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From my experience over the years of working in the window cleaning industry people are aware of the Hierarchy of Control, but not everyone understands their responsibilities or requirements and how the decisions they make could be contradicting it. This applies to companies delivering window cleaning services, the window cleaners, facility managers responsible for the site or development, even architects and façade designers.
I have come across many scenarios but one that stands out happened only about a year ago. We had a new customer who’s BMU was due for its LG3 Inspection, which is required every 10 years, due to various issues the inspection was going to take some time. The tenants were putting pressure on our client as they wanted the windows cleaned, so we were asked to rope access the site. Following this request, we carried out a full review of site to identify if it was reasonably practicable to move down the hierarchy and conduct the works. Due to various issues, the main one being access to the roof areas, it left us with the only option to use the BMU track as an anchor point for rope access.
When asked if the track had been tested for the purpose of rope access activity, the response was “oh yes it must have been as our previous provider would abseil all the time”. Yes, you guessed it we asked for the certificate and there wasn’t one. We continued to support the customer and interacted with the BMU company who had the maintenance contract, they advised against using this particular track for a number of reasons and refused to test it. Whilst we considered alternative options, the customer became frustrated which I could sympathise with. Out of the blue the contract was terminated and within 2 days the previous contractor was back onsite cleaning the windows via rope access and using the BMU track as the anchor point. Whilst this raises many concerns, it highlights that there was clearly a lack of understanding from the contractor and customer with regards to the Hierarchy of Control for Working at Height from the outset. What are your thoughts?
This situation and many others are why I have put together the following overview to give those who need it, some support. This Blog will also be followed by a series of others that will pick up on requirements linked to the Hierarchy of Control for Working at Height.
Working at Height
Defined by the HSE “Work at height means work in any place where, if there were no precautions in place, a person could fall a distance liable to cause personal injury.”
The Work at Height Regulations 2005 place a duty on employers and contractors to ensure that all work at height is:
Properly planned and organised, including planning for emergencies and rescue.
Assessed for risks using a Hierarchy of Control measures.
Appropriately supervised.
Done in a way that is as far as is reasonably practical, safe.
Always done by competent people, including managers and supervisors, who are appropriately trained.
Done using appropriate equipment that is regularly inspected and maintained.
For every task that needs to be carried out at height there needs to be an assessment of the risk and appropriate control measures in place. In terms of the Hierarchy of Control, there are measures in place that need to be considered and you only move to the next level of the hierarchy when you decide that the control is not practicable. The below image highlights these eight levels.
Why?
Falls from height are one of the biggest causes of workplace fatalities and major injuries and the Hierarchy of Control is a system used in the industry to prioritise possible interventions to minimise or eliminate exposure to hazards.
In principle, ensuring the task is carried out in the safest way possible means that operatives doing the work are provided the safest environment allowing them to stay safe and return home to their families every day.
How?
The key things to consider are having the correct processes and procedures in place, backed up with adequate training for your entire team from management to frontline operatives. Facility managers (clients) should also have basic training so they understand all requirements that should be in place and considered.
The Hierarchy of Control must be considered before any work at height is carried out, there must be sufficient evidence escalated through the management chain to demonstrate that other access methods or equipment cannot be used and as a result, you have done all that is reasonably practicable to reduce the risk. This should be documented and evidenced as part of the risk assessment before any work begins.
Where work must deviate from the standard method of access for site, it is strongly recommended that all parties involved sign off the documentation evidencing that the Hierarchy of Control has been followed. All parties would include but not be limited to the manager responsible for the works, operatives doing the work, Health and Safety representatives for both the supplier and customer and the facility manager responsible for the site.
Remember just because you’ve always done it that way and never had an accident, doesn’t mean it’s safe, or that there isn’t a better way.
Key points to remember are:
Avoid working at height in the first instance, if possible
Ensure all those working at height are properly trained and supervised
Select work equipment that prevents falls
Ensure equipment is suitable
Regularly check and maintain equipment
Provide necessary PPE and protection from falling objects
Ensure the working environment is safe
Plan for emergencies and rescues.
It would be great to know your thoughts or if you have been faced with similar situations.
If you need any support in this area please contact us.