Working at Height

Most major incidents and fatalities today are related to working at height, where work is conducted at height without applying the appropriate safeguards. Despite the vast number of regulations, standards, and guidelines, incidents continue to occur.

The information contained in this article is based on a review of technical knowledge, experience, and notable practices from oil and gas industries. It is important for all organisations to establish a standard to ensure nobody falls and hopefully bring about a significant reduction in the number of work at height related injuries.

Many organisations have achieved this already, through:

• The establishment of minimum expectations on safe behaviours and practices
• Increasing awareness of WAH hazards and control measures
• Implementing safety systems with adequate controls and/or checks and balances
• Utilising adequate controls to verify that the expected behaviours, practices, and systems are followed

All company workers working in elevated areas where the risk of injury from falls exists are considered to be working at height. According to the latest statistics from the UK’s Health and Safety Executive (HSE), working at height was the most frequent cause of fatal accidents to workers in 2017, and accounted for 28% of all total workplace injuries. This research also revealed, however, that there were 43,000 nonfatal accidents involving falls from height across all industries. Also, over 60% of deaths during work at height were found to involve falls from ladders, scaffolds, work platforms and roof edges, and through fragile roofs etc. The major causes of this type of accident involving working at height include the incorrect use of ladders and stepladders, overstretching from ladders, and standing on benches or chairs to reach high surfaces. Work at height accidents could also involve equipment such as mobile elevated work platforms (MEWP) and suspended access equipment such as window cleaning cradles.

The question to ask is how could a business keep its workers safe, and stay compliant with its legal and regulatory obligations? Employers should use a good safety management system to identify work at height tasks and put in place measures to prevent falls before work at height starts. Work at height also encompasses the risk of falls from low heights where a person could be injured, as well as the more obvious risk of falling from elevated heights.

Some of the common areas of concern for work at heights include working:

• On fragile roofs such as asbestos cement roofs without precautions or proper means of access, which can lead to serious and fatal accidents
• Outside of approved scaffolding (the individual’s centre of gravity could potentially extend beyond the vertical plane of a properly constructed safety barrier or guardrail); on any type of suspended scaffolding; when erecting, dismantling, or repairing scaffolding
• At heights greater than 1.8m/6ft above the surrounding ground or work surface when no guardrails exist; when in proximity to the edge of elevated floors, floor openings, or roofs (greater than 1.8m/6ft) with no guardrails or wire rope railing
• On all scaffolds with incomplete decking or an incomplete guardrail
• When removing floor planks, hole covers, grating, etc.; on roofs with slopes steeper than 20%
• Riding in or working from spiders and sky-climbers; in areas exposed to impaling hazards where the potential for injury exists by falling on them, even when the height is less than 1.8m/6ft
• From or travelling in powered work platforms or personnel lifting/hoisting devices (personnel transfer baskets such as Billy Pugh’s are excluded)

“when it’s impossible to eliminate risk, you have to take steps to minimise the distance and consequences of any potential fall”

As a worker, protecting yourself from the risk of falling from height is very important, and you should know the risks in your workplace. When the risk is unavoidable, the safety hazards in your work area should always be considered in the selection of equipment. This would assist both employers and employees in selecting the right equipment required to work at height.

Philosophy and standard

In the working from height guidance, the Health and Safety Executive (HSE) details simple steps to minimise the risk. Aside from the most obvious, which is to avoid work at height altogether when possible, the guidance states that workplaces should ensure:

• Usage of the right type of equipment and ensure that it is stable, strong enough for the job and maintained correctly
• That as always workers can get to their position of work safely
• You don’t overload or over reach when working at height
• Precautions are taken when working on or near fragile surfaces
• Provision of protection from falling objects
• Preparation and knowledge of the emergency evacuation and rescue procedures

The regulations

The Work at Height Regulations 2005 contain a set of rules that must be followed when any work is undertaken at a height, with the aim of preventing deaths and injuries. These are mandatory for all employers and people who control work at height, and are enforceable by law. There is also provision within the rules that sets out responsibilities that employees must know. The regulations define work at height as any task where there is a risk of staff falling from one level to another. This includes work above the ground or floor, near an edge where someone could fall through an opening or surface, and at ground level where someone could fall through an opening. According to the Health and Safety at Work Act 1974 (HSW Act), its required that employers ensure the health, safety and welfare of their employees and ensure that people that could be affected by activities are not exposed to risk, so far as is reasonably practicable. Also, the Work at Height Regulations 2005 require that employers and those in control of any work at height activity ensure that the work is properly planned, well supervised and carried out by competent people.

How to comply

There are a number of things that would need to be done to ensure full compliance with the regulations as an employer or controller of work at height. The first thing is to ensure hierarchy is set up and followed. This involves, if at all possible, avoiding any work at height altogether. When work at height is unavoidable, however, you need to do everything reasonably expected to eliminate the risks to employees. When it’s impossible to eliminate risk, you have to take steps to minimise the distance and consequences of any potential fall. However, employers must ensure roles and responsibilities are clear and well understood when work at height must take place.

Below are some of the basic facts to consider as employers and controllers of work at heights:

1. Undertake a risk assessment – This will help to identify any hazards and those that may be affected, level of risk to be assessed and suitable precautions. This could be done as part of a wider risk assessment or as a one-off for a specific task. The findings shall be recorded and shared amongst employees.
2. Manage any risks identified – Measures must be put in place to eliminate or reduce the risks identified and specified into actions that need to be closed out.
3. Ensure that any staff undertaking work at height are competent – Competent persons must be used all the time. A ‘competent’ person is someone who has the skills, knowledge and experience to safely complete the task.
4. Ensure work at height is planned – Planning is very essential and would need to plan all aspects of any job at height, making considerations for factors like weather, management of tools and materials, and safety of workspaces, as well as procedures for rescue or emergencies.
5. Provide appropriate equipment and ensure it is used – Proper safety equipment is essential for managing risk and it is important to choose the best option for the job. Collective protection that guards everyone, such as a guard rail, should be prioritised.
6. Inspect and maintain protective equipment – Employers have a responsibility to inspect and maintain equipment to make sure that it’s always up to the job of protecting employees. Be sure to follow any manufacturer instructions and get a competent person to inspect gear when it is first installed or subjected to something that might cause a defect.

How bad could it be?

So, just how bad could it be? Well, since injuries incurred through falls from height vary vastly in severity, that depends greatly on the individual circumstances of each fall. Given the fragile nature of the human body compared with, for example, the unforgiving rigidity of concrete, it’s no surprise that fatalities occur. According to the HSE, in 2016 to 2017 there were 137 workers killed at work, and an estimated 609,000 workers suffered non-fatal injuries as a result of work at height activity.

All this resulted in around 5.5 million working days lost. Specifically, a high potential near-miss occurred in my workplace where two masonry contractors were positioned on a scaffold erecting a block wall. One of them was observed on an unguarded portion of the scaffold wearing a fall arrest harness and self-retracting lanyard, but the lanyard was not attached to an anchor point – leaving him exposed to a fall of approximately eight feet. The individual stated that he had just ventured out onto the unguarded platform and had simply forgotten to attach his lanyard to an anchor point. The below graph shows the range of fall from height incidents in comparison with other occurring incidents.

Safety precautions

Some important steps identified below would be required by the employers to ensure safe practices of working at height.

Proper planning

The law requires employers of any work at height activity to take into account the risk assessment when organising and planning work. This is how the precautions required can be identified and work carried out with optimum safety. The HSE provides clear advice that working at height should be avoided altogether whenever it is possible to do so. Yet since that would entail using some other alternative methods available, let’s consider those for a moment. The best option would be to use an existing place of work that is safe, but on occasions where working at height is unavoidable, employers must make sure that the people doing the work are trained and very competent, and that the equipment provided is suitable for the type of activity, is properly maintained and will be correctly used.

Where the equipment being used involves a risk of falling, additional measures must be adopted to minimise the distance and consequences of any fall to prevent any person falling with potential to cause personal injury; for example, by using a scaffold platform with double guard-rail and toeboards. It is very important to arrest a fall with available equipment to minimise the consequences of a fall. The options available include the use of safety nets, particularly in areas where work at height cannot be avoided or the risk of falling could be prevented. Something to always remember is that whenever work at height accidents are investigated and employers are prosecuted, one of the most common findings is that the work was not properly planned and supervised. The guiding principle is to prevent the potential for a fall rather than protecting against the consequences of a fall.

When possible, remove or significantly reduce the amount of work requiring working at height. Plan and confirm all feasible measures are taken to prevent workers falling while working at heights. During the job planning phase of the project, the priority order for selecting the preferred method of working at heights should be discussed. When working at heights is unavoidable, design should include safety considerations and input from constructability reviews to facilitate ease of use for scaffolding, fall protection, life lines, hole covers, stationary ladders, and rescue procedures.

Training

All persons involved in planning/ performing work at heights must be trained and competent for their role to be performed. Proper equipment selection and equipment limitations must be understood to the extent required to perform their role. The contractor must keep records for their personnel which contain the identity of personnel receiving training, the date of training and the type of training. Further to this, employers must confirm that personnel under its supervision have received the necessary training to work at heights.

Competency of personnel must be verified. Company employees required to work at heights must be able to recognise potential working at heights hazards and have completed the necessary training to enable them to select the appropriate type of safety equipment and/or PPE to mitigate these hazards.

In addition, overview training must be given to all workers whose job duties potentially involve working at heights for overall awareness of the hazards related to working at heights. Comprehensive training must be given to workers working at heights where tie-off is required (basket, scaffolding, mobile platform, ladders, PPE, etc). Employees and contractor personnel required to work at heights must be trained in the proper selection and use of fall protection equipment.

Equipment

Equipment should be selected based on the guiding principle of preventing the potential for a fall, rather than protecting against the consequences. It is important to ensure that equipment used is fit for purpose and used properly. Scaffolds and scaffold alternatives must be constructed and operated, if applicable, by a competent person.

It’s essential to confirm proper fit of PPE and consider physical comfort in the equipment’s selection. After all, if it’s uncomfortable the likelihood of its being used will drop off significantly. All scaffolds, ladders, PPE and/or other WAH equipment must be inspected by a competent person(s) before use and periodically thereafter. WAH equipment not meeting manufacturer’s specifications must be removed from service. Furthermore, proper maintenance must be performed to confirm effectiveness and integrity. Maintenance should include inspection, care, cleaning, repair, and proper storage of equipment. Some of the important equipment required is highlighted in the following sections.

Full body harness

The maximum weight for a person to use the prescribed full body harness must be defined based on vendor specification. The full body harness must not be used if showing signs of damage or excessive wear. The full body harness must be properly inspected before each use and determined to be in good repair (e.g., check the buckles, straps, D-rings, and manufacturers label for more information). The full body harness must have a back mounted D-ring located between the shoulder blades. The full body harness straps must be adjusted so they are tight but comfortable. Personnel must not work alone when working at heights. Fall protection equipment must be retired from service after a shock load/fall.

Lanyards and fall arrestors

The lanyard or fall arrestor (plus shock absorber, if required) must allow for a safe free fall distance and 100% tie-off.

If work activities require personnel to move beyond the reach of one lanyard while working at heights, a double lanyard must be used, so for example, scaffold builders should always have double lanyards. Whenever changing anchor points, one lanyard must remain tied off to a secure anchor point at all times. With one lanyard attached, place the body in a stable position and attach the second lanyard before unclipping the first. It is not advisable to over stretch or become unbalanced while doing this. The lanyard or fall arrestor should be secured above the person to prevent dangling. When not transitioning while using a “U” lanyard (two independent parallel lanyards), only one lanyard should be secured at any time to ensure proper functioning of the restraint device or devices. The lanyard or fall arrestor should be provided with a double locking snap hook.

One of the following options must be used for fall restraint in conjunction with a full body harness for different applications of fall protection:

• “U” lanyard – Two independent parallel lanyards, each with a shock absorber
• “Y” lanyard – One twin tail “Y” lanyard with shock absorber and recommended break-away lanyard keeper

The diagram below calculates potential fall distance using a full body harness with a traditional shock absorbing lanyard.

“when it is not practical to eliminate the exposure, sufficient safeguards and controls must be put in place”

Anchor points and lifelines

When considering anchor points and lifelines, the layout in plan and elevation, including anchor locations, installation specifications, anchor point design, and detailing must be considered. Anchor points for collective and personal fall protection should be sufficiently strong with a minimum capability of supporting a 5,400 lb (that’s 2,450 kg) impact load, unless country-specific regulations are more stringent. The anchor point for fall protection should be located as high as is practicable, and if at all possible should be located above the person. Tie-off points must have sufficient height so that if a fall is initiated, a safe free fall distance is available. Note that, as an example, a 1.8m/6ft fixed length shock absorbing lanyard will require a minimum fall distance of 5.6m/18.5ft.

Lifeline systems are points of attachment for fall protection lanyards and may be mounted either vertically or horizontally. They are generally intended to provide mobility to personnel working elevated areas. Horizontal steel anchor cables should be engineered for the applicable forces.

A lifeline system should give special considerations to: safe free fall distance, clearance to obstructions below, elevation above the walking surface, wire rope size, system breaking strength, termination details, initial sag or tension, the number of people permitted to connect to the lifeline, maximum arrest force to each person, total lifeline length, number of intermediate supports, and the type of deceleration device used.

Conclusion

When it is not practical to eliminate the exposure, sufficient safeguards and controls must be put in place to manage the risk with a high level of confidence that, should a fall occur, the outcome will not result in a significant injury. A very important precaution to always take is to use approved equipment. It is expected that personnel working at height will wear a full body harness with 100% tie-off.