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#1 Posted : 05 June 2008 14:02:00(UTC)
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Posted By MickN I think we've gone too far. Use of a ladder now comes under new WAH legislation (Irish, before you ask) requiring a risk assessment to determine if a safer way cannot be found to perform each job. I recently came across a tradesman standing on a small, unsteady cable drum (just enough room for both feet) in order to gain no more than six inches. I enquired as to why he didn't use a step ladder (surely the norm in such situations) and the answer I got was that it would have taken too long. Due to permits, risk assessments and signatures it would have taken a minimum of 40 minutes to organise a step ladder. I ask you, is this reasonable or practicable? Mick
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#2 Posted : 05 June 2008 14:11:00(UTC)
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Posted By Pam Phillips If your company sets a rule that you have to have permits/RA's etc for gaining 6 inches in height then that's what the trademen have to do. Its not for them to decide that it takes too long so we wont do it, they have to do what the employer tells them. Now on a practical basis a generic RA for low risk WAH is entirely acceptable. This can then be amended if there are other hazards presented not obvious at the generic RA stage. Remember its not the regulations that are at fault its the people who interpret them. Hope that helps.
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#3 Posted : 05 June 2008 14:51:00(UTC)
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Posted By MT No, I do not think we have gone too far. The scenario you describe is typical of many companies where there is a lack of knowledge and education and of the skills required to put in place a suitable Work at Height Policy. If someone was interpreting the legislation as per the spirit of the law, then use of a ladder certainly would not require 40 minutes of form-filling and getting signatures. It is entirely reasonable for a generic RA to be in place for the short duration task this person was carrying out which would be used time and time again. Just another example of poorly trained people in H&S positions - as I'm assuming than an H&S person within the company has claimed that a brand new RA and PTW is required every time this man steps on a ladder? Is it just me or is this scenario starting to sound more and more like an urban myth?
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#4 Posted : 05 June 2008 15:17:00(UTC)
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Posted By John A Wright MickN, Hope you come back to respond to rhe replies to your message, it's very frustrating for posters here to not know if their advice is useful or not. I have to agree with others above. If it takes 40 minutes to organise a step ladder then it's the procedures that are at fault. The maintenance manager should have a ladder register which identifies which ladders can do which jobs and he or a supervisor can decide if a separate risk assessment is necessary for a job. To reach/do a small job (e.g. stick a sign on a wall or whatever your tradesman was doing) should already have a ladder assigned and issuing the ladder should take 2 minutes, not 40. John W
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#5 Posted : 05 June 2008 15:42:00(UTC)
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Posted By MickN All, Thanks for the advice/opinions, but I feel the need to clarify further. The example I gave was from a construction site as opposed to the more controlled (my opinion) environs of other industries. Not that we are in any way deficient when it comes to applying the law. No place of work is 100%, our profession is proof of that and I agree that interpretation of the law is very important. I'm simply asking if we have gone too far. Have we taken too much responsibility away from the individual and placed it within systems and paperwork. This tradesman was no longer allowed to use a stepladder to elevate himself six inches in the course of a days work. Of course the ladder needs to be in good condition, checked and documented before use. But what's next, weekly checks on screwdrivers, hacksaws? I'm not trying to be flippant, I'm a safety professional with a strong belief in what we do as a whole. Does anyone else see the possibility that we could go too far?
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#6 Posted : 05 June 2008 15:51:00(UTC)
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Posted By MikeP MickN You said "This tradesman was no longer allowed to use a stepladder to elevate himself six inches in the course of a days work".....WHY If he needs to work off the ground surely it is safer to let him use a ladder. As the others stated it is the company procedurews that need reviewing not the regs MikeP
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#7 Posted : 05 June 2008 15:57:00(UTC)
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Posted By db It sounds like a bit of a dodge from the contractor to me. To suggest that he thought he'd be in more trouble to use a ladder without a PTW than any old bit of rubbish lying around shows either quick thinking on his part or poor HR management from the company.
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#8 Posted : 05 June 2008 16:06:00(UTC)
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Posted By Philip McAleenan Mick, At last years joint anniversary conference between the IOSH Ireland and NI branches Ciaran McAleenan presented a paper on the very issue of competence which examined how the competent worker is often neutered by the existence of superfluous functions and roles in the workplace. This can be extended to include those who devise and apply rules and regulations in such a manner that competence cannot be effectively exercised as the worker is held responsible for what he does but his authority to make competent decisions is negated by the existence of someone else who makes those decision for him. The paper is available to download from this link, http://www.web-safety.co..._Matrix_of_Authority.pdf The paper describes a number of examples of innovate practice from around the world and invites safety professionals to consider these as models for transforming the culture in workplaces that leads to the type of situation that you have described. A follow up paper has been written for the World Congress of Safety at the beginning if July and it will be generally available after it has been presented. Regards, Philip
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#9 Posted : 05 June 2008 16:11:00(UTC)
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Posted By Tabs Nick - you ask "have we gone too far?" I would say, yes YOU have - the rest of have not. On my sites, wooden steps are banned (do to bad habits of poor repairs), aluminium and fibreglass ones are registered initially, clearly numbered, inspected in line with usage, visually inspected each time selected for use. No permit, no signature. A 10 minute job takes 10 minutes. We did the thinking beforehand and set up the risk assessments to suit the everyday usage. If someone wants to use them in a new fashion, there will be more work to do. The other posters nailed it for you, poor system set by someone who perhaps needs a dose of pragmatism and practical experience. ...unless you know different? Why was that system set up? Continuous mis-use perhaps?
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#10 Posted : 05 June 2008 17:06:00(UTC)
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Posted By MickN OK Tabs I agree, the system I describe is flawed and should have flexibility. I would, however, suggest that it is representative of many workplaces and workpractices. I want a world where we have the right balance between the safety professional and a competent workforce. Philip, Thanks for your reply, I have downloaded the file and although I'm now off home, I'm looking forward to reading it as it looks to be just what I'm looking for. See you all tomorrow. Mick
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#11 Posted : 05 June 2008 20:23:00(UTC)
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Posted By Robert K Lewis MickN Practicable - Yes Reasonable - No It does show the importance of professional advice and following it when setting policies and procedures. Bob
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#12 Posted : 05 June 2008 23:36:00(UTC)
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Posted By John A Wright Mick, Maybe you are reading too much into the incident and getting confused, as you now say the tradesman was not allowed to use a ladder, yet earlier you said he WOULDN'T use it because it would take him too long. Can't be both, eh? Anyway, I'm pleased that you are taking a positive approach to the responses here. I hope you see that H&S is not the real problem, but how some people interpret it and deal with it. John W
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#13 Posted : 06 June 2008 08:12:00(UTC)
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Posted By Pete48 There are echoes here of the experience in the UK. There is a strong belief from my samples that many small businesses who may have no professional support have received a message that ladders and stepladders are generally banned unless there is a wealth of paper or systems to justify it. I would be a rich man if I had a shilling for every time I have been complained at about how the new regs have made this sort of work more unsafe because it does encourage the wrong sort of initiative. Of course I know the law and the codes and the guidance. The comments about poor systems etc are all valid but the reality is still there. We, that is; the regulators, the H&S fraternity, the insurers, have somehow failed in the message and many tradesman in small businesses or as sole traders etc do feel that the reasoned choice has been taken away from them. Thus the availability of ladders and stepladders has reduced. So when faced with that little job, it is neither as easy or as acceptable to borrow a ladder/stepladder. So what do you think happens? Do they walk away or? So whilst you can castigate people for not having the perfect systems or using professional advice, the reality is that many don't have that advice, are directed by hard pressed site agents or are just trying to do their best. And that ladies and gentlemen is often standing on the nearest thing because they are terrified of using a ladder or stepladder "because they are banned". I am fully supportive of the need to improve WAH safety but I think Mick has raised an interesting point that is about more than "improve your systems".
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#14 Posted : 06 June 2008 09:09:00(UTC)
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Posted By MT Good post Pete, which raises the question in my mind "Where did the message that ladders are banned come from?". There's probably one camp we can definitely point a finger at, and that would be the press. I'm trying not to make a sweeping generalisation or denigrate people for their choice of reading material, but could it be fair to say that tradesmen who don't have access to professional H&S advice, perhaps the self-employed or small companies, most likely read the red-tops and therefore have believed the anti-'elf 'n' safety stories? To be fair, the WAH regs clearly do not say that ladders are banned, nor does any of the WAH info on the HSE website. Good advice is out there if people look in the right place, but people seem to be making poor choices about where to get their information from.
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#15 Posted : 06 June 2008 11:17:00(UTC)
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Posted By Kevin Brown I definitely think MT is on the right track. See HSE's Mythof the Month from April '07 http://www.hse.gov.uk/myth/april.htm
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#16 Posted : 06 June 2008 11:27:00(UTC)
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Posted By MickN Pete, I'm glad that you see my point here. I frequently find that where I allow a little latitude with regard to individual responsibility and where I alter my approach to H&S situations I find that I get back so much more in return. I guess this is what I've been driving at here. Philip, I read the piece you referred to above and I found it to be a valuable insight and one I happen to agree with. I do believe that H&S has natural limits with respect to what is achievable. To break through those limits, in my opinion, we need to look at the psychology of what we do. Why do we do it this way? For those who think I'm nuts, and from the comments above there are a few, it's important to note that what I'm referring to here has it's place in the H&S professionals' armoury. Safety management systems, documentation and certification, disciplinary procedures and actually walking the job and talking to people are of paramount importance, providing the foundation to a solid safety department. I simply worry that we can wrap ourselves up in bureaucracy to the point where we remove the ability of the individual to influence his own H&S in a positive way. John W, I found your comments to be unhelpful and pedantic. Happy Friday All Mick
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#17 Posted : 06 June 2008 11:52:00(UTC)
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Posted By Heather Collins With respect Mick you have said two different things in two different posts which do change the answer people might give you. First you said the tradesman did not use a ladder because it would take too long to organise. Then you said he was "not allowed to" use a ladder. One shows the wrong decision has been made with respect to which equipment is suitable for the task and the other shows that the system in place to allow use of the right equipment is simply too complex. This is not being pedantic, it is merely asking you to be precise about the nature of the issue.
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#18 Posted : 06 June 2008 12:04:00(UTC)
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Posted By Mitch Hear hear Heather,
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#19 Posted : 06 June 2008 12:31:00(UTC)
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Posted By peter gotch Hi Mick The requirements of the 2006 Irish work at heights legislation are worded in identical terms to those of the 2005 equivalent in GB, which have caused plenty of misinterpretation. That your cable drum is not specifically mentioned in either code of regulations does not mean that its use would be indicative of breach of the general requirements as regards work at heights [whilst of course risk assessment is also required under your General Application Regs - suitable and sufficient - which means quickly deciding to use inherently safer means of access/workplace] HSE stats indicate that over 60% of reported major injuries in construction arising from falls from heights [NOT on the level]are from falls of less than 2m. This is almost exactly the same proportion as in 1980. Having a 2m threshold meant that sometimes insufficient attention given to preventing these smaller falls, so far as reasonably practicable. Regards, Peter
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#20 Posted : 06 June 2008 12:35:00(UTC)
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Posted By Phil Errup Not specifically related, but i thought is was funny. Our warehouse operative uses a broom to dislodge the waste, that will not budge in a tipper bin (the sort an FLT lifts to height) when it refuses to fall naturally into a skip. I am introducing safety to the business, and have gone through risk assessments etc (mine eyes glaze over)... so when I mentioned PUWER, PPE, manual handling and the other regulations to consider ... it was so evident that behind the poor chaps eyes, lay a mixture of pain, disbelief, depression... the works. All I could say to him was, do it once, learn from it, and remember what you learn. It didn't have any effect. Oh well, Onwards and upwards
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#21 Posted : 06 June 2008 13:05:00(UTC)
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Posted By MickN Heather, point taken. I should have had the word allowed replaced with "allowed", mea culpa! I do believe that all of this is getting away from my central point. Surely we can hold a conversation here without deconstructing each post for grammatical errors. True, we need to maintain standards, but it can get in the way of the discussion. Mick
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#22 Posted : 06 June 2008 13:14:00(UTC)
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Posted By Martin Mulholland MickN You state that "we take(n) too much responsibility away from the individual" and in some cases I agree with you. However, it is very important to ensure that systems of work are monitored, as not all workers demonstrate competency all of the time. This is obvious from your comment that you "recently came across a tradesman standing on a small, unsteady cable drum". Sensible systems need to be in place so that workers understand where they can use their own judgement and where site rules need to be complied with. Establishing a system, communicating it effectively and then enforcing non-compliance is the best way to secure a sensible safety culture.
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#23 Posted : 06 June 2008 13:56:00(UTC)
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Posted By jmc Hi Surely these alluminium podiums that can be folded down and have a gaurdrail could be used in the situation You are describing. Also if further height is requered small electric M.E.W.P`s would be Your answer. There are lots of options when working at height without using ladders. Most operative`s that use ladders on sites see them as convinient i.e. stick the ladder on yer shoulder and job done move to next job. The reason for the new regs is that accidents involving ladders was increasing over the years so somthing had to be done to prevent people from harming themself. Thats the way health & safety works.
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#24 Posted : 06 June 2008 14:12:00(UTC)
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Posted By Pete48 Can I just clarify again here that the world of construction and other activity does not only occur in the rarified atmosphere of systems, controls, audits etc. I would hazard a guess that far more people are at risk from work at height in situations and areas well away from such matters. They often only come into contact with such situations where they know someone who works on a large site, or they used to work on large contracts or they get visited by a local authority inspector. Yes they read the papers and listen to the TV but they are unlikely to visit the HSE website. ( as a matter of interest only 1 in the last 50 small business people I have asked even knew the HSE site existed, let alone visited it. A trench of generalisation in this paragraph, I accept, but please see as being used to demonstrate a point. There are other examples such as inductions before entry to site. I was talking to a small business man the other day. He was visiting site to vegetation spray a small area of ground in a large site. He and his 2 men had to endure a two hour induction in order to complete 20 minutes work? And most of the induction was either irrelevant to him or he already knew it because he had done managing safely. He was very explicit about how modern, systems based safety is castrating individual responsibility and initiative. He told me that he suggested to the site operator that next time he would rather pay to have a site guide to keep him on their straight and narrow; it would cost him far less!! So it is all well and good saying the law says, improve the systems, audit them to hell and back and even splitting hairs about the nature of the question. But the situation that Mick described is very real and happening right now in x places across the UK. Do we really think the answer is systems and professional safety advice? Important though they are I am not sure that they are suitable and sufficient to cover the sorts of situations I describe. I often think wistfully of the days when most legislation and codes were a touch more prescriptive. I wonder what the outcome would have been if we had developed laws that more explicitly dealt with issue of use of stepladders and ladders? It was always going to be the alligator pit of the changes, was it not? And for the pedants, yes I know but I have left it in to see if you spot it?
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#25 Posted : 06 June 2008 14:47:00(UTC)
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Posted By Colin Reeves Interesting that today I got a circular from the HSE regarding their "Ladder Exchange" initiative this coming September - the blurb clearly shows that they are looking at users exchanging dodgy ladders with new. Clearly the HSE do not have a blanket ban on ladders! One of the links in the circular is: http://www.hse.gov.uk/fa...m?ebul+slips/jun-06&cr=2 Colin
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#26 Posted : 06 June 2008 14:53:00(UTC)
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Posted By Carolc I agree that it is the interpretation and application by certain people that is making life difficult and, dare I say it, creating a climate where H&S will be treated with contempt instead of respect. My company has a division that works as specialist subbies on large construction sites (a finishing trade). A large number of sites have simply ordered a blanket ban on stepladders and require the use of the podium towers as suggested by jmc. I have found on occasions that although I have presented the PC with a risk assessment giving all of the various reasons why a stepladder is actually a safer more appropriate tool for the job than the pod, we have still been required by the site manager enforcing his company's site rules to use the pods. What's the point of a risk assessment if you are going to be told to use a more hazardous method?
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#27 Posted : 06 June 2008 15:28:00(UTC)
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Posted By andyp MickN, I must say that I empathise with you for the responses posted to your thread, to which I personally believe that you have a valid point with. All too often on this forum do you see individuals suffering a backlash from what appears to be nothing more than a lynch mob; on many occassions because someone dares to step outside the realm of total H&S and points out an issue that may have real validity in what is being said. I am a H&S professional who, as no doubt you do, know all about correct procedures, systems, working practices etc without requiring the need to be belittled, castrated etc for daring to have an opinion that is obviously not conforming to certain other individuals. Good thread.
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