introduced this legislation to combine requirements for working at height which were needed under existing regulations. An inherent part of the regulations by way of Regulation 6 is the duty on employers to consider a simple hierarchy of controls to protect workers from falling or minimise the consequences of a fall.
The Work at Height Regulations are designed to be goal setting and are based on risk assessment, the aim is to maintain existing controls and yet improve current standards. The Regulations allow duties from legislation such as The Workplace (Health Safety and Welfare Regulations 1992, The Construction (Health, Safety and Welfare) Regulations 1996 and The Provision and Use of Work Equipment Regulations 1998, to come together
Consultations on the Regulations were held during 2004 and included focused consultation on retaining the requirements for particular precautions for construction work at or above two metres. It was decided not to retain the so called two metre rule to ensure that there is no reference to any specific height and therefore encourage all work areas to be considered. It would appear that the two metre rule that was mentioned in The Construction (Health, Safety and Welfare) Regulations was misinterpreted and only really applied to work involving certain types of work equipment. The facts are that there have been a number of fatalities and significant injuries that have occurred as a result of falling from a height of less than two metres.
The Regulations were brought into force on 6th of April 2005. There was no transitional period because the Regulations were to consolidate what should already be good practice.
It is important for all industry to understand that they should familiarise themselves with the Regulations and ensure they take sufficient actions in order to comply with its requirements. There has been no Approved Code of Practice (ACOP) produced for the new Regulations as the Health and Safety Executive are taking a different approach to communicate the Regulations to all concerned. This is based on “A Brief Guide to the Regulations” and promoting sector specific guidance, which is available online from the HSE web site.
Employers should already have certain arrangements in place where there is a requirement for their employees to work at height. Under the new Regulations there is a specific hierarchy which needs to be considered in order to control the risks from work at height – employers should avoid working at height if at all possible, if work is required measures should be taken to prevent people from falling, if this is not possible then controls should be put into place in order to minimise the severity of any likely fall.
The Work at Height Regulations cover work in any place from which a person could fall any distance that is likely to cause personal injury. With this in mind it is likely that any employee in any industry could possibly work at height during some part of their work activity. It has to be considered that there are some types of work which are more obviously work at height than others, examples include roof work, scaling of structures or window cleaning using a gondola. There are other work activities which are not as obvious such as order pickers in a warehouse using a step stool or the loading and unloading of vehicles.
The Regulations also apply to access and egress from a place of work and work at or below ground level where there is a risk of a fall, so now any personnel who work in areas such as deep chambers, confined spaces or even excavations if there is a risk of falling which might result in personal injury are included.
The Regulations cover all industries and work activities where work at height is involved and they place duties on employers, the self employed and those who have power over others during the execution of their tasks when carrying out height work.
The Regulations also place specific duties on employees and require them to use any equipment provided for their work in accordance with the training they have received, and the instructions they have been given. Employees are also required to inform their employers or supervisors of any shortcomings or activities that they feel could endanger themselves or others who may be in the vicinity.
Where work at height is to be carried out it should be properly planned and organised, all work should have appropriate supervision. All planning should take into consideration any requirements for emergency rescue in the event of an accident.
As a general rule employers should ensure that reasonable precautions are taken to protect people from bad weather. Work at height should not be undertaken when the weather conditions could affect the health and safety of workers or others. Conditions likely to affect work at height are high winds, heavy rain and extreme temperatures that may cause the work surface to become slippery.
Any persons who are required to work at height need to be competent. Although there is no definition of competent in the Regulations, in order to be competent a person should have received the correct level of appropriate training and instruction and have a certain amount of experience to enable them to carry out the required task safely and correctly. Competence could also include some involvement with the equipment that is required to work at height in the organising, planning, supervision and supply.
As a requirement of Regulation 3 of the Management of Health and Safety at Work Regulations 1999 (MHSWR) any work carried out should be risk based. A suitable risk assessment should be carried out prior to any work at height commencing and where necessary this assessment should be recorded. Once the hazards and level of risk have been identified the work should be properly organised and planned in advance.
For a lot of work at height tasks the risk assessment may be straightforward and just require you to follow industry good practice to complete the task. But in other cases if the work activity may be more complicated you will be required to carry out a more detailed risk assessment.
There is a simple hierarchy for managing and selecting equipment for work at height. Duty holders must avoid work at height wherever possible.
The importance of implementing safe systems of work
There are a number of things that can be put in place to avoid work at height, obviously it will depend very much on the location and type of work required, but there are a number of tried and tested methods in use today. Examples of avoiding working at height are using extension poles for use by window cleaners, having adjustable lighting fitted which allows the light to be lowered to ground level in order to change a light bulb or carryout a repair.
If work at height cannot be avoided then the duty holder must prevent workers from falling. This can be achieved by either using an existing place of work at height or an existing means of access, which has suitable and sufficient features to prevent a fall. For example a sound, flat roof with parapets or guardrails or the use of work equipment or other measures to prevent falls where they cannot avoid working at height by installing temporary guardrails around the roof edge to prevent falls.
Where a duty holder cannot eliminate the risk of falling, work equipment or other appropriate safety measures should be used in order to minimise the distance and severity of a fall should one occur. Whatever the system is it should be designed and installed with the aim of minimising the height that a person may fall.
Where possible safe systems of work should use a collective protection method. Collective measures are designed to protect more than one person at a time and can be in the form of a guardrail, appropriate type of scaffolding, airbags or safety nets or a working platform that is protected. If collective protection is not appropriate then you should consider using personal protection. Personal protection can be in the form of fall arrest systems and harnesses, but duty holders should be aware that collective control measures must at all times take priority over personal protective measures.
Other ways for duty holders to prevent injury include providing adequate information and instruction on safe working procedures. This should include information on the findings of any risk assessments and what, if any, control measures need to be used and how to put them into practice. It is important to remember that if equipment is to be used an appropriate level of training must be given on each piece of equipment.
In addition to selecting collective methods before personal protective measures you should also consider how other aspects of the work may dictate the way you select your work equipment. You should consider the working conditions and the location of the task where the work is to be carried out and if it is appropriate for the work equipment which you are planning to use.
It is important to ensure you have safe access and egress to and from the work area. Consider the distance of any possible fall and the likely severity of injury; this should include what may be in the area and what a person may fall on to or in to and how access to an injured person will be achieved.
You will need to consider how regularly you need to use the equipment and what the duration of use will be on each occasion. In the event of an emergency and in the case that a rescue would be required what arrangements will be necessary when using that specific piece of equipment.
When selecting equipment for working at height consideration should be given as to whether there are any significant risks that could arise during installation, erection or dismantling. You may find that some equipment may be of lower risk than that of a similar type.
The Work at Height Regulations have some detailed requirements regarding particular types of work equipment this includes the use of guardrails: guardrails must be suitable and sufficient for the task and be at least 950mm in height and have no gap between rails that exceeds 470mm width.
Working platforms including those on scaffolding and mobile elevated work platforms (MEWPs) must be suitable and sufficient for the task and the number of workers involved in the job. Nets and/or airbags should only be used where other preventative safeguards are not appropriate. Personal fall protection systems which include restraint harnesses, fall arrest systems, rope access and positioning should only be used if other types of equipment are inappropriate.
Ladders and stepladders are used widely across industry and need to be treated with respect. These Regulations do not ban ladders but say they should only be used when all other safer alternatives for work at height have been ruled out. The Regulations impose particular duties for the use of ladders, a risk assessment must show that the task is low risk and of short duration, between 15 to 30 minutes or that there are site features that mean other equipment is not appropriate for the job, if this is the case then ladders may be used. In any event a suitable risk assessment should be carried out and appropriate control measures should then be put into place.
Suitable arrangements should be taken to prevent the ladder from slipping; this could include securing the ladder at the top or bottom or using an effective anti slip or other stability devices. Statistics show that as much as 30% of all falls from height involve working from a ladder. Duty holders should think carefully before specifying ladder use and consider if other safer access equipment can be used in their place.
Those who are required to use ladders must be given sufficient instruction on their safe use. If ladders must be used it is important that they are used sensibly and safely. When using a ladder it is essential that the user always follows good practice, when choosing a ladder for use you must ensure that it is suitable for the required task. Prior to commencing the task the operator must carry out a pre-use inspection and make sure that the ladder is in good condition. Having chosen and inspected the ladder examine the area where it is going to be used to ensure it is suitable to support a ladder, appropriately secure the ladder and when working follow a suitable safe system of work.
If airbags are to be used duty holders must consider how they are used and ensure that placement will minimise the height of any fall that is likely to occur. When using fall arrest devices operators should always try to connect the device above the worker. Fall arrest equipment should only be used after the operator has received appropriate training and instruction on the correct inspection and use of each specific item.
Work on or near fragile surfaces should be avoided where possible. If the work is unavoidable suitable precautions should be taken to minimise the risk to everyone involved. Risk controls should be put into place to prevent falls occurring and if this is not possible appropriate equipment should be used to mitigate the severity of a fall. In addition to equipment being used all fragile surfaces should be identified by placement of suitable warning signs and all personnel should be briefed accordingly Arrangements should be made to ensure that the risks from falling objects are properly controlled using appropriate equipment. Strict controls should be put into place to ensure that only authorised people with correct protection are allowed access to a site where there is a risk of falling objects.
It is important that any area where work at height is required is properly inspected and examined before work is allowed to commence. The inspection should include consideration of any significant risks and any appropriate actions are taken to minimise the risks.
So working at height is an issue and we all know about the dangers. Remember that all duty holders under the Regulations must ensure that any activities or operations that involve working at height are managed in an appropriate way in order to minimise the risks. If you follow good practice you should be doing enough to comply with the Regulations. Carry out an appropriate risk assessment, plan and organise any work at height properly. Follow the hierarchy of control:
- avoid work at height
- prevent falls
- if this is not possible minimise the consequences of a fall
Choose the right equipment to ensure that the work can be done safely and make sure that all operators are properly trained and informed. If this is done we should see the numbers of fatalities and serious injuries at last begin to fall!
Published: 10th Oct 2006 in Health and Safety International