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redken  
#1 Posted : 29 January 2014 09:35:22(UTC)
Rank: Super forum user
redken

https://www.gov.uk/gover...illion-working-at-height htttp://www.hse.gov.uk/work-at-height/myths.htm I am working at height if I’m walking up and down a staircase at work No, you are not. Work at height does not include walking up and down a permanent staircase in a building. http://www.hse.gov.uk/st...lips-trips-and-falls.pdf 2008/09 Changes in coding practice by HSE’s Incident Contact Centre (ICC). Injuries reported as “slips or trips on stairs” were reclassified as falls from height. Fall numbers rose and slip or trip numbers fell. The effect was disproportionately greater on fall numbers, which are lower. • 2011/12 Mid year change in RIDDOR reporting system. Without a code to identify stairs, reported slips and trips on stairs can no longer be reclassified as falls. Injury definitions now more directly reflect reporters’ own interpretations of the Kind codes than was the case when ICC applied data quality checks. Flyer form HSL Stair Assessment 12th February 2014 Stairs present significant potential for harm to their users, with falls often leading to serious injury or even death. Around 20% of all major injuries reported to HSE in 2008/2009 from slips, trips and falls from height occurred on stairs. This course allows delegates to understand the design features of stairs which can give rise to a risk of falling, undertake a stair fall assessment and identify simple remedial solutions to reduce the likelihood of a fall occurring. The cost is £350, which includes course notes, lunch and refreshments, and assessment tools developed by HSL.
Frank Hallett  
#2 Posted : 29 January 2014 11:39:24(UTC)
Rank: Super forum user
Frank Hallett

Hi Redken Unless the Regs have been changed; the WaH Regs exclude the use of stairs for their normal use of moving from one level to another whether the person concerned is "at work" or not! However, any work of any nature that takes place on the stair - ie cleaners hoovering, electrician changing light bulb - is work within the context of the WaH Regs and a fall then becomes a WaH fall. I didn't realise that the HSL course that you mention was promoted in this way! Frank Hallett
Phil Grace  
#3 Posted : 29 January 2014 12:16:54(UTC)
Rank: Super forum user
Phil Grace

Don't forget that irrespective of WaH reqirements the use of stairs is an intregral part of "getting around" many workplaces. And, as a result features heavily in accident statistics. You'd be surprised (well perhaps you wouldn't!) at the number of civil/compensation claims that originate from falls on stairs. And don't get me started on the third party claims from vistors, shoppers, pedestrians etc that come in under Public Liability policies. So, perhaps it would be worth going on the course if the workplace (or public premises) had a significant number of steps and stairs. Phil
Tigers  
#4 Posted : 29 January 2014 13:46:03(UTC)
Rank: Forum user
Tigers

The new guidance does contradict the indg455 in other ways too. Take the guidance from INDG455, it states 3 points being 2ffet and one hand on page 3 of http://www.hse.gov.uk/pubns/indg455.pdf Take the 3 point of contact rule in the myths section it now allows for the body to be a point of contact, not sure where this came from?? http://www.hse.gov.uk/work-at-height/myths.htm
Tigers  
#5 Posted : 29 January 2014 14:23:45(UTC)
Rank: Forum user
Tigers

2ffet is local slang for 2 feet!!
kevkel  
#6 Posted : 29 January 2014 15:52:04(UTC)
Rank: Super forum user
kevkel

Tigers, The mythbusters piece talks specifically about using stepladders as does the section in the indg455 on page 4 about stepladders.
Steve e ashton  
#7 Posted : 29 January 2014 16:34:48(UTC)
Rank: Super forum user
Steve e ashton

Judith Hackett believes we have good regs does she? Really? WAH Regs 12.2 anyone? "Every employer shall ensure that, where the safety of work equipment depends on how it is installed or assembled, it is not used after installation or assembly in any position unless it has been inspected in that position." ... So the window cleaner's ladder, the stepladder used to change bulbs, and the librarian's kickstool.... need to be inspected before use every time they are moved.!!!! And Regs 12.6 / 12.7 - the inspections need to be recorded. And kept for three months!!!!. So whilst HSE might choose to promote sensible H&S and 'simple guidance' - you are still perpetrating a material breach if you cannot produce at least three months worth of inspections for your office kickstool???? Sensible? Proportionate? Well drafted? My big toe could have written a better set of regs. Sooner or later I will have to take off my Mr Grumpy hat!
Frank Hallett  
#8 Posted : 29 January 2014 16:37:21(UTC)
Rank: Super forum user
Frank Hallett

Steve - hold it in 'till Friday! Frank Hallett
Victor Meldrew  
#9 Posted : 29 January 2014 17:21:51(UTC)
Rank: Super forum user
Victor Meldrew

steve e ashton wrote:
My big toe could have written a better set of regs.
I guarantee if your big toe does have a go at writing a set of regs, someone will find fault with them.
JohnW  
#10 Posted : 30 January 2014 11:27:42(UTC)
Rank: Super forum user
JohnW

tigers wrote:
Take the 3 point of contact rule in the myths section it now allows for the body to be a point of contact, not sure where this came from?? http://www.hse.gov.uk/work-at-height/myths.htm
the body as one point of conatct has always been implied in HSE training toolbox talks, indg403 last revised in 2011 said "When working from a ladder, try and maintain three points of contact with it at all times (e.g. both feet and one hand)". So by saying "e.g." implies there is another choice, maybe using body and holding something in both hands - for short duration of course. (I suppose one foot two hands wouldn't be an option !?! ) I've always said that in my ladder training. Anyway the new indg455 has replaced indgs 402, 403 and 405. And 455 now says "where you cannot maintain a handhold, other than for a brief period (eg to hold a nail while starting to knock it in, starting a screw etc), you will need to take other measures to prevent a fall or reduce the consequences if one happened" "Other measures" to me is not an example of a good explanation, and doesn't imply that your 'body' can be a point of contact. I don't think this has clarified or simplified the guidance. John
Frank Hallett  
#11 Posted : 30 January 2014 12:02:46(UTC)
Rank: Super forum user
Frank Hallett

The whole point about the "3 points of contact" was to ensure that whilst moving up or down the ladder, the user maintains a good degree of contact - ie only moves one of the 4 named appendages [2 arms + 2 feet] at any one time; and also indicated that when doing what they were up the ladder to do, they maintained the same level of balance and control by only allowing 1 hand to be used. In the light of some "real world" experience that has shown that sometimes it can be necessary to use 2 hands to do whatever they're there for whilst still being acceptably safe, the Guidance has been revised to allow the body resting on the face of the ladder to become that 3rd point of contact providing that the arms don't stray outside the ladder stiles and alter the ladder centre of gravity of course. Additionally, it now allows the use of the "leg-lock" on a ladder as in what firefighters were trained to do since Massey Shaw and Braidwood [never met them] - and before in the RN [when ships still had sails and stuff - I joined shortly after]. A long overdue and sensible adjustment to the Guidance in my opinion - of course, that means that so many of the already useless "Work at Height with Ladders" courses will become even more useless; but I doubt that will stop them being promoted or provided. Frank Hallett
JohnW  
#12 Posted : 30 January 2014 13:46:29(UTC)
Rank: Super forum user
JohnW

Thanks Frank.
Frank Hallett wrote:
The whole point about the "3 points of contact" was to ensure that whilst moving up or down the ladder, the user maintains a ....
but, the old indg403 specifically referred to WHILE WORKING, and said "When working from a ladder, try and maintain three points of contact ...."
Frank Hallett wrote:
...the Guidance has been revised to allow the body resting on the face of the ladder to become that 3rd point of contact ..... it now allows the use of the "leg-lock" on a ladder
I can only see that for stepladders in indg455. Have I missed something? Frank, point me in the direction of where this is explained in the NEW guidance for lean-to ladders. John
Dean Elliot  
#13 Posted : 30 January 2014 16:51:06(UTC)
Rank: Forum user
Dean Elliot

Steve, I guess that part (10) of reg 12 says "means such visual or more rigorous inspection by a competent person as is appropriate for safety purposes" The term "as is appropriate" is key here. Not great but that's why there aren't any notices ensuring people keep written records of ladders in every location they are used. Of course, ladders still need to be inspected and that is why they have been included.
steve e ashton wrote:
Judith Hackett believes we have good regs does she? Really? WAH Regs 12.2 anyone? "Every employer shall ensure that, where the safety of work equipment depends on how it is installed or assembled, it is not used after installation or assembly in any position unless it has been inspected in that position." ... So the window cleaner's ladder, the stepladder used to change bulbs, and the librarian's kickstool.... need to be inspected before use every time they are moved.!!!! And Regs 12.6 / 12.7 - the inspections need to be recorded. And kept for three months!!!!. So whilst HSE might choose to promote sensible H&S and 'simple guidance' - you are still perpetrating a material breach if you cannot produce at least three months worth of inspections for your office kickstool???? Sensible? Proportionate? Well drafted? My big toe could have written a better set of regs. Sooner or later I will have to take off my Mr Grumpy hat!
Frank Hallett  
#14 Posted : 30 January 2014 17:21:22(UTC)
Rank: Super forum user
Frank Hallett

To those who may feel that I've missed the point; can I just invoke what Steve Ashton wrote and then support that with the following:- The Guidance is still grossly inadequate and fails to recognise the realities of use; It is only Guidance so with a good legal representation you stand a chance of proving that it's inadequate; And It's about the best we'rer going to get until some other politician who knows absolutely nothing about ladder work needs a quick, easy "seen to be doing something" PR show. Frank Hallett
firesafety101  
#15 Posted : 30 January 2014 18:08:25(UTC)
Rank: Super forum user
firesafety101

Steve you have to be careful what you say, I have a very good friend who uses his big toe to write as he is unable to use his arms.
frankc  
#16 Posted : 30 January 2014 18:19:43(UTC)
Rank: Super forum user
frankc

Frank Hallett wrote:
Additionally, it now allows the use of the "leg-lock" on a ladder as in what firefighters were trained to do since Massey Shaw and Braidwood [never met them] - and before in the RN [when ships still had sails and stuff - I joined shortly after]. Frank Hallett
Frank, could you point me in the direction of where it states the above re 'leg-lock' is now allowed as it's a system i personally used quite a few times in my career as a steel erector and in my opinion, massively increases the safety while working on a ladder for work of short duration.
Frank Hallett  
#17 Posted : 31 January 2014 10:55:19(UTC)
Rank: Super forum user
Frank Hallett

In response to earlier observations requesting for greater detail on my assertion that "leg-locks" are acceptable:- Please remember that we are talking about the Guidance to the WaH Regs; not the Regs themselves, nor even the ACoP. The use of the WaH Regs, ACoP & Guidance descended into confusion and disrepute from before it actually came into being. The way in which the HSE, alleged H&S professionals and others [including politicians who don't even know which bit of ladder is which] have conflated the legal requirement with the ACoP [seriously flawed in some places 'cos it was not written to reference "real world" situations] and the Guidance all into one homogonous dollop of poorly understood principles is nothing short of disasterous to effective understanding and application of the Regs themselves. So, Guidance, is by definition, a set of challengeable and non-exhaustive examples of how the enforcers consider the users may wish to consider applying the Regs by providing examples of possible use; it neither defines, excludes, nor provides an exclusive list of what may, or may not, be acceptably legal. Therefore, it can only be considered to be extremely unrealistic for the Guidance to be "definitive" in the way that - ie earlier request for location of the reference to the use of "leg-locks" - some expect. It is most unfortunate that pretty much all groups involved in applying and enforcing the LAW fail to differentiate between the legal requirement and Guidance - no matter how authoritative it is perceived to be. Asbestos is another topic where this is endemic! Frank Hallett
Bruce Sutherland  
#18 Posted : 31 January 2014 11:29:10(UTC)
Rank: Forum user
Bruce Sutherland

Frank Forums are good things for forced revision before posting... I am struggling to find the WAH ACOP? And what in particular is trying you about the magic mineral now? Kind regards Bruce
Frank Hallett  
#19 Posted : 31 January 2014 11:43:47(UTC)
Rank: Super forum user
Frank Hallett

Thanks Bruce - Doh! There's no hiding place on this forum - not even a PM to warn me you sadist! My apologies to all for my incorrect reference to a WaH ACoP - I simply got all ahead of myself with thinking about the Asbestos topic and failed to edit properly. Fortunately, it doesn't materially affect the misuse of the Guidance though - just makes me look a touch silly. My reference to asbestos was not about the actual stuff; just to raise another example of the way in which the various types of documentation [including BS ENs] get all mixed into the one perception and presented as if it's all "the legal requirement". Frank Hallett
JohnW  
#20 Posted : 31 January 2014 11:44:46(UTC)
Rank: Super forum user
JohnW

Frank Hallett wrote:
In response to earlier observations requesting for greater detail on my assertion that "leg-locks" are acceptable:- Please remember that we are talking about the Guidance to the WaH Regs; not the Regs themselves, nor even the ACoP.
Frank, I'm sure those who have posted in this thread know that the guidance has been revised, not the reg. But many of us use the content of guidance in our training and toolbox talks (and we will say that it is guidance or good practice). So, since I do TBT on lean-to ladders, if I can say again, I can only see the reference to 'body' as a contact point in the new guidance, indg455, for stepladders. Have I missed something on lean-to? Please, point me in the direction of where this is explained in the NEW guidance for lean-to ladders. John
frankc  
#21 Posted : 31 January 2014 18:13:54(UTC)
Rank: Super forum user
frankc

Frank Hallett wrote:
Therefore, it can only be considered to be extremely unrealistic for the Guidance to be "definitive" in the way that - ie earlier request for location of the reference to the use of "leg-locks" - some expect.
Ok, Frank. I took your previous comment "Additionally, it now allows the use of the "leg-lock" on a ladder as in what firefighters were trained to do...." literally. I wanted to provide evidence of where it 'now allows it' if asked during safety training.
JohnW  
#22 Posted : 31 January 2014 18:28:06(UTC)
Rank: Super forum user
JohnW

Right so, if I haven't missed something about lean-to ladders, the guidance indg455 only says , with regard to 3 point contact, "where you cannot maintain a handhold, other than for a brief period (e.g. to hold a nail while starting to knock it in, starting a screw etc), you will need to take other measures to prevent a fall or reduce the consequences if one happened". Holding a nail for 5 seconds is OK. So anything longer like taking a measurement, or a photo, or painting something, or sealing, or adjusting a security device etc etc, which will take a little longer, the guidance does not recommend using body as one contact point? Hmm I may have to re-do the ladder training I've provided to over fifty people in recent years....
JohnW  
#23 Posted : 01 February 2014 10:56:33(UTC)
Rank: Super forum user
JohnW

I wrote
JohnW wrote:
Hmm I may have to re-do the ladder training I've provided to over fifty people in recent years....
Sounds like a nice little 'earner' but, seriously, all the lads will think I am having a laugh!
frankc  
#24 Posted : 01 February 2014 19:33:33(UTC)
Rank: Super forum user
frankc

JohnW wrote:
I wrote
JohnW wrote:
Hmm I may have to re-do the ladder training I've provided to over fifty people in recent years....
Sounds like a nice little 'earner' but, seriously, all the lads will think I am having a laugh!
That's why i asked for clarification regarding the leg lock system. I've been asked over the years if this is acceptable and always said no so i was intrigued by Frank Halletts statement "It now allows the use of...." although his next response contained the words "It may or may not be legally acceptable" Confused? You should be.
firesafety101  
#25 Posted : 03 February 2014 10:09:23(UTC)
Rank: Super forum user
firesafety101

In my experience (25 years fire brigade) you can not fall off a ladder after taking a "leg lock". However if the ladder slides you will slide with it.
Salis  
#26 Posted : 03 February 2014 14:09:59(UTC)
Rank: Forum user
Salis

I think we need to re-read the myth buster, it refers to step ladders, no mention of ladder.
damian2701  
#27 Posted : 04 February 2014 12:53:19(UTC)
Rank: Forum user
damian2701

I think from all previous posts that it has been proven that the new guidance lacks agreeable clarity. Why? Having read all the threads it occurs to me that if several proficient practitioners are unable to agree on the intricate interpretations from revised guidance notes then how are the masses supposed to get it right on the shop floor or staircase in this instance. Should a classroom exercise involve training over a 2 day period delivered by two different practitioners with conflicting interpretations of guidance notes then surely our audience's will be left with an overwhelming sense of confusion and bewilderment. I for one would rather see clarity and simplicity in revised guidance notes to allow trainees to be saturated with clear and concise guidelines.
frankc  
#28 Posted : 04 February 2014 17:28:17(UTC)
Rank: Super forum user
frankc

FireSafety101 wrote:
In my experience (25 years fire brigade) you can not fall off a ladder after taking a "leg lock". However if the ladder slides you will slide with it.
Always acceptable as an ex steel erector too. The only proviso was the ladder had to be tied off (not footed) Never saw or heard of anyone falling while using the 'leg lock' method either.
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