Products, training and operational support services for professional work at height and rescue

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1 In what legislation, ACoP, Guidance, etc. is the distinction made between the requirement for two ropes in a planned rescue and one rope for unplanned rescue? Answer: Work at Height Regulations 2005 (WAHR) 1. The WAHR 1 (Reg. 4, Organisation and planning) require that: Every employer shall ensure that work at height is (a) properly planned; (b) appropriately supervised; and (c) carried out in a manner which is so far as is reasonably practicable safe 2. Reference to planning of work includes planning for emergencies and rescue (Reg. 4(2)). 3. Also, every employer (Reg. 4(3)): shall ensure that work at height is carried out only when the weather conditions do not jeopardise the health or safety of persons involved in the work 4. This (Reg. 4(4)): shall not apply where members of the police, fire, ambulance or other emergency services are acting in an emergency. 5. A number of other provisions are relevant: Avoidance of risks from work at height 6. (1) In identifying the measures required by this regulation, every employer shall take account of a risk assessment under regulation 3 of the Management Regulations. Selection of work equipment for work at height 7. (1) Every employer, in selecting work equipment for use in work at height, shall (b) take account of (ii) in the case of work equipment for access and egress, the distance to be negotiated; (iii) the distance and consequences of a potential fall; (iv) the duration and frequency of use; (v) (vi) the need for easy and timely evacuation and rescue in an emergency; any additional risk posed by the use, installation or removal of that work equipment or by evacuation and rescue from it; and Requirements for particular work equipment 8. Every employer shall ensure that, in the case of (d) a personal fall protection system, Part 1 of Schedule 5 and (i) in the case of a work positioning system, Part 2 of Schedule 5; (ii) in the case of rope access and positioning techniques, Part 3 of Schedule 5; (iii) in the case of a fall arrest system, Part 4 of Schedule 5; (iv) in the case of a work restraint system, Part 5 of Schedule 5, 1 Work at Height Regulations

2 are complied with; and Work positioning versus Rope access and positioning techniques 6. Figure 1 2 can be used to indicate which Schedule applies. Work positioning 7. If the rope moves with the user functionality of the system is likely to be work positioning, e.g. a bosun s chair or arboricultural prussiking on a single rope. Therefore, Schedule 5 Parts 1 and 2 would apply. Part 1, Requirements for all personal fall protection systems, requires that: A personal fall protection system shall be used only if (a) a risk assessment has demonstrated that (i) the work can so far as is reasonably practicable be performed safely while using that system; and (ii) the use of other, safer work equipment is not reasonably practicable; Part 2, Additional requirements for work positioning systems, requires that: A work positioning system shall be used only if either (a) the system includes a suitable backup system for preventing or arresting a fall; and (b) where the system includes a line as a backup system, the user is connected to it; or (c) where it is not reasonably practicable to comply with sub-paragraph (a), all practicable measures are taken to ensure that the work positioning system does not fail. Rope access and positioning techniques 8. If the rope remains stationary and the user moves along it using their own effort, functionality of the system is likely to be Rope access and positioning techniques (more usually called industrial rope access). Therefore, Schedule 5 Parts 1 and 3 apply. 9. Part 3, Additional requirements for rope access and positioning techniques, requires that: 1. A rope access or positioning technique shall be used only if (a) subject to paragraph 3, it involves a system comprising at least two separately anchored lines, of which one ( the working line ) is used as a means of access, egress and support and the other is the safety line; 3. The system may comprise a single rope where (a) a risk assessment has demonstrated that the use of a second line would entail higher risk to persons; and (b) appropriate measures have been taken to ensure safety. So, when can you use single line system? 10. Work positioning requires a suitable back-up system. However, if it is not reasonably practicable to comply with this then all practicable measures must be taken to ensure that the work positioning system does not fail. This is a high legal standard and accepted industry 2 Flowchart taken from The Work at Height Regulations 2005 and Ladders Briefing (HSE Safety Unit)

3 and best practice for work positioning makes it difficult to justify not having a backup (an exception to this being some arboricultural techniques or situation resulting from a real emergency). 11. Rope access and positioning techniques (industrial rope access) requires two separately anchored lines. However, if a risk assessment has demonstrated that the use of a second line would entail higher risk to persons (and appropriate measures have been taken to ensure safety) then a single line could be used. That said, industry guidance sets out the use of two ropes and it would be difficult to justify not having two (an exception perhaps being in an emergency situation). Work at Height Safety Association (WAHSA) 12. WAHSA draws a distinction between rescue and evacuation, with rescue typically involving the recovery of a casualty by another person and evacuation typically being carried out by the user themselves to escape an existing place of work such as a tower crane, narrow aisle truck or wind turbine It may be argued that rescue uses a two-rope system and evacuation uses a single rope system. However, the Work at Height Regulations do not make this distinction. The key issue is that using a second rope would result in a greater level of risk, e.g. in the short time available to escape the user would be at higher risk in remembering how to use two ropes and any associated equipment. 14. In terms of rescue, the Fire and Rescue Service use two rope systems for lifting and lowering (and industrial rope access), with a principle of no single piece of equipment being relied upon in the system, apart from an approved harness. The provision of two ropes is relied upon as a minimum. However, risk assessment, rescue site conditions and overall manageability will dictate the actual number of ropes required 4. Single rope evacuation 15. OC 282/31, Rope evacuation from mechanical handling equipment 5, discusses rope evacuation equipment from mechanical handling equipment (e.g. narrow aisle order pickers 6 ). It states: 7. The principle of a rope evacuation system is the use of a single descent line with the user attached via a harness, to a descent device (descender). Descenders offer a controlled descent to floor level when correctly used. 16. Also: 8. Rope evacuation equipment should be differentiated from the techniques employing two ropes used for rope access/positioning (e.g. by industrial rope access technicians) where a Work at Height Safety Association, Technical Guidance Note 5 (Page 3, Section 3, Safety Issues and Considerations), Fire Service Manual Volume 2 Fire Service Operations, Chapter 9.6.1, Principles of Operation Health and Safety Executive - Field Operations Directorate - Operational Circular OC282/31, Page 2, Paragraphs 7 and 8, Note: The guidance in this OC is not intended to cover evacuation from lifting equipment such as tower cranes, but many of the principles can be applied to evacuation from such equipment.

4 safety line is used in addition to the main working line. This is anchored independently of the working line and provides a security back up. 9. In a real life emergency evacuation from mechanical handling equipment, there is little benefit in using a two rope system. Operators are unlikely to ever gain the skills required to use them properly and, as they may be under stress, there may be a delay or confusion during evacuation. 17. A rope evacuation system is described as: a last resort which should only be used in exceptional circumstances, e.g. where: a) the mechanical handling equipment is immobilized and cannot be repaired, lowered or long travelled in a reasonable time; and b) alternative safer means of escape cannot reasonably be provided; and c) the operator is at risk from another more imminent hazard, which cannot reasonably be controlled to allow rescue without using a rope evacuation system. Examples include risk of fire (e.g. where fire fighting measures such as sprinkler systems do not adequately control the risk); smoke, halon, the effects of cold in a cold store (though thermal clothing and heated cabs may control the risk sufficiently to allow time for a safer method of evacuation). 18. Two generic types of descender considered suitable: (i) (ii) handled descenders ( double brake ); and automatic descenders ( hands free ). 19. The type chosen will dictate which Schedule applies in the WAHR: (i) a small personal evacuation descender, e.g. heightec Micron The rope is stationary and the user moves relative to it so Schedule 5 Parts 1 and 3 apply. o The risk assessment must have demonstrated that the use of a second line would entail higher risk to persons (ii) Controlled Rate Descender (CRD) The rope is not stationary so Schedule 5 Parts 1 and 2 apply. o It has been deemed not reasonably practicable, in a real emergency, to include a suitable backup system. Planned versus unplanned 20. The terms planned and unplanned have their origins in training nomenclature. The use of a CRD for rescue is sometimes referred to unplanned. The use of self-contained rescue system, e.g. heightec RescuePack Pro is sometimes referred to as planned. 21. However, all rescue should be planned, with the risk assessment looking at the likely scenario and determining when a single rope may be acceptable.

5 Backup during training 22. OC 282/31 states: 16b) Training should be undertaken with a safety rope controlled by the trainer even if staff have received regular training and are deemed competent. and 17 During training, descent should always be supervised (generally from the upper level) by a competent person trained in emergency rope evacuation methods BS 8454: states: If any person is to be suspended on a single line, for example, when using equipment for personal evacuation or rescue after a fall, an additional safety system should be used. 7 BS 8454: 2006, Code of practice for delivery of training and education for work at height and rescue, Delivery of training, Page 21, Section