Posted By Dave Merchant
There is nothing in the Work at Height Regulations nor in the current Falls From Vehicles campaign that bans workers from standing on the bed of a goods vehicle where it's justified by a risk assessment, and there's no intention to impose such restrictions.

You must take 'reasonable steps' to make work at height as safe as is reasonably practical, so for example you wouldn't climb onto the vehicle for no good reason, or hold an Xmas party on it, but short-duration access as part of commonplace unloading operations is perfectly OK. If the vehicle has edge barriers they should be used where possible, if not, the worker simply has to take a little more care to look where they're going! Given the stability of a vehicle vs. a portable ladder it's far LESS safe to restrict your workers to hook up lifting gear from a ladder instead of allowing them to stand on the vehicle bed.

The techniques used as examples in the current FFV campaign only work in specific situations, often where a vehicle is accessed from a fixed structure (such as filling a bulk tanker). Beyond that the general guidance is the same as it always has been - keep the surfaces you're standing on clean and maintained (no oil or loose piles of pipe) and don't act like a fool while you're up there.

Posted By Jim Masson
"keep the surfaces you're standing on clean and maintained (no oil or loose piles of pipe)"

Interesting, half of our yard work is unloading returned pipe from rigs...

Posted By Dave Merchant
ahh, I can't be giving you perfection, can I!

(OK, I can, but it costs you a beer...)

The only reason for the RA is to have something on paper that shows why the guy's on the truck in the first place - it's a trivial thing to do and would basically say:-

1) can they do the task from the ground? no.
2) is a portable ladder safer? no.
3) is it practicable for a working platform to be built? no.
4) are the truck and any side panels, steps etc. maintained in a safe condition? yes.
5) is the task kept to a minimum? yes.
6) is the person able to hold their balance better than a flamingo on heroin? ...probably.

Posted By Mark Eden
with regard to the initial comment that the WaH Regs are unworkable - last year five people died falling off the backs of delivery vehicles and numerous people were seriously injured.
Other respondees have given their (very good) responses and opinions.
The Regs are there to help us all perform our various tasks in as safe a manner as possible not to hinder, as a lot of people think. I agree they don't get them right first time all the time but the powers that be are getting there. So lets stop the griping and get on with our job and help operatives carry out their work in a safe and practical way

Posted By David McGuire
Why not source a supplier who will palletise the goods etc?????

Posted By Stephen Sherratt
Back in 2006 we reviewed totally our work at heights in one of many areas we covered were Harnesses. we set about a programme of new User Training and Harness Inspections at three monthly intervals. Roughly a quarter or our Harness Users have done a Gotcha Rescue training Course and we have purchased two GOTCHA kits for site work and their capacity suits our scope of work and assessment of the hazard.

They are available from two sources as is the User Training

http://www.ppsafety.co.uk/index.php

http://www.spanset.co.uk/height_safety/rescue.aspx

There is a great film clip of the Gotcha on the Spanset site – I stress it’s not for all. Both are excellent companies. A suitable rescue plan should at least detail:

Where the Rescue Kit stored. (near to the work)
Set up good communications between the workers at height and the rescuers
Nominate a trained rescuer and First Aider.

Finally you need to do a bit of re training with your First Aiders in Suspension Trauma.
Most First Aiders are trained to put the casualty in the recovery position – If they do that to a ST victim they will kill him. Read the following link.

http://www.system-concep...rticles/article0210.html

Stephen

Posted By Melanie Fellows
My dilemma is that our goods cannot be palletised and is so diverse we can't seem to find a suitable solution to our men working from the back of trailers when loading and unloading.

We deal with large steel structures and steel beds. Sometimes we can offload using fork lift trucks, sometimes with cranes. There is no anchor point for harnesses and no-where to fit one. We can't use a working platform due to the variation of the works and steps/ ladders to the trailers seem to cause more problems than they solve.
When loading the trailer, a man is required to be on the trailer to assist and direct the crane operator (or fork lift driver) and put blocks of wood down on the trailer to support/ secure the load.

We do have a risk assessment in place, but is that enough?
Would it be beneficial to provide WAH awareness training? (& would this prove that effort has been made by the company in the case of an accident?) Or should we be doing more?

Mel

Posted By Dave Merchant
Mel:-

the sequence of 'problems' you describe is basically your risk assessment and justification of ALARP done and dusted - you've tried to find all reasonably practicable ways to reduce the risk but can't find any, so while you're not saying you're ignoring the Regs, you're simply opting to use the "..where practicable" exemptions. That's fine, and it's the same argument we were using for railway platforms (and canal towpaths, river banks, roadside ditches, etc.). I've been through this exact problem many times and while there are always "solutions" the practicality of them tends to be somewhere between "none" and "stop laughing".

There are a few (and I stress few) cases where it's possible to use fall protection harnesses on vehicles, but the type of work you're describing is not one of them - you need freedom of movement and you're simply too close to the floor for any PPE-based system to stop you in time. One day someone will bring out an HGV with inbuilt airbags and an anti-gravity device, but until then you go with ALARP methodologies. It's not about trying to avoid the Regs, it's about realizing that the Regs themselves avoid things.

Awareness training is always an idea, but be careful that it's appropriate - sending people on a harness-users course will only confuse them, and in your case I'd be looking at getting your policy sorted in your head and on paper, then running simple toolbox talks to explain to people what you're "doing", and also what responsibilities *they* have for acting safely and reasonably. Often people will think that unless they get a new piece of safety gear the company isn't doing anything, and the best fix for that is just to talk to them about it. The task has some element of risk, and you've doing what you can to control it but it's down to the workforce to act sensibly - just as with the other risks from his "work equipment", namely crashing the truck into a bridge.

Yes, previous posters are correct that falls from vehicles and from below 2m are significant - but so are accidents involving cutlery and hot coffee. Throwing scaffolding and harnesses at the problem makes it worse, not better.

Posted By Pete Sutton
thanks all....the replies help but i would have liked an official HSE response..surely theres someone on this site from the HSE or are they not able to offer clarification?

I will look into our RA's and adapt our SSW as a matte rof urgency....my procurement team will be ove rthe moon as we were gonna invest a fortune in bespoke lifting appliances to fit our excavators...

Posted By Dave Merchant
Flamingos are notorious for it.. it's a pink thing. Lone delivery drivers are notorious for not following complex safety procedures either .. it's a speed thing.


To answer Robert's query on using harnesses, there are two options that 'work', but each only in specific situations:-

1) Use a work restraint system based on a harness or belt connected to an anchorage on the vehicle that allows the worker to move within the 'safe area' but not to approach the edges. This is often used when accessing the roof of a bulk tanker (a system called BiLINE is popular in the UK) but assumes the person has a very strictly-defined route and limited sideways movement. It also needs free clearance for the rope or lanyards so won't work on a flat bed where there are high obstructions. The vehicle has to be modified and staff extensively trained as it's all to easy for them to 'forget' to use it if nobody's watching. Being restraint-based there's no need for a rescue system.

2) Use a fall arrest system based on a harness connected to a retractable block or horizontal wire system secured to an anchorage *several metres* above their heads. This works best for fixed sites (loading bays etc) where there's a structure under which the vehicle can park, but occasionally has been used on Hiab-style vehicles by using the crane arm to support the anchorage. Of course you can't then use the crane. This idea has the advantage of freedom of movement and a vertical 'connection' that is less likely to be obstructed, but won't work at the side of a road on a typical vehicle. The advantage is no need to modify the vehicle, so it works for example at a garage. Being fall arrest you then have to implement rescue plans, 2-man teams, etc.

Posted By Dave Merchant
Robert:

I certainly hold the opinion that PFPE (harnesses, belts etc) are not practicable for use on generic flat-bed delivery vehicles where the bed is less than 2m above ground and there are obstructions (loads etc) which prevent a restraint system from being used. There's always going to be a few cases where someone can make it fit, but for me the primary issue is not "can we beat this equipment into working?" but "will the driver bother to use it?". Deliveries are almost always lone working and time-pressured, so to enforce a system that takes five minutes of rigging ropes is almost certain to be ignored by users when nobody's watching.

Risk-awareness education (I won't use the word 'training' as it's probably not that formal) is the simplest and most effective measure - if people are aware of the risk of injury they'll take care. If they aren't, they won't. The employer makes sure the vehicle and working procedures are as safe as is reasonably practicable, but even the HSE accepts that there's no such thing as a zero-risk job, hence the idea of "managing" risk instead of "removing" it.