Working at height can be a high-risk activity and statistics from the Health and Safety Executive (HSE) consistently show us that it is the leading cause of fatalities and serious injuries at work. But this is well-known by the health and safety community, and so what more can be done to improve the situation? In this article we consider how work at height can be better planned and managed, particularly with regard to ensuring adequate competency of those involved.
Managing work at height
The Hierarchy of Control from the Work at Height Regulations tells us that we should avoid work at height, but where this is not reasonably practicable then we should prevent the possibility of falls. Where this is further not practicable, we should mitigate the extent and consequences of any fall. Following this staged approach is correct and is both a legal and moral duty for all those who plan and manage work at height.
There are a multitude of reasons why avoiding work at height for many tasks is not a reasonably practicable option, and so managers and planners are faced with the challenge of effectively and efficiently preventing falls or mitigating their extent and consequence. To achieve this, control measures need to be implemented. These can be considered in three basic groups:
Effective management of work at height requires a blend of all three types of measures and the emphasis will vary depending on the activity, the environment, and the personnel involved. No single type of control measure will normally be adequately effective on its own. Where any single type of control measure is found to be weaker, then it should be compensated for by strengthening the other types. Each of these types of control measures are described further below.
Management control measures ensure that adequate processes and supervision are in place before, and during, work at height activities to reduce the risk of harm. Examples include permits to work, exclusion areas, monitoring, and implementing closer supervision.
Engineering control measures are physical systems designed to separate workers from fall risk areas or to arrest any fall that may occur. There are many different types of these systems, with a huge variety of design options for any given type. Figure 1, below, identifies the many different types of engineering control measures for access and protection while working at height.
The protection afforded may be considered as personal or collective:
• Personal protection systems will protect each worker individually, they are usually quite active systems requiring consistent correct actions to be taken by workers to ensure they are safe
• Collective protection systems usually protect any and all workers in a given work location, they are usually passive and require no actions to be taken by the workers to ensure their safety
Both personal and collective control measures can provide protection as either fall prevention or fall mitigation. The Work at Height Regulations tell us that we must consider prevention before mitigation and collective before personal.
Competency control measures involve restricting work at height in a given location to those workers who have adequate knowledge, skills and experience to work safely in those areas. The Work at Height Regulations (specifically regulation five) require us to ensure no person is engaged in “any activity, including organisation, planning and supervision, in relation to work at height unless they are competent to do so…” This can be a challenge for managers, as there is little guidance available defining how competent a person is to work at height.
It is clearly not a binary issue and is usually dependent on the complexity of the engineering control measures provided and the activities being undertaken. Therefore, it is necessary to quantify the degree of competency required to work safely in a given location and then use the same means to assess the competency of those who may work in those areas.
Work at height zones
When assessing an area for work at height, for example the roof of a building, it is often a good idea to divide the area into a number of smaller, clearly designated, work at height zones. These work at height zones may be defined by:
• physical characteristics of the building, such as different roof levels
• activities expected, such as maintenance of a roof-top plant
• engineered control measures (existing/ proposed), such as guard rails or lifelines
The creation of work at height zones and their assessment for required competency levels can readily be done for existing buildings, or for proposed new builds and modifications.
For new buildings, the required level of competency for a work at height zone can be used to create a performance specification for the design and construction teams. A performance specification will still allow for innovation and value engineering during construction procurement, but should ensure that the competency levels required to work safely on the building throughout its life are suitable for those who will manage and undertake such work.
If a performance specification approach is not used, then often construction value engineering will lead to a lower cost installation. This will usually be more complex to use safely, requiring higher competency levels, and so will restrict availability and/or increase cost for workers who are able to operate safely at height over the life of the building. It is strongly recommended that work at height zones are developed in the design of any new building, and that performance specifications for each zone are included as a part of the overall building specification package.
For existing buildings a similar approach can be taken, though there will probably be more technical and commercial limitations on what can be achieved compared to working on a new build. There may be potential to introduce or modify engineered control measures, or it may be more prudent to simply define the competency levels required to work in each zone as they are. Either way, once the required competency level is clearly understood it can be used to ensure that any workers entering each zone have adequate competency.
Ensuring safe access
A further consideration when assessing or specifying competency requirements for work zones is the access route to a particular zone. It may be the case that once in a zone a relatively low level of competency is required to maintain safety, but in order to gain access to the zone, a higher level of competency may be required. If this is the case, then the final work zone should be rated as requiring the higher level of competency, as this is required for safe access.
Thus far, we have been considering the competency of those who will use engineered control measures and this will be discussed in further detail later. However, there is another competency-related issue which must also be considered by managers, and that is the competency of those involved in designing and installing fall protection equipment.
Safe design and installation
Unfortunately, there are currently no meaningful independent qualifications available to those who design and install fall protection systems. This means that there are very few entry barriers into this market for potential suppliers. There are British standards, based on European norms, for most of the equipment, but there are many examples of well-engineered products being poorly set out and installed, leaving high risk situations for unwary users and managers.
Those who employ installer companies have a duty to ensure they are competent. Currently, this is extremely difficult for managers to do well, and the commercial size or history of the installer company is not indicative of the competency of individual designers or installers. Many of the installation contractors are more sales-focussed than solutions-focussed, so it is recommended that you ask the system designer to ‘walk through’ how any proposed system can be used safely by the personnel who you plan will use it, considering those users’ competency in work at height. When it comes to installation work, ask for the details of the specific installation technicians who will undertake the work and for evidence of their work history in this area.
Equipment inspection and practise
There are similar issues related to the inspection of work at height equipment. Again, there are no meaningful, independent qualifications available to those who undertake such work. There are many examples of inadequate inspection work being undertaken, leaving unsafe systems in service.
It is the duty of the inspector to ensure a system is safe for use, this includes consideration of the competency of the users, the suitability of the system for the expected activities, and the mechanical condition of the equipment. It is very common for many inspectors to undertake a limited physical inspection of the equipment, looking only for signs of degradation. Such inspections are not usually adequate and are not compliant with current standards.
It is also common practice for some types of work at height equipment, such as rope grabs, to be used outside of the scope to which they have been assessed under technical standards. In such circumstances, additional testing is specified by notified bodies, and therefore, the competency of those who select both the type and specific model of equipment for each application should be ensured.
Standards and compliance
One standard which has been recently introduced is BS7883:2019, which relates to personal fall protection anchors. This standard
has not changed the legal or moral duties of the designers, installers or inspectors, but does set out clearly how these duties should be fulfilled. In essence, it requires that clear evidence be recorded and supplied to the client in a system technical file, showing how the system has been designed, installed and commissioned. It also requires that an examination scheme be provided, detailing when and how the equipment should be inspected over its service life. It is recommended that any organisation employed to design, install or inspect fall protection systems demonstrates that they will work in compliance with BS7883:2019.
Categorising competency levels
It should now be apparent that understanding and being able to define levels of competency in work at height is extremely important in order to ensure safety and meet our legal duties as managers and planners. One approach is to use distinct levels of competency in work at height, and then to categorise both work zones and workers within one of these levels. Once both zones and workers have been categorised, then access to any zone can be restricted to only those with an appropriate competency level.
Below is an example of a series of competency levels, which can be used in this way:
• Beginner – someone who has no specific competencies in work at height
• Basic – someone who is able to correctly use simple fall protection systems, that do not need adjustment to ensure falls are prevented, meaning no competency in rescue is required
• Intermediate – someone who is able to use complex fall protection systems, that may need adjustment and/or that may not prevent falls, meaning competency in rescue is required
• Advanced – someone who is able to rig their own anchor systems and work in tension and/or suspension, these are typically qualified members of a rope access team
This system is already used by some leading designers in the fall protection sector. It is essential that the approach is adopted and applied in a consistent manner to ensure that designations for both zones and workers are applied across a range of organisations, locations and time. There is a significant amount of detail, beyond the brief descriptions above, which may need to be considered by a competent system designer in assessing the competency category of a work zone or of a worker.
Assessing competency needs
These categories cover general competencies and it is essential to realise that there may be some specific work at height competencies which are required to work safely in a given location, such as the ability to operate a particular type and model of equipment correctly. Of particular significance, for any situation where there is the potential for a fall to occur, it is essential that there is a rescue plan in place. Guidance from BS8437:2012 (Annex D) is that approximately 20% of people can suffer pre-syncope within 10 minutes of being suspended in a harness, and that a rescue plan should be in place to recover them before this deteriorates to syncope and potentially death. We should therefore, always ensure that we have adequate competency in rescue and any required equipment readily available where there is a significant risk of a fall.
A practical example of using this approach could be when inviting tenders to undertake servicing of roof-mounted equipment. The required competency level can be stated in the tender documentation, making it clear to tenderers what level of competency their workers will be required to have, to work safely in the work zone. This means that a site manager can much more effectively ensure competency of those who are working at height on their site.
Another example could be where some workers on a particular site have different levels of competency in work at height and some work zones are assessed as requiring higher levels of competency than others. Access to each zone should be restricted to only those with suitable competency.
This structured approach to managing competency would also have benefits in planning expenditure on training and provision of engineered systems. The clarity afforded will highlight where there are disparities between competency levels required and those available across large sites or multiple site estates. Deciding between expenditure on decreasing competency requirements for a work zone, by improving other control measures, or increasing the competency levels available through training or the use of contractors for some tasks, becomes a much more structured and justifiable process.
To summarise, the risk of harm while working at height should be addressed by following the hierarchy of control in the Work at Height Regulations and applying the principle of doing all that is reasonably practicable.
However, where the avoidance of work at height is not reasonably practicable then a mix of management, engineering and competency control measures should be applied to prevent falls or mitigate the extent and consequence of any fall.
There is therefore a clear need for managers and planners of work at height activities to ensure adequate competency of all those involved. However, this is challenging to achieve as there is little guidance available on levels of worker competency, and so ensuring adequacy requires the introduction of some structured approach to competency.
Work at height areas should be divided into clearly designated zones and all workers should have their competency assessed.
Once a structured system has been adopted by an organisation it can be applied to both workers and to work zones. This allows required competency levels to be compared to available competency levels. Where there is disparity between these two, workers can be trained to increase their competency level, or where contractors are to be used, required levels of competency can be specified.
Alternatively, competency requirements for work zones can be modified with engineered control measures to decrease the competency level required, or access can be restricted to only those with adequate competency.
For any location where there is significant risk of a fall there should be a rescue plan in place, and where this requires specific competencies and/or equipment, this should be readily available at the work location. Where additional control measures such as fall protection systems are to be introduced, great care should be taken in ensuring the competency of the individuals involved in the design and installation of the equipment, as there are very few barriers to working in such roles. The same is true of inspection of fall protection systems. It should be ensured that inspectors are competent and undertake suitably thorough examinations of equipment, including its suitability for use and the competency of expected users. Ensuring compliance with the requirements of BS7883:2019 will be very beneficial in achieving this.
Background images for this article have not been supplied by the author