Hi, we have several warehouses that unload shipping containers by hand a few times a year. I have published a spec for an unloading platform to protect workers from unguarded edges and other risks but several of them say that they cannot store it because it is too big and they don't have the room to store it safely.

My view is that without a platform that meets our spec, the containers cannot be safely unloaded - or in other words the risk would be unacceptable.

The counter argument is that we only have to reduce the risk ALARP and that as it is impossible to store the platforms, it is okay to use a smaller spec.

I am sure this is wrong because we have to provide a safe working environment and if something cannot be done safely then it would be illegal to do (except for some limited situations that don't apply)

The trouble is, I can't find anything legal to support this. 

Can anyone point me in the right direction please?

“so far as is reasonably practicable” means that it has to be proportionate to the severity of the hazard. For example in an office environment, it is likely that someone at some time will get a paper cut. You do not have to sweat this one or spend a fortune trying to prevent a paper cut. On the other hand if there is a possibility of someone dying or being seriously injured then the expectation is that you take steps to prevent this.  What are the odds of this happening in this situation? If they are significant you need more controls.  Just because a control is expensive or needs extensive modification is not a reason to not to apply it.

It is no wonder you are getting push back - have you discussed this with the warehouse personnel or just provided your solution?

For a repeated activity a purpose built platform would be sensible but consider your post - this is an infrequent activity ergo there may be alternative solutions to the predicament.

What are the risks you are trying to control - if it is employees inadvertantley stepping from the back of an open container what else could you do?

How about two ratchet straps?

Once the container has arrived the doors are opened - from ground level a ratchet strap is placed between the uprights at the maximum height an employee can reach - it is then tensioned to act as a barrier.

Then using suitable access steps an employee climbs on the container with a second strap - this is positioned above the first as a second "stop"

The remainder of your crew move the access ladder and working from floor level take the de-stuffed goods from the rear of the container.

Once de-stuffed they return the access steps - the employee in the container removes the higher strap and dismounts. Once everyone is off the container the lower strap is removed.

Two rolled up ratchets easily fit in a drawer so storage is no issue (they are quite cheap to buy and can even be specified in some quite bright colours to ensure they are visible)

As the task of unloading these containers by hand is infrequent and there is no space for storing access equipment, have you considered having the containers delivered by a transport company that supplies specialist lifting equipment that allows the container to be lifted from the trailer to ground level?

The WAH risk is immediately removed as its a small step into the container. 

https://www.containerlift.co.uk/transport/

Ok, there will be an additional cost, but I wonder how that compares with the supply of an access platform and the costs of storing that off site (which is an alternative)

Good luck!

Not sure if it helps however, in the past I have had scaffold platforms with access steps built up around flatbeds to load and unload large equipment and parts.

Low cost & temporary as you hire the scaffold only when you need it

But it's not impossible to do the job safely - it just means that some money has to be spent and you need to find room to store the access equipment when not is use - that's the basis of the "defence" put forward if things go wrong - and your main duty will be under the work at height regs - not HASAWA - which has different qualified standards to SFAIRP.

I am sure that temporary platforms, stages, hired in scaffold, ratchet straps, off-loaded elsewhere......etc are all feasible and practical and achievable.

You may find talking to operatives it's more down to the faff of using the proposed solution.