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#1 Posted : 25 May 2005 14:12:00(UTC)
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Posted By Lawrence Hughes with all the WAHR excitement and a large increase in WAH PPE we have also trained up some of our people to be the Competent Person to do the 6 monthly LOLER Thorough Examination of WAH PPE. So here I am, sat in the office trying to make a working system, which includes the form for the examination report. Reference to LOLER Schedule 1 (para 9 & 10) reads to me that the personal address of the examiner and the person signing are required. Given the sensitivity of personal information these days (eg. accident books) is the inclusion of personal address details correct? - especially as these reports will be copied to 3rd parties (eg. customers & principal contractors) ? any thoughts please?
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#2 Posted : 25 May 2005 14:18:00(UTC)
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Posted By Paul Leadbetter Lawrence But para 9 says that the name and address of the employer is required, if the person making the report is an employee. Paul
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#3 Posted : 25 May 2005 14:26:00(UTC)
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Posted By Lawrence Hughes thanks, but I read para 9 as requiring 3 groups of information: name, address and qualifications of the person making the report are they self employed (yes / no) if not self employed then ALSO need name & address of employer
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#4 Posted : 26 May 2005 09:43:00(UTC)
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Posted By Mark Eden Please excuse my ignorance, but WAH PPE is not lifting equipment or plant and is not covered by LOLER. PPE Regs & PUWER do, also the HSE produce a leaflet "Inspecting fall arrest equipment" INDG367 - one comment is that inspections should be carried out by independent & impartial persons
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#5 Posted : 26 May 2005 11:21:00(UTC)
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Posted By Lawrence Hughes Mark, thanks for the input but WAH PPE is covered by LOLER. The PPE Regs, & PUWER have a relevance, but at the end of the day we are looking at supsension of persons which is LOLER. The new WAHR makes specific reference to LOLER applying (ref. WAHR reg 12 (9) I think ). INDG367 is a great document, but I consider some of the example pictures are a bit extreme and the equipment should never be allowed to degrade to anywhere near that state, ref a system of pre-use inpections by trained users, let alone regular thorough examinations. I dont believe INDG367 references LOLER directly, but does recommend the detailed inspection at a maximum interval of 6 monthly (derived from LOLER). Intervals to be less in more arduous conditions. impartiality - the quote from INDG367 is "It is essential that the person carrying out any inspection is sufficiently independent and impartial to allow them to make objective decisions, and has appropriate and genuine authority to discard defective lanyards. This does not mean that competent persons must necessarily be employed from an external company, although many manufacturers and/or suppliers offer inspection services and training in the inspection of their products." and given our spread of business across the country and the resultant nightmare to co-ordinate equipment for inspection we have trained our Site Managers and myself to be competent persons. The result is impartial, these guys (except me) depend on the kit and are keenly responsible for safety on site. We also have concerns that some external inspections lack understanding and experience specific to our fall arrest PPE please be careful with INDG367 there are 2 versions in circulation as it was updated but the file name was unchanged, the centre bottom of the last page should say "reprinted 2/03" - NOT "09/02"
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#6 Posted : 26 May 2005 12:18:00(UTC)
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Posted By Mark Eden Just a point you mention WAH PPE- PPE which covers fall arrest equipment is not work equipment and is not covered by LOLER(Straight from the HSE) Suspension harnesses and the like are work equipment and covered by LOLER. they are also completely different in design to fall arrest / safety harnesses
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#7 Posted : 26 May 2005 14:00:00(UTC)
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Posted By Lawrence Hughes coming from a crane industry background I've always seen fall arrest PPE as subject to LOLER thorough examination on the basis that if you fall you are suspending and LOLER has been the universal basis of lifting gear examinations (since docks regs etc) including for accessories to suspend people. It may be a historical convenience and confused reasoning but at the end of the day we've had a good system of examination and the dodgy kit has been filtered out promptly. I'd be interested in where the HSE are saying its not LOLER. The WAHR in reg 8 "Requirements for particular work equipment" includes fall arrest PPE (8 d iii). however here and now with WAHR2005 we are stepping more firmly into this grey area because of the rescue requirement. We are using manually controlled descender equipment that requires the rescuer and casualty to be suspended in some situations, so what are primarily fall arrest harnesses are now in use for suspension, although suspension is not a part of the work activity. We are also incorporating work positioning (not suspended rope access type positioning) and restraint as fall prevention solutions for some situations. So we need to move to a more advanced harness than traditional simple scaffolder types. hmmm . . . I'll still be happier calling it LOLER, but would like to know if it really is or isn't applicable, I'm not convinced either way now! lets throw the original question another way - if it was a LOLER report for lifting equipment instead of PPE, should we put personal addresses on the report?
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#8 Posted : 28 May 2005 22:54:00(UTC)
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Posted By Christopher Kelly Just their office address or where they can be contacted in writing. Are you sure you can provide a competent person if you don't know that ? You should be very careful !
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#9 Posted : 28 May 2005 22:57:00(UTC)
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Posted By Christopher Kelly Actually Laurence fall arrest equipment is not covered by LOLER, only lifting equipment.
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