CORPORATE HEALTH AND SAFETY POLICY:

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1 CORPORATE HEALTH AND SAFETY POLICY: Part 3 Arrangements Working at Height Ref: WAH/V01/2014 EALING COUNCIL

2 Table of Contents 1. Introduction Legal Context Glossary Who is and is not affected by the Arrangement Responsibilities Managing and Controlling Risk Information and contacts Appendix 1 Ladder checklist Author: Chris Stacey Job Title: QSHE Manager staceyc@ealing.gov.uk Date of Issue: July 2014 Review Date: July 2016 Amendments Number Description Date W o r k i n g a t H e i g h t - J u l y Page 2

3 1. Introduction The objective of these arrangements is to provide managers and staff with sufficient information and guidance to enable safe management of all activities involving working at height. 2. Legal Context Employers have a duty to safeguard the health and safety of their employees under Section 2 of the Health and Safety at Work etc. Act 1974 (HASWA) and assess the risks arising out of their work activities and working environment under regulation 3 of the Management of Health and Safety at Work Regulations Section 3 of the HASWA places general duties on employers towards people other than their employees. The Work at Height Regulations 2005 (WAH) place strict duties on employers to prevent death and injury caused by falls from height. Failure to comply with the legislation detailed in the paragraphs above renders Ealing Council liable to criminal prosecution and unlimited fines in certain circumstances. 3. Glossary Fragile Surface Means a surface which would be liable to fail if any reasonably foreseeable loading were applied to it Ladder: Includes a fixed ladder and a step ladder Line: Includes rope, chain or webbing Personal fall protection system means: a) A fall prevention, work restraint, work positioning, fall arrest or rescue system, other than a system in which the only safeguards are collective safeguards b) Rope access and positioning techniques Work at height means: a) Work in any place, including a place at or below ground level; b) Obtaining access to or egress from such place while at work, except by a staircase in a permanent workplace, W o r k i n g a t H e i g h t - J u l y Page 3

4 Where, if measures required by these regulations were not taken, a person could fall a distance liable to cause personal injury. Working platform a) Means any platform used as a place of work or as a means of access to or egress from a place of work; b) Includes any scaffold, suspended scaffold, cradle, mobile platform, trestle, gangway, gantry and stairway which is so used. 4. Who is and is not affected by the Arrangement This Arrangement applies to the following groups of staff: All Employees of Ealing Council All Maintained schools in Ealing i.e. (Community, Community special, Voluntary- Controlled, Maintained Nursery Schools and Pupil Referral Units/Study Centres.) These arrangements do not apply to, but may be adopted by; Voluntary-Aided and Foundation Schools. For services procured from external sources, the supplier should ensure all staff members while working for the council adhere to relevant health and safety legislation. Ealing staff who procure any contracts must monitor this. 5. Responsibilities The responsibilities of key individuals throughout the council for managing the risk from working at height are detailed below. Chief Executive The Chief Executive has overall responsibility for health and safety throughout the organisation. Executive Directors The Executive Directors are primarily responsible to the chief executive for the implementation and effective management of the council s health and safety policy. They are responsible for delegating specific health and safety roles and responsibilities to nominated officers within subordinate management levels. The implementation of these arrangements is monitored and reviewed every two years to ensure working arrangements and provision of financial, technical, human and other resources are suitable and sufficient to meet its requirement Director Level Managers and Head teachers of Community Schools Each Director Level Manager is responsible for the effective management of health and safety within their area or function, and for those specific responsibilities assigned. This level of responsibility includes head teachers of community schools W o r k i n g a t H e i g h t - J u l y Page 4

5 where the council is the employer and remains principally responsible for health and safety at work of all employees and others (including pupils) Director level management are considered responsible persons for ensuring all operations within their responsibility undertake the day to day management of risks from work at height and have in place arrangements to ensure: o Any work at height activity is properly planned, supervised and carried out by competent persons. This includes using the right type of equipment for working at height. o A programme of assessment from the risks of working at height is in place. Where there is more than one director/manager at this level in a single premise, for example, Perceval House, then the responsibility for ensuring a work at height risk assessment is in place, is that of the director of the premises manager. General Level Management Responsibilities This level of responsibility will include: Service heads, managers, supervisors and team leaders, who will have defined health and safety responsibilities for work activities, must ensure: All equipment used within their area of responsibility complies with the Supply of Machinery (Safety) Regulations 2008 and the Provision and Use of Work Equipment Regulations 1998, and where applicable the Lifting Operations and Lifting Equipment Regulations Control of risk from work at height by: o Avoiding work at height where it is reasonably practicable to do so o Where work at height cannot be avoided, prevent fall using either an existing place of work that is already safe or the right type of equipment o Minimise the distance and consequences of a fall, by using the right type of equipment where the risk cannot be eliminated. Based on the findings of the risk assessment ensure any work at height is properly planned, supervised and carried out by competent persons. Contractors Contractors employed by or working in partnership with the council have a similar responsibility to their employees and must demonstrate compliance with the Work at Height Regulations 2005 Ealing staff that are responsible for procuring contractors must ensure control of risk from work at height is considered in the procurement process. Ealing staff that manage contracts must ensure control of risks from work at height is monitored. W o r k i n g a t H e i g h t - J u l y Page 5

6 Corporate Health and Safety The Corporate Health and Safety Team provide advice, training, support and monitoring arrangements as appropriate. 6. Managing and Controlling Risk When planning to conduct any work at height managers should take a sensible, pragmatic approach when considering what precautions they should put in place. Factors need to be taken into consideration include: The height of the task The duration and frequency Condition of the surface being worked upon There will be occasions where certain low-risk situations require no particular precautions. The following are all requirements in law that need to consider when planning and undertaking work at height. Take account of weather conditions that could compromise worker safety Check the place (e.g. a roof) where work at height is to be undertaken is safe. Each place where people will work at height needs to be checked every time, before use Stop materials or objects from falling or, if it is not reasonably practicable to prevent objects falling, take suitable and sufficient measures to make sure no one can be injured, e.g. use exclusion zones to keep people away or mesh on scaffold to stop materials such as bricks falling off Store materials and objects safely so they will not cause injury if they are disturbed or collapse. Plan for emergencies and rescue, e.g. agree a set procedure for evacuation. Think about foreseeable situations and make sure employees know the emergency procedures. Do not just rely entirely on the emergency services for rescue in your plan. Ensuring Competence Managers must ensure people have sufficient skills, knowledge and experience to perform the task, or, if being trained they work under the supervision of somebody competent to do it. Where the task requires a more technical level of competence then training and certification schemes drawn up by trade associations and industry is one way of demonstrating competence. For example: National Federation of Roofing Contractors (NFRC) Flat Roof Alliance (FRA) Rural and Industrial Design and Building Association (RIDBA) W o r k i n g a t H e i g h t - J u l y Page 6

7 Industrial Rope Access Trade Association (IRATA) Prefabricated Access Suppliers' and Manufacturers' Association Ltd (PASMA) National Access and Scaffolding Confederation (NASC) International Powered Access Federation (IPAF). Method Statements A competent person should prepare a safety method statement before work at height starts. It needs to be appropriate to the scale and complexity of the work. In all cases, it should make sure risks are recognised and assessed, and the appropriate control measures specified. It should identify working positions, access routes to and on the place at height, and show: How falls are to be prevented, or where this is not possible, minimised How danger to those at work below, and to the public, from falling materials is to be controlled How risks to health will be controlled How other risks identified at planning and survey stages are to be controlled, what equipment will be needed What competence and/or training is needed Who will supervise the job on site How changes in the work will be dealt with without affecting safe working Who will check the system is effectively controlling risk. Safety method statements should be clear and illustrated by simple sketches where necessary. There should be no ambiguities or generalisations, which could lead to confusion. They should be produced for the benefit of those carrying out the work and their immediate supervisors and not be over complicated. Equipment needed for safe working should be clearly identified and available before work starts. Workers should know what to do if the work method needs to be changed. This should then avoid ad hoc methods of work on site and the use of improvised equipment, which can often lead to accidents. Protection Methods Always consider measures that protect everyone who is at risk (collective protection) before measures that protect only the individual (personal protection). Collective protection is equipment that does not require the person working at height to act to be effective, for example a permanent or temporary guard rail. Personal protection is equipment that requires the individual to act to be effective. An example is putting on a safety harness correctly and connecting it, via an energyabsorbing lanyard, to a suitable anchor point. Common causes of accidents when working at height Roof work is high risk and falls from roofs, through fragile roofs and fragile roof lights are one of the most common causes of workplace death and serious injury. As well as in construction, these accidents can also occur on roofs of factories, warehouses and buildings when roof repair work or cleaning is being carried out. W o r k i n g a t H e i g h t - J u l y Page 7

8 The following surfaces are likely to be fragile: Roof lights Liner panels on built-up sheeted roofs Non-reinforced fibre cement sheets Corroded metal sheets Glass (including wired glass) Rotted chipboard Slates and tiles. Planning for emergencies Regulation 5 of the WAH regulations requires planning for emergencies and rescue. It is natural to assume once a fall has been arrested then the fall protection system has successfully completed its job. Unfortunately, this is not the case. An operative suspended in an upright position with the legs dangling in a harness of any type is subject to suspension trauma and orthostatic intolerance. Rescue must come rapidly to minimise the dangers of suspension trauma. The circumstances together with the lanyard attachment point will determine the possibility of self-rescue. In situations where self-rescue is not possible, operatives must be supervised at all times. Regardless of whether an operative can self-rescue or must rely on others, time is of the essence because an operative may lose consciousness in only a few minutes. For conscious casualties it is recommended (where possible) the suspended person keep their legs moving to keep the blood pumping and reduce the risk of venous pooling. Rescue plans do not have to be complex, but should include procedures for: Preventing prolonged suspension Performing rescue and treatment as quickly as possible Identifying orthostatic intolerance signs and symptoms. Management's reasonability for safety needs to give careful consideration to the methodology of rescuing a fallen operative. Further advice on rescue plans and procedures is available from the Corporate Health and Safety Team Selecting the right equipment When selecting equipment for work at height, you 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 The risks to the safety of everyone where the work equipment will be used. If you are still unsure which type of equipment to use, once you have considered the risks, the Work at height Access equipment Information Toolkit (or WAIT) is a free online resource that offers possible solutions. It provides details of common types of equipment used for work at height. Make sure the equipment itself is in good condition W o r k i n g a t H e i g h t - J u l y Page 8

9 Work equipment, for example scaffolding, needs to be assembled or installed according to the manufacturer s instructions and in keeping with industry guidelines. Where the safety of the work equipment depends on how it has been installed or assembled, you should ensure it is not used until it has been inspected in that position by a competent person. A competent person is someone who has the necessary skills, experience and knowledge to manage health and safety. Any equipment exposed to conditions that may cause it to deteriorate, and result in a dangerous situation, should be inspected at suitable intervals appropriate to the environment and use. Do an inspection every time something happens that may affect the safety or stability of the equipment, e.g. adverse weather, accidental damage. You are required to keep a record of any inspection for types of work equipment including: guard rails, toe-boards, barriers or similar collective means of protection; working platforms (any platform used as a place of work or as a means of getting to and from work, e.g. a gangway) that are fixed (e.g. a scaffold around a building) or mobile (e.g. a mobile elevated working platform (MEWP) or scaffold tower); or a ladder. For as example ladder checklist see Appendix 1) Any working platform used for construction work and from which a person could fall more than 2 metres must be inspected: After assembly in any position After any event liable to have affected its stability At intervals not exceeding seven days. Where it is a mobile platform, a new inspection and report is not required every time it is moved to a new location on the same site. You must also ensure before you use any equipment, such as a MEWP, which has come from another business or rental company, it is accompanied by an indication (clear to everyone involved) when the last thorough examination has been carried out. W o r k i n g a t H e i g h t - J u l y Page 9

10 7. Information and contacts Health and Safety Executive Corporate Health and Safety London Borough of Ealing Perceval House Uxbridge Road Ealing W5 2HL Work at height regulations 2005 Health and safety in roof work HSG33 Inspecting fall arrest equipment made from webbing or rope INDG367 Working at height INDG401 Safe use of ladders and stepladders INDG455 Safety in window cleaning using rope access techniques MISC612 W o r k i n g a t H e i g h t - J u l y Page 10

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