Work at height

1. Introduction

      More than 4000 people a year in the UK suffer major injuries from falls while working at height and it is a major cause of workplace death. While the majority of these incidents occur in construction, other sectors of employment are also affected. For instance, HSE data for the education sector shows that in the last six years there have been five deaths and over 3000 injuries due to falls from height. Most of the major injuries were associated with falls of less than two metres.

      The Work at Height Regulations 2005 apply to all work at height where there is a risk of a fall liable to cause injury[1].

      2. What is work at height?

       

      The Regulations do not specify any height limit: the previous emphasis on work at heights exceeding two metres was not carried over into this legislation. Instead, the legislation encourages a risk-based approach to work at any height where injury may result if suitable precautions are not taken. This covers a range of circumstances, e.g.

      • using work equipment (a work platform, scaffolding, or a ladder)
      • work on a roof or up a tree
      • work next to openings such as cellars or excavations
      • use of inappropriate means (standing on a table or chair) to change a light bulb.

      3. Managing work at height

        Work must be planned, organised, supervised, and carried out by competent persons, using the following hierarchy of controls:

        (a)  avoid work at height wherever possible where there is a risk of significant injury

        (b)  prevent falls where work at height cannot be avoided (by using suitable measures, e.g. guard rails or work platforms, that protect all workers)

        (c)  mitigate falls: minimise the distance and consequences of a fall where the risk of a fall cannot be eliminated (by using personal protective equipment, e.g. fall arrest systems)

        (d)  take additional measures if it is not reasonably practicable to avoid, prevent or mitigate falls (e.g. provide additional instruction and training, demarcate edges with painted lines).

        All work at height must be subject to appropriate risk assessment, whose complexity will depend on the risk of injury that has been identified. The assessment should not just consider the height of a fall (the higher the fall, the more likely it is to cause injury, although injury may be sustained even in falls from lesser height, i.e. less than two metres). It should also take into account:

        • environmental conditions (especially slippery conditions or high winds)
        • materials onto, into, or through which, someone could fall (they may be hard, there may be sharp edges or impalement hazards, or they may be fragile and cannot support a person’s weight).
        • risks from falling materials or objects (e.g. of materials stored at height, or dropped tools – barriers and warning signs may be needed to prevent access to danger areas).

        The aim is to identify practical precautions that are proportionate to the risk. Where it is not reasonable practicable to prevent falls or mitigate their effects then residual risks should be addressed by suitable instruction, training, and safe systems of work.

        Departments are responsible for ensuring that no unauthorised persons have access to their roofs and access must be subject to a permit to work system as outlined in UPS S6/08 (Control of Contractors on University Premises). An example of a proforma permit is attached as .

        4. Additional information

          While this policy is concerned with the way work at height is conducted, those who design workplaces have an important role to play in preventing falls from height. There is a specific duty on designers in the CDM Regulations to consider risks to those who

          • carry out construction work, including demolition
          • clean any window, transparent or translucent wall, ceiling or roof in or on a structure, or maintain the permanent fixture and fittings
          • use a structure designed as a place of work
          • may be affected by such work (staff, students or members of the public)

          Estates Services project officers and those in departments who commission designers should note the above duties and be prepared to question them on their strategy for avoiding or minimising the risks from work at height.

          The Regulations contain a number of schedules containing detailed requirements for existing places of work and means of access for work at height; for collective fall prevention (e.g. guard rails and working platforms); for collective fall arrest (e.g. nets, airbags etc.); for personal fall protection (e.g. work restraints, fall arrest and rope access) and for ladders. The appendices to this policy give information on those aspects most relevant to the University:

          • Appendix 3: Ladders and mobile elevating work platforms (MEWPs)   
          • Appendix 5: Permit to work

          5. Action required

            Departments[2] must ensure that:

            (a)       all work at height is properly planned and organised, ensuring this is proportionate to the risks involved in the work

            (b)       the risks from work at height are assessed and the appropriate work equipment is selected and used

            (c)       those involved in work at height are suitably trained and competent for the task

            (d)       those involved are reminded of their duty to use work equipment safely and to report any unsafe activities or defects relating to work at height

            (e)       equipment provided for work at height is properly inspected and maintained

            (f)        permits to work are issued where access to roofs is required and there are risks attached to working there (e.g. falls from the roof or through fragile surfaces, or exposure to harmful substances discharged around roof level)

            (g)       designs for new buildings or refurbishments take into the risks of work at height and avoid or minimise those risks.

            THIS STATEMENT FORMS PART OF THE UNIVERSITY SAFETY POLICY.  UNIVERSITY POLICY NOTE S5/05 IS WITHDRAWN.  PLEASE AMEND THE INDEX.

            A C Kendall

             


            [1] They do not apply to the provision of instruction or leadership in caving or climbing by way of sport, recreation, team building, or similar activities.

            [2] The head of department or institution retains the overall responsibility for implementing the policy, but in the context of the University the responsibility is delegated to those giving instructions to others where the instructions involve persons working at height.

            December 2011