Working at Height
Published: 01st Jul 2006
How far have we come, and how far have we still to go?
In 2005 the UK introduced the Work at Height Regulations into statute law. The reason for introduction was twofold. Firstly to ensure that the UK complied with fundamental requirements of the European Temporary Work at Height Directive as it is duty bound to do, and secondly to take the opportunity to target an area of work where there were real concerns about existing work practices. The previous Regulations concerning work at height were scattered throughout the Health and Safety at Work Act and provided little in the way of practical guidance to those engaged in work at height. The new Regulations aimed to change that and give those at work a structured approach to dealing with these tasks.
The Regulations introduced a basic hierarchy that put avoidance of work at height as a priority. Impossible? Well in some circumstances yes, but how many times have buildings or machinery been designed with high maintenance items placed on top just to get it 'out of the way' with no thought to access in the future?
Where existing features would make modification impracticable, the Regulations made it clear that avoidance of falls was the next goal (you are allowed to place people at height, but you have got to do it in such a way that they should not fall).
Only when these two options are not justified would systems that mitigate the consequences of a fall be acceptable (your personnel may fall but you have to make sure that it does as little harm to them as possible).
Within this hierarchy more detailed requirements were supplied for each stage to focus thinking on the methods and equipment that could be used. Access methods considered included permanent walkways and platforms, scaffolding, mobile platforms such as MEWP's, collective protection in the form of nets and airbags, the three basic PPE based systems (restraint, work positioning and fall arrest) and, where appropriate, ladders. Further specific information detailing the methods of use and selection of these systems and equipment was made available during 2005 with the publication of BS 8437 Code of Practice for selection, use and maintenance of Personal fall protection systems and equipment for use in the workplace.
Twelve months on, 'What impact have the Regulations had on industry'
Any new Regulations are generally subject to deep suspicion by businesses fearful of interference by those they perceive to be less knowledgeable than themselves.
The Work at Height Regulations were no different when first mooted. However, the detailed consultation carried out by the Health and Safety Executive across a wide spectrum of industries before and during the draft stages allowed for a better understanding of the range of tasks undertaken at height and the techniques currently used. Over 180 separate trade organisations representing trades as diverse as scaffolders, builders, window cleaners, lighting technicians and offshore rope access operators all had chance to discuss in detail the possible effects of the proposals. Many other industry sectors that until then had not really considered themselves to be mainstream workers at height also initially found items of concern within the draft. Arboriculturalists, theatrical performers, emergency service personnel, mountain guides, shop staff and warehouse workers for example.
By the time the Regulations were finally passed into law they had evolved into a document that was almost a 'work book' of how to approach work at any height. It addresses the importance of planning, management, training and competency.
A high profile information campaign by the Health and Safety Executive, backed up by information and guidance documents proved very effective in making employers, and more significantly employees, aware of the risks involved with work at height and their responsibilities to reduce those risks to the minimum level possible.
The hotly contested removal of the 'two metre rule' (with its common misconception that situations where a potential fall of less than two metres existed protection was not required) produced endless discussion on construction sites throughout the country but also served to bring the new legislation to the attention of many workers who would perhaps otherwise have taken little notice.
So, lots of people appear to know about the new rules, but how well are they complying?
It is difficult for anyone to say with certainty on how effective the Regulations are. Accident and prosecution statistics have yet to be published and it will be many years before trends are clear, but from a purely personal view based on visiting sites and dealing with clients it is apparent that times are changing.
Architects are consulting specialists in work at height for advice on access systems at the planning stage, long before the first brick is laid. They understand that retro fitting systems can be very expensive and delay final hand over for long periods. Installing protection at the time of the build can protect workers during construction, speed up the building process and provide future safe access for cleaning and maintenance.
Equipment designers are also being encouraged by their clients to provide plant and machinery that reduces the need for work at height, or provides the user with safe access and a safe worksite once there. For an example, look at the trailer unit of the next fuel tanker you pass on the road. In the past many of the driver's tasks involved him climbing up onto the top of the tank. Now you will see signs indicating that everything can be carried out from ground level, eliminating the risk of a fall.
Walk around construction sites these days and you will see more work tasks being carried out from temporary structures and mobile work platforms, more workers wearing harnesses with restraint or fall arrest systems and the more widespread appearance of new technologies such as catch nets for collective protection.
Even loading and unloading vehicles has come under scrutiny with some major companies using airbag 'docks' for articulated trucks to allow crane riggers safe access onto the load bed for slinging operations on green field sites.
Where people have approached the Regulations with an open mind and used the information contained within it, there generally appears to have been a positive outcome. The time spent planning the task, finding the most suitable work method and the financial outlay required to obtain new equipment is recouped because of more efficient working on site and reduced down time. Not only that, but reduced accident rates make companies more attractive to prospective customers who want a safe site, and help keep insurance premiums at a manageable level.
What concerns still remain and where can improvements be made?
Well, the best equipment and the most well thought out systems come to nought without staff who can apply them effectively. The focus on work at height has given manufacturers a reinvigorated market and new equipment is launched every week. With this equipment comes new operating techniques. Keeping pace with these changes involves the retraining of users and the more complex the item, the higher the skill level needs to be.
UK law has always required people to be 'suitably and sufficiently' trained for a task. The exact qualification held is rarely stated. This has enabled those with practical knowledge and experience to be approved within their company to carry out tasks which they are obviously capable of undertaking. However it has also allowed others to pay only token notice to what is sometimes seen as an expensive luxury.
It has been left to trade organisations to produce and promote their own qualifications specific to their own areas of expertise and try to get them nationally accepted within their industries. Good examples of well run and well respected trade produced systems are those run by IPAF (the International Powered Access Federation) and IRATA (the Industrial Rope Access Trade Association). Successes like these, where the background skills and knowledge come from within the industry, are now leading other sectors to produce their own qualifications. For example PLASA (the Professional Lighting and Sound Association) are currently launching a rigger's award for lighting and sound technicians working at height which they hope will become their industry standard.
But is all training good training? When the Work at Height Regulations came into force there was a leap in the number of companies and individuals wanting specific training. There was concern by many established height safety training providers that with a greatly expanded market there was the potential for people who perhaps did not have the necessary technical experience and facilities to set up as work at height trainers. With no nationally recognised single work at height qualification the content and delivery method of such training could be 'variable' at best.
In the last month, B.S. 8454, the Code of Practice for the delivery of training and education for Work at Height and Rescue has been published. The aim of this document is to ensure all work at height training meets a minimum standard in terms of quality of content, presentation, assessment and facilities. This document has been formulated with the assistance of trade organisations and training companies and sets out realistic requirements for those intending to train others in this specialist field. Its introduction will allow a customer to assess the abilities of a potential training provider and ensure that the trust placed in them is not misplaced.
But personally, one of my biggest outstanding concerns is in the area of rescue. The Regulations clearly state that part of any task planning and risk assessment is the requirement to consider what might happen if things go wrong, and to have a workable means of rescue available. This plan needs to take into account the worksite location, the environment and most importantly the speed of response required by the casualty's injuries.
In the past, such detailed provision has been sadly lacking in all but the most enlightened organisations. Too often the blanket reply to such questions has been to 'call the Emergency Services' and leave them to sort things out.
Such a response was never acceptable but this legislation puts rescue firmly back to the fore.
Along with the increase in the use of PPE based systems such as fall arrest equipment comes an increasing potential that at some stage they will be used for real. When ideally placed, such systems will stop the user quickly with little discomfort and with no risk of contact with the ground or obstacles below. They may even be able to recover themselves. But, a moment's inattentiveness can change the outcome leading to users dangling helplessly in free space having felt impact forces of up to 6 kN on their bodies.
Now think of the same accident not on a factory site in the middle of a big city, but on the side of a Scottish wind turbine five miles off shore. Or in the middle of a February hailstorm nine levels up on a petrochemical stack. Growing knowledge about the effects of suspension on the body makes the swift and organised recovery of such casualties to a safe area a priority.
Add in any injuries that they may have suffered before or during their fall and it is obvious that casualties in these positions require help immediately and that help can realistically only come from their own colleagues. A delay of even ten minutes could seriously affect their chances of survival.
So, what should a company do to address this extremely important issue?
Considering the potential risks and then choosing the most effective access system right at the start is still the best thing to do. Using a method of work that will prevent employees from ever getting into a position where they can fall will dramatically reduce the need for speedy intervention. Once again the information already provided within the new Regulation will help in this choice. Where the potential for incidents still exists (and let us not forget that medical problems such as heart conditions can cause incidents requiring evacuation from height) then companies must ensure that they have personnel on site who can access the incident quickly, provide appropriate first aid treatment and then assist in the recovery of the casualty to a point where the Emergency Services can take control.
This will require a core of employees to be more highly skilled in moving around at height and accessing areas not normally entered. They will also need to be supplied with appropriate equipment to allow them to do this. At first glance this may seem an expensive and excessive response to a potential problem that may never occur, but the consequences of not taking such steps should the unthinkable happen are both legally and morally indefensible. Many larger companies are raising awareness of these issues with their subcontractors by using a contractors rescue plan as a means of assessing their competence and adherence to Health and Safety law. Failure to provide an adequate system quite simply means no access to the site.
Yet after all this there is one other essential component to any rescue provision that even the new Regulations have failed to highlight. That is the level of medical response appropriate for the situations casualties may be found in.
From the comments above it should be obvious that any rescue will require those first on scene to provide not only life saving first aid but also extended care as the recovery progresses. Significant falls from height always carry the risk of cervical and spinal injuries which demand appropriate handling to prevent further injury during rescue. Use of items such as oropharyngeal airways, cervical collars and spinal boards is not covered in the basic UK First Aid at Work Certificate but should be seen as essential for those providing rescue cover on 'remote' work sites.
Excessive? Why? The Emergency Services would be the first to agree that rapid access and intervention can make a vast difference to casualty outcomes. Medical people talk of the 'golden hour' in which casualties should be recovered, treated and passed to definitive care. The initial 'platinum ten minutes' is where life saving interventions can be made. The chance of a statutory body even getting onto a site and finding the casualty within these timescales is unrealistic for the majority of incidents. To give a casualty the best possible care the initial response must come from within.
The Health and Safety Executive is currently reviewing the recommendations on first aid provision for work at height and it may be that requirements change in the near future. There are a number of 'advanced' courses under commercial development that are generating significant interest.
So, with the Work at Height Regulations firmly in place, are they achieving what they set out to do?
The fundamental reason for having such rules is to ensure that everyone makes every effort possible to prevent accidents, and that people go home at the end of the day as fit and well as when they started.
The view from where I am is that this document will help in achieving that aim. Yes there are areas that need highlighting further, but when seen as a practical 'guide' to work at height it is definitely worth what it is written on!
Paul Witheridge of Lyon Equipment Limited.
Lyon Equipment Limited is a leading provider of training & equipment for work & rescue at height. It is a founder member of the international Industrial Rope Access Association (IRATA), members of the British Safety Industry Federation (BSIF) and the Height & Access Safety Group (HASG).
Members of Lyon staff sit on various committees including BSI PH/005, Industrial Safety Belts & Harnesses. They are also involved in working group BS8454 (Specification for delivery of training and education for work at height and rescue), International Standards for Personal Fall Protection Equipment and the Health & Safety Executive Advisory Committee on Lifting and Rope Work.
Tel: +44 (0) 15396 25493
Published: 01st Jul 2006 in Health and Safety International