How to comply with the new Working at Height Regulations

8/9/2019 How to comply with the new Working at Height Regulations

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How to comply with the new Working atHow to comply with the new Working at

Height RegulationsHeight Regulations

Ron BonnerRon BonnerMIOSH MIIRSMMIOSH MIIRSM



Why do we need to introduce these Regs?Why do we need to introduce these Regs?

The Working at Height Regulationsare being introduced by theHealth and Safety Commission as aresponse to the EuropeanDirective on Temporary Workingat Heights (2001/45/EC) whichshould be implemented bymember states by July 2004

This consolidates the working at

height requirements found in theCHSWR 96.



Interpretation (Reg 2) What is “Working atInterpretation (Reg 2) What is “Working at Height”

Work in any place, including a place in:Work in any place, including a place in:

• The course of obtaining access to or egress from any place exceptThe course of obtaining access to or egress from any place exceptby a staircase in a permanent workplaceby a staircase in a permanent workplace

or or

• At or below ground level from which a person could fall a distance At or below ground level from which a person could fall a distanceliable to cause personal injury and any reference to working atliable to cause personal injury and any reference to working atheight will include access to or egress from such places whilst atheight will include access to or egress from such places whilst at

workwork



Working at Height - what is and what isn’t?Working at Height - what is and what isn’t?

Working at heightWorking at height

• Working on a scaffold orWorking on a scaffold orMEWPMEWP

• Working on the back of aWorking on the back of alorrylorry

• Using cradles or ropes toUsing cradles or ropes to

gain accessgain access• Climbing permanentClimbing permanent

structuresstructures

• Working close toWorking close toexcavations, cellars orexcavations, cellars or

other openings.other openings.• Staging or trestlesStaging or trestles

(concerts filming etc)(concerts filming etc)

Not working at heightNot working at height

• Activities carried out byActivities carried out byprivate individuals.private individuals.

• Trips and slips on the levelTrips and slips on the levelsurfacesurface

• Permanent stairways (unlessPermanent stairways (unlessunder structuralunder structural

maintenance)maintenance)• Working in a buildingWorking in a building

(e.g.office) with multiple(e.g.office) with multiplefloors where there is no riskfloors where there is no riskof falling (except if of falling (except if the staff the staff use a stepladder to changeuse a stepladder to change

the bulbs within the office)the bulbs within the office)



Who does the regulations apply too? (Reg 3)Who does the regulations apply too? (Reg 3)

The requirements imposedThe requirements imposed

on an employer by theseon an employer by these

Regulations shall applyRegulations shall apply

in relation to work-in relation to work-

By an employee of his or By an employee of his or

By any other person under By any other person under

his control, to thehis control, to theextent of his control;extent of his control;

The requirements imposedThe requirements imposedon an employer by theseon an employer by these

Regulations shall also applyRegulations shall also applyin relation to –in relation to –

Self-employed person inSelf-employed person inrelation to work – by himrelation to work – by himor person under hisor person under his

control; and control; and Any other person other than Any other person other thanself-employed person, inself-employed person, inrelation to work by arelation to work by a

person under his control, person under his control,and to the extent of hisand to the extent of his

control.control.



Reg 4 Organisation and PlanningReg 4 Organisation and Planning

4-14-1 Every employer shall ensure that work at height is –Every employer shall ensure that work at height is –

i.i. Properly planned;Properly planned;ii.ii. Appropriately supervised; and Appropriately supervised; and

iii.iii. Carried out in a manner which is so far asCarried out in a manner which is so far as

reasonably practicable safereasonably practicable safe

iv.iv. and that its planning includes selection of workand that its planning includes selection of workequipment in accordance with regulation 7 of theequipment in accordance with regulation 7 of the

WAHRWAHR.

4-24-2 Planning includes planning for emergenciesPlanning includes planning for emergencies

4-34-3 Every employer shall ensure that working at height isEvery employer shall ensure that working at height is

carried out only when the weather conditions do notcarried out only when the weather conditions do not

jeopardise the health and safety of persons involved jeopardise the health and safety of persons involved

with the workwith the work



Guidance for Regulation 4Guidance for Regulation 4

• Assess the risks to decide how to work safelyAssess the risks to decide how to work safely



Risk AssessmentRisk Assessment

Subject to be assessed (Hazard, task or premises) Working at height on stage trussing, (construction, suspension of equipment

and dismantling)

Significant identified hazards Controls

1. Slips Trips and falls from

follow spot positions, trussesand access equipment(ladders & MEWP’s)

2. Falling of persons andequipment from overheadpositions onto persons below.

3. Injury due to long periods

of suspension following fallarrest.

(suspension trauma)

4. Weather, location andenvironmental conditionsduring working at height .

Individual rigging plan to

ensure as much constructionand installation carried out atground level before hoistingtrusses.

All staging equipment andaccess equipment inspected atregular intervals for damage.

Only competent and physicallyfit staff allowed to work at

height.Secondary safety bondingplaced all suspendedequipment.

Persons working at height wearfall arrest harnesses, safetyfootwear (non slip)

No rigging to take place duringinclement weather.

Risk Evaluation

Persons identified as being exposed tothe hazards (incl numbers)

Likelihood Severity Risk Rating

a)

b)

c)

d)

Riggers at height

Riggers atground level

Other trades

performers

No.

1

2

3

4

2

4

2

1

5

5

4

4

10

20

8

4

12

4

24

30

Duration Frequency

a)

b)

c)

d)

2- 4hrs

8 hrs

8 hrs

4 hrs

2x daily

Daily

Daily

Daily



Risk AssessmentRisk Assessment

Action planning to improve risk on this assessment Suggestedimplantation dates

Projected risk score after improvements areimplemented

1. Increased supervision of the ground area belowworking at height positions.

The use of portable light weight barriers and signsto cordon off areas below working at heightpositions

Compulsory wearing of head protection whilstworking at height or at ground level

2. Development of emergency rescue procedures ,trained staff, and supply emergency rescueequipment

Immediate

Immediate

Immediate

Immediate

Likelihood Severity Projected risk rating

1

2

2

2

5

3

10

6

Management Ownership Details

Date of assessment

Signature of Assessor

Signature of Dutyholder

Date

Review date



Guidance for Regulation 4Guidance for Regulation 4

• Assess the risks to decide how to work safelyAssess the risks to decide how to work safely

• Follow the hierarchy for safe working at heightFollow the hierarchy for safe working at height

• Plan and organise the work properly not forgetting toPlan and organise the work properly not forgetting to

taking into account weather and emergency provisionstaking into account weather and emergency provisions

• Competency of those working at heightCompetency of those working at height

• The correct use of work equipmentThe correct use of work equipment

• Manage the risks from working near or on fragileManage the risks from working near or on fragilesurfaces and manage the risk of falling objectssurfaces and manage the risk of falling objects

• Inspect and maintain the work equipment to be usedInspect and maintain the work equipment to be used

and carry out inspections of the place where the work isand carry out inspections of the place where the work is

to be carried out (not forgetting to include access andto be carried out (not forgetting to include access and

egress)egress)



Competence (Reg 5.)Competence (Reg 5.)

Every employer shall ensure that no person engages in any activity including organisation,Every employer shall ensure that no person engages in any activity including organisation,planning and supervision in relation to work at height or work equipment for use inplanning and supervision in relation to work at height or work equipment for use insuch work unless he or she is competent to do so or, if a person is being trained, thatsuch work unless he or she is competent to do so or, if a person is being trained, that

the person receiving the training is supervised by a competent persons.the person receiving the training is supervised by a competent persons.

Guidance (or how the Regulations define competence with regard to WAH)Guidance (or how the Regulations define competence with regard to WAH)

A combination of appropriate, practical and theoretical knowledge, training and A combination of appropriate, practical and theoretical knowledge, training and experience, which collectively should enable a person to:experience, which collectively should enable a person to:

i.i. Undertake safely their specified activity at their level of responsibility;Undertake safely their specified activity at their level of responsibility;

ii.ii. Understand fully any potential risks related to the work activity (tasks and Understand fully any potential risks related to the work activity (tasks and equipment) in which they are engaged; and equipment) in which they are engaged; and

iii.iii. Detect any defects or omissions and recognise any implicationsDetect any defects or omissions and recognise any implications for health for health and and safety with the aim of specifying appropriate remedialsafety with the aim of specifying appropriate remedial actions that may actions that may bebe

required in relation to their particular work activity. This could required in relation to their particular work activity. This could includeinclude refusing torefusing todo a particular task if the potential risk is assessed asdo a particular task if the potential risk is assessed as being toobeing too great.great.



Reg 6.Avoidance of risk from Work at Height

Every employer will need to makesure that any work is not

carried out at height where itis reasonably practicable tocarry out the work safely byother means



Prevention

Where work will have to carried outat height, every employer shalltake suitable and sufficientmeasures to prevent, so far asis reasonably practicable, any

person falling a distance liableto cause personal injury



Mitigate the effects

Every employer shall take suitableand sufficient measures tominimise the distance andconsequences of a fall

At all stages the collective protective measures shouldalways have precedence over personal protectiveequipment

R 7 G l i i l f l ti f k i t



Reg 7.General principles for selection of work equipmentfor working at height

7.2 The employer must select work equipment for work at height which-

a) Has characteristics including dimensions which are appropriate to the nature of the

work to be performed and any foreseeable loadings and allow passage without risk.

b) Is in other respects the most suitable work equipment having regard in particular to thepurposes specified above in the previous regulation (Reg 6)



Reg 8. Requirements for particular work equipment

The employer shall ensure that, in thecase of-

a) Guard rail, toe board, barrier or

similar means of protection –schedule 2 is complied with.

b) A working platform.

3. Part 1 of Schedule 3 is compliedwith.

4. Where scaffolding is provided, part

2 of schedule 3 is also compliedwith

c) A net, airbag or other collectivesafeguard for arresting falls whichis not part of a personal fallprotection system – Schedule 4 iscomplied with;

d) A work positioning system – part 2of schedule 5 is also complied with

c) Rope access and positioningtechniques – part 3 of schedule 5 iscomplied with;

d) Any personal fall protection system– part 4 of schedule 5 is alsocomplied with;

e) A work restraint system – Part 5 of schedule 5 is complied with; and

f) A ladder – Schedule 6 is complied

with.



Guidance on LaddersGuidance on LaddersNo matter what type of ladder – (step, suspended, extension, Zarges, fixed etc.) and

regardless of their use, they will need to meet the requirements of WAHR . Itmust also be remembered that they are classified as work equipment underPUWER 98 and as such must be suitable for the for the task.

A risk assessment will be needed for all ladder work and the assessment should beproportionate to the risk.

Use “Ladders should only be used as work equipment, either for access/egress or asa place from which to to work where a risk assessment shows that the use of

other work equipment is not justified because of the low risk and the shortduration of the job or unalterable features of the site”

Working from a ladder

“ a secure hand hold should be available” means that the user can grasp an upperrung (round) or handrail on the ladder. It does not mean that the user is

expected to be holding the rung or handrail at all times as this would clearlymake it impossible to carry out many tasks for which two hands are needed.



Fragile Surfaces (Reg 9)

The employer must take suitable and sufficient steps to prevent any person at work fallingThe employer must take suitable and sufficient steps to prevent any person at work fallingthrough any fragile surface.through any fragile surface.

And to achieve the requirement of the above paragraph, the employer shall ensure that-- i. No person whilst at work should be allowed to pass across, work on or from, a

fragile surface where it is reasonably practicable to carry out that work safely and under ergonomically acceptable conditions unless there is no other method of doingso safely;

ii. No person whilst at work should be allowed to pass across, work on or from, a fragile surface unless there are suitable and sufficient platforms, coverings or other similar means of supporting the loadings expected for the task are in place;

iii. No person whilst at work should be allowed to pass across or work near to a fragilesurface unless there are provided suitable and sufficient guard rails, coverings or any other methods that would, as far as reasonably practicable, prevent a person falling through the fragile surface; and

iv. Where a person may pass across or work near a fragile surface, prominent warningsigns are, so far as reasonably practicable, fixed to the approach to the area wherethe fragile surface is located.

If, after all the above are implemented, the risk of falling through the fragile surface stillIf, after all the above are implemented, the risk of falling through the fragile surface still

remains, the employer must provide suitable and sufficient means for arresting hisremains, the employer must provide suitable and sufficient means for arresting hisfall, again, so far as is reasonably practicablefall, again, so far as is reasonably practicable..



Falling Objects (Reg 10)Falling Objects (Reg 10)

10-110-1 The employer must take reasonably practicable steps to make suitable andThe employer must take reasonably practicable steps to make suitable and

sufficient arrangements to prevent the fall of any materials or objects.sufficient arrangements to prevent the fall of any materials or objects.

10-2 If it is not reasonably practicable to comply with 10-1 above then the employer10-2 If it is not reasonably practicable to comply with 10-1 above then the employer

will need to take suitable and sufficient steps to prevent any person being struckwill need to take suitable and sufficient steps to prevent any person being struck

materials or objects, which are likely to cause injury.materials or objects, which are likely to cause injury.

10-3 The employer must ensure that no material is tipped or thrown from height if it10-3 The employer must ensure that no material is tipped or thrown from height if itis likely to cause injury.is likely to cause injury.

10-4 And the employer shall ensure that materials and objects are stored in such a10-4 And the employer shall ensure that materials and objects are stored in such a

way as to prevent risk to any person arising out a collapse, overturning orway as to prevent risk to any person arising out a collapse, overturning or

movement of those materials or objects.movement of those materials or objects.



Danger Areas (Reg 11)Danger Areas (Reg 11)

11. The employer must ensure that:11. The employer must ensure that:

• If due to the nature of the work, the workplace contains and areaIf due to the nature of the work, the workplace contains and area

in which there is a risk of any person falling a distance or beingin which there is a risk of any person falling a distance or being

struck by a falling object which is liable to cause injury then thestruck by a falling object which is liable to cause injury then theworkplace is, as far as reasonably practicable, equipped withworkplace is, as far as reasonably practicable, equipped with

devises which will prevent unauthorised access; and devises which will prevent unauthorised access; and

• That this area be clearly indicated.That this area be clearly indicated.



Inspection of Work Equipment (Reg 12)Inspection of Work Equipment (Reg 12)

This regulation will only apply to work equipment to which regulation 8 and schedules 2 and 6This regulation will only apply to work equipment to which regulation 8 and schedules 2 and 6

will applywill apply 12-2 Every employer must ensure that, where the safety of work equipment (including equipment12-2 Every employer must ensure that, where the safety of work equipment (including equipment

to which paragraph 12-3 applies) depends on how it is installed or assembled, it is notto which paragraph 12-3 applies) depends on how it is installed or assembled, it is not

used after installation or assembly in any position unless it has been inspected in thatused after installation or assembly in any position unless it has been inspected in that

position.position.

12-3 Every employer shall ensure that work equipment is inspected:12-3 Every employer shall ensure that work equipment is inspected:

i.i. At suitable intervals; and At suitable intervals; and

ii.ii. Each time that exceptionalEach time that exceptional circumstcircumstance, which are liable to jeopardise the safety of any of are liable to jeopardise the safety of any of the work equipment have occurred.the work equipment have occurred.

12-412-4 If a scaffold is built for whatever purposeIf a scaffold is built for whatever purpose andand aa person could fall more than 2 metres, thenperson could fall more than 2 metres, then

that scaffold must not be used in anythat scaffold must not be used in any positionposition unless the scaffold has been inspected inunless the scaffold has been inspected in

the previous 7 days.the previous 7 days.

12-5 No work equipment: (other than lifting12-5 No work equipment: (other than lifting equipment,equipment, which will have its own requirementwhich will have its own requirement

under Lifting Operations and Liftingunder Lifting Operations and Lifting Equipment RegulationsEquipment Regulations, LOLER), LOLER)

i.i. Leaves the employers undertaking or Leaves the employers undertaking or

ii.ii. If obtained from another undertaking is used in his place of work unless it is accompanied by If obtained from another undertaking is used in his place of work unless it is accompanied by physical evidence that the last inspection required to be carried out under this set of physical evidence that the last inspection required to be carried out under this set of

regulations, has been carried out.regulations, has been carried out.



Inspection of Work Equipment (Reg 12 cont…)Inspection of Work Equipment (Reg 12 cont…)

12-6 The employer shall ensure that the result of an inspection under this set of 12-6 The employer shall ensure that the result of an inspection under this set of Regulations is recorded and kept until the next inspection is carried out.Regulations is recorded and kept until the next inspection is carried out.

12-7 A person carrying out an inspection of work equipment to which paragraph 412-7 A person carrying out an inspection of work equipment to which paragraph 4

applies (scaffolds) shallapplies (scaffolds) shall--

i.i. Before the end of the work period which the inspection is carried out prepare aBefore the end of the work period which the inspection is carried out prepare a

report containing the particulars in schedule 7 ( report containing the particulars in schedule 7 ( see schedule 7 see schedule 7 ))

ii.ii. Within 24 hours of completingWithin 24 hours of completing the inspectionthe inspection, provide a report or a copy , provide a report or a copy

(electronic if wished) to the(electronic if wished) to the person on whose person on whose behalf the inspection has beenbehalf the inspection has been

carried out.carried out.



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

13.13. Every employer shall ensure that the surface and every parapet,Every employer shall ensure that the surface and every parapet,

permanent rail or any other suchpermanent rail or any other such fall protectionfall protection measure of all places of measure of all places of

working at height are inspected on each occasion before the place of working at height are inspected on each occasion before the place of

work is used.work is used.



Duties of personsDuties of persons at work (Reg 14)14)

14-114-1 Every person mustEvery person must report to the persons that areto the persons that are in charge of their work andof their work and

activities, any defects or activityactivities, any defects or activity relatingrelating to work at height, which that personto work at height, which that personknows to endanger the safety of his or herself or the safety of others.knows to endanger the safety of his or herself or the safety of others.

14-2 Every person shall use any work equipment or safety device14-2 Every person shall use any work equipment or safety device provided to him forto him for

working at height by his employer in accordance withworking at height by his employer in accordance with--

i.i. Any training in the use of the work equipment or device that has been received; Any training in the use of the work equipment or device that has been received;

and and

ii.ii. Any instructions regarding the equipment provided by the employer or Any instructions regarding the equipment provided by the employer or supplier of sup plier of

the equipmentthe eq uipment



In summary – The Working at Heights Regulations require

You carry out a risk assessment for ALL work carried out at height and put into placearrangements for:

Eliminating or minimising risks from working at height;

Safe systems of work for organising and performing work at height;

Safe systems for the selecting suitable work equipment; and

Safe systems for protecting people from the consequences of working at height.

That’s what you need to do to comply with the



That s what you need to do to comply with theWorking at Heights Regulations 2004..

AnyAny

Questions?Questions?

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How to comply with the new Working at Height Regulations