Working at Height

Working at height is defined by the International Labour Organization (ILO) as working in any place where, if precautions are not taken, a person could fall a distance liable to cause personal injury.

It remains one of the biggest causes of fatalities and injuries globally.¹

Examples of working at height include:

• Work above ground / floor level
• Work where the individual could fall from an edge, through an opening or fragile surface
• Work where the individual could fall from ground level into an opening in the floor (a hole in the ground) IOSH

It is important to note that working at height does not include a slip or trip on a level surface, as a fall from height has to involve falling from one level to a lower level. Equally, walking up and down a permanent staircase in a building does not constitute working at height.

Ever-present danger

Given the recent investment and construction activities in the Middle East, working at height is a key part of many roles and sectors in the UAE and GCC region. In Abu Dhabi, falls from height and falling objects are the leading cause of fatal injuries on worksites, responsible for almost 50 per cent of fatal injuries² .

It is easy to think that this is only a risk on construction sites, but the danger is also present in the agricultural, industrial and commercial sectors, meaning working at height is an everyday reality for many. However, in this article we will focus on the risks in the construction industry.

With so much new development in the region, the risks of falls from height are ever-present and must be taken account of. A great example of the large-scale construction activity which is taking place, is the development in the Kingdom of Saudi Arabia of Jubail II Industrial Area – the world’s largest civil engineering project.

What the law says

In the Middle East, occupational health and safety is regulated through the use of various codes of practice, standards, municipal regulations and technical guidelines. Abu Dhabi EHS Centre, for example, has published a specific regulation on working at height: the Abu Dhabi Environment, Health and Safety Management System (ADEHSMS) Code of Practice number 233 , which has jurisdiction within the Abu Dhabi Emirate. Other jurisdictions will have similar laws and will often adopt existing industry guidance. For example, the ILO guidance has a direct read though to best practice guidance from the United Kingdom’s (UK) Health and Safety Executive (HSE).⁴

So, there is agreement that when considering working at height, there are three simple rules to follow:

1. Avoid – If you do not need to work at height, then don’t.
2. Prevent – If work at height cannot be avoided, then prevent falls by selecting and using the right access equipment.
3. Minimise – Where you cannot eliminate the risk of a fall, use work equipment or other means to lessen the distance and consequences of a fall.

Selecting equipment

If working at height is unavoidable, there are mitigation measures to consider. When selecting these, collective measures should be selected if possible before personal protection measures.

When selecting equipment for work at height, employers must:

• Provide the most suitable equipment appropriate for the work
• Take account of factors, such as: the working conditions (e.g. weather), the nature, frequency and duration of the work, and the risks to the safety of everyone where the work equipment will be used

Some of the options are outlined in the following sections: mobile elevating working platforms, scaffolding, rope access, fall arrest, restraint or protection, and ladders.

Mobile elevating working platforms (MEWPs)

It is worth noting that the most significant MEWP dangers arise from the operation and use of the machine rather than from their movement as a site vehicle.

Most fatal and serious injuries involving MEWPs arise from:

• Entrapment – there is a risk of operators becoming trapped between part of the basket and fixed structures or becoming trapped against the platform controls. In the latter case, they may not be able to stop the machine from running
• Overturning – this could cause the operator to be thrown from the basket
• Falling – the operator could fall from the basket during their work activities
• Collision – which could occur with pedestrians, overhead cables or nearby vehicles.

When selecting MEWPs as a method for working at height, you should ensure that a risk assessment and suitable control measures are put in place.

These control measures include:

• Selecting a MEWP which has been designed to prevent accidental contact with overhead structures and ensuring that operators are briefed on the dangers and the safe system of work which they are to follow
• Selecting a MEWP which has shrouding or other protection around the controls
• Making sure the platform is kept tidy to reduce the risk of the operator tripping or losing balance
• Ensuring that the MEWP is used on firm and level ground and avoiding certain ground features such as trenches, manholes and un-compacted backfill, which can lead to the MEWP overturning
• The use of outriggers that are extended and choked before raising the platform
• Ensuring that effective guardrails and toeboards are fitted to the work platform
• The use of fall arrest systems – if there is still a risk of people falling from the platform, a harness with a short work restraint lanyard must be secured to a suitable manufacturer provided anchorage point within the basket to stop the wearer from getting into a position where they could fall from the basket
• Making sure the area around the platform has barriers to prevent people from being struck by falling objects
• Keeping an eye on the weather – high winds can tilt platforms and make them unstable and storms and snowfall can also damage the platform – you should make sure you inspect the platform before use following severe weather conditions
• Checking the weight and dimensions of any materials that you are using the MEWP to install – consider using additional lifting equipment to transport materials to the work position if they would pose a risk to the safe operation of the MEWP
• Considering what is happening in the vicinity of the work operation area – think about overhead cables, other dangerous machinery and traffic routes

You should also ensure that MEWP operators have attended a recognised operator training course and can demonstrate this with a certificate, card or licence. Additionally, you should make sure that the operator is familiar with the controls and operation of the specific MEWP they will be using.

Finally, you should ensure that daily visual checks, regular inspections and servicing schedules are established in line with the manufacturers’ instructions. These examinations should include, as a minimum, a six-monthly inspection by a competent person or in line with an examination scheme which has been written by a competent person.

A good place for recognised industry guidance on MEWPs is the International Powered Access Federation, who offer training and guidance on their correct use.⁵

Scaffolding

Correctly-installed scaffolding provides one of the best solutions where long duration works need to be undertaken. It is worth remembering that it is often not cost effective to put permanent access in place when you only need low frequency access. Any permanently[¹]installed access will need regular inspection. It is more cost effective to install what is needed when it is needed.

With modern designed and system scaffolds, the available configurations and loadings can surprise many with their flexibility.

It is worth remembering that scaffolds can be suspended to allow access below as well as above.

Industry best practice in the UK is driven by the National Access & Scaffolding Confederation⁶ or Prefabricated Access Suppliers and Manufacturers Association⁷ . This provides a good repository for any scaffolding guidance.

Rope access

Rope access techniques have been developed to the point where it is now a chosen means of access for much of the work in the offshore oil and gas industry as well as in construction, civil engineering and the built and natural environment.

In Europe, for example, Article 4.1.3. of Directive 2001/45/ EC8 notes that “Rope access and positioning techniques may be used only under circumstances where the risk assessment indicates that the work can be performed safely and where the use of other, safer work equipment is not justified.”

This is a key consideration when considering how maintenance will be completed in the future. It is not good enough to design a structure and let the maintenance engineers of the future work it out. However, as rope access became a more popular solution, IRATA (Industrial Rope Access Trade Association) International9 was created in 1987 as it was recognised that the legislation at the time did not cover rope access techniques.

Since then, IRATA has worked with the UK HSE to formulate working philosophies for regulated rope access. It has developed three broad schemes to regulate and control related safety issues. These are described below.

International code of practice – all technicians working in the industry are required to be trained and assessed in accordance with the IRATA International Training, Assessment and Certification Scheme.

Membership audit – all companies wishing to become members if IRATA must be audited by the association to confirm they are working to the guidelines. These audits look at all aspects of rope access management including technical and quality assurance.

Training and certification – all technicians working within the industry are required to be trained and assessed in accordance with the IRATA training, assessment and certification scheme. Individuals who have successfully completed the relevant training and assessment are issued with a logbook and identification card.

Fall arrest, restraint or protection?

Different equipment is available for each of these three. Fall protection is where a person is prevented from falling in the first place, for example by a guardrail. Fall restraint allows the person to move freely, but not far enough to fall – known as a ‘Mansafe’ system. Fall arrest involves the safe stopping of a person already falling, using eyebolts and appropriate cables, and is the technique of last resort.

When should I use a ladder?

Ladders should only be used for working at height where the requirement of the activity is both low risk and of short duration, or where there are existing workplace features that cannot be altered which require the use of a ladder. As a guide, if the task being undertaken would require the individual staying on a leaning ladder or stepladder for more than 30 minutes at a time, it is recommended that you consider alternative equipment.

You should only use ladders in situations where they can be used safely. For example, where the ladder will be level and stable and, where its reasonably practicable to do so, the ladder can be secured.

If you do have a frequent need for ladders, consider the industry guidance and training developed by The Ladder Association.¹⁰

As above so below

As we know from the HSE’s definition of a fall from height, you do not need to be above ground level to fall from a height. The risk of falling from ground level into an opening in the floor or a whole in the ground is also considered as working at height. In these circumstances, there are also other risks which must be taken into consideration, such as confined spaces.

Imagine having to consider all the issues of working at height while at the same time having to wear breathing apparatus and working in confined spaces.

The safe supply chain

When considering any activity which results in working from height you should ensure that you consider the whole supply chain to ensure you minimise the associated risks. What is the overall purpose of the buildings being constructed? Have the designers designed out risk as far as they can? What products are you sourcing and is there a safer product or tool on the market? How is the construction happening, and what can you do to ensure that safe practices are being followed? Finally, consider the end users; if you can prevent them having to access items at height when maintaining a building then the risk is either eliminated or reduced.

Determining competence is a key part of the safety supply chain.

You should consider the individual: do they have sufficient skills, knowledge and experience to perform the task? If they are being trained, you should ensure that they are being supervised by a competent individual.

Identifying competence will vary depending on the level of risk and duration of the work being undertaken. For example, low risk, short duration tasks involving ladders may simply require ensuring employees receive instruction on how to use the equipment safely. For example, how to tie a ladder properly, and that they have the appropriate training. When a more technical level of competence is required, such as drawing up a plan for assembling a complex scaffold, existing training and certification schemes drawn up by trade associations and industry is one way to help demonstrate competence.

This list is not exhaustive nor definitive, but qualifications you should look for in checking if someone is competent to work where there is a risk of falling are:

• International Powered Access Federation
• The Ladder Association
• Prefabricated Access Suppliers and Manufacturers Association
• National Access & Scaffolding Confederation
• Industrial Rope Access Trade Association International

And finally

It’s not just you that could fall…

Whilst we are predominantly talking about individuals falling from height in this article, it is worth remembering that if there is a risk of an individual falling, there is also a risk of other items falling and striking those below.

Some simple rules to prevent that sudden stop at the end are:

• Follow the hierarchy of control measures: avoid the need to work at height, for example by using extending equipment from the ground or remote inspection vehicles; prevent falls using appropriate access equipment such as work platforms, secondary grills under access chamber covers, or rope access techniques; reduce the distance and consequences of a fall should one occur
• Do your risk assessment
• Select the right equipment for the job and ensure you inspect it before use • Make sure the person has received and understood the training they need, i.e. they are competent

The key take away from all of this is that you need to consider the people, the process and the purpose when any activity you carry out involves working from height in order to keep everyone safe.

References 1 www.ilo.org/global/topics/labouradministration-inspection/resourceslibrary/publications/guide-for-labourinspectors/working-at-height/lang– en/index.htm 2 www.doh.gov.ae/news/falls-fromheight-and-falling-objects 3 www.oshad.ae/en/Pages/Code-OfPractice.aspx 4 www.hse.gov.uk/work-at-height/ 5 www.ipaf.org 6 nasc.org.uk 7 pasma.co.uk 8 op.europa.eu/en/publication-detail/-/ publication/c4e26d24-8bd3-4d15- 8204-3cbfe43fa32c/language-en/ format-PDF 9 irata.org 10 ladderassociation.org.uk