WORKING AT HEIGHTMOHSG

30 March 2005Chris Gallagher

HSE Safety Unit

Overview

• What is the problem?

• What is HSE doing?

• What should you do?

• New Work At Height Regulations

• Practical examples

What is the problem?

• Fatal accidents falls from height 2003/04

- 67 fatalities (average1992/02 was 78)- Largest cause 29% - Construction 67% of all fatals 2002/03• Major injuries 2002/03- 4256 majors all workers (14%)

(average 1996/03 was 5450)

Costs and consequences

• HumanDeath or injury,bereavement, trauma

• Business Lost production, experience, reputation and higher insurance

• Consequences

Prosecution

What is HSE doing?

• HSE set targets to reach by 2010• Programme working is the method

chosen by HSE to reach these targets • Injury reduction is a component of the

programme • Falls from height is a topic within the

injury reduction program• Falls from height are a key HSE target

HSE is targeting falls

• Inspections

• Accident investigations

• Complaints

What is work at height?

• Work in any place (including access or egress) where a person could fall a distance liable to cause personal injury

• Law has always required control

• Does not include slips or trips on the same level or falls on stairs

What do people fall from

• Ladders

• Scaffolds

• Working Area or Platforms

• Roofs

• Vehicles

• Plant and Equipment

• Racking

The 2 metre rule

• Currently no 2 metre rule in WAHR

• Use risk assessment to determine whether precautions are needed and in what form

• Precautions are needed when there is a risk of injury

Low falls

• Employers need to tackle low falls

• Consultation has shown that employers are concerned about workers safety below 2 metres as well as above it

• Have you got low fall risks?

• WAHR advocates sensible risk assessment and pragmatic precautions

Low falls cont.

• Working platform to the left of a printing machine

• Approx 1 metre high• Work with back facing

edges• Risk of a fall onto sharp

edges• Guard rails required?• Platform in front OK?

Low falls cont.

What should you do?

• Identify the activities and precautions involving falls from height

- Includes work on or near fragile surfaces

• Select appropriate equipment and ensure it is well maintained and inspected

• Have systems for the procurement and control of contractors

Identify the activities and precautions

• Ensure risk assessments have identified work at height activities both routine and non routine

• Have workers been instructed in necessary precautions

• Have fragile surfaces been identified and are access points marked

Identified suitable precautions?

• No fall protection• Working on unprotected

fragile surfaces• Unsafe access?• No risk assessment • Workers not instructed

in necessary precautions

Fragile surfaces

• Identification• Warning signs• Control access• Protection Required

if you need to work on or near fragile materials

• Contractors aware

Select appropriate well maintained equipment

• Ensure risk assessments have identified appropriate equipment for the work

• Use a selection hierarchy

• Maintained

• Inspected

Selection of appropriate equipment?

Well maintained?

Inspected?

Tower scaffolds

• Erected by competent persons in accordance with the manufacturer/suppliers instructions

• Firm level ground• Adequate guard rails,

toe boards and platform• Height not exceed 3

times minimum base dimension

Fatal accident

Mobile elevating working platforms (MEWPS)

• Safe plant

• Safe site

• Safe operator

MEWP’s

Illegal MEWP!

Working platforms on fork lift trucks

• Occasional use only• Working Platforms

Must be purpose built Guard rails Secured Inspected (6 month LOLER)

• Don’t Stand on forks Stand on pallets

Work restraint and fall arrest equipment

• Work restraint prevents the user reaching a position where a fall could occur

• Fall arrest includes PPE (harness, lanyard, inertia reels) Also nets and airbags

• Fall prevention should take precedence• User training• Inspection of equipment• Clearance distances, deployment zones, sharp

edges• Rescue plan

Ladders

• Do you need to use them ?

• Primarily a means of access

• Not suitable for two-handed or heavy work

• Suitable for short duration light duty work

• Critically review work from ladders

Ladders cont.

• In good condition • Angled 1 out for

every 4 up.• Secured or

stabilized• On firm level ground• Used by trained

persons

Appropriate use of ladders?

Selection and control of contractors

• Clients have a duty

• Selection – are contractors competent to work at height

• Communication and co-operation

• Monitoring

• Review performance

The Work at Height Regulations 2005

• Bring into effect amendments to a European Directive on the use of work equipment

• Due to come into effect 6 April 2005• Single set of Regulations will cover all

industry sectors• Existing requirements covering work at height

in the Construction (H,S&W) Regs and the Workplace (H,S&W) Regs will be revoked

Important messages

• Build on existing good practice

• Those managing risk now will generally already comply

• Goal setting/sensible risk assessment

• Existing construction standards maintained

• Ladders not banned

Drivers for change

• Falls are the biggest killer in the workplace

• Existing piecemeal legislation • HSC wants single set of Regs for all

sectors• Centrepiece of HSC Falls From Height

Programme • Need to implement the Directive

New requirements

• The hierarchy may be new to some (particularly non construction)

• When selecting work equipment must now consider risks entailed with- Installation- Use- Dismantling- Rescue (associated with work equipment chosen)

New requirements cont.

• Some new terms• Take into account weather conditions• Guard rail heights to increase to at least

950mm for construction work (CHSW 910mm)

• Toe boards heights should be suitable and sufficient

• Some new technical requirements in the schedules

Application (Reg. 3)

• Employers, self employed, employees and others

• Contractors

• Employers in charge of premises where work at height is carried out

• Those in control of people at work, to the extent of their control

Organisation and planning (Reg. 4)

• Ensure work at height is properly planned

• Appropriately supervised• Carried out in a safe manner• Includes the selection of appropriate

work equipment • Plan for emergencies and rescue• Take into account weather conditions

Don’t loose the plot

Planning for emergencies and rescue

• Proportionate to the risk• Reasonably foreseeable

situations such as stuck equipment, deployed fall arrest

• Suspension trauma• Over-reliance on the fire

brigade

Weather conditions

• Ensure work at height is carried out only when weather conditions do not jeopardise the health and safety of workers

• This is an absolute duty

• Strong winds will be the most common reason for halting work at height

Competence (Reg. 5)

• Employer shall ensure that persons engaged in any work at height activities are competent

• Persons must also be competent in

- Organising

- Planning

- Supervision

- Selection of appropriate work equipment

- Use of work equipment

Competent?

Avoidance of risk from work at height (Reg. 6 Hierarchy)

• Regulation 6 is at the heart of WAHR• First step is take account of a risk

assessment to identify appropriate precautions (Reg. 6(1))

• Reg. 6 sets out the HIERARCHY of - AVOID- PREVENT, or- MITIGATE FALLS from work at height

Avoid the need to work at height

Prevent the fall

• Using an EXISTING PLACE OF WORK

- includes access and egress

OR

• Use WORK EQUIPMENT to PREVENT the fall

What is an existing place of work?

• A place that is already safe

• Does not require the addition of anything to prevent a fall

• Includes safe means of access and egress

Create a safe existing place of work?

Use work equipment to prevent a fall

Mitigate the consequences of a fall

• When fall prevention is not reasonably practicable provide work equipment to

- Minimise the distance and/or

consequences of a fall

Final step in the hierarchy

• Prevent any person falling a distance liable to cause personal injury by,

- providing additional training and

instruction

- or take other additional suitable and

sufficient measures

Ladders and the hierarchy

• Bottom of hierarchy can be used to justify work from ladders

• Must consider fall prevention and mitigation first

• But ladders used just for access and/or short duration work can be justified instead of providing fall prevention or mitigation measures

• Also ladders can be used in conjunction with other work equipment eg fall arrest

Example of how the hierarchy applies : Roof duct installation

• Avoid work at height• Prevent a fall by,

- Using an existing safe place of work or,

- Using work equipment to prevent a fall

• Mitigate a fall by using work equipment to minimise the distance and consequences of a fall

Selection of work equipment (Reg. 7)

• Give collective measures priority over personal protective measures

• Includes a list of principles which should be taken into account in the risk assessment when selecting work equipment most suited for the job

• Work equipment must be able to cope with foreseeable loadings and allow passage without risk

Principles for the selection of work equipment

• Take account of

- working conditions

- distance to be negotiated for access and

egress

- distance and consequences of a fall

- duration and frequency of use

- need for evacuation and rescue

- additional risk when installing,removing

Requirements for particular work equipment (Reg. 8)

• Lists requirements for particular work equipment via the schedules- Existing place of work, schedule 1- Guard rails etc, schedule 2- Working platforms inc scaffolds, schedule

3- Collective fall arrest safeguards, schedule

4- Personal fall protection, schedule 5- Ladders, schedule 6

Fragile surfaces (Reg. 9)

• Same principles as the Reg 6 hierarchy• Eliminate the need to pass across, work on,

from or adjacent to a fragile surface• Prevent a fall by ensuring suitable platforms,

coverings or similar means of support • Provide other suitable and sufficient means

for minimising the distance and consequences of a fall

• Provide warning notices at approaches to fragile surfaces

Avoid/eliminate the need to work on a fragile surface

Fragile surface with no fall prevention/protection

Falling objects and danger areas (Reg. 10 and 11)

• Prevent fall of material or object

• Prevent people from being struck by falling material or object

• Do not throw or tip material from height

• Store material and objects safely

• Prevent access to danger areas and clearly indicate them

Inspection of work equipment (Reg. 12)

• Inspection requirements are based on pre-existing duties

• PUWER Reg 6 no longer applies to work equipment for use during work at height (now covered by Reg 12 WAHR)

• Work equipment currently inspected under LOLER will continue to be inspected under LOLER

• 7 day inspection required for platforms used in construction

Requirements of Reg. 12

• Inspection after assembly or installation• Inspection at suitable intervals and after

exceptional circumstances• Scaffolding inspected every 7 days• No work equipment leaves or is

obtained from an undertaking without physical evidence of an inspection either under WAHR or LOLER

Inspection of places of work at height (Reg. 13)

• Involves the inspection of an existing place of work (place not needing work equipment to make safe)

• Before use check condition of surface, parapet, permanent rail or other such fixed/existing fall protection measures

Duties of persons at work (Reg. 14)

• Every person working under the control of another person shall report any activity or defect relating to WAH which is likely to endanger the safety of himself or another person

• Every person shall use any work equipment or safety device provided to him in accordance any training and instructions he has received

Some reassurance

• Do you follow current law and industry good practice?

• Do you assess risks, plan the work and act accordingly?

• Do you consider avoidance first then prevention and mitigation?

• Do you consider collective before personal protection?

• If yes, you should be able to comply

Next steps

• 1st Consultation ended April 04, 2nd Dec 04• 750 comments received • Ministerial approval 16 March 2005• Will be a brief plain English guide to the

Regulations• HSE will encourage and help industry

develop their own sector specific guidance• Implementation 6 April 2005

References

• Working on roofs INDG284• Preventing falls from boom type

MEWP’s Misc614• Avoiding falls from vehicles INDG395• Inspecting fall arrest equipment made

from webbing or rope INDG367• Use of contractors a joint responsibility

INDG368

More information

• Press release on HSE Website at http://www.hse.gov.uk/press/2005/c05008.htm

• Copies of HSE’s simple guide to the Regulations will be available shortly and will be free to download at http://www.hse.gov.uk

• The Work at Height Regulations 2005 (S.I.2005 No 735) will be accessible shortly via the HMSO website at: http://www.hmso.gov.uk/si/si20050735.htm