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#1 Posted : 18 January 2008 10:10:00(UTC)
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Posted By JonH
Here's one for a Friday - the work at height regulations. Falls from height are the joint largest cause of fatalities in the workplace. OK so we have controls in place to eliminate work at height, reduce the work at height or at the very least, reduce the consequences of falling from height. OK, lets look outside the workplace.

If I stand on the platform of a train station, the only thing stopping me from falling a metre on to an electrified rail and a Virgin express doing 120mph is a strip of yellow paint!

On the Jubilee line in London round by Canary Wharf, they have a barrier/door system so you cannot gain access to the rails from the platform. When the train arrives, the screen doors open and the train door opens. The doors close before the train pulls away again.

If they can implement this system in London, why have they not rolled it out across the network? I know why - the vast cost of doing it. I am waiting for a case where someone drops off a platform at a station, and the family seek compensation. What would be the result, with the fact that there is a system known and in operation in London? The family could argue that it should have been in place?

What are the stats for injury/death at station platforms?

What do you think - should more be done to protect platform edges? Or should it remain as it is, with the onus being on the individual to look after themselves. What about the young parent with lot of bags and a little child who runs off and falls over the platform?

Jon
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#2 Posted : 18 January 2008 10:18:00(UTC)
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Posted By Tabs
I have mulled over this a few times myself ... in 1991 when I visited Hong Kong for the first time, they had the door system on their underground and I was impressed.

I used the Jubilee line for 18 months and the system was generally very well designed (a few minor problems, but nothing that would stop you using it everywhere).

My local station is an old Victorian affair and I would love to have the protection against the weather that such a design would offer ...

But ... I am not sure that all the trains have all the doors at the same spacing. Can a train buff help me there please?

I think the new trains on our line has slightly different spacing. Bit of a pain when trying to line it up with the sliding doors of a barrier.
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#3 Posted : 18 January 2008 10:33:00(UTC)
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Posted By Liesel
Jon, I don't know if you're being tongue in cheek here, but here goes........

Like with other activities, rail safety is based on the ALARP principle and Tolerable Death limits (there is also a "broadly Acceptable Death Limit" value for rail passengers). The rail industry has a sophisticated model for hazard identification and risk assessment to deliver such. So I think you'll find that these issues have been and are assessed- a trip to the ORR website and a look at "Railway Safety Principles and Guidance" and a trip to the Railway Group Standards site and you'll find the methodologies used.

"RSPG Principle 11: Platforms safe for people. Platforms should allow for the safe waiting of people, their boarding and alighting from trains."

Also, I have been told that the Jubilee line platform doors are more about air flow control in tunnels than about people falling/jumping off platforms.

But, no doubt there is someone far more experienced in rail safety than I am on here who can explain better.
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#4 Posted : 18 January 2008 10:43:00(UTC)
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Posted By Sally
This concept of numbers of acceptable deaths and injuries is one that we tend to shy away from but one that is important in effective safety management.

OK so if someone is killed falling off a platform (as people occasionally are) and the family sues for compenstation the cost of paying this is still considerably less than cost of implementing the control measures. In fact you could pay compensation to a fairly large number of families and still be in pocket.

This idea that we should prevent all deaths and injuries and avoid being sued at any cost is what leads to the conkers bonkers culture. We could prevent 500 deaths in Scotland alone each year by banning cars - but no-one would seriously suggest it.

The idea that it is ok for a small number of people to be injured and that if they are we may need to pay compensation needs to be accepted if we are to avoid scenarios like the one banning homemade cakes in a college.
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#5 Posted : 19 January 2008 17:23:00(UTC)
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Posted By Ben Keen
Maybe some people don't have enough to do on a Friday.

Have a read of this report http://www.rssb.co.uk/pd...Station_Safety_Final.pdf
and you will see that falls from platforms are far from the biggest issue at stations. Of course some people do manage to fall from platforms; Charles Darwin has theories on that one. I'm not dismissing the occasional unfortunate or innnocent falling from the platform but the point about ALARP is well made.

The Jubiliee line is underground, the platforms tend to be more crowded and different issues arise. It is cheaper to fit doors when building a new line for standard configuration trains than to retrofit to existing lines, hence some of the Jubilee has doors, some doesn't. When building the Jubilee Line extension it was seen as desirable and affordable to install the doors, and very nice they are too.
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#6 Posted : 20 January 2008 12:55:00(UTC)
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Posted By Bob Shillabeer
Thanks Ben, glad to see some sence on this one or we would end up with fancy doors all over the place and lots of trains out of service because they won't fit where the opening doors are on the platform. The railway companies have many different types of train that fit onto an open sided platform with ease but with so many different types of train how can you design a platform barrier to fit all trains, a lifting one purhaps. Anyway look at the work that has been done to address the most common types of platform incidents such as drunken behaviour, station overcrouding, etc. That's the biggest problem not the lack of a barrier between the platform edge and trains.

Bob.
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#7 Posted : 20 January 2008 15:54:00(UTC)
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Posted By Al..
I think we should look at Jon's original question from another perspective. He asks "should more be done to protect platform edges?" We quickly concluded, no, it's not really feasible. Instead we concentrate on trying to control the behaviour which results in people falling off platforms. No argument with that.

However, if we are prepared to accept railway station platforms with no edge protection, why do we get so uptight about needing edge protection in other places? Many of the staff in my company would be quite happy to work on flat roofs with no edge protection and no other safeguards. They would behave in exactly the same way as they would on a station platform and avoid going too close to the edge. However the company (and the HSE) does not allow them to do this. We demand edge protection or other safeguards. We do not allow them to use their common sense.

What is the difference between doing a job on a flat roof and doing it on a station platform?
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#8 Posted : 20 January 2008 17:39:00(UTC)
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Posted By MP Grayson
Al..

Is that question a wind up questions?
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#9 Posted : 20 January 2008 18:03:00(UTC)
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Posted By Al..
No, not a wind up. It is genuine request.
What is the difference between doing a job on a flat roof and doing it on a station platform? Falling from both can result in death, one from impact with the ground, the other from impact with a Virgin express or electrocution from the third rail.

The answer might be obvious to some, but I cannot, for the life of me, see it. Help me please.

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#10 Posted : 20 January 2008 19:46:00(UTC)
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Posted By Ben Keen
The original question was about standing on a platform waiting for a train, not WORKING on a platform. If you are working on a platform then the requirements as for any other workplace are applied. You could draw a comparison with sea defences, you can walk along the sea wall and the cliffs at your own risk because you choose to be there; if it is your workplace then your employer must exercise his duty of care. You can also maintain your own flat roof with no edge protection, that's up to you, but not if your employer requires you to do it.

Bottom line anyway is, if you fall of a flat roof you'll probably die, if you fall off the platform you probably won't (especially as the live rail, where fitted, is very rarely on a platform side).

The death of any safety professional is when he starts looking for problems that don't need a solution; and misses the ones that do.
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#11 Posted : 20 January 2008 21:01:00(UTC)
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Posted By Al..
I am not convinced by this. What about two employees, one tasked with sweeping a flat roof and one tasked with sweeping a station platform. Both at work, both at risk. There would be protection for the roof worker but nothing for the railway employee. (The station by the way is on a very busy line with trains passing through every few minutes, many at high speed.)

30 to 40 years ago the chances are that both workers would have worked with unprotected edges. Now it is only the worker on the station platform. Is it simply that the risk on the roof is higher or that it is not reasonably practicable to protect the edge of the platform?

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#12 Posted : 20 January 2008 21:17:00(UTC)
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Posted By Liesel
Al, if you want to understand the rationale go take a look at some of this:

http://www.rail-reg.gov.uk/server/show/nav.1118
and http://www.rail-reg.gov.uk/server/show/nav.1096

Gives a flavour of the extent the risk analysis goes to on the railway, and hence why that mode of transport is so safe compared with our beloved cars. I wonder, if it was decided that all station platforms need have doors at edge, maybe all pavements would simultaneously be fitted with chest-high barriers to stop pedestrians stepping out in front of cars....? Doors interlocked with the traffic lights at specified crossing points- and systems in the cars so the drivers don't jump said red lights? [takes tongue back out of cheek].

Also, trespass and level crossings seem to be the biggest problem in terms of folks getting flattened by trains. You watch car drivers and pedestrians trying to "beat the barriers" at a level crossing or the bods who take a "short cut" across a high-speed main line and you'll understand what I mean.

To try answer your q a bit better Al the point of all this is that it is about relative risk. That the risks of falling off a platform and having an argument with a Virgin express are pretty small and below a level society regards as significant. There is no such thing as an activity with NO risk- it's all about what society regards as acceptable, hence my points about ALARP and tolerable death limits above. These issues ARE assessed too see R19 of ROGs.

As for worker safety; the rail industry controls this rather more tightly than most, especially if there is a hint of going anywhere near the line.
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#13 Posted : 20 January 2008 21:24:00(UTC)
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Posted By Pete48
Of course we have been instructed by the rail company on how to behave; there are both visual and verbal information/warning aids to remind us. Now if we also accept that a % of the populace will never follow instructions out of sheer individualism and another % will not understand or have the ability to act in the required manner and a further % will be talking on their mobile phones whilst kicking the nearest empty coffee carton over the edge of the platform and will hear neither the announcement or the approaching train; we have a pretty large variable to include. So, are there any numbers?
I seem to recall reading somewhere that on LUL there were about 9,000,000 interface events PER DAY. ( people in the zone, getting on, getting off etc) There were about 4500 incidents PER YEAR and those include wilful actions to self harm. So, if you want to put some numbers into your assessment, you might try those until you find something better.

They sort of suggest to me that most of the time, most of us have enough common sense to follow the simple precautions and stay safe.

Put against the cost of protection, because protection is possible?

" I don't believe it" to coin a well known catchphrase. Maybe this is a case where we have done enough to control the risks and it is tolerable today.(ooh did he say accept a risk?)
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#14 Posted : 20 January 2008 21:33:00(UTC)
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Posted By Ben Keen
If there's one thing better than risk assessment, it's experience. When you have 150+ years of stats you know which risks need looking at, and which don't.
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#15 Posted : 20 January 2008 21:59:00(UTC)
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Posted By Pete48
I should perhaps explain that I was talking about passengers or members of the public in my post which I was writing whilst others had posted.

Ben, I think I know what you mean but not sure I agree with the experience beats assessment line as written. Are they mutually exclusive or does one inform the other?

Is it really true that railway workers do work at unprotected edges in the manner suggested by the example given? Seems unlikely to me but I have no information other than observation of work along the railway.
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#16 Posted : 20 January 2008 22:43:00(UTC)
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Posted By db
It's quite easy surely? If you fall off a roof there's no need to jump the seven feet or more back up before a train comes. You'll more likely be dead.
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#17 Posted : 20 January 2008 22:49:00(UTC)
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Posted By Ben Keen
Of course the experience informs the risk assessment, you apply appropriate controls (e.g. competence of the individual) and move on. Train speed, frequency, electrified or not etc. are all taken into account. I've given a reference to a document in an earlier post which gives you a feel for the significant risks related to platform edges.

The beauty of a regulatory system that requires consious thought, risk assessment and approriate management action is that we don't end up with blanket rules that are not appropriate. This is where the true safety professional saves the employer money to spend on the real risks.
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#18 Posted : 20 January 2008 22:53:00(UTC)
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Posted By Ben Keen
Seven feet! BIG TRAIN!

It's more like half that.
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#19 Posted : 21 January 2008 09:51:00(UTC)
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Posted By KEVIN O'KANE
I recently went on a real ale train special in Hampshire one saturday night in November.This runs monthly and has done for many years.Old type steam train, with slam doors.The train stops at different stations to allow people to smoke and use loos ..even though toilets on train.Anyway at one station wewe were told not to get off the train ...I did after asking guard if we had time for quick smoke ..he answered yes as long as we stood by his carrige and jump on when he told us.Train leaves platform , suddenly stops and there is a 61 year old man under our carrige ...he tried to board train whilst it was moving and was dragged under and killed!..H&S ..who needs it...A bloke goes out for a night out, with his wife and is killed!What could possibly go wrong?It was a horrible night out
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#20 Posted : 21 January 2008 11:11:00(UTC)
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Posted By Andrew M
Call me cynical if you want, but railways used to be a public sector industry - now they are in private hands but they still recieve a substantial public susbsidy - the reason why they are not affected by the same level of regulation is due to the effect it will have on the public purse.

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#21 Posted : 21 January 2008 11:28:00(UTC)
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Posted By M Forbes
See the problem arises due to the lack of clear guidance on working at height.

The problem we face is that working on your tiptoes, can be claseed as working at height. Standing on a chair is working at height, being lifted by another employee is working at height. . . .

Working at height is a widely interpretable term, that people take too far. Working at height regs should only be applied where there is a high risk of a serious injury relating to falls.

Risk = Severity x likelihood

However at the moment it is applied to any situation where "height" is involved. Until HSE provide clear legislation that actually tells us what to do, we're always going to be pestered with if's but's and maybe's.

Why is health and safety law treated differently from criminal law. Criminal law defines EXACTLY, what attributes to commiting an offence, and EXACTLY what the consequences are. Criminal law says "you MUST NOT do this" or "you MUST do that". However compare it with health and safety law, "IF you commit an offence - which we will have to decide is an offence, (as there is no definition of what is classed an offence), we may or may not prosecute you and we may or may not be successfull, as you may or may not have the adequate control measures in place (which also have not been clearly defined). In which case we may or may not find you guilty, however if we find you guilty we WILL punish you, to whatever extent we want to make up at the time.

I bet employers probably get slapped harder on days the judge has been arguing with his wife.

Health and Safety law is a joke, as there is no "letter of the law" just interpretations.

This "Breach of duty of care" is the same as criminal laws "committing a crime" (Breach of the law). Would it be acceptable to charge someone for "committing a crime", or do you need to state what the crime was and exactly where it is IN WRITING in the law. I.e. to charge someone for murder you have to show the law that says murder is illegal and apply the guided sentances.

In health and safety people get charged for breaching the duty of care on the account that an employee got killed whilst performing "task a". Unless it says in writing it is illegal to allow "task a" to go ahead without these defined set of control measures in place, how can employers be charged for not doing it.

Too much is left to interpretation and it is really not acceptable.

Regards

M Forbes
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#22 Posted : 21 January 2008 12:15:00(UTC)
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Posted By Ian_P
I think you've entered another argument there MF, or are you just having a bad morning?! Read the Robens report, which lead to the so called 'interpretation' of legislation.

Incidentally, didn't the Work at Height regs have a specific ruling (.....2 metres anyone?). The whole reason the "do this" and "don't do this" wording was removed is because people can be just as injured working from a chair as they can from 6 foot. It's up to us to make a suitable and sufficient assessment of this risk.

In my and many peoples opinion, modern legislation is more effective than the old stuff (take the factories act for example). But that's an argument for another day...
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#23 Posted : 21 January 2008 12:47:00(UTC)
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Posted By anon1234
Haven't read all the responses, but here is my view for what it is worth:

I think you have identified the reason - cost. i.e. it is not reasonably practicable - when you weigh up the time (disruption) and cost involved in such an activity compared to the history of such events the scales do not balance or tilt in the favour of doing the work.

However, that said, it could be argued, as was probably the case with the Jubilee line extension etc - that on new builds and major refurbishments it MAY (I stres the word may) become reasonably practicable to undertake such works
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#24 Posted : 21 January 2008 13:40:00(UTC)
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Posted By M Forbes
Lol i suppose i am having a bad morning really. . . . well was, now im having a bad afternoon. I guess i'm just in the mood for an argument.............. that said i don't agree that modern legislation is more effective, as you have small companies being shut down as a result of "interpretable" laws. I.e. as it didn't say specifically anywhere to do this, and they never identified a risk (i.e. using a stepladder). If said person falls of stepladder falls against sharp object - splits head open and dies of brain injuries from bone entering the brain, The small company would be held responsible, even though it hasn't really done anything wrong.


If the HSE even laid a framework, i.e.

Risk = Likelihood x Severity

Likelihood can be broken into:

1 - Highly unlikely (No forseeable opportunities for injury)
2 - Unlikely (Few forseeable opportunities for injury)
3 - Likely (Small amount of forseeable opportunities for injury)
4 - Very Likely (Many forseeable possibilities for injury


Severity could be broken into:

1 - No forseeable possibility for injury
2 - Forseeable Possibility of minor injuries (cuts, bumps and bruises)
3 - Forseeable Possibility of severe injury (broken bones, lacerations, acid burns etc)
4 - Possibility of death.

Then if they laid down that framework they could say, If the risk is between
1 - 3: This is acceptable and does not require a RA.

4-8 a documented risk assessment will be required.

9-12 a review of the processes and procedures must be performed and if nothing can be done to reduce the risk a record declaring these findings and the need to perform this task will be kept

13-16 The job must be stopped and ways of reducing the risk to employees must be put in place before the task can proceed.


Surely thats a solution. . . if people got confused over the categorising of tasks HSE could submit examples.
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#25 Posted : 21 January 2008 13:43:00(UTC)
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Posted By Colin Reeves
Luckily, in my industry, the "2 metre" rule is still in place which makes life much easier!!

Colin
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#26 Posted : 21 January 2008 13:44:00(UTC)
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Posted By db
OK, It seems Ben at least missed the irony of my post.

Compare how many people fall off a roof and are sreiously injured compared with falling three feet off a platform - and how many are actually hit by a train (taking away suicides as we were talking of people sweeping up next to the platform edge).

Then take the cost of putting widely available, relatively easy to use control measures in place compared to the astronomical cost of putting in barriers on all platforms (where very few people are killed).

There has to be some cost benefit as I'm sure all the posters are aware... blah blah blah..

Surely this is basic stuff?
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#27 Posted : 21 January 2008 14:37:00(UTC)
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Posted By MP Grayson
I have two issues here.

1. I've got to go to London soon. By train. Please help. D'OH.

2. I can actually remember steam trains. Double D'OH. Was there an issue then or was it before safety was invented in 1974.

Seriously: -
Al.. Hopefully the post after your last one answered your question?

For the rest.
The answer is a simple one. Cost, (my opinion only)

Crack on.
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#28 Posted : 21 January 2008 15:46:00(UTC)
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Posted By Ian_P
.....right....

You're confusing me now MF.

You've just described, broadly speaking, the Management regs - thoroughly modern legislation. i.e. Assessing risk, recording significant findings & reducing risks where necessary / possible.

Anywho, enough hijacking of this thread.

Apologies Jon et al.
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#29 Posted : 21 January 2008 16:45:00(UTC)
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Posted By M Forbes
Yes and no.

Yes this is the duty of care part of the management regulations. However this would be setting a clear plan for all occupations to obey. At the moment its up to the company whether to risk assess, whether to document it, the layout of the assessments, the content etc etc. If they get it wrong they are responsible, yet if they need assistance getting it right, no-one can help. . . . they just get told to do a risk assessment. . . .

This would be CLEARLY defining what situations require a documented Risk Assessment, those that are not risky enough to require a documented assessment, employers shouldn;t be held reliable for any accident.

I hate all the storys about H&S bonkers conkers. We need some way to control the Risk Assessing making a cup of tea and Risk Assessing using a pen. . . it's all taken too far, and apologies for thread hijacking.

Regards

M Forbes
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#30 Posted : 21 January 2008 17:00:00(UTC)
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Posted By Jon H
Wow, that was quite a varied response!!

My point was that in some cases, I believe that H&S law (or some peoples interpretation of it) is a bit daft in places, such as the WAH regs. I have clients who tell me that they have to call in electricians to change a light bulb because "its working at height, and ladders are banned" or guys on site who have come back to do some snagging work on a curtain rail and cant unless a scaffold or mobile tower is in place.

I fully support the need to reduce falls from height, and the resultant injury and death, however I do think that some of the controls that some people implement are excessive in places, such as bringing in a mobile tower scaffold and two competent persons to change a spotlight in a ceiling (the result being that the company wait until most bulbs are gone before calling in the sparkies - they fail to realise that staff are stumbling around in near darkness due to lack of lighting...) The employees who stood round watching the light bulb being changed, then go home and de-moss their guttering, or climb Snowdon, or catch a train (with a 3ft drop to the rails), and then moan at us safety people for imposing "stupid rules, just to make you guys some money - your not health and safety, your wealth and safety...etc etc ad nauseum"

The point being, a little modicum of common sense is required - problem is, its not always common, or sensible.

As for the original point about the trains, thanks for the responses, I don't have any experience of railway safety, just curious to know what the outcome would be in the event of an accidental death, such as the child running off, if a savvy lawyer tried to imply that as controls are in place elsewhere, why were they not in place in this instance?

Cheers all, keep up the healthy debating!
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#31 Posted : 21 January 2008 18:48:00(UTC)
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Posted By Al..
Point well made Jon. The HSE have to carry out impact assessments before proposing new legislation. Perhaps those impact assessments should also include the likely cost to the economy of people failing to understand the legislation and over-zealously interpreting it along with the likely damage to the overall health and safety cause from the resulting media response.

I suggest that WAHR has been a bit of a disaster and we could have done without it.
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#32 Posted : 22 January 2008 15:51:00(UTC)
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Posted By Ian Mitchell
Hi.

The yellow line on station platforms is not there for passenger safety per se. For rail work you are either 'on or near the line' 'on the lineside' or 'in a high street environment'. On or near the line is within 3m of the nearest rail with no permanent barrier between you. Lineside is more than 3m from the nearest rail but visible to drivers, and high street is where you cannot import risk to the infrastructure by your works.

Station platforms are treated differently. You are not 'on or near the line' when working on a platform unless you are within 1.25m of the nearest running rail. The yellow line denotes this distance for rail staff.

Works 'on or near the line' are treated very seriously indeed. If you want to work beyond the yellow line you must protect or possess the nearest running line first. It won't stop you falling over the edge, but it will stop you being squashed as you climb up the 3ft 3ins back onto the platform!

Regards

Ian
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#33 Posted : 22 January 2008 19:27:00(UTC)
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Posted By Al..

Interesting stuff. You never stop learning. Perhaps then a yellow line around my flat roof, 1.25m from the edge. Special precautions required beyond the line. Anything goes this side of the line.
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#34 Posted : 22 January 2008 22:06:00(UTC)
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Posted By Raymond Rapp
On the basis of risk, Automatic Train Protection (ATP) would have been rolled out all over the UK. Ladbroke Grove, Southall, Clapham and Purley train accidents would have been prevented. However, a little thing that is far more important than ALARP got in the way - CBA or cost in simple terms.

Why is it that very little attention is paid to the thousands who get killed on the roads each year? What a strange world it is...

Ray

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#35 Posted : 22 January 2008 22:34:00(UTC)
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Posted By Al..
3000 or so road deaths every year - tolerable risk?

250 or so workplace fatalities every year - tolerable risk?

Rail fatalities, not sure - tolerable risk?
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#36 Posted : 24 January 2008 13:15:00(UTC)
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Posted By Ian Mitchell
"Interesting stuff. You never stop learning. Perhaps then a yellow line around my flat roof, 1.25m from the edge. Special precautions required beyond the line. Anything goes this side of the line."

Do I detect a touch of sarcasm/tongue in cheekness there? ;) The yellow line is for the passing trains, not to protect against the drop!!!
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