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Posted By Telfie
In our organisation we have to carry out roof inspections, one of my colleagues has stated that The Work at Height Regulations do not apply to this line of work?
I agree under CDM 07 inspection is not classed as work, but surely when someone has to access various roofs and take photographs/notes of the inspection, then in my opinion they are "working at height"
Your thoughts please
Telfie
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Posted By Ian D Jones
Any one is working at height, if there is a risk of an injury as a result of a fall. If an individual fell from a roof there is a risk of injury so yes they would be deemed as working at height. Also the wearing personal protective equipment ( Harness & Lanyards) are mandatory when working on roofs so it may be worth your while doing some more research. ijones@mccarthygroup.co.uk i have lots of info on work at height, if i can be of any help please do not hesitate to contact me.
Ian
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Posted By MAK
unless the properties you are inspecting are under ground level, making the roof's all on a flat level ground then yes its working at height. ask your colleague how he proposes to get to the roof? if there is any risk of falling then it needs to be assessed.
BUT, if you are inspecting roofs accessed only using safe and cosy internal stairways and the roofs are flat roofs with an appropriate level of fall arrest i.e parapet walls then would you say there was any significant risk of falling?
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Posted By MAK
ahem>, the wearing of fall arrest systems is NOT mandatory for working on roofs.
The system used to safeguard againt falls from height must be relevant to the task at the location, i.e given the type of roof I describe above, why would you employ fall arrest/lanyards if the parapet wall afforded a suitable level of protection on a flat roof?
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Posted By Martyn Hendrie
TElfie,
I haven't looked it up but I think CDM states that inspection is not "construction work" as defined. i.e. CDM would not apply.
That is something quite different to "not at work" If the person inspecting is acting by way of trade or business they at "at Work"
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Posted By Telfie
Thanks for comments
I have started to review our working at height procedures and have hit a brick with some of our managers.
They keep quoting "short duration work" at me, therefore "no need to use edge protection" however I don’t seem to find any mention of short duration in the work at height Regs?
I also can’t find a statement saying if it is short duration you are exempt from the Regs.
These inspections only take minutes although I do appreciate it only takes a minute to fall.
My problem is getting the right balance, and ensuring the correct procedures and protection is put in place.
Telfie
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Posted By Pete Longworth
You're not "exempt from the regs" for work of any duration. However the level of control has to be proportionate to the risk. So if the work is inspecting an area of a flat roof for a few seconds well away from the edge then you wouldn't expect to have to provide edge protection, lanyards etc. But can you guarantee that? There is a well established hierarchy of control for work at height ie collective protection before individual protection, fall prevention before fall arrest, but it is all, as I have said, dependent on the level of risk and what is reasonably practicable.
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Posted By Pete Longworth
Ps don't forget, whatever controls you choose, if there is an accident, your company will have to justify them in court and the onus of proof will rest with the company.
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Posted By J Disney
Telfie,
Work at height regs state Section 2 "Interpretation"
"Work at height means" a) work in any place, including a place at or below ground level
b) obtaining access to or egress from such place while at work, except by a staircase in a permanent work place.
So if there is a risk of fall then you have to do what ever is reasonable and practical to eliminate the risk.
Check out the web address for the regs.
//www.legislation.hmso.gov/si/si2005/20050735
Hope this is of some help
Cheers
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Posted By CFT
Telfie
Based upon the information you have supplied your colleague is indeed completely incorrect.
nuff said.
CFT
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Posted By Jonathan Sandler CMIOSH
Simple
Carry out a risk assessment see what you come up with.
In the words of John Macenroe You can not be serious.
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Posted By patrick carr
I would most certainly say you would be expected to carry out your inspection, with the WAHR 2005 as a regulatory framework for your task.
I would not bother delving into CDM regs 2007, as all the info you require is in the WAHR 2005.
REG 4. ORGANISATION AND PLANNING.
work at height must be properly planned.
appropriately supervised.
carried out in a safe manner.
REG 6. AVOIDANCE OF RISKS FROM WORK AT HEIGHT.
Employers must undertake risk assessments prior to work at height.
REG 7. SELECTION OF WORK EQUIPMENT.
Employers shall give collective measures priority over personal protective measures.
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Posted By patrick carr
Schedule 6 in the WAHR 2005 covers ladders and stepladders, that is where it is mentioned "The short duration of the work (30 mins, max)" which is work from ladders.
I do not know what industry/workplace, or the situation regarding your inspections, etc, but to wear a safety harness and lanyard, is the last resort, (i have to wear one at all times as i am a scaffolder).As was stated before their is a Hierarchy of controls to be systematically followed, and personal fall protection equipment is right at the bottom of the controls,you must also be trained in the wearing of fall arrest equipment, and there must be a rescue plan in place. good luck, paddy.
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Posted By Dave Merchant
patrick - there is no place in the WAHR (or any other current UK law) where 'short duration' is defined with a time period.
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Posted By patrick carr
sorry when i stated short duration 30 mins max, it was from the HSE,guidance on work from ladders, sorry if i have mis-led anybody.
cheers paddy.
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Posted By Jonathan Sandler CMIOSH
Gents
The guidelines are quite simple.
HSE never put an exact time for duration, this is down to risk assessment, but if required to carryout an investigation, then their question might be, why so long??? any more than 5 mins on a ladder use something different.
Basically comes back to risk assessment.
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Posted By Martin Mulholland
Mr Jones, as MAK popinted out, and despite the link to the article you posted, harneses and lanyards are not mandatory.
The article mentioned that these systems seemed to have been installed after the incident - this was related to the reference to "pervert the course of justice"
Any control measures identified for work at height must be decided by a process of risk assessment. This is requried by WAH2005. The law comes from here and here alone - interpretations are only that.
Whilst i agree that use of FAS has its palce in some situations when working at height - it is after a risk assessment that this must be chosen and - it is not without risks itself (search on these forums to see many previous posts relating to injuries associated with falling in a harness, difficulty in rescue, etc.).
I would suggest that you read the specific wording of the Regs rather than rely on other information before you make your mind up about what the law is.
www.opsi.gov.uk/SI/si2005/20050735.htm
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Posted By Robert K Lewis
Telfie
I was talking to my wife's uncle at the weekend. They used a 60 stave (rung to you and me) to inspect gutters and access high roofs when he was an apprentice, he is 76 now. He was "rather tired" (not his words) by the end of the climb. He then had to climb over the gutter having eased tiles to provide a foothold and then progressed up the roof in similar manner.
The WAH regs 2005 were brought in expressly to ensure work at height ceased to follow such as these practices, not just in construction but in every work sector. Perhaps your people need to be reminded that they are exposing people to this sort of risk. From April they will also be exposing themselves to potential CM charges.
Bob
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Posted By Telfie
Thanks for your comments so far
To get the message across on how serious this issue is, I have sent some interesting e-mails to management (Thanks for the Links Ian)
Further to this I have instigated a review of all working at height
This includes
The identification of each building we inspect.
The types of training our inspectors have received
The type of roof to be inspected (fragile, pitched etc)
The system we use to conduct the inspection, (for example using a pole system with a camera attached) depending on height
As I mentioned in an earlier post the main issue is getting the right balance, and ensuring the correct procedures and protection is put in place.
Through the above review I am confident this will happen
Telfie
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