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Posted By Alan Barthrope
I was recently informed both by an HSE inspector and PASMA that the WAH Regs has brought about a change in the inspection criteria for Tower scaffolds.
Under CHSW Regs a Tower would be inspected after being erected but a written report was not required unless the tower was due to remain in position for 7 days, or more.
The interpretation of the WAH Regs is now that a written report must be made for every tower, each time it is "erected" (not moved) in a new position (over 2m only). As well as the time required to do the written report there will be another rainforest of paper going to waste.
PASMA have altered their inspection form to accommodate this change and expect all PASMA trained operatives to use this form.
What is your feeling on this, or your interpretation of the WAH Regs, and how are you managing to comply with this? Do you feel that such a system as the scafftag one would satisfy this regulation requirement (No written records)?
Thanks in advance for any of your thoughts.
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Posted By Robert K Lewis
The requirement to inspect after every substantial alteration was always in PASMA if I remember correctly. Substantial being defined as anything greater than the removal of the top handrail section. More than this and it was termed re-erection. So what has changed? Are we about to be convinced that further training is required - I trust not.
On the paperwork, use one of the proprietary tag systems and register at first erection and weekly thereafter, given the constraint that it will not be totally dismantled and re-erected whereupon it becomes a fresh tower,then use the tag at each intermediate move; or even daily.
Bob
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Posted By Chris Pope
Surely this is a joke /
Down in darkest westcountry most users aren't even trained and those that are rarely erect them correctly - I was on site yesterday and 2 out of 4 on a major homebuilders group site were without any handrails !!!
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Posted By Alan Barthrope
Thanks for your response Bob,
I believe the original criteria was that an inspection needed to be made, but a written report was not required unless you knew the tower was likely to remain in the same positionj for 7 days.
The new requirement is that you need to provide a written report every time you erect or substantialy alter a tower scaffold.
I am still not sure that such a system as the scafftag one is evidence that the inspection has been done.
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Posted By Robert K Lewis
The written report was always required for substantial alteration and for erection so the regs should not be changing what is the required practice. I think the real problem is actually contained in Chris' flip comment. These have always been badly managed and the WAH regs are now causing people to realise what they should have been doing all along.
I fully support Chris by the way as these are the best piece of kit for many access purposes but are so widely abused that they are falling into disrepute. Unfortunately I have yet to see the HSE be as active against their abuse as they are for tube and fitting scaffolds. The trouble is most believe that any idiot can erect them and mostly they do.
Bob
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Posted By R Joe
Alan
I have just been mulling over this one myself, along with some other WaH questions.
Reg 12(4) is relevant in that a tower scaffold by virtue of its working platform requires a ‘7 day inspection’ for which the required report format is then specified in 12(7) i.e. as given in Schedule 7.
The inspection required on initial erection/assembly appears to be covered by Regulation 12(2) which states that ‘Every employer shall ensure that, where the safety of work equipment depends on how it is installed or assembled, it is not used after installation or assembly in any position unless it has been inspected in that position.’ Unless I am missing it, however, I can’t then see a format being prescribed for this inspection.
Interestingly, as written, however, Reg 12(2) appears to apply to the use of a tower scaffold in ANY position unless it has been inspected in THAT position i.e. will a new inspection be required every time it is moved? Its also interesting to consider if Reg 12(2) could also apply to the ‘installation or assembly’ of a ladder or stepladder……….
What do people think of the HSE/LA Inspectors WaH training package that has been made available? Whilst openness is definitely welcome, I’m finding more questions than answers in some areas. For example, the training package refers to the importance of (unrecorded) pre-use inspections for ladders and stepladders but it is unclear if this is linked to Reg12(2) or if it is being promoted as good practice (possibly) covered by other legislation.
Any thoughts?
Regards RJ
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Posted By Chris Pope
I would have thought that user inspection, by a competent person (who els ?) is always applicable to every use of access equipment.
For example if I use a tower I ought to check for myself that the handrails are in position and the brakes are on - I always teach tower users never to trust anyone !
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Posted By Alan Barthrope
You are absolutly right Chris, but the question is not about doing the inspection, its about producing the written report.
Thanks for your response.
Alan B
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Posted By Bill Fisher
Chris
Don't disagree with your points but I would come at it from a different angle. That being the employer ensuring a safe place of work!
The "seven" day inspection and after adverse weather etc are all part of that but what about the intervening period? Where there is remote sites, large numbers etc your comment on user inspection is actually the only way to be absolutely sure.
Of course it is not a formal inspection but the employee playing their part in looking after their safety (oh, I suppose health as well!)
Bill
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Posted By James M
Blimey, who would have though by reading this post that the regulations have been in for 6 months? Where have you been?
Chris, the key point that you mentioned on your first post was 'homebuilders'. next to shop fitters probarbly the worst for health and safety standards. Did you expect anything else?
Next you will be telling us that you were not aware of the HSE campaign that has been underway for two weeks now.
Last comment before I tuck myself up for the night, you can record the information electronically as long as it is readily available for inspection if required. This cuts down on the use of paper and is obviously better for the environment, or is it? Electricity or paper? which ruins the environment more? maybe save this for another thread.
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Posted By R Joe
Apologies for being a full week behind folks - HSE issued a revised CIS Sheet 10 'Tower Scaffolds' week commencing 3 October. It addresses these issues in large part. Surprised James didn't mention this to us.
Regards RJ
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Posted By steve e ashton
RJoe: you may be interested to read the discussion under 'Are you thinking what I'm thinking' thread, dated 15th June.
You are right - the regs DO require a competent person to inspect and record every time a ladder /scaffoled / stepladder etc etc is put up in a new place. HSE have said they will adopt a 'risk based approach to enforcement'.... but that's not what the law says (and presumably will not be what the claims jumpers will be alleging when they sue...)
Steve
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Posted By R Joe
Thanks Steve
made an interesting read. Like you, I suspect, I'm all for progressively improving standards but also get frustrated with, and a bit sceptical about, loosely worded legislation which apparently 'will be alright on the night' due to a 'risk based approach to enforcement'...... By the way, for anyone still wondering about the 'three points of contact' reference for ladders and step ladders, take a look at the HSE / LA Inspector WaH training pack now available, that I referred to above.
Regards RJ
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Posted By James M
Good point RJoe,
I have been doing toolbox talks on the new guidance this week.
One of the key points that has not been clarified on page 2 figure 4 is how you fit or release the end section at the opposite end to the trap door if you are positioned in the trap door as per the picture. Also how do you secure or release the horizontal guard rails at the opposite end to the trap door as all towers that I have used or trained operatives on have a release catch to pull back when fitting.
Initally impressions are that it is a poorly thought out document with respect to existing scaffold towers. Perhaps the answer is to get the cranfield man to assemble the towers for you as he will be the only person physically able to complete this task from the trap door.
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Posted By Alan Barthrope
Response to James M, When using the 3T (Through The Trap) system, the HSE and others have tested and can confirm that releasing the catches on the claws prior to sitting in the trap position is a SSW. The tests proved that if any operative accidentally fell against the guardrail whilst they were in this state, they would re-lock or still support the person falling against them.
Alan B
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Posted By Robert K Lewis
Cranfield man probably won't have a CSCS card so will not be allowed on MCG sites no matter how competent he is at tower erection!
Bob
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Posted By Alan Barthrope
After kicking this thread off and now having read the latest CIS sheet No 10, I can now see that my understanding was correct. This leaflet confirms that both an inspection and a report are required each time the scaffold is altered or re-erected etc. Thanks to all those who responded.
Alan B
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Posted By James M
Alan,
the document states: (3T) This allows the person ERECTING the tower to position themselves at minimum risk during the installation of guard rails to the next level. It involves the operator taking up a working position in the trap door of the platform, from where they can add or remove the components which act as the guard rails on the level above the platform. It is designed to ensure that the operator does not stand on an unguarded platform, but installs the components to a particular level while positioned within the trap door of that same level.
If you are assembling a 6m tower will you have to assemble the end section on the ground and then attempt to stand it up? It is clear that the operative will have to stand on the platform to fit the end frame furthest away from the trap door. Then walk back to the trap door to fit the hand rails.
Which again comes back to the cranfield man as the only person who can complete this task.
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Posted By Alan Barthrope
James,
You obviously do not understand the erection/dismantling sequence and I would suggest that you attend a PASMA course so that you fully understand this. The sequence allows for operatives to be in a safe position at all times, therefore all competent users are not put at risk, and hopefully will work to this system. Thanks for the input, but it does not assist the thread topic.
Alan B
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Posted By James M
Alan,
I fully understand the erecting and dismantling sequence and I am a competent trainer of scaffold towers. However the guidance document does not clearly state the method of safely placing the end frame.
If the HSE state as you have indicated that this is a SSOW where does it indicate the method of fitting end frames in the document? A SSOW is a detailed method that should be easily understood by the user (otherwise it is not safe). or do you have to be a member of a funny hand shake club to know this?
cranfield man is the ONLY solution to erecting towers using THIS guidance.
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Posted By Alan Barthrope
James,
I don't know why I am getting into this debate with you. I was not suggesting that the CIS explained how the erection sequence might work.
All I know is that the PASMA approved method works, and thats the one that I teach. I don't know what sequence you use, nor do I want to. The correct sequence will be as per the MIM, not as per the HSE leaflet. This will be the last you hear from me on this matter. Have a good weekend. Alan B
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