Applying the Hierarchy of controls to Working at Height
In this video, former HSE Inspector Melvin Sandell and Principal Consultant Dr Richard Brown discuss the hierarchy of risk control, and how this feeds into your duty to do suitable and sufficient risk assessments and manage the risks in your workplace.
The critical regulation is the Management of Health and Safety at Work Regulations and the hierarchy of control is found in the schedule of prevention, which is appendix 1, or schedule 1, in the back of those regulations in the approved code of practice.
The hierarchy is something that you have to start at the top with, and here are a few basics about the hierarchy.
It’s found throughout regulations in UK health and safety law. The hierarchy of controls can be found in the Management Regulations but also in Control of Chemicals, the COSHH Regulations, the Work at Height Regulations, Confined Space Regulations and lots of others.
The fundamentals of the hierarchy of controls are to avoid risky work if you can. If you can’t do that then you have to control it, and very often the regulations require that you control it collectively. If not, you use personal controls and then PPE or discipline and the use of safe systems of work tends to be at the bottom of the hierarchy.
Applying the hierarchy of control to working at height
Your first objective is to eliminate work at height. There are many ways this can be done these days, for example, by using a drone to complete an inspection of things at height. Assuming you can’t utilise this and you need to go up at height to do your work, then your first option is to use an existing workplace that may already be fitted with walls or handrails that keep you safe while you were doing that work and reduce the possibility of falling.
Assuming then that you can’t get away with working on the floor and you have to go up at height, ideally, you would work from an existing safe workplace, perhaps an adjacent building or a walled area which is near to where you are going to work that you can do your work from.
Supposing this wasn’t possible the next step would be to create your own safe workplace perhaps by using a scaffold. If that’s not possible either the next step down would be to take a workplace with you i.e., a MEWP (mobile elevated workplace platform) or scissor lift which would have the appropriate handrails and kickboards already attached to it, and you can use that to get access to where you want to.
If none of those is possible and you have to be at a height in the workplace in a situation where there is an open edge that you can possibly work from, then a running line and a harness which would prevent you from going over the edge if you got too close would be the next step down.
The next step down the hierarchy (and we are getting towards the bottom!) is the idea that you can fall but the distance of the fall or the harm that is likely to result from the fall would be reduced as such that the harm would be reduced or eliminated.
This would be an inertia reel attachment to the harness or airbags or nets which again would allow you to fall a bit but will reduce the distance and reduce the harm. But remember whenever you are thinking about using these methods of risk control some of which will be cheaper or easier, you need to justify each step down that hierarchy by risk control, and always remember if something goes wrong you may need to justify those decisions to step down that hierarchy in Court.
If we can prevent work at height (or applying the hierarchy to any other regulations) then that is the ultimate control. If we can’t do that then we need to look at collective protection or using the existing building – a parapet wall for example or scaffolding systems.
Then down towards the bottom of the hierarchy, we need to think about individual protection such as running lines. If you are right down to the bottom of the hierarchy, if we’re allowing people to fall and mitigating the height that the fall, then we should be looking at collective fall measures such as bean bags or nets.
Inertia reels are at the bottom of the hierarchy and the reason is that they require an individual to physically clip on. When we’re looking at things like bean bags or nets the control is already in place and the individual who falls didn’t need to actually take any action themselves.
To subscribe to the Finch Consulting newsletter for updates and news articles please click here.