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#1 Posted : 24 April 2008 19:42:00(UTC)
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Posted By Adam P
Hi,

I asked the question at a visit to another company wether scaffolders are exempt to any working at height rules as there seemed to be many in the process of erecting scaffolding while not harnessed etc...
Do they have to comply to the same rules as everybody else or are there separate rules for this type of work?

Any help would be appreciated.

Regards
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#2 Posted : 24 April 2008 20:38:00(UTC)
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Posted By patrick carr
hi adam
scaffolders are not exempt from the wahr 2005,
it is normal policy for scaffolders to wear safety harnesses at all times, however in your post you stated "many were not harnessed". so some were wearing harnesses,at what height were the scaffolders, not wearing harnesses ? and were they inside a boarded handrailed scaffold ? i look forward to your reply.
best regards
paddy
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#3 Posted : 24 April 2008 22:05:00(UTC)
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Posted By jasonT
Adam

I have the same issues on my sites, some wear them some don't, if you check, their method statements it will tell you harness must be worn and fixed, but do require 4m clearance

I would suggest you purchase a copy of SG4:05 preventing falls in scaffolding and falsework, this guidance is available from the National Access & Scaffolding Confederation (NASC)

I now produce this booklet when talking to our scaffolders

Jason



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#4 Posted : 25 April 2008 04:30:00(UTC)
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Posted By Dave Merchant
The 'clearance' concept is sensible, but usually people implementing the policy fail to understand what it actually means.

If you're using a fall arrest lanyard, it's possible for you to need several metres of clearance below you in order for the fall to be arrested without the person impacting the ground. It's actually up to 6m, not 4m, but the point still stands. Using a lanyard with 2m of slack when you're 1m above the floor is utterly useless.

HOWEVER

The procedures you're referring to don't say "below 4m you don't need anything" - they say "below 4m you need SOMETHING ELSE". It may be another harness-based solution such as a retractor block, or it may be rails, netting or airbags. It has to be something as the WAHR have no concept of a minimum height for fall protection.

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#5 Posted : 25 April 2008 16:21:00(UTC)
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Posted By Telfie
Dave

SG4:05 preventing falls in scaffolding and falsework makes reference to 4m clearance (in black text)

so if it is actually 6m and they are wrong you may want to let them know

as suggested get a copy of the guidance and go from there.

Telfie
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#6 Posted : 25 April 2008 19:44:00(UTC)
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Posted By patrick carr
Hi all
Jason, you say 'Their method statements tell you harness must be worn and fixed, but do require 4m clearence', (fixed)?

Hi Dave, with all due respect,6m clearence:-
SG4:05 Question paper "A"-
Q) 11. At what height should scaffolders clip on?
A) When there is a anchor point at 4m or more above the scaffold base/ground.

Dave, 'using a lanyard with 2m of slack....'
Q) 6. What is recommended in SG4:05 as the maximun length of fall arrest lanyard that should be used by scaffolders?
A) 1.75mm

scenario A
you have secured a year contract,to erect scaffolding for the renewal of hipped roofs,(no peaks).The roof tiling contractor,requires a 1.8m scaffold with a foot tie, as all the properties are bungalows, would you require your scaffolders to wear full body harness on-site?

scenario B
You have secured a contract to scaffold a cathedral, to base out the job,will take 2 weeks,do you require your scaffolders to wear harnesses? Every lift is 2m you board out the 1st lift from the ground, secure your ladder, then progressively install handrails,traversing to the maximun length of material used to install the next section of guardrail,would you make them wear their harness? or would we be placing air-bags all round the cathedral?

Q) 4. In accordance with SG4,how do you reduce the risk of a fall whilst traversing?
A) Install a single guardrail.

Wearing of a full body harness whilst erecting scaffolding for long periods,is a most uncomfortable experience,however we wear them when we have to,after all it's a regulation,however zero tolerance of caught without wearing them, as in the scenarios i have mentioned, is what gives people like myself and Health & Safety professionals a bad reputation of a blinkered approach to the situation.Right off for a pint.
best regards
paddy
ps forgot to take my harness off for the pub.

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#7 Posted : 26 April 2008 10:57:00(UTC)
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Posted By Garry Adams
Adam

Your observations of the Scaffolders non-compliance to the WAHR, associated ACOP and HSE sanctioned NASC Guidance Notes is not an Isolated case.

Did your Organisation Induct The Scaffolders from the outset before the commencement of Scaffolding Operations ?. Clear and Concise In-House Rules and Regulations Bolster the aforementioned Documents, further more the expectations to comply to these requirement must be Implemented by the use of On-Site Supervision both from the Principal and Scaffolding Sub-Contractor. Perhaps your Organisation should have vetted the Scaff-Sub-Contractor more vigorously as to the Content of their Safety Policy and Arrangements.

I do not wish to lam bast my Brother Scaffolding Erectors...Scaffs are maverick free radicals, however some have to be reminded that their epidermis is made of skin and not feathers...they have to be slightly mad to perform the Tasks asked of them, however, that said most Seasoned Vets are Pro's and comply to the modern Status Que of Regs.

I would like to cite the issue of anchor points as a defence...one particular bonafide point that Paddy touched on was where dose one fix too...this issue was discussed on a recent Post by Ross...I found the ensuing debate most enlightening especially the technical Data regarding Anchor Points.

So Paddy of to the bar wi the harness on eh...fall arrest LOL...hook on to the bar gantry m8.

Gaza ...
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#8 Posted : 26 April 2008 14:34:00(UTC)
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Posted By Dave Merchant
*sigh*

First point - SG4 is not a law, or even an approximation to one. It's guidance, and in places very poorly-worded guidance. The WAHR is the law. It says you must prevent "any fall liable to cause injury". Falling from 2m onto a concrete surface, an adult human will typically experience a deceleration force of 48G. From 4m that rises to about 95G. Traumatic brain injury is almost certain in an event exceeding 40G. One-third of all fatal falls in the UK workplace is from below 2m. Nowhere, at any point now or in the past, has the HSE or UK law ever said a 4m fall "is OK".

Second point - Fall arrest lanyards can be up to 2m in length end-to-end before deployment. A 1.75m lanyard is more common as it matches user height, but during a fall the slack take-up on harness webbing adds an extra 25cm onto the total distance of travel, so you still have a 2m effective length.

Third point - it's perfectly possible for a person using a 1.75m lanyard to connect it to a point at foot level (not sensible, but perfectly possible, especially during construction of scaffolding where higher anchors are not available). They will therefore free-fall 1.75m before the lanyard receives tension, plus a further 0.25m in harness take-up. The energy absorber in a 1.75m lanyard has a total deployment length of 1.75m, giving a total distance from the anchor point to the casualty's ribcage of 3.75m - onto which you must add the length of their body, so their feet arrive at 5.5m without any safety factors. In guidance for fall arrest there should be at least 0.5m of free clearance below that point to allow for movement in the anchor point, so anyone who thinks 4m is still safe may want to think again, or jump off and see what happens. I hear the NHS has good food these days, assuming you are still able to swallow.
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#9 Posted : 26 April 2008 18:29:00(UTC)
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Posted By patrick carr
Hi Dave,
You may be correct in your explanation of this post,however why the sigh at the start of your response?

as scaffolders we are trained, at SG4:05 we believe this to be the std for the scaffolding industry,the SG4:05 test papers i quoted from ,to the best of my knowledge were the set std,adopted throughout the scaffolding industry.

As i stated in my previous thread, "with all due respect Dave" i was not being sarcastic,pedantic or any malicous intent, i was using the research tools and experience of over 30 years in the scaffolding industry to add my contribution to this thread, i hope i have not tried to undermine anybodies superior knowledge on this subject.Now i will need to get in touch with NASC for further guidance for my fellow scaffolders.
best regards
paddy

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#10 Posted : 27 April 2008 09:22:00(UTC)
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Posted By patrick carr
Morning all
Dave, i've just read my product information booklet from Ridgegear, who supply our fall arrest equipment, EN 361, EN 355 page 13, During use, bullet point 9 :-
Clearence below the operator should be a minimun of 5.75m for a 2m absorbing lanyard,this is the potential extension plus operator body length.

I would like to take this opportunity to thank you, for bringing this to my attention, i will bring this up at our next H&S meeting (2 weeks time).
best regards,
paddy
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#11 Posted : 27 April 2008 11:21:00(UTC)
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Posted By Dave Merchant
No problems Patrick - I wasn't being specifically peeved at anyone in particular - but it really annoys me when codes of practice or standards are waved about as being Gospel when they clearly don't agree with the UK law. It's not specific to this thread or to the scaffolding industry, but it can lead to extremely dangerous mistakes being made, the topic of this thread being a good example of one.

Apart from the few ACOPs out there, people need to bear in mind that guidance from industry bodies (however respected that body is in their chosen field) can be wrong. Laws can change after the guidance is issued. People writing it can make mistakes, as there is rarely the same level of technical scrutiny and review as there is for a new SI. Rarely, there's even attempts to slip things through to serve the interests of the body or their members.

The same can be true of BS standards - I can show you many parts of current BS 'codes of practice' which are so wrong, if you followed them to the letter it'd kill you. Usually the mistakes are fixed in an amendment, but it can take many years for the BSI to get round to it.


Ultimately my 'problem' with this topic is competence. I've no doubt the people posting are good at their jobs, but it comes down to a pyramid of failure. If a scaffolder or roofer has been trained to the correct legal standards of competence, he or she WILL KNOW that using a lanyard below 6m is dangerous, and that being unprotected at 2m is illegal. What's printed in SG4 or BS8437 is irrelevant. If the person managing the job is trained and competent to do so, he or she will ALSO KNOW the same things. I'm not picking on names, but if I hear someone saying "SG4 says XXX and I don't know enough about the topic to see if they're right or not" then by definition they're not competent to be doing the job. People don't need a sign on their car dashboard to remind them to drive with their seatbelt on, because they've been taught what the law says - and more importantly because they understand what it's for and how it protects them. If someone can only drive to work because they've got a copy of the highway code open on the passenger seat, they should be walking.
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#12 Posted : 27 April 2008 15:00:00(UTC)
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Posted By Garry Adams
Just show that your never to old to learn.
I for one appreciate the information both Technical and advisory which have been posted by fellow Forum Members...and in particular...I refer to Paddy, Dave and Bob.it can be like a mine Field ...trying to negotiate through the various directives required to stay in compliance. H&S really is a life long learning curve. Take your eye of the ball for a moment and its went through your legs, lol.

Best regards to all, Garry...
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#13 Posted : 28 April 2008 05:08:00(UTC)
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Posted By Dav
I recently raised a query with the NASC regarding a section in SG4:05 - something called the 'tunnelling principle' in para 53. They confirmed that it would be acceptable for a scaffolder to traverse a scaffold the length of a 21 without being clipped on whilst erecting or dismantling a scaffold.

I then checked this stance with two HSE inspectors for different regions and they both confirmed that if they saw someone working in this way that they would issue a prohibition notice.

The guidance provided in this section of SG4:05 is completely at odds with the WAHR, so my stance is not to allow scaffolders to work in this way. It exposes them to the risk of a fall and you to enforcement action should the HSE call. This does cause problems as scaffolders just refer to SG4:05 as their bible of what they can do and what they cant, but until some proper guidance on what to enforce is issued then this is the stance that i will take.



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#14 Posted : 28 April 2008 20:30:00(UTC)
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Posted By Garry Adams
EEmmm Im confused.com

Firstly, with regard to the content of the WAHR and their place within the hierarchy of requirements.

I acknowledge that the WAHR are the prime requirements for working at height, however, they do not give specific practical instructions on how a particular discipline should take appropriate steps as how to comply.

Control measures to prevent falls from height developed from the content of the WAHR at the core, guidance notes are then applied to put flesh on the bones ...so to speak...I accept that NASC guidance notes are a valuable addendum to the WAHR, given that these Guidance notes have been SANGTIONED by the HSE...Until the wording of the H.A.S.A.W.A and enabled Regulations give clear and concise instructions, (as is reasonably practicable) will be interpreted as a liaise fare and open to different interpretations. Perhaps a more Autocratic stance by Government would yield a more responsive result to compliance

A response from a member of the HSE or indeed a member of the NASC H&S or Technical Committees may clarify matters. Any takers Gentlemen ?.

Garry...

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#15 Posted : 28 April 2008 22:01:00(UTC)
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Posted By db
The regulations must be complied with. The reg says that you SHALL prevent all falls. Irrespective of what the guidance says. HSE does not approve all guidance

As far as I can recall, SG4 states that where possible a single guard rail should be installed as soon as possible. There should be few reasons why anyone would need to work outside this area - and a harness is to be used when there is a need. The new edition suggests the use of advanced guard rails but I've not had much to do with this for a year or so, so I don't know if they are advised by HSE. They certainly were when I was an inspector but things may have changed.

As an inspector, by far the largest number of notices were issued to employees who were accessing, or had potential access to an open edge. Scaffolders included.
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#16 Posted : 29 April 2008 07:50:00(UTC)
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Posted By Dav
Gary

The discrepancy i had with the two differing pieces of advice has been raised to the HSE through the MCG and the feedback i have is that the HSE may be reviewing their support of SG4:05 in light of the discrepancy. Wouldnt hold your breath on any decision in the near future though.
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#17 Posted : 29 April 2008 08:26:00(UTC)
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Posted By Lloyd Cole
"An excellent thread"

Something like this happened to me last week, when scaffolders working on a demolition project were staggered up 5 levels passing scaff tubing upwards, 1st man passed to second man, second to 3rd man..and so on to the top. These men where leaning out over their built platform handrails, obviously because they had to grip the tubing from below.
I noticed that no fall system was used and when I asked one of the lads , he said that the teams work within SG4 and wasnt required. I asked the lads to take advise from their foreman, before i insisted on, as a minimum a lanyard, I believe i was right to ask this.
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#18 Posted : 29 April 2008 16:14:00(UTC)
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Posted By Garry Adams
Dav

I concur, constant vigilance and monitoring is required...Guidance notes are in constant flux given the new technologies available as an aide to compliance to the Core requirements stated in the H.A.S.A.W.A....addendum's and re-writes are common place. however, given that the HSE and NASC collaborate to develop Loss Prevention Strategies, one would have thought that the HSE would have picked up on the discrepancies during the initial draughting of the latest version/series of guidance...then again no one is infallible. You were quite right to raise concerns.

Regards, Garry...

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#19 Posted : 29 April 2008 21:16:00(UTC)
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Posted By patrick carr
Hi
(whispers to lloyd)and what length lanyard would they be?

This has been a very informative thread for me, this time last week, i thought if i took a short cut to the deck, from 4m i would still at least be doing a impression of a stingray puppet, now i know i would be on my backside, with a coil of lanyard on my head. however on a more serious note, i have been doing some research on anchor points. There are several anchorage systems out that attatch to a scaffolding std,and one of the more simpler ones is a scaffolders anchorage attatchment sling, hopefully these would do away with having to clip on at foot level. If you had 2 of these slings, and a double lanyard, you could progressively traverse along the scaffold structure,from std to std, whilst at all times being clipped on at 1 point,while moving the sling to the next std (without a sleeve in the bay)till the maximun length of the material to be used as a handrail.These, depending on your std spacing could be above head height at most times, ensuring reaching the safe clip on point at a earlier stage and reducing the trip hazard of a trailing lanyard.

All being said and done,the risk of falls from below harness and lanyard arrest height, has to be addressed,assessed and a safe system of work, must be adopted,as Garry and Dave explained, monitoring,training,compliance and competence must be strictly adhered to at all times.IMO the Hierarchy of control within the WAHR2005 is the place to start. A lot of Employers/Employees (if they know about it), don't use these controls as they are meant to be used, they must be started from the top I.E DONT- if you don't have to go up there dont. Then systematically followed till you can adopt a action, not go straight to PPE/fall arrest equipment.

The sling i viewed can be found at
http://www.ppsafety.co.uk/datasheet.php?id=384

best regards
paddy
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#20 Posted : 29 April 2008 21:30:00(UTC)
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Posted By Garry Adams
Paddy

Just the info Iv been looking for ...you beat me to the punch M8...thanks

Fraternal regards, Garry...
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#21 Posted : 01 May 2008 07:42:00(UTC)
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Posted By Dave Merchant
The anchor slings are a good idea, and there's also a set of lanyards with a purpose-designed double-action clamp on the ends instead of the normal hooks, which will grip on a VERTICAL pole just as well as a horizontal one, which means it's not a two-handed job as it is for the slings.

You do however need to be careful as they're only available in single-leg designs, and to work safely you have to wear two of them. It's very important not to have both connected at the same height, as if they activate in parallel the forces will be too high. It's not difficult to keep them 'dog-legged' but users need to be carefully warned about how to use them.

Google for "Miller Barracuda". Lots of UK suppliers carry them. I've no connection to the manufacturer but I've used them in the past and they certainly do what they claim to do.
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#22 Posted : 03 May 2008 13:18:00(UTC)
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Posted By patrick carr
Hi
Dave, thanks for that, the 'Barracuda'seems like a good bit of kit.

regards
paddy
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#23 Posted : 06 May 2008 11:20:00(UTC)
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Posted By Garry Adams
Paddy

Ye M8 I found the site very interesting.

I wonder if requires a slip test or a SWL rating , when applied on the vertical of the tube ?. just a passing thought.

Garry...
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#24 Posted : 10 November 2008 23:53:00(UTC)
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Posted By raymondoscaff
hi all,
another good consructive debate by all participants,
As a SG4.05 instructor I find this of most interest, it is clear that you all identify with the guidance in this training as flawed.
You would be correct to interpret this ,this way.
SG4.05 training is a minimum st'd, but does allow a degree of being "reasonably practicable", however this as said in this thread could leave some being exposed to falling whilst traversing + liable to prosecution from HSE.
NASC must ammend this potential failure of a otherwise well intended ACOP for scaffolders working @ Height
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#25 Posted : 21 November 2008 16:30:00(UTC)
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Posted By garyjr
Garry Adams and db touched on it in an earlier post. 'Collective Protection' must be selected ahead of P.P.E (Harnesses) in the selection process of appropriate equipment.
I don't want to break any rules by naming any particular products but these types of products are called Advanced Guardrails.
The Regulations are not the law but failure to comply with them can be used in a point of law to support a Prosecutors case.
Therefore Employers and 'duty holders' should do all they can to comply with them.
All employers have a duty to provide 'safe systems of work'. This means the main contractor cannot get out of the loop, in terms of blame, if an accident does occur. This is why the first two questions a Solicitor asks when you do have a fall are, 1. Who do you work for? and
2. Where were you working?

If you in turn tell him you were working on a large site for one of the larger contractors, he starts rubbing his hands, thinking about the pound signs.
(I should know, I've fallen 35 feet onto concrete - head first. I'm also a former Advanced Scaffolder)
At the moment Scaffold companies are able to avoid blame to some extent by hiding behind SG4:05 Guidance "We were working to SG4", (which the HSE accepted) but recently the NASC have produced Interim Guidance, which clearly states that 'Collective Protection' should be considered ahead of harnesses. It also makes clear that the HSE were never comfortable with the 'traversing' or 'tunnelling' phases contained in the original guidance.
The problem with the Interim Guidance is that it does not go into any great detail about the products out there, it merely shows the reader that they're are products available but new Guidance is currently being produced which the HSE are making final alterations to, before it goes to print.
Lots of companies and organisations have been involved in producing this new guidance and it is very extensive, however the HSE are very much in control of the timing of it going to print and the content.
The company I work for have contributed to it and so have other companies who produce advanced guardrails.
The job of a scaffolder is about to become a hell of a lot safer.
Remember, scaffolding has been around since the pyramids but scaffolders have been exposed to the risk of fall for all those years.
Now they can be afforded the same level of protection as the user of a completed structure.

Gary Jnr
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#26 Posted : 21 November 2008 16:44:00(UTC)
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Posted By Kirsty Davies2
Thanks guys

Welldone for your quick and prompt response.

Have a good weekend.
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#27 Posted : 21 November 2008 18:22:00(UTC)
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Posted By nheathsiae
NOT my industry and you would not get me on ANY scaffold!!! But happy to be 300m up a "fixed" structure, mobile phone mast!!!

My industry, fall off, best chance is, DEAD.

Reading through the post, which I found very intresting, most posts were about FALL ARREST.

Surely you use WORK RESTRAINT as the first choice, don't let them fall in the first place.

Using purely FALL ARREST, you have a documented rescue plan, DON'T SAY DIAL 999!!!!!, to recover the "fallee" (English word??)

Nick

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#28 Posted : 21 November 2008 18:56:00(UTC)
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Posted By patrick carr
Hi Garyjr
Great post,sorry to learn of your fall.

Nick you might want to also look at http://www.iosh.co.uk/in...iew&forum=1&thread=40049 for some additional cross reference material, regarding SG4:05 Appendix A

Regards
Paddy

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#29 Posted : 21 November 2008 20:38:00(UTC)
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Posted By nheathsiae
Hi Paddy,

Reason I posted was that I looked at the NASC website and the posted "test" questions, their main title PREVENTING falls, don't let them fall in the first place.

Quite strange, I did the two test papers and disagreed with many of the questions/answers so, TO THE ORIGINAL POSTER, I think there IS a difference between the WAH Regs for scaffolders and the rest of the industry, well (Telecomms) for sure.

PREVENTING to me means not allowing the fall in the first place, FALL ARREST is "it happened" minimise injury, NOW WHAT??

The questions seemed to be based around FALL ARREST which confused me!! If they haven't fallen (Work restraint) then WHY fall arrest??

On the one hand they are taking about PREVENTING falls but the main topics are FALL ARREST.

OK, not my industry but a strange approach to me in the hierarchy of controls.

So if NASC recommend FALL ARREST, which rescue system do "they" use.

Nick

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#30 Posted : 22 November 2008 07:50:00(UTC)
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Posted By Hossam
Hi

with respect to all contributors..
from Adam's post..I understand that
his main inquiry is about scaffolders
& harnesses in general not only
the minimum clearance for harness use!!..

from experience.. the dilemma of scaffolders & harnesses usually comes from the absence of having an above head anchorage point..for that I totally recommend Dave's piece of advice "it's perfectly possible for a person using a 1.75m lanyard to connect it to a point at foot level (not sensible, but perfectly possible, especially during construction of scaffolding where higher anchors are not available)

Hossam
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#31 Posted : 22 November 2008 12:42:00(UTC)
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Posted By Garry Adams
Gary Jnr

Firstly, may I congratulate you on surviving such a horrendous fall, I have served the Scaffolding Industry since 1972, I too have had a few white knuckle moments and still do on occasion.

I have just read your post with interest, in particular your reference regarding "Safe Systems of Work".

The creation of effective and efficient Safe Systems of work allied with a suitable and sufficient Method Statement should compliment the selected collective protective measures necessary to mitigate the risks associated with the correlation, configuration and permutation of the Scaffold Structure.

SG4:05 and the addendum appendix A addresses most of the off the shelf System Scaffolds and Tube and Fitting Structures taught at CITB and CITB accredited Training Centres.
However, where a bespoke esoteric special structure has been requested, collective protection and indeed in some instances the recommended PPE, i.e. Fall Restraint, Fall Arrest by Inertia Reel, may prove impracticable. Is there a case for abseiling techniques to be include in the Method Statement ?...

Garry...
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#32 Posted : 22 November 2008 13:23:00(UTC)
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Posted By patrick carr
Hi All
Garry some interesting observations there regarding 'Abseiling Techniques'(Food for Thought).

This thread originated on 24.04.2008 by Adam P, it ran till 6.05.2008. The thread was reopened by Raymondoscaff on 10.11.2008. As the majority of us know,NASC in the meantime had produced SG4:05 Appendix A 'Interim Guidance on Collective Fall Prevention systems in scaffolding'

A further development within this time span, was the HSE Guidance on Scaffolding structures that need to be Designed.

Will the 'Designers' of these Bespoke Scaffold structures, also be responsible for RA,SSOW or method statements, regarding the application of 'Advanced Guardrails' alternate means of collective fall protection, powered access etc ?

Paddy
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#33 Posted : 22 November 2008 23:24:00(UTC)
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Posted By Garry Adams
Paddy

With regard to the comparitivly recent HSE Scaffolding Information Sheet and Associated T.G. 20:08 and allied SG4:05 + Appendix A.

My Resent discussions with leading Scaffold Design Software Providers has revealed that the software programmers are indeed creating Safe Systems of Work, Method Statements and Risk Assessments that will interface with the Type of Scaffold Structure requested by the client. However, amendments to these Safety Management Documents may be required at the pre-task analysis stage given the dynamics of the location and working conditions.

Garry...

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#34 Posted : 24 November 2008 12:20:00(UTC)
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Posted By garyjr
Paddy, you asked a very good question i.e. will the designers be responsible for Risk Assessments, Method Statements and Safe Systems of Work for bespoke structures?
As far as I am aware the answer to that question is yes. CDM Regs Part 3 18 (2) under Additional Duties of Designers - 'The designers shall take all reasonable steps to provide with his design sufficient information about aspects of the design of the structure or its construction or maintenance as will adequately assist the CDM co-ordinator to comply with his duties under these regs, including his duties in relation to the health and safety file'.
I am by no means an expert on all the CDM regulations but I think there are additional requirements contained within the CDM Regs which impose a duty on the main client to ensure these things are in place.
New Guidance will cover all basic scaffolding configurations including wall scaffolds fully boarded and top lift only, towers and birdcages but designers should be supplying method statements and Risk Assessments for bespoke structures. My own prediction for how things will develop going by the requirements of the WAHR's is this: Avoiding working at height is often not possible but where you have to build a scaffold, designers or their support personnel should be looking at ways of 'preventing' the risk of fall in the first instance by looking at 'collective equipement/ advanced guardrails, however if they feel this bespoke structure cannot be built using advanced guardrails, then they must look further down in the heirarchy of measures.
The next stage down Reg 7 (a) would be using P.P.E in a way which prevents the risk of fall but these types of harnesses are not recommended for scaffolders because they restrict movement, however as long as there is no danger of falling objects or anyone working above the scaffolder while wearing these body restraints (which I think answers Garry Adams question) then they can still be considered. The next stage down would be Reg 6 (5)(a)(i) minimise the distance using 'collective equipment' i.e. safety nets and that sort of thing at foot height, tied to the scaffold. This however is not always very practical and again a rescue plan is required but it does offer collective protection. The next stage down would go back to Reg 7 (a) Current Industry Practice SG4:05 Minimise the distance using P.P.E. In other words the types of harnesses currently being used, which do still allow a fall to occur but eventually they deploy. The 2nd last option is Reg 6 (5)(a)(ii)to minimise the consequences using 'collective equipment' air bags or some kind of crash mat, which will very seldom be an option unless there is no activity down below (I think this option is really only for people jumping out of burning buildings). The final option is Reg 6(5)(b) minimise the consequences through training and instruction, which when you look carefully at the 3T Method for building aluminium towers, you will find interesting.
I am not going to name any companies or products but there is an organisation called SA-FE (Safe Access - Fall Elimination)which gives great advice on the collective protection options available and Clive knows more about safe working at height than anyone else I know.
The people on this forum looking at harness and body restraint options for scaffolders are looking at the wrong options. They only protect the individual, they don't collectively protect. Therefore they require a great deal of observation and safety monitoring, in comparison to advanced guardrails which are both higher up in the heirarchy of measures and can clearly be seen from ground level. Sorry my post was so long but this is a very complex subject and until the new guidance on collective options goes to print, it will remain complicated.
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