WORKING AT HEIGHT MOHSG 30 March 2005 Chris 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/ fatalities (average1992/02 was 78) -Largest cause 29% -Construction 67% of all fatals 2002/03 Major injuries 2002/ majors all workers (14%) (average 1996/03 was 5450)

Costs and consequences Human Death 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 1 st Consultation ended April 04, 2 nd Dec 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 m m Copies of HSE’s simple guide to the Regulations will be available shortly and will be free to download at The Work at Height Regulations 2005 (S.I.2005 No 735) will be accessible shortly via the HMSO website at: