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Storage of bales of hay in barn and the working at height regulations
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Posted By Chris Knagg Setting the scene
Bales of hay are stacked by hand from the floor to the eves in one bay of a large pitched roof agricultural steel framed building. The hay stack is supported on three sides by the building structure and the bales are stacked by bonding the layers to key them in and prevent collapse. The sides of the building is yorkshire boarded. That means there are small gaps between the vertical boards for ventilation. You can not fall from hieght on three sides of the stack. The side which faces into the building you can fall from.
Custom and practice is such that when hay is required for feeding the animals, the farm staff climb a ladder and reduce the stack layer by layer to ensure the stack remains stable dropping the bales to the floor as required on a daily basis during the winter months.
Risk There is a risk that someone can fall from hieght and there is a risk that someone could be hit by the bales of hay as they are dropped to the ground.
Question
What is the safest most reasonable and practical cos effective solution to this problem?
Your opinions, advice and comments are welcome
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Posted By Frank Hallett Interesting question Chris
It would appear that there is no compliance with the WaH from your description and I bet that the legislators don't even understand your problem; though that's no defence as the WaH Regs IS the curent law.
You're obviously already seriously considering this so - how can the traditional methods can be modified to meet the WaH requirements for storage and removal?
Either a hinged & fenced platform capable of being adjusted for height [not an MEWP], or a move away from working at height altogether by means of [suitably] modified plant.
Sorry, but the specifics would need further info.
Frank Hallett
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Posted By Chris Knagg Frank,
You have hit the nail on the head.
1) The (young) EHO (not HSE) inspector has challenged the work activity on the basis of the application of WAH at this farm and is minded to place a prohibition notice on the activity. This places immediate difficulties in feeding the animals which then puts the farm in breach of animal welfare legislation! And yes I don't think he understands the activity in this context
2) This activity is undertaken on thousands of farms in the UK
3) I am not disputing the application of the law and indeed it is recognised that there is a benefit inmaking the improvements.
4) The dificulty is what is a reasonable, practical and affordable solution to the problem?
Long term the farm is considering moving to mechanical handling, but they sell hay to others and the small bales are an important revenue stream so they need to store the traditional size bales whilst their own use bales can be high density and mechanically handled but they need to make an investment to get the equipment to do this in the future.
The building is a traditional steel portal frame multi purpose storage barn and cattle shed which is lees than 3 years old. It needs to be a flexible space and so having some permanent edge protection system, whilst possible, needs to be adaptable and flexible and this has its own attributable risks in the erection, adjustment and dismanting of such a system.
I have thought about fall arrest systems too but the challenge here is where do you secure to.
Looking at the bigger picture hay making and gathering in the hay in traditional bale size presents a number of working at height challenges if done the way "its always been done"
My difficulty is what does the Farm Manager tell the EHO upon his return?
Short term, get a scaffold company in to erect edge protection on the stack. Is this reasonable and pactical?
Medium term, investigate the practical use of a fall arrest system and fit anchor points and safety wire. Signicant cost, training and annual operating costs that may cancel out the revenue generated by the sale of the hay, defeating the reason for making hay. Need to evaluate. Is this a practical and reasonable solution.
Long term, move towards mechanical handling of high density bales. Business plan making provision to make this investment. The Farm is a Charitable Trust working farm that works with homeless and vulnerable young adults and relies heavily on funding and charitable donations to operate so investment in plant and machinery has to be carefully planned.
In addition to all this there is a need to look at the stacking of bales on trailers in the field as well, as there is a significant WAH issue here also.
After all that rambling, I suppose I am looking for some concensus of opinion and support from my peers that I am tackling this challenging problem in a balanced, reasonable and practical way.
If money was no object I know exactly what they need to do. But money is a factor!
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Posted By Frank Hallett OK Chris
The 2nd posting was extremely useful as it identifies that you've got a clear understanding of the requirements and the fundamental issues and cuts out all the stuff you know already.
I would suggest that you aim for:- You re-store the "traditional" bales in something similar to a large stock-pen or old-style bunker arrangement so that the "working face" is always prevented from collapsing by a robust wall that can be progressively raised or lowered as the height changes [demountable fencing] and can be fitted with a "Youngmans" or similar working platform that has the necessary access and fall prevention measures.
Harnesses & fall arrest may appear like a good interim or even long term; but, as you identify, they introduce a range of other problems - not least the essential training, selection of equipment, supervision to make sure it's used, etc AND emergency procedures required to ensure that no-one can be suspended for longer than about 10-15 mins and can always be retrieved to a safe place without external assistance.
If you find that you really need in detail help; please email me direct.
Frank Hallett
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Posted By CB I thought the guidance allowed for short periods of working time off a ladder i.e. enough time to paint a window. How long does the working process take?
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Posted By James M CB,
The windows in your house, my house or Buckingham Palace??
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Posted By CB I dont know, I live in a bungalow
CB
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Posted By Chris Knagg Gents, I'm sure your humorous comments are meant with good intention, but on Monday morning an EHO is returning to this charitable trusts working farm with the intention of serving a prohibition notice on the activity of retrieving hay from their barn which will mean they will be unable to gain access to their food stock for their animals.
I am looking for professional constructive and intelligent comments and solutions on this real life issue that potentially could have an impact on every farm in the UK.
So unless you can join in and be helpful #### off and stop making stupid comments because I get an email every time saying some one has made a contribution to the thread and I'd like them to be relevant and helpful comments.
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Posted By Danny Swygart Mobile Tower Scaffold?
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Posted By John Webster It's a good few years ago now, but my Grandfather had a Dutch Barn in which he stored traditional bales of straw and hay. As a youngster I often assisted at harvest time. As I recall part of the working end of the stack was left stepped. About half height a "platform" was created, and covered with a sheet of timber which extended under the adjacent bales to keep it secure. Edge protection was provided by the walls of the barn, at least until the stack was quite low, and although it was possible to fall down the "steps", it was unlikely to be traumatic. Bales could be thrown from the top onto the platform, then from the platform to the ground. This reduced the risk of bales bursting.
Maybe those old timers weren't so daft
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Posted By Mev Chris Is the roof structure directly above the stack made of steel beams and capable of being used as a secure point to hang an inertia reel from taking into account shock loading, if so hang a reel with a line connected to the hook so you can pull the inertia reel line out without leaving the floor, connect it to your harness then climb the ladder and do what you have to do, when finished climb back down and unhook, would this help in the short term, obviously the training would come in to it but shouldn't be difficult.
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Posted By Dave Daniel Chris:
The WAHR actually say "where work is carried out at height, .. suitable and sufficient measures must be taken ... so far as is reasonably practicable...".
Contrary to the opinion of some (including HSE inspectors) there is no ban on the use of ladders and there is certainly scope to work near open edges where this cannot reasonably be avoided in the wording of the law. The WAHR also apply to sitting on a horse for example and I've yet to see anyone daft enough to apply barriers to that!!!
You may wish to consider whether the transitory nature of the work and the varying height of the stack make the use of any protection really appropriate, particularly given the traditional nature of the work. Your "suitable & sufficent" seems to be the fact that there's walls on 3 sides.
Try asking the EHO what they believe should be done and ask them to point to a farm where such methods are actually used... If there is a "reasonably practicable" solution then I'd expect to be shown someone using it.
Your final fall-back if all else fails would be to challenge any action in the courts. remember that the EHO would need to show that there was a "reasonably practicable" solution to convict you (unless you plead guilty to avoid the cost)
As a safety consultant I'm often placed in a position of challenging the unreasonable demands of the enforcement agencies. It can be done but it is time consuming.
Good luck Dave
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Posted By alison lothian HSE advice safe stacking and handling of bales on HSE website. Why is Local Authority inspecting agricultural activity?
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Posted By ian mcnally Chris,
I assume you don’t have a tractor with bail spike, these as you probably know are good as they avoid work at height altogether. But on the assumption you do not, Dave Webster’s response was logical and very practical, albeit you will lose potential storage space it would seem a good solution. Ok the operatives may be exposed to a small risk but only the height of a bale at a time and we do have to consider cost.
If you happen to have a mobile tower knocking around (it’s amazing what some farmers store) this could be used to provide progressive fall protection at the leading edge and could improve storage. The ramped bales could be placed to suit size of tower.
Not sure if harness use is really practical for a small farm tight on funds (most are) as you would need to consider – purchase – training- inspection – attachment points and of course rescue provision (less than 10mins) but the retractor / inertia reel could be a consideration that might keep the EHO happy short term but to be honest would it be used!
I have done a little hay bailing / stacking works myself and would have to say moving bales on or from a ladder would not be advisable.
Would be most interested to hear what system you adopt
Best of luck
Ian
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Posted By Chris Huckle Hi Chris
You are not alone with your problem it has exercised our minds for a considerable amount of time. The approach that we have used to try to reduce/minimse any working at height, is to use a materials handler/foreloader fitted with a flat eight grab (that we use for loading and handling small bales in the field) and mechanically load and unload the barn, you do end up with a stack that is not quite as stable as if you do build it by hand but if nobody is going onto the stack it helps eliminate the problem.
The other option is to move gradually to large bales that have to be handled by machine, leaving only a minimal number of small bales.
Whilst I know that neither the above situations are perfect it would show that you are trying to manage the risk. You could also point out to the inspector the number of people injured when removing bales from the stack at ground level and making the stack unstable.
If they still insist you should ask them what their solution would be. I also think that you need to be realistic in that I am sure you would have a devils own job getting someone to put a harness on everytime they went onto the bale stack. I am sure they would do it when you are there but when they work on their own I would doubt it very much.
If you want to discuss it further drop me an email.
Good luck.
Chris
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Posted By Chris Knagg
Thanks to all who have made constructive contributions to help me with my reality check. Richard Hinckley from Total access has given me some inspirational thoughts about using nets to protect the unprotected edges.
Mechanical handling is certainly a solution they will be moving towards, but it is not entirely the solution.
Thanks everyone. I'll let you know the outcome.
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Posted By John Webster Following Alison's posting, I was curious enough to look up the HSE's leaflet on the topic INDG 125 Handling and Stacking Bales in Agriculture http://www.hse.gov.uk/pubns/indg125.pdfTheir high tech solution for your situation is "Avoid working near edges" "Consider guarding the edges of stacks in buildings by fencing in non-loading sides" "Use a strong ladder which is secured to prevent it slipping and is long enough for the job". Suggest you get a copy for your enforcer!
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Storage of bales of hay in barn and the working at height regulations
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