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#1 Posted : 17 June 2008 09:04:00(UTC)
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Posted By Gerry Marchant We have been asked to inspect and then repair a roof line within a valley gutter. The Clerk of Works has stated that he can see no reason why a cherry picker cannot be used to access the vally gutter, the operative to climb out of the basket and access the valley to initially inspect the area, and then effect a repair at a later stage using the same method for access. The operator is IPAF trained therefore using his training knowledge has said he will not climb out of the basket due to the risk...and I support him with this, however there is nothing in legislation to say he cannot climb out of the basket and the CoW has done some some digging and confirms this (so have I) even down to the BS...anyone out there got soemthing different they can give me to say to the CoW it will not happen. We have discussed the hierachy of control and scaffold, mobile towers etc is cost prohibitive at this stage for the client/ Gerry
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#2 Posted : 17 June 2008 09:40:00(UTC)
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Posted By Dave Merchant You *can* climb out of a MEWP safely and legally, but it's not taught as frankly it's easier to ignore the problem than go through all the combinations of how and when to do it. Even the HSE agreed there are situations where it can work - see their pre-WAHR report on tree surgery access methods. The possible issues include the basket moving when the weight changes (risking it hitting something, or moving out of reach, or unbalancing another person in the basket, etc.) or the person being at risk from falls while they transfer from the basket to the roof (you can't connect lanyards to both the building and the basket at the same time, in case the MEWP moves and wishbones you in half). However if the landing place is safe and the basket can be brought into a position where movement isn't a hazard, there's no real problem. For those who say "OMG noes! such crimes against safety can never happen!" then consider a big, flat, concrete roof with no edge protection, and a big boom-style MEWP. If the basket is positioned so it's an inch above the roof, and 3 metres in from the edge, then there's no possible WAHR risk from climbing in and out of it - if there was you couldn't get in the thing at ground level!
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#3 Posted : 17 June 2008 10:59:00(UTC)
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Posted By Robert K Lewis Garry Obviously a poorly thought out design from the start!!. I admit that in exisiting pre CDM 94 buildings one might have been forced to this type of situation but, and it is a big but, it should have been designed out and the fault lies with the designers. If one is to use a MEWP far better to use a flying carpet, ie scissor, lift as these do have specific access gate points and slide out platforms for this type of access. Proper design would have envisaged such use prior to construction. What we have here is rather like stating that abseilers will be used for window cleaning without considering fully the options available. They were simply chosen because it was the easy solution. The design team, I am afraid to say, failed to spot this one during the period when costs would not have been an issue ie before construction started. Bob
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#4 Posted : 17 June 2008 11:06:00(UTC)
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Posted By Ron Hunter To apply some logic to the issue then, the stepping off area has to be as safe as the area at ground level where I stepped in? In other respects, BS 8460:2005 "Safe use of MEWPs - Code of Practice" prohibits leaving the basket at height other than in an emergency UNLESS a rigorous risk assessment indicates that this is the safest and most effective means of accessing a particular location.
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#5 Posted : 17 June 2008 11:13:00(UTC)
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Posted By Ron Hunter And as a postscript Gerry, there's no way using a MEWP in the circumstances you describe could be justified by risk assessment.
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#6 Posted : 17 June 2008 11:23:00(UTC)
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Posted By John A Wright I agree the valley gutter is a problem location which we on this forum cannot properly assess and therefore cannot confidently approve Gerry's boss's plan. While we are here, however, if we were talking about a flat roof could we say that employees CAN climb out of an MEWP if: - risk assessment has been conducted by competent persons which concludes sufficient controls are in place to allow employees to exit the MEWP at height, and these controls are: - operation will be supervised - effective method of communication ensuring employees at height are in contact with supervisor on the ground - employees being raised by MEWP are fully trained - an employee on the ground has been trained to used the controls on the ground - fall arrest equipment is worn by empoyees which can be attached to MEWP while inside MEWP - fall arrest equipment is worn by employees which can be attached to anchor point on roof - rescue plan is in place to rescue suspended employee or injured employee on roof - all other controls for MEWP use (e.g. WAHR for protection of employees on the ground) are in place John W
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#7 Posted : 17 June 2008 11:34:00(UTC)
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Posted By Dave Merchant John - the difficulty comes in the 'fall arrest equipment' parts of your proposal. If the person needs to be attached after they exit the basket, then they need to be attached *as* they exit - and that *can* by impossible without risking being torn in two by a moving MEWP. There are situations where it's possible (for example when climbing into a tree, you can attach to pre-slung PFPE above you while still in the basket and don't strictly need to be clipped to the MEWP). The big no-no is being connected to both - so in the example in my previous post I moved the basket away from the edge so there was no need for a harness once out of the MEWP. You'd wear a restraint lanyard while the MEWP moved you to the landing place, but then could disconnect completely as you climbed out (just as if it was back at ground level). The same works in a scissor - if there's no need to attach to the lift then it doesn't matter if, on exit, you attach to something on the roof. If however you have to attach to the lift, then you can't simultaneously attach to the roof. (there are of course workarounds involving securing MEWP baskets to the structure, but that's a whole different can of worms)
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#8 Posted : 17 June 2008 11:38:00(UTC)
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Posted By CFT Gerry Forgive the obvious question; is there no way of accessing the gulley gutter in question by internal means and working via restraint? On a rare, and I mean rare occasion I have a commercial premises where access is restricted to either a purpose build scaffold access or via MEWP, the roof edge has a barrier with an opening section (similar to many mezzanine floors internally) this is quite safe as the barrier of the MEWP and the barrier on the roof prevent any possibility of fall; I won't go into the control measures, suffice it to say they are extremely comprehensive. I note that when 'a' company install fall arrest or restraint to a new build the initial fixings are made from the MEWP, then when protection is certain they latch on and complete the installation via protected means; it is therefore possible, but not in the manner you describe. I have one suggestion for you based upon the information you have given, forget a scissor lift and run with an over reach triple boom CP style MEWP, you can rise, then take the basket across the roof (subject to physical restrictions of course) and inspect/take pictures from the safety of the basket, thus ensuring you are protected at all times; with respect to the actual works you would need to supply a lot more information for help in devising a totally safe methodology for the task. All the best CFT
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#9 Posted : 17 June 2008 11:42:00(UTC)
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Posted By John A Wright Thanks Dave, I wasn't envisaging an employee simultaneously attached to both the MEWP AND the roof, apart from the problem you mention I would think the trip risk would be unacceptable :o) Properly supervised with communication I was thinking the employee could safely exit the MEWP and walk onto the roof, then attach himself to an anchor point if the risk assessment required. John W
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#10 Posted : 17 June 2008 12:07:00(UTC)
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Posted By CFT Hi Dave In a given set of circumstances what actually is the problem with Johns proposal? I would consider the likelihood of a MEWP moving (with thorough control measures) once connected via twin tail method (one in basket, one on roof)to be almost impossible (not considering earthquakes etc) Once the individual is in place and connected via lanyard before exiting, then moving towards the arrest post/wire and connecting second tail, returning to disconnect original I don't have a problem with (subject to professional input from all concerned.) I would have a problem with remaining connected to both at the same time throughout duration however. Just curious Dave, as I have the utmost respect for your contributions. All the best CFT
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#11 Posted : 17 June 2008 13:44:00(UTC)
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Posted By Ron Hunter Respectfully, if BS 8460:2005 "Safe use of MEWPs - Code of Practice" Annex B can't be followed, then you can't use a MEWP. Those involved in MEWP operations should have that CoP to hand.
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#12 Posted : 17 June 2008 14:51:00(UTC)
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Posted By John A Wright Ron, wth respect, If BS8460 is an ACoP then it gives practical guidance on how to comply with law. Following all that guidance is not compulsory and we are free to take other action. We can decide to NOT follow a provision of the ACoP if we can show that we have complied with the law in some other way. That is what this thread is all about. John W
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#13 Posted : 17 June 2008 15:45:00(UTC)
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Posted By Ron Hunter It isn't an ACoP, it's a Code of Practice = guidance. It is also the accepted standard & guidance within the UK for MEWP work which the HSE may refer to in any proceedings in determining what is and what is not "suitable and sufficient" and "reasonably practicable". Prepare a Risk Assessment without reference to that relevant Standard at your peril.
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#14 Posted : 17 June 2008 16:08:00(UTC)
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Posted By John A Wright Ron, Not an ACoP? ACoP = Approved Code of Practice. Just to muddy things further, on page (ii) of some (maybe all?) ACoPs it says that an ACoP is accompanied by guidance..... note the word accompanied - the guidance is actually NOT part of the ACoP. In an ACoP book : - regulation text is in italics - ACoP text is in bold - accompanied guidance is in 'normal' text So, as I said, following all the guidance is not compulsory and we are free to take other action AND if we do not follow the PROVISIONS of the ACoP we should aim to comply with the law in another way that would satisfy a court. We can comply with the law by preparing/conducting a risk assessment which allows a task to be done safely in another way. John W
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#15 Posted : 17 June 2008 16:30:00(UTC)
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Posted By Kenneth Patrick Surely if you can "climb" into it safely then you can also "climb" out of it safely. But why can't you walk in and out of them?
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#16 Posted : 17 June 2008 16:32:00(UTC)
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Posted By Ron Hunter Thankyou John, I am well aware of the structure and status of ACoPs. I am also aware of (and the distinction between) ACoPs and CoPs - a point you seem to be labouring. The Code of Practice I refer to provides guidance for hirers, responsible bodies and persons using the MEWP to assist them in complying with the Provision and Use of Work Equipment Regulations 1998 (PUWER), the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER)and the Work at Height Regulations 2005. It also provides valuable guidance for training those involved in MEWP operations. The Health and Safety Executive (HSE) commends the use of this British Standard to those who have duties under the Health and Safety at Work etc.Act 1974. This standard was drawn up with the participation of HSE representatives and will be referred to in relevant publications. As a code of practice, this British Standard takes the form of guidance and recommendations. Now given all that, would you choose to ignore it?
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#17 Posted : 17 June 2008 16:43:00(UTC)
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Posted By Dave Merchant CFT - it's not impossible to devise a way to keep the basket steady, but in general if you're using a boom-style MEWP then when you step out (with the boom elevated) the basket moves a fair way. You don't see the same at ground level as the booms are stopped to their rest points, but given that most Y-pattern lanyards are extremely easy to damage by loading them in a wishbone fashion, it remains a problem unless you lash the basket to the building. That's doable of course, but most MEWP manufacturers will forbid it because the hydraulics can't cope with pulling instead of pushing (if someone knocks a control or tries to activate the emergency descent, amusing things can happen). There's a secondary issue where the EN standard for MEWPs requires the basket is lowerable in any emergency event, and lashing it off obviously stops that, but given enough people it's workable with care. *Personally* I'd say once the basket has been parked in position and the controls turned off, there'd be no real reason to keep the restraint lanyard connected to the basket (it's only there to stop you being thrown out, and if nothing's moving you won't be). Once disconnected you're free to connect to something on the structure provided you don't need to climb out first to reach it (that's the system used to climb into trees). The problem with that is of course BS/IPAF guidance is really picky about never taking your restraint line off, so you annoy them for a few seconds. It's worth remembering that the guidance is based on typical scenarios in typical workplaces, and there'll always be a case when the guidance doesn't work - it doesn't mean you can't engineer a safe solution though!
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#18 Posted : 17 June 2008 16:48:00(UTC)
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Posted By John A Wright Ron, Thanks for saying there is a distinction between an ACoP and a Code of Practice which I admit I was not taking into account above. I have never specifically referred to BS 8460:2005, "Safe use of MEWPs - Code of Practice" Annex B, when risk assessing an MEWP task, so can you tell me if BS 8460 Code says that we can use alternative methods to those set out in the Code and comply with the law (health and safety regulations)? John W
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#19 Posted : 17 June 2008 17:08:00(UTC)
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Posted By CFT Dave Impossible for me to disagree with the scenario you have just used, and with the equipment you have cited it would be wrong to suggest otherwise. I suppose given the artistic licence and visual perception of an imaginary event that a written response allows, I had a scissor lift in mind on a nice flat surface extending upwards within a few mm of the roof edge, (thus eliminating likelihood of fall)clip on in the basket...actually forget it, it does not work due to the absolute outside possibility of an arrest whilst clipped in at near full extension, there is a possibility of topple. I'm going to have to have a re-think for a bit;-) I think I am still erring on an over reach access method; amazing sometimes how you go full circle! CFT
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#20 Posted : 17 June 2008 17:10:00(UTC)
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Posted By Ian D Jones Please correct me if i am wrong, Attachment points in basket are fall restraint rated. If you climb out of the basket whilst connected you would be in a fall arrest position, the anchor points are not rated for fall arrest.
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#21 Posted : 17 June 2008 19:09:00(UTC)
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Posted By CFT Yes generally unless they are clearly marked for fall arrest purposes. The usual method for a MEWP would be as you surmise fall restraint. CFT
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#22 Posted : 17 June 2008 19:10:00(UTC)
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Posted By CFT That should read restraint, not fall restraint. Apologies. CFT
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#23 Posted : 17 June 2008 20:21:00(UTC)
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Posted By patrick carr Hi all Very interesting subject and some very interesting and informative responses. You mention the Clerk of works as saying due to the cost,Scaffolding or Mobile towers are not a option. In my experience the cost of delivery and hire of a MEWP, in this case on 2 seperate occasions as a minimum, could well be more costly than the hire of a mobile tower. I realise i do not know what height your project is or any obstructions surrounding the work area, but in my opinion get the Scaffs in. regards Paddy (scaff) iamnotbiased.com
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#24 Posted : 17 June 2008 22:05:00(UTC)
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Posted By chris lee hello chaps just a quick word on this if the operator of the mewp is experienced and the mewp used is an articulate boom you can drop the basket from above therefore keeping the movement to a minimum basically the main boom extends to full hieght then use the secondary boom to point down toward the roof then use the basket jib to lower basket to within inches of the roof surface when you then step out lift up is small due to angle of the booms you are all right in your opinions and legislation but one thing no one has mentioned while out of the basket hydraulic oil pressure can sometimes drop and unless operator ensures pressure is back up before manouvering off the roof injury or damage could possibly occur
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#25 Posted : 17 June 2008 22:38:00(UTC)
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Posted By Ron Hunter John, I think you know the answer to your last question.You are not bound to use BS 8460:2005,I'm only suggesting you would be wise to do so. It tells you how to comply with what the law requires. The HSE commend it.It is authoritative. Few (if any) of us will better it. There are a fair few responses and suggestions on this thread which fall short of what the law (particularly WAHR) requires. Some suggestions are downright dangerous.
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#26 Posted : 18 June 2008 00:25:00(UTC)
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Posted By John A Wright Thanks Ron. Some of us are just trying to answer part of Gerry's question: when he asks can an employee climb out of an MEWP at height, and the answer is yes but with a big IF depending on the control of the risks, as postings above have detailed, and only if a safer access method can't be chosen. There will be circumstances where I won't stop work if the job can be supervised by competent people and very good controls are in place, but I like to use the word 'dangerous' when I'm not happy. I can't answer the part of Gerry's question about safe to walk/work on the valley gutter roof; that needs examination. I've been on a few roofs in my time; they are all different and I'm very uneasy near the edges and on sludge :o) John W
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#27 Posted : 18 June 2008 13:24:00(UTC)
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Posted By Gerry Marchant All Thank you for your responses to this....i'didn't think it would open up such a debate! However to update on this scenario i find out htis morning,,to be precise at 11:30 that the Clerk of Works *ordered* the guys to do the work in the way i decribed above....when i finally come down off the ceiling and spoke to the operative concerned he was very concerned in the fact that he was told to do the work or clear off the site therefore lose us a considerable amount of money...this is a local well established Colleges in the City of Spires...clue their to where we are!! however when i pointed out that nothing would replace the cost of his life if he were to fall he saw sense... The basket i beleive was placed adjacent to the roof structure, not on it and he exited from the basket through the lift up access bar, he did state the basket rose some 300mm when he did get out. I'm now waiting for the Clerk of Works to contact me about this and to discuss the issue of consulting me first...and on another note the CoW did not do a risk assessment! Gerry
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#28 Posted : 18 June 2008 21:37:00(UTC)
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Posted By John A Wright Gerry, Glad the job was done without incident, though not in the manner you would have wished. I try and risk assess MEWP work as thoroughly as possible and watch/supervise them too because of an 'incident' last year. We did the RA and the engineers wrote out the Method Statement which I read and said was OK. Next morning I came in and the work had already started, the fitter was on top of a newly erected resin tank (via the way we have just discussed) and he was attaching the top end of the new hooped ladder. I asked if they'd had problems raising the ladder up and a fitter said to me 'No it hung steady from the MEWP....' 'Huh, you mean they used the MEWP as a crane and your mate was in it?' I was not pleased. I checked the Method Statement and the wording was, I realised, ambiguous and I'd assumed the raising of the ladder was being done manually, an embarrassing oversight on my part. I explained to the Eng. Manager that I thought their method was wrong, using lifting equipment in a manner it was not intended, but it took me days to find a source that said it WAS wrong and found in it the IPAF guide to using MEWPs. On the positive side that incident was a great teacher, is forever in my mind as a permanent reminder to not assume anything and make sure what engineers mean in the wording of Method Statements ! John W
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#29 Posted : 18 June 2008 23:29:00(UTC)
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Posted By Garry Adams Gerry Your post has certainly raised a few eyebrows among my peer group members (Scaffolding Industry). Although the initial inspection has been conducted safely my concern would be the recommendations of remedial works to be undertaken (If Any). The mode of access may have been adequate for the task's purpose i.e. inspection/pre-task analysis, however, if the inspection has revealed that remedial works are required, then surely the Clerk of Works would not expect a cherry picker to transport the men, materials and tool required to under take the repair. All too often ,so called cost effective alternative modes of access are a false economy and can prove counter productive on occasion. Get the Scaffs on the job, eh Paddy m8. Garry...
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#30 Posted : 19 June 2008 08:24:00(UTC)
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Posted By Robert K Lewis Am I to presume in this that the CoW is employed by the occupiers/owners of the structure? If so a gentle reminder that responsibility of failure would rest totally upon him in future if he should wish to continue this. I personally would have a quiet talk to your local HSE if this person wishes to continue in this manner. You however are at risk as the competent contractor - following instructions that are in your view wrong does leave you potentally liable for injury or damage. The courts have a number of decided cases in this area, recently there was a collapsed wall that was built to engineers specification even though faults were identified in the design. Some clients are best left alone. Bob
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