Posted By ian mcnally I thought you may all be fed up to the back teeth with WAHR by now, judging by the recent request from NickW for ACoP info I see this may not be the case. It would make interesting reading to see if there was a consensus of opinion on the term “short duration” when applied to working from a step ladder. I have read with interest the postings of Karen Jane Bradley last month (and a few others) I wonder if she now has a clear understanding of situation? My view for what it’s worth. I work in the construction and maintenance sector and accept that providing a risk assessment has been carried out and identified that the task doesn’t involve for example: above average ceiling heights (2.7m+) fully boarding / plastering ceilings or installing heavy equipment and that the individuals working will be holding the ladder with one hand for 99% of the time, then 5/10 minutes for each task would be acceptable. I’m concerned that I may be taking an over the top stance about this and that the conkers bonkers analogy may be levied at my interpretation of the Regs. I am aware of alternatives ranges of products such as podium steps ankalad etc but nobody, including many safety people at my local IOSH branch have been able to give me much more on this, other than the standard (it would depend on what you were doing and on the risk assessment – very helpful!) Interestingly, I have had conflicting HSE feedback. Yesterday I was informed that a senior HSE individual from Rose Court suggested to 60+ safety advisors at a seminar last week, that he considered it acceptable practice for work from a pair of steps to be carried out for 30mins then move the steps and repeat the process, he did not clarify the three points of contact situation which I feel is crucial to establishing a SSW. I must now confess to be genuinely at a bit of a loss. I have read much of the guidance and also the recent THSP article but can't find anything on 3 ponits of contact? More responses on this the merrier and if enough confusion out there I will pursue with IOSH / HSE to see if the situation can be made available to us all. Thanks in anticipation. Ian

Posted By Geoff Burt I hope you get somewhere with this Ian. I was at a site in Crawley yesterday trying to explain why steps are not supposed to be used to put electrical trays up. I gave in in the end and wrote the RA to reflect that the risk using steps is low and that the use of steps is perfectly acceptable. Which is my genuine opinion. So where do we go from here?

Posted By ian mcnally Hi Jane/Geoff, I have been recommending 3 points of contacts for many years now but haven’t the foggiest what guidance document it’s contained within and haven’t been able to find it in any recent guidance either. The company I work for has one of our sites very near Crawley Geoff and I have been recommending our sub-contractors use podium steps or mobile towers for such works, the reason being that most of the electrical trays I’ve seen require both hand free to install. A Principal HSE Inspector (not from East Grinstead) has already suggested we should be encouraging our contractors to adopt this practice wherever possible/practical and we’re none to keen on picking up an improvement notice despite my own views. My own views probably wouldn’t count for much in court so, very small rooms aside; we have been implementing the PI’s advice. I too would like to know where we collectively go from here so if enough views expressed indicate a need for clarification I will pursue. Incidentally Geoff if you live anywhere near Crawley, have you considered coming along to the local South Downs IOSH meeting? Interesting meetings and a good number of us always go for a curry afterwards and put the world to rights. http://www.ioshsouthdowns.co.uk/ Anyone else welcome too! Ian

Posted By Jane Watts I'll see if I can find anything about where the 3 point contact thing came from according to my colleague.

Posted By John W Brown Try the "Manual of Firemanship" - it has safety aspects of ascending/descending ladders in it - not sure if it mentions 3 points of contact though!

Posted By Jeff Watt I could be wrong but.... I think the 3 points of contact came from Du Pont any of them out there... calling all nylon manufacturers... On the "is it safe to use a ladder for short durations" the WAHR applies a heirarchy of controls similar to COSHH. If there is a better system and someone gets injured and it was reasonably practicable to use the better system your snookered IMHO. I agree with the previous poster, ladders are a means of access. The only time I allow them to be used as a work platform is when I judge the use of other means(like scaffold) to create additional risk to persons due to their erection in difficult conditions etc. and then only under supervision. If i ever have any safety query I am not sure about I ask myself "Would I let my kids do it or my mother in law do it?" If the answer process goes No/Yes it definitely ain't safe.

Posted By Stuart Nagle Some interesting coments Ian... In my opinion the regulations would require short term works from ladders to be almost noi more than access....e.g: Changing a lightbulb in a normal height ceiling, or obtaining something from high shelving than can be carried safely ect etc... The regulations imply that anything over and above access or short tasks should be carried out from a work platform that is suitable for the task such as in jobs involving electrical conduits etc to which you refer and other tasks that involve anything more than simple manual tasks that do not really involve the use of tools etc in the work at height.... As stated, caselaw will need to be evolved by the courts and no doubt we will, as in the past stand to be more learned from the misfortunes of others..... without donning mt american football kit to play conkers.... I will risk emphising that the factets of control methods for the prevention and reduction of risk from hazards and suggest if it can be done more safely from a platform than a ladder, then that is what we should do....unless we can find methods to remove the risk by installing systems that do not require works to be undertaken at height where reasonably practicable..... floorlights and negative gravity atmospheres come to mind immediately but perhaps we have some work to do yet..... All the best in your endeavours.... Regards.... Stuart

Posted By Geoff Burt Jeff Are your kids and mother-in-law trained in the use of ladders? Geoff

Posted By Stuart Nagle Geoff. As I am sure you're aware there are situations that appear similar but present differing levesl of risk. Having mounted electrical conduits into roof spaces myself, I know its backbreaking and arm wrenching work over a period of time and balancing on steps, maintaining balance, using electrical tools and trailing cables etc etc etc... is not the easiest or best method, and steps do not have a lot of storage space for tools and equipment... and overbalance is a problem.... platforms that offer a firm and wider surface with edge support and space for tools are by far the better option. I'm not of course saying that ladders are not of use...for very limited overhead work, but I certainly would not want to do more than an hour or so's work in this manner if I could use a platform!! Hence my statement on control measures to remove / reduce risk... whether or not significant risk, after all persons have been killed falling from lower heights than 2.0m steps have they not, and I seem to recall the Work at Height Regulations specifically removed the 2.0m rule.... Regards.... Stuart

Posted By steve e ashton st: you wrote "Ladders or stepladders or trestles erected safely, used safely not a problem - but can you all honestly say that happens every time, every day! " In the real world, I've got to agree. But in the Disneyesque world of EU compliant regulation, all means of access such as ladders, stepladders etc will be formally inspected by a competent person before use following erection in a new position. The inspection must be recorded.... These are absolute duties in the WAH regs (ie not 'so far as is reasonably practicable') So - the regulation-compliant user will always be working safely. Yeah ... Right.... So the librarian moving her kickstool will do a recorded inspection.. The window cleaner will complete anew set of paperwork every time he moves his ladder... Yeah.... Right.... The regs are a mess, HSE claim they will apply a 'risk based' approach to enforcement (anyone want to challenge their stance as lowering the standards of protection supposedly provided for by the regs?). And who is (like me) awaiting eagerly the first ambulance chaser to lodge a claim alleging breach of statutory duty because a stepladder was not formally inspected in a new position.... Our courts are not permitted to apply a 'risk-based' approach to interpret statutory duty, our law writers are supposed to get it right. In WAH, they have not (see the earlier thread commenting on adverse weather ...). Should the regs be renamed the WaaaaaagH! REGS? Steve

Posted By peter gotch What's new?? There's been relevant legislation almost from the beginning of the Industrial Revolution. Section 26 of the Factories Act 1937 "There shall, so far as is reasonably practicable, be provided and maintained safe menas of access to every place at which any person has at any time to work, and every such place shall, so far as is reasonably practicable, be made and kept safe for any person working there". So we have to do what is reasonably practicable and there is plenty of case law on this INCLUDING as regards falls of less than 2m. Accidents involving access equipment such as ladders have been relatively common in the construction and other sectors. Current HSE statistics provide limited break down of causes of construction site accidents involving falls from height, eg as to the type of place of work from which the victims fell. However, more detailed analysis has been published in the past, eg in HSE’s “Construction Health and Safety 1981-82” According to these published statistics 30 construction workers fell to their deaths from ladders and step ladders in 1980 and 1981, ie slightly over 10% of all those sustaining fatal injuries in those years. In terms of all construction accidents reported to HSE in 1980, Table 2(b) 1398 involved falls from ladders and step ladders. This represented 16% of all reported accidents involving falls of persons whether from heights or on the flat. HSE and other research indicates that historically (and still) many accidents that are legally reportable [currently as required by the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995] have not been reported. Hence the number of accidents recorded in Table 2(b) involving falls from ladders and step ladders is probably significantly less than the total number of reportable injuries to construction workers in 1980 arising from their falling from such access equipment. I have personally investigated a fatal accident involving a painter falling less than 2m from a step ladder. HSE guidance points to the 3 points of contact principle e.g. on pages 41 and 42 of HSG150. HSE guidance has also challenged the use of ladders and steps as a workplace, unless risk assessment justifies for a significant period, and specifically prohibited such workplace unless risk justified in the Construction (HSW) Regs 1996. But as far back as 1984 [and probably earlier] guidance was questioning the ubiquitous use of such equipment e.g. GS31 “Safe use of ladders, step ladders and trestles” GS31 comments at paragraph 6 “The first question to ask is – can the job be done more safely in a different way?” Paragraph 25 of GS31 advises that the “Work should never be carried out from the top platform nor should overhead work entail overreaching”. For many operations a step ladder would provide access to do a relatively limited amount of work before a person was liable to be overreaching, before they would need to move it to a new location. Alternate access equipment, eg a lightweight aluminium tower scaffold would often provide inherently safer means of access and place of work. F urther, in the words of paragraph 7 of GS31, “a proper platform can often ensure the job is done more quickly and efficiently”. A tower scaffold would be inherently more stable than a step ladder; its platform would provide more secure footing than a single step on a step ladder; the provision of guard-rails would provide better handhold than would be available on a step ladder; the greater area of platform would enable a much greater extent of work to be done safely before it became necessary to relocate the access equipment. Further it is possible that the worker themselves would feel more secure, and thence be capable of working more efficiently. Finally don't know where HSE are taking there 30 minute rule from. HSG150 rightly comments: "many ladder accidents happen during work lasting less than 30 minutes" So just because the stepladder has been custom and practice, why should we accept the status quo. Revitalising H&S? Regards, Peter

Posted By ian mcnally Wow……….. good responses so far and no shortage of reference material in the posting from Peter, funnily enough I too have HSG 150 and have re read pages 40 & 41 but still cannot find the reference to 3 points of contact. Perhaps I have been looking in the wrong place or have an old copy, if I haven’t and the reference isn’t there, the information may have resulted in some readers incorrectly accepting it and this would not be helpful. Steve, you are right but it doesn’t talk about 3 points of contact either. Over my lunch however I found it (how sad is that ). YOU WILL FIND A REFERENCE IN…….. Question and answer brief for the construction industry on WAHR http://www.hse.gov.uk/construction/pdf/fallsqa.pdf 17 pages long and in the very last paragraph it states. “When using a ladder ensure the person using it always has 3 points of contact ie two legs and a hand” Glad it was in that order anyway. Well at least you will be able to refer to it, not guidance I agree but at least it’s in black and white. I wonder if the HSE inspector that wouldn’t agree on the 3 points of contact and that suggested working on a pair of steps for 30 minutes was OK, was aware of it? So next time we see an individual installing a cable tray, or replacing a 6ft tube or diffuser from a pair of steps you can be a little more certain what is required by the employer! Enjoy the hot weekend Ian

Posted By peter gotch Hi Ian, Sorry misread HSG150 yesterday. But it does say for Ladders (and doesn't differentiate for steps) make sure the work only requires one hand to be used and a good handhold is available in the bullets on page 41 Glad you found the references helpful. No, I didn't type them all out yesterday. The power of cut and paste!!! A good weekend to all. Like Merv, I'm a consultant (Trust me), so I'm flying down South Sunday. Nottingham. Well it's down South from my perspective. 10 years down the line and our clients still need CDM training. regards, Peter

Posted By Ron Hunter Steve, Ian et al: I stand corrected. Reg12 of WAHR applies to ladders. This reads as requiring a record of inspection before each use. I can only hope that's not what was meant, 'cos no-one's going to be doing that for ladders or steps!

Posted By steve e ashton Max: In my use of English, when a ladder is put up at 1:3 instead of 1:4, or a stepladder is put up with the stay rope slack, or a kickstool is positioned over a floor level change... then the safety of that 'ladder' is compromised by the way it has been 'installed' in that position. And I still maintain that common useage demands application of the absolute duties from reg 12..... Steve

Posted By Robin B I've never really understood the 2m rule. Is that 2m from floor to head or to feet? If to feet there's a potential for a almost 4m fall. If to head 1 rung of a ladder!!!!! Robin

Posted By Frank Hallett Good morning to all. The last few comments appear to be talking about something that was never properly understood nor effectively utilised - the 2 metre limit that USED to be a part of the construction mythology in that it was freaquently and incorrectly assumed that a fall of less than 2 metres didn't count for some reason. Well, that arguement no longer exists as there are NO mimimum or maximum limits for falls or working at height in the Work at Height Regs. Incidentally, there were two very good articles on this topic in the June SHP that so many people seem not to have read yet [and I didn't write either!]. Frank Hallett