Inspection of Height PPE
Published: 10th Jan 2007
Just how competent does a person need to be?
Every year businesses invest large amounts of time and considerable sums of money in providing suitable systems for carrying out work at height.
Producing these systems involves many different people. Health and safety specialists, Height Safety consultants, structural engineers and workforce representatives for example all come together to make sure that not only can the industries’ needs be met, but also that full compliance with UK legislation is achieved.
For many of the situations faced access can be achieved by temporary structures with collective protection or by the use of powered access equipment. Sometimes the use of Personal Protective Equipment is the most satisfactory answer.
If using PPE, all of this effort and the outcomes ultimately produced depend for their long term effectiveness on the skill of one individual; the competent person, who issues, inspects and maintains the items finally chosen.
All too often in industry the maintenance of PPE is seen as a burden that eats into productive time and something that can be delegated off to either the apprentice or the old hand filling in time before retirement.
But is this really the right attitude and just what does make a ‘competent person’?
UK Legislation talks at great length about the need for ‘competent people’ in a whole variety of situations and circumstances and thankfully takes an enlightened approach when defining them.
It states that: ‘A competent person is a person with a full understanding of potential hazards related to the equipment and the work it may be used for. A person with appropriate practical and theoretical knowledge and experience of the equipment to be thoroughly examined as will enable them to detect defects or weaknesses, to assess their importance in relation to the safety and continued use of the equipment, and be able to specify appropriate remedial action’.
This definition alone should immediately tell the reader that far from being a position easily filled by anyone in the workforce with time on their hands, this role is going to need someone who knows the tasks intended, and the conditions the equipment is expected to operate under.
The role of the competent persons
So, how does this definition translate into real life, what should an employer look for when selecting competent people and what does their role actually entail?
The best way to answer these questions is to consider the stages in selecting, purchasing and putting into service an item of work at height PPE and see where input from a ‘competent person’ may be required.
Before a new item of PPE lands on the store’s counter its performance suitability for the tasks intended should have been fully assessed by the team mentioned earlier. They hopefully will be up to date with the exact technical requirements of the task and what PPE is commercially available.
But even at this early stage the ‘competent person’ should be involved.
Where new products are an evolution of existing equipment in stores they may be able to offer comment on the performance of the old items and give guidance on areas where they consider improvements should be sought. Excessive wear, fragility in service, difficult maintenance and supply issues can affect service life and push up costs. The person who is looking at the gear day in, day out will have a historical profile of the equipment they are probably only too willing to share. After all, they don’t want to see the same problems again!
Other things that the competent person will want to discuss at this point may include the products unique identification (does it come ready numbered or have instruction on how and where to mark?), service ‘lifetime’, cleaning methods and storage requirements. It may be that existing storage; inspection and maintenance facilities are inadequate and will need to be upgraded before a product can arrive.
And where a change to a new supplier is necessary, is the chosen supplier able to offer the easy access to technical support that will be needed when looking after the product over its working life?
They will certainly want to have access to Certificates of Conformity and product instructions at this stage to confirm that the products meet the relevant EU Directives and European Standards and to prepare their inspection systems ready for logging in on arrival.
In circumstances where radical changes in design and technology are being considered they will also want to know about the amount of practical and theoretical retraining required and flag up the need for them to be included in such training if they are to be able to confidently inspect it from day one.
Input from the competent person at this selection stage is vital so that a smooth transition from one product or system to another is ultimately achieved.
With the selection process completed the competent person will then move onto a ‘preparatory’ stage.
System for work
The Provision and Use of Work equipment Regulations (PUWER), The Lifting Operations and Lifting Equipment Regulations (LOLER) and the Work at Height Regulations all require that PPE for work at height needs to be maintained and inspected and give clear guidance on the records that need to be kept.
To comply with this the competent person will have either built up a system, or have comprehensive knowledge of the current system used to cover all the equipment under their control.
Such a system will include:
- Method statements on how equipment is purchased, issued, maintained and ultimately disposed of
- Equipment Identification and Traceability lists
- Product Instructions
- Information on PPE / system compatibility
- Procedures for the inspection of all equipment
- Schedules for Inspections and Thorough Examinations
- Formal records of Inspections
- Maintenance logs which may include details of any recurring problems and corrective actions
- Detail on correct storage methods for each item
- Handling and storage of Certificates of conformity/purchase orders/ delivery notes
- Company approved equipment lists
- Details of approved suppliers
- Training records (including lists of authorised persons allowed access to the equipment)
Before any new equipment can be put into use it will need to be integrated into this system. This can take time, hence the need for early notification and involvement of the competent person.
When a new product finally enters service with a company the first few months will see a continuation of this close involvement.
End users will undoubtedly have questions about the items use and will be quick to highlight any practical issues with its suitability or performance. Having a point of contact for them is important so that such questions can be answered with authority and reassurance given where necessary.
This is also the time when systems can be ‘tweaked’ based on the information being received and observations on the gear as it comes back off the jobs.
Is it wearing as well as expected, is the proposed timescale for Inspections adequate, Is it working with other PPE or have unforeseen compatibility issues arisen, are spares coming in as quickly as required?
The competent person should be gathering all this data and be a focal point for those involved with the continuing evaluation of the gear. Their experience of dealing with PPE for work at height should allow them to sift through this information and provide balanced judgements to supervisors and management on any issues that have arisen.
But it’s not every day that new items come on stream and in larger companies much of the competent person’s time will be spent carrying out hands-on inspections of the equipment.
Once again, experience is vital. Unlike general lifting equipment where proof loading is used as an easily quantifiable way of assessing service condition, proof loading has no place in the inspection of PPE for work at height.
Instead, inspection is reliant on the observational skills of the competent person and their ability to relate what they see, hear and feel in front of them to knowledge they have gained about such materials in use and its survivability.
Here the competent person needs to become a cross between a friend and confidant, a materials expert and a criminal detective.
For example, a body mounted ascender comes back to stores as part of a rope access kit. It’s dirty and scratched just like they all get but its unique identifier is legible and its records are pulled out.
Having cleaned it up the competent person notices that the alloy body of the device is not only scratched but has some crazing and flaking of the anodised finish near the rope entry point, looking more carefully he sees that the attachment hole that connects it to the harness is dented at one point on the inner face. He immediately recognises these as signs of heavy impact damage. Opening up the cam he notices that one of the tiny hardened teeth on the face has broken off, leaving only the round dot of the stump behind. Previous discussions with the manufacturer have told him that it is unknown for these teeth to break off in normal service.
A picture has built up now of a device that has perhaps been subject to a fall in service and one that should not be used again.
Congratulations you may say, but the job should not end there.
For a piece of PPE to get into that condition something on site has gone wrong. It may be that someone has overloaded the device when hauling up a bag of tools. That turned out to be bad news for the device but also indicates that there is a training issue with the person that did it.
Were they aware that this was a misuse of the device, and why did they not spot the damage that they had done?
The competent person is ideally placed to quietly find out more about the circumstances and perhaps to offer some advice to ensure that a repeat never occurs. If they feel that this is not enough then they can pass their findings on to a supervisor who can take more formal action.
If however the damage did occur from a fall then obviously this is a major issue.
Again, investigations must be made to discover the exact circumstances of the incident and decisions be made about changes to work methods and training. At this point these are best left to others.
But the competent person will still be busy. When a device holds a fall it will invariably be damaged. But what about all the other parts of the system it was connected to?
In the above example the competent person will be immediately going through the equipment issue records and retrieving all the other items involved. If the ascender has a tooth missing where is it? Is it stuck into the rope, slowly moving around and embedding itself further into the ropes construction possibly cutting the load bearing strands?
What about the connectors and anchor devices? Have they been damaged in any way?
And let’s not forget the harness the ascender was attached to in the first place. To break off a tooth it will have absorbed energy from a fall far higher than the manufacturer will allow for continued service.
With everything retrieved the competent person is then obliged to dispose of the equipment in a manner that prevents any part of it being reused by any of the workforce, or anyone else who may come across the remnants. Just throwing gear in a handy skip is not acceptable. This may need a little ingenuity and some advice from the manufacturer to ensure that this is done safely.
Finally, having done all of this a detailed record should be made of what has happened and why, and the companies inspection records updated to indicate the end of the items life.
So, even in this brief article you can see there is perhaps much more to the job of the competent person PPE inspector than you originally thought.
One of the questions that often come up when competent people are discussed is qualifications for the role.
Well, somewhat surprisingly for such a complex and important job there is no single, industry recognised certificate.
The various Regulations have studiously, and in some peoples opinions wisely, avoided laying down the requirement for a formal qualification, reinforcing the desire for a sound base of knowledge and experience, and they may have a point. After all, it would be unwise to allow someone with no past history of dealing with such equipment to be put on a course and ‘crammed’ with information over a day or two and then be pushed out into the workplace as ‘competent’.
However, without some form of training and assessment companies run the risk of leaving staff to work in isolation, unchecked as to if the judgements they make are correct and possible unknowing to changes in technology and Legislation.
A number of equipment manufacturers, suppliers and training providers now offer PPE inspection competent person’s courses. Some are single days which give an insight into the role and grounding in the techniques, others run for up to four days and are aimed at experienced people who are about to take up senior roles, providing them with detailed information on the legal requirements when specifying and selecting equipment, the range of systems and equipment available, equipment management systems as well as covering practical inspection techniques.
Is it time you looked again at your competent people? Their job may be more important than you first thought.
Published: 10th Jan 2007 in Health and Safety International