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Posted By Brian Sutherland
I've been asked to design and implement a "No Stepladder" Policy across all our major refurbishment construction sites nationally. Obviously, there are advatages and pitfalls to such an end product - but as the Planning Supervisor has written it into the Client's Site Rules - it has to be done.
Has anyone implemented such a policy or can point me in the direction of someone/company that has - thanks.
Brian
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Posted By steve e ashton
Brian
On what basis and whose authority is the PS imposing site rules? I suspect you may be victim of some over-zealous newcomer to the world who has completely misunderstood (or never bothered to find out) everything HSE and everyone else has been saying about work at height and 'sensible health and safety' for several months or years.
In your position, I think my first response would be to go back and mount a robust challenge to the edicts of the Planning Supervisor, rather than blindly and slavishly trying to introduce / implement a 'policy' which is not founded on reasonable management principles, and which could end up significantly increasing risks in some activities.
Steve
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Posted By Peter Rees
Brian
I have to agree with Steve. However, to give yourself some 'ammunition' to back-up your arguments, download the following (free) documents from the HSE website. These give excellent advice/guidance on the use of ladders and stepladders, and explain what is required and when.
INDG 402, INDG 403 and INDG 405
Cheers
Pete
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Posted By bigwhistle
This a new HSE iniative- however I am interested to know whether if its in the pre tender plan it has to be done under any regs because I thought it was guidance for the principal contractor unless of course it is a statutory requirement.
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Posted By Robert K Lewis
A number of Gov dept's now write this into the client rules, including the DWP, and as a site rule it is legally enforceable. A lot of clients are now following suite, but spot the number of stepladders in use in their own activities!
Your best bet now is to try and negotiate a degree of freedom permitting stepladders under specific method statement in areas where towers etc cannot reasonably be used. Don't get me wrong though as the move to reducing stepladder use is to be encouraged but the contracting side of the industry still requires some scope for assessment.
I know some major contractors tried this but drew their horns in a bit when it was found to be impracticable, at all times, not to use stepladders in some areas.
Bob
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Posted By allan wood
ladders & step ladders are not banned under the work at height regulations and can still (if used correctly) be a usefull piece of kit, but should only be used for short duration works, or where another type of work equipment cannot be used. if you are concerned as to the over use or selection of equipment for work at height why not only permit the use of such equipment through a permit to work, and on this permit you would have to demonstrate how you have worked through the hierachy of controls for work at height.
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Posted By Ian Scholey
By imposing an outright ban on the use of stepladders you will find your contractors significantly increasing their prices as alternative means of access equipment to perform the task will result in increased labour times and if this has not been written into contract documentation for current projects there is a case for your subcontractors claiming additional costs to cover for the increase in labour. They will where appropriate justify the useof stepladders for certain tasks. Whilst the concept of the new regulations is welcomed (to prevent injury and death caused by working at height) there is too much confusion with people misinterpreting the regulations.
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Posted By Martin Mulholland The use of podium steps seems to be an increasing and attractive alternative to step ladders in light of the reaction to WAH. Check them out: http://www.podiumsteps.com/
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Posted By Robert K Lewis
There is no point in merely stating that the WAH regs does not ban them. The site rules are enforceable under CDM and if it is in the contract it is a contractual requirement. The only way forward is negotiation and possibly some mediation to reach a compromise.
Talk to the client representative and clarify what they intend, and if they actually instructed the PS to insert the rule.
Bob
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Posted By bigwhistle
Can you clarify the bit about site rules being enforceable under CDM?
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Posted By Dave Daniel
CDM does not include the provision for the PS to write in rules like these. Indeed there is no legal ownership of the Safety Plan - the Principal Contractor can modify it and add to it, or I suppose even scrap it and re-write it. I have certainly allowed such rules to be ignored where complying with the rule would have introduced additional risk when working with Principal Contractors. Why don't you re-write the rules in your capacity as PC (see Reg 16) to allow steps to be used?
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Posted By Robert K Lewis
If the client has instructed the PS to insert the requirement it is then as such a client rule and must be included in the other site rules developed by the PC. There is no power for a PC to ignore a client side rule as it is a requirement under the contract. Contractors have a duty to comply with the site rules and the PC a duty to enforce them (Reg 19(1)d and Reg 16(1)b).
If the PC does not include a client rule then the client, via any appointed representative is entitled to reject a Construction phase plan as inadequate. Negotiation is the key not a bullish refusal to insert, especially if you wish to retain the client relationship.
Bob
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Posted By bigwhistle
Interesting but I disagree for instance if the whole site is a hard hat area but a contractor in a safe area takes off his helmet whilst having a break he may not be complying with site rules but I suggest no prosecution could be brought against him or the PC or the PS.
I am open for comment however.
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Posted By gham
I would have thought that is you could argue that the rule is not reasonably practical or even safe for the work which you carry out then you should have this rule remove for the purposes of you undertaking.
Too often these risk are not managed properly, I have worked on sites where safety glasses, and hand protection are mandatory at all time when at work, consequently instead of cutting a finger some have been lost due to drawing in to machinery etc, and is take electricians even longer to do second fixes, such rule give rise to confusion amongst the workers and supervisors who fear being removed from the job where zero tolerance enforcement can do more damage than good
G'
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Posted By Robert K Lewis
The PC and the contractor are however open to enforcement as the duty holders if the rule is made and they take no action to manage the problem of say non-hard hat use in an area simply because they think it ought not be so adjudged.
The semantics here can leave us chasing our own tails. Whether we like it or not a client is entitled to have specific rules and, if properly notified to the contractor, should expect them to be followed. As I said before unilateral action is not the best course - rather negotiate the situation in order to maintain what is a beneficial relationship, potentially at least.
Everything I am reading seems to be based around the specifics of H&S legislation. But this is a management issue and as soon to be Chartered status holders we need to begin to demonstrate our competency to manage not simply wave the specific regulation expecting immediate support for our stance.
Bob
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Posted By ken mosley
Having read all the comments on this during my lunch, I feel the need to respond, as there appears to be some conjecture on legislation/enforcement.
The intention of site rules within CDM is for issues relating to a clients activities that impact upon the health and safety aspects of a PCs activities.This is usually where the construction works are on or adjacent the clients premises. The intention is not to allow a client or PS to determine specifically how the PC manages safety.
It would be interesting, unlikely and most of all extremely difficult for HSE to bring a criminal action against a PC for non compliance with a site rule. In effect it could be argued that clients would become legislators which they clearly are not. To take this argument to its daftest extreme, a client could have a site rule for contractors to walk backwards on Fridays?
It couldn't be enforced and non-compliance would not be a criminal breach.
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Posted By Robert K Lewis
Ken
All rules have to be seen in the light of reasonable and such as pink hats on a Friday are not in this realm. It is however reasonable for the employer/client to set out rules such as I do not want stepladders and ladders used during any work for me. As I made clear the HSE approach would be one from a failure to manage what is in the plan and thus is evidence of management ineffectiveness if a rule is set but not then enforced. Why set out a rule if it is not to be enforced. Equally if you do not like a client rule the options are
a) Negotiate a change and relaxation
b) Negotiate a removal from contract and plan
c) Tender for another job and leave the client to those who will institute and enforce the rule.
As a PC we may well call the HSE in to ensure the other contractors follow the rules we wish to set - where is the real difference?
Having said that I do not think blanket bans work because there will always be the exception to any rule.
Bob
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Posted By gham
Who has the overall resposibility of safety on the construction site?
Whose Site rule should be inplace?
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Posted By Robert K Lewis
gham
The PC has
Both the PC's and any the client wishes there to be - subject to previous discussion comments
This is not a question of who is responsible but rather the ability of the client to make rules which then need to be enforced.
Bob
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Posted By gham
Yes I know!
The point i was trying to make is that surley if you are to be responsible for the enforecemnt of the rules you would at least want to negotiate their content, resulting in a set of rules that are practical and enforcable, rather than attempting the impractical requirements of an overzelous ill informed client, they after all as you have pointed out will not be responsible for managing health and safety on the site.
Don't get me worng we have worked on sites were ladders and step ladders have been banned and there where few problems if any and other site it has been a nightmare
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Posted By gham
And yes I know I should have checked my spelling... I'm sorry!
G'
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Posted By ADEPTSAFETY
The rules do have to be enforced by the PC according to reg 16 of CHSWR but they have to be reasonably practicable. Asked an HMI construction yesterday and would only be looked at if there was an injury or loss. Sorry about posting for a Nurse in the chat section is now in careers forum.
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Posted By Robert K Lewis
G
It is friday after all. As I have tried to say all along PSs we can ignore but not if the client is indicating a requirement - we have to address it with a degree of acceptance even if we seek to change it.
Sorry to keep banging on about it but negotiation ability is often a key skill to have.
B
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