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Working at Height Hierarchy of Control

Laying the foundations

Covered in this article:

  1. Choosing an employee
  2. Getting the equipment right
  3. Questions for the supplier

Further Reading:

  1. Working at Height Hazards and Control Measures
    1. Hierarchy of control measures
    2. Prioritising collective measures
    3. A safe place of work
    4. Recent cases

In virtually every industrial sector there is the requirement at some stage for work to be carried out at height. Although we now strive to engineer out the need, with legislation in place to encourage us to do so wherever possible, the fact remains that for many years to come those responsible for safe and efficient work are going to have to manage employees at height.

So where should they start?

Well, before everyone gets too involved with systems, training and equipment let’s take one step back and consider something that all too often gets forgotten in the rush for technical solutions - the person doing the work.

Choosing an employee

There are a number of basic elements to consider when choosing any employee for a work at height task:

  • Do they have the practical skills to do the work needed (electrical, building, non-destructive testing etc)?
  • Do they have appropriate training in the specific access systems intended?
  • How experienced are they in actually working at the height and exposure expected?
  • Are they physically capable of the work in the environment expected?

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All too often the first one on this list is considered straight away because it was described in the original request: ‘We need to get an electrician up there to swap that motor’. But from then on things tend to become less certain.

Without proper thought, selection of personnel becomes a skills based box ticking exercise that draws the project manager away from the correct solution and places the inexperienced or unwilling in a dangerous place.

BS 7985:2009 ‘Code of practice for the use of rope access methods for industrial purposes’ has a whole section dedicated to selection of operatives (section 6), which is entirely relevant to work at height in general.

It clearly reinforces the principles that those working at height should have “an appropriate attitude, aptitude, physical capability and training,” and that because of the difficulties in direct supervision such people “can always be relied upon to behave in a sensible and responsible manner.”

Aptitude and experience can be difficult things to assess. Asking someone if they are capable of doing something, especially in front of their work colleagues, does not guarantee the correct answer. Peer pressure, the desire to help or even a genuine belief that their abilities are better than they really are can find employees dramatically overstating their aptitude.

"companies expecting employees to work at height should ensure that all such employees possess a full industrial medical certificate"

Section 6.2

Section 6.2 suggests that an aptitude and experience assessment should be made before employees are selected for work at height tasks. These assessments should be up to date and readily available to those organising work. Such assessments should look carefully at previous experience, and where claims are made these are checked against up to date personal training or work records, or any previous job references held. Some previous employment types may have already involved a significant amount of work at height such as Fire and Rescue, arboriculture or the Armed Forces, and some of the skills and experiences learned might be directly transferable.

Where necessary, a suitably controlled and supervised practical assessment may be required, imitating the type of equipment, techniques and environment expected at the work site. If the company does not have the ability to carry out such an assessment then it may need to consider bringing in a competent outside organisation to help it with the assessment.

Section 6.1.3

Section 6.1.3 of BS 7985 also reminds managers that physical fitness is of real importance and not something that can be deferred so as not to cause offence.

Medical contra-indications listed include the more obvious heart disease, epilepsy and blackouts, but also include obesity, fear of heights/vertigo and giddiness, or difficulty with balance. The former contra-indications should have been picked up during a routine company medical, but the latter may not unless the examination was specifically tailored for work at height.

Ideally companies expecting employees to work at height should ensure that all such employees possess a full industrial medical certificate such as those used in the offshore industry, and take regular reassessments.

Specialist industrial trade bodies such as the Industrial Rope Access Trade Association (IRATA), insist on trainees signing a specific ‘Statement of Medical Condition’ confirming their fitness to work at height.

Sections 7.1 and 7.2 of BS 7985

Finally, when looking at personnel selection supervisors must ensure that employees not only have generic work at height training, such as that described in Sections 7.1 and 7.2 of BS 7985, or in the Advisory Committee on Work At Height Training (ACWAHT) Awareness Syllabus, produced in 2006 and inserted into BS 8454, covering basic knowledge for all who work at height, but also specific, detailed knowledge on the exact method and equipment being used on the intended work.

Harnesses have different adjustment systems and attachment points, fall arrest lanyards have differing deployment lengths, inertia reel blocks work better in some orientations than others.

Assumptions must never be made that one type will be much the same as the other.

If specific training is not already available in house then manufacturers or suppliers will need to be consulted and external providers brought in before any of the equipment is put into service.

Read more about control measures for working at height in our latest article:

https://www.hsimagazine.com/article/working-at-height-hazards-and-control-measures

Getting the equipment right

Once workers have been selected and suitably trained, an employer’s concern for safety is far from over, since the selection of appropriate equipment for the job, its maintenance and eventual replacement remain key priorities.

Correct selection of equipment and techniques for work at height is a massive topic that is too extensive to cover in this article, or in a single magazine issue. For larger companies whole departments are created to manage the myriad of different access systems and specialist gear needed on a multi discipline site.

But what about those smaller businesses where work at height is not a daily feature, but one that still needs solutions?

For these smaller concerns one possible avenue of advice and support is often mistrusted or overlooked entirely - their equipment suppliers.

The second part of this article aims to get you looking at your relationship with your supplier and help decide whether their comments are all just ‘marketing patter’ or helpful advice that could improve safety, speed up the job and save you money.

All too often when things go wrong, the cry goes up that the product sold was ‘not up to the job’ or turned out to be ‘no good for this site’. But did you really know what you were asking for and what it was truly designed to do?

“work at height is one of the most visible applications of specialist PPE and it is a common activity in the majority of mainstream industries”

Don’t fall at the first hurdle by not understanding the language your suppliers speak. Every industry has its ‘own’ names for tools and equipment, but these may describe different things to different people. BS 7985 and BS 8437 ‘code of practice for selection, use and maintenance of personal fall protection systems and equipment for use in the workplace’ both have excellent lists of definitions which cover many of the components in common use.

Article about choosing an "competent person" to inspect PPE:

https://www.hsimagazine.com/article/inspection-of-height-ppe-488

Key Terms

Reproduced below are some terms from both documents that you should be familiar with:

  • Work restraint: Technique whereby a person is prevented by means of personal protective equipment from reaching zones where the risk of a fall from height exists
  • Work positioning: Technique that enables a person to work supported in tension or suspension by personal protective equipment in such a way that a fall from a height is prevented or restricted
  • Rope access: Technique using ropes, normally incorporating two separately secured systems, one as a means of access and the other as back-up security, used with a harness in combination with other devices, for getting to and from the place of work and for work positioning
  • Anchor: Fixture or place for the secure attachment of anchor lines or persons
  • Structural anchor: Element or elements, permanently secured to a structure,to which an anchor device or equipment for personal fall protection can be attached
  • Anchor line: Flexible or rigid line connected at least at one end to a reliable anchor to provide, as part of a personal fall protection system, a means of fall protection of support
  • Anchor sling: Sling, strop or lanyard made from textiles, wire rope or chain, which is used to provide an anchor point for anchor lines, cow’s tails etc, to anchors to which it is not possible to connect directly
  • Working line: Anchor line used primarily for suspension, work positioning and restraint including ascending and descending
  • Safety line: Anchor line provided as a safeguard to protect against falls if the user slips or if the primary support (e.g. working line), anchor or positioning mechanism fails
  • Full body harness: Body holding device primarily for fall arrest purposes e.g. a component of a fall arrest system which comprises straps, fittings, buckles or other elements, suitably arranged and assembled to support the whole body of a person and to restrain the wearer during a fall and after the arrest of a fall
  • Sit harness: Body holding device comprising straps, fittings, buckles or other elements in the form of a waist belt with a low attachment element and connected supports encircling each leg, suitably arranged to support the body of a conscious person in a sitting position
  • Connector: Openable device used to connect components, which enables the user to link himself/herself directly or indirectly to an anchor point
  • Guided type fall arrester: Anchor line device with a fall arrest and self locking function, which travels along an anchor line without requiring mechanical adjustment by the user, during upward or downward changes of position
  • Retractable type fall arrester: Fall arrest device with an encased flexible extending lanyard that has a self braking and locking function and an automatic return facility for the lanyard into the casing
  • Energy absorber: Component or set of components in a fall arrest system, designed to minimise the impact force generated in a fall
  • Ascender: Rope adjustment device which, when attached to an anchor line of appropriate type and diameter, locks under load in one direction and freely slides in the opposite direction
  • Descender: Manually operated, friction inducing, rope adjustment device, which when attached to an anchor line of appropriate type and diameter, allows the user to achieve a controlled descent and to stop with hands off anywhere on the anchor line
  • Back up device: Rope adjustment device for a safety line of appropriate type and diameter, which accompanies the user during changes of position or allows adjustment of the length of the safety line, and which locks automatically to the safety line, or only allows gradual movement along it, when a sudden load is applied
  • Certificates of conformity: Documentation provided by a supplier of equipment at the time of purchase, stating performance specifications of the equipment or indicating conformity to known standards or compliance with relevant legislation
  • Working load limit: Maximum load that can be lifted by an item of equipment under conditions specified by the manufacturer
  • Safe working load: Maximum working load of an item of equipment under specified conditions, as designated by a competent person
  • Minimum breaking load: Minimum load at which an item of equipment breaks when it is tested new, under specific conditions

Assuming now, that you and your supplier are singing from the same song sheet, and you are getting what you actually asked for, in most cases the main damage done is financial, with the user having to purchase a more suitable replacement. However, when PPE is incorrectly purchased for safety critical applications the results can be truly disastrous.

Work at height is one of the most visible applications of specialist PPE and it is a common activity in the majority of mainstream industries, yet time and time again we see examples of inappropriate systems, poor equipment selection and misuse.

So why does it happen so often and would a little more discussion with suppliers really help? Lack of knowledge is one of the most commonly cited reasons for things going wrong.

“aside from the manufacturer who will know most about the applications and performance of a specialist piece of work at height PPE? Your supplier, that’s who”

Any decision made without all the facts, without doing any research and without taking good quality advice is going to be little more than a guess.

When selecting PPE and systems for work at height, a guess is not good enough.

Aside from the manufacturer themselves who will know most about the applications and performance of a specialist piece of work at height PPE?

Who will have access to the manufacturer’s product instructions, technical bulletins, and maintenance and inspection schedules?

The supplier

Who has a legal duty to ensure that the PPE sold meets not only all the legislative requirements of the country it is being supplied in, but also that as part of the supply chain they do not knowingly supply a product that is unsafe for the task described?

Your supplier, that’s who.

Work at height PPE suppliers have a vested interest in knowing their customer’s industries, understanding the problems they face and providing solutions that work.

They want to work with you, ensure you are happy with the solutions they offer and they want you to come back in the future.

A well established supplier will, over the years, have been approached with a vast array of enquiries covering all aspects of worker protection. They will have gained an insight into many forms of work, and from their remote position accumulated and distilled the best practices used by their previous customers.

What may be a new problem to you, they may well have come across many times before. So having said how good they can be, how do you assess if your own suppliers are there to help or just take your money?

The selection of a new supplier should involve as rigorous an assessment as you would expect to undertake before allowing a demolition team onto your site!

The effect on your business if you get it wrong can have equally ‘explosive’ repercussions.

When deadlines are looming and teams are waiting to get on with the job, it is not the time to find out that your cheap source of PPE isn’t able to supply or the PPE is not what you needed.

The use of ‘new supplier’ questionnaires is becoming more and more popular with purchasing departments, but if you have not considered something like them up until now, then here are some key points that may set you off in the right direction:

Questions for the supplier

  • How long have they been established in this particular market?
  • Are they a specialist dealing with a specific set of key brands, holding good levels of stock of products and spares for immediate delivery?
  • Have they any formal business accreditations such as ISO 9001:2008 which indicate a well run and efficient structure?
  • Are they members of any relevant industry federations such as BSIF or trade groups such as IRATA or WAHSA?
  • Can they provide technical support or relevant documentation efficiently on request (technical information or certificates of conformity)?
  • Can they provide or organise formal training on the products they supply if requested?
  • Who else do they deal with? Can they provide any customer references or testimonials?
  • Have they an efficient customer service system if you do find a problem?

And don’t forget about the people you will have to deal with:

Their staff

  • Have they any real life experience in using the products they are recommending?
  • Are they trained or qualified in work at height and do they receive regular training updates on the products they sell?
  • Do they have the ability to offer definitive advice on uses not covered by product instructions?

“the selection of a new supplier should involve as rigorous assessment as you would expect to undertake before allowing a demolition team onto your site!”

Don’t be afraid to push for answers. Be polite - you want to build a relationship that will bring benefits to both sides - but remember you are the one with the responsibility for your employees’ welfare. You need to be sure that the people supplying their PPE are also doing the best they can for them.

A quality supplier will understand your need for reassurance and be happy to show just how good they are. Time spent at this stage will pay dividends for years to come.

A final benchmark I use is to see how many times a supplier will admit that they have nothing suitable in their range and advise you to look elsewhere for what you need.

A professional business knows that there is no real profit in supplying something just to make a sale. If the product does not work on site then the trust built up through previous dealings will have gone in a moment.

So, with all this in mind, how did you choose the last employee to work at height for you, how did you pick your equipment supplier, and how carefully will you listen to both of them in future?

Published: 10th Sep 2010 in Health and Safety International

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