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Jam52  
#1 Posted : 14 October 2025 15:53:56(UTC)
Rank: New forum user
Jam52

Hi everyone, i posted this question in another part of the forum and it was reccomended i post it in the public forum to get more insight, my question was: I’d be interested to hear views from fellow IOSH members on this.Following a recent incident at one of our sites (bitumen spill), scaffolding was erected around a storage tank to enable remedial works. The scaffold was proprietary system scaffold, fully boarded with guard rails and toe boards, and inspected/tagged before use.Here’s the point of debate:My position is that once the scaffold was being accessed for work, aWork at Height (WAH) permit[/b]should have been raised.My reasoning is based on HSG250, which listswork at height[/i]as an example of a high-risk activity requiring a permit-to-work system, and the Work at Height Regulations 2005, which require work at height to be properly planned, supervised, and carried out safely.In my view, the physical compliance of the scaffold does not remove the need for a WAH permit, because the permit is what demonstrates planning, authorisation, and consideration of factors such as: competence of users, exclusion zones, weather conditions, and crucially, rescue/escape arrangements.However, I wasstronglychallenged on this by another manager, stating that in theirexperience a WAH permit is not required for proprietary scaffolding, and that the controls built into the scaffold (guardrails, toe boards, etc.) are sufficient without the permit.My concern is that if the HSE reviewed this case, we’d be missing documented assurance that these checks were made, and they may well expect to see a WAH permit in place.It should also be noted that there were no references made in the open permit for the location of the leak that the work would be carried out at height, the area they were working on is approximately 5 to 6 meters above ground level.So, my question to the forum is:In this situation, wouldyou require a Work at Height permit for proprietary scaffold access during remedial or maintenance works? Or do you consider the scaffold and inspection/tagging regime sufficient on its own?[/b]Interested to hear how others are approaching this.

Edited by user 14 October 2025 19:17:18(UTC)  | Reason: Not specified

Roundtuit  
#2 Posted : 14 October 2025 18:53:31(UTC)
Rank: Super forum user
Roundtuit

Long post - short answer.

No I would not require a WAH permit for employees working from a proprietary (inspected) scaffold.

Roundtuit  
#3 Posted : 14 October 2025 18:53:31(UTC)
Rank: Super forum user
Roundtuit

Long post - short answer.

No I would not require a WAH permit for employees working from a proprietary (inspected) scaffold.

stevedm  
#4 Posted : 15 October 2025 08:25:16(UTC)
Rank: Super forum user
stevedm

...and here’s why:

  1. Legal and Guidance Basis
  • Under Regulation 4 of the Work at Height Regulations 2005, all work at height must be “properly planned, appropriately supervised and carried out in a safe manner.”
  • HSG250 – Guidance on Permit-to-Work Systems lists work at height as an example of an activity that may warrant a permit due to the potential for serious injury or fatality.
  • The presence of compliant scaffolding and inspection tagging satisfies equipment safety, but not activity-level planning and authorisation.
  1. Purpose of a Permit-to-Work (PTW) The PTW system is not about the physical structure — it’s about control of the work activity. A WAH permit demonstrates that:
  • The task was risk assessed in context (e.g., adjacent operations, weather, simultaneous works).
  • Personnel are competent and authorised.
  • Rescue and emergency arrangements are in place.
  • Any necessary coordination with other permits (e.g., hot work or confined space) has occurred.

These aspects are not evidenced through scaffold tagging alone.

  1. Regulatory Expectation (HSE Viewpoint Discussion) In the event of an incident, the HSE would expect to see a documented process showing how the work at height was planned, controlled, and authorised.  A scaffold inspection record demonstrates the scaffold’s condition a WAH permit demonstrates the safe management of the work being undertaken upon it. Without the latter, you’d lack assurance that the higher-level planning and supervision requirements of Reg. 4(1) were met.

Conclusion

A scaffold tag confirms the equipment is safe; a WAH permit confirms the work activity is safe. For a 5–6 m temporary scaffold used for remedial works following an incident, a Work at Height permit is absolutely justified and expected under both HSG250 and the Work at Height Regulations 2005.

Jonny95  
#5 Posted : 15 October 2025 09:03:25(UTC)
Rank: Forum user
Jonny95

I’d probably say I’m with Roundtuit on this. If your planning process achieves the same outcomes, safe planning, supervision, and effective controls, which it most likely does if done correctly, then you may already have ticked the boxes that Steve outlines as being satisfied by a permit.

In the introduction to HSG250, it states that not all hazardous work requires a permit and that a permit is not a substitute for good risk assessment and planning.

I would step back and look at the whole process and environment. This is non-routine work, and depending on various factors specific to your workplace, that would probably determine if a permit system is needed as a control measure.

However, as mentioned, if this is about ticking boxes and remaining compliant, then those requirements should already have been addressed during the planning stages.

andybz  
#6 Posted : 15 October 2025 10:07:29(UTC)
Rank: Super forum user
andybz

The job described involves 'elevated work' and not 'work at height.' There may still be thing to consider on a permit for the job, but no compelling reason for a WAH permit.

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