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Following a request to explain the 1.8m rule and to clarify some points.
1 Sorry Ray for using the word nonsense, it was an 8 oclock word.
2 I am not new to H&S Safety, far from it I am soon to pack in and dedicate myself to raising money for a childrens hospice.
3 The 1.8 m rule was introduced so that all partners know that anybody working above that height must take all necessary measures to stop a fall, (edge protection harness etc) including tethering tools. Anything under 1.8 is subject to a Risk Assessment and allows a fair degree of common sense, i.e the guy stood on the back of a trailer for two minutes to tie straps doesnt have to go and purchase air bags.
It depends on how you measure your professional view versus your personal oppinion.
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tonymurphy wrote:Following a request to explain the 1.8m rule and to clarify some points.
The 1.8 m rule was introduced so that all partners know that anybody working above that height must take all necessary measures to stop a fall, (edge protection harness etc) including tethering tools. Anything under 1.8 is subject to a Risk Assessment and allows a fair degree of common sense, i.e the guy stood on the back of a trailer for two minutes to tie straps doesnt have to go and purchase air bags.
Tony, could you supply a link to the '1.8m rule' as i must admit i've never come across it, not that i pretend to know everything, by a long chalk. In the past, i've heard of inspections not being required on platforms below 2m and the 2m rule in the old construction regs but i've never heard of the 1.8m rule. Thanks in anticipation
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Its not regulated, its purely in house following a review of the WAH regs, although it does affect over 1000 employees, contractors etc.
Sorry for the confusion.
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tonymurphy wrote:Its not regulated, its purely in house following a review of the WAH regs, although it does affect over 1000 employees, contractors etc.
Sorry for the confusion. No worries. Where is it used and what tasks do the 1000+ do at height?
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6 feet, to the nearest 100mm.
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Mostly maintenance of plant, steel erection, scaffold, tank cleaning, civils etc.
It was carefully thought out and was, I believe, discussed with the HSE.
We felt it went over and above what was required if you will excuse the pun. Some people despise it, others love it. I think it adds more clarity because, in theory, the headteacher stood on the school stage is in breach of the regs.
It certainly gives rise to better planning because there is no ambiguity when working over 1.8. Its clip on or dont come back.
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Tony, it's my opinion if one of your maintenance crew have a fall from 1m or 1.5m and it could have been avoided, those discussions you believe were held with the HSE would not be worth a carrot in a court of law.
People can be badly hurt or die from falling 0.8m or 1.8m, depending on their landing.
I can still see lot's of ambiguity mate, tbh.
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Yes I Know. The worst injury I ever saw was a guy who fell off the third step on a stepladder and his wrist ended up near his shoulder. Also, some years ago I saw a scaffolder fall 5 metres and he didnt have a scratch.
There does need to be some common sense though and as I said I love it because the guys on site know where they stand.
The question is. How would I feel if somebody fell 1 metre and was seriously injured?
Hence the original post on another thread.
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I would say it is in my site that it is regarded as best practice to use the 1.8m rule,most companies put this in thair safe works procedures,even if a worker go on the platform for 1 minute it is required as per company policy,if that worker going up that platform for one minute and the rule and precuosions was not applied and the worker falls of the platform for what ever reason,what duty of care was taken by the company? and consider the reasonable man theory.The fact is a accident happens and is mesured in a split second not minutes.so to follow safey work prcedures and practices we allways require workers to wear full body harnass .sometimes even lower that 1.8m.
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Tony I have to agree with Frankc on this, I witnessed someone fall backwards off a step ladder and break many bones a week before his wedding.
Personally I think it was a lucky break!
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Tony,
I'd be interested to know how you got to 1.8m as a cut off point? Does the risk classification relating to working at height change somewhat between 1.75m and 1.85m?
It may add a bit of clarity to those who don't want to think for themselves, but I'd suggest it's a backwards step in terms of risk management. It could be an open door for those who want to take short cuts and not conducting a risk assessment, "no its ok, we're working at 1.6m and I remember someone saying we don't have to worry about controls" etc.
Don't think for a minute I'm suggesting the Head Teacher wears a harness or delivers the assembly behind barrier work though!
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Tony,
I trust you are not an IOSH member?
Because if you are, you are advertising that you willingly breach our code of conduct (code point 2).
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tonymurphy wrote:
There does need to be some common sense though and as I said I love it because the guys on site know where they stand.
Hence the original post on another thread.
Unfortunately, Tony, there will be no common sense allowed should someone be injured on your site/sites. The HSE will look at Regulation 6, section 3 which states... "Reg 6(3) is the key duty in the WAHR. Namely, ‘every employer shall take suitable and sufficient measures to prevent, SFAIRP, any person falling a distance liable to cause personal injury’. Reg 6(3) will be the most commonly quoted breach in any enforcement action because it is the key duty to prevent any fall. I haven't seen the other thread mate but i believe you are leaving yourself wide open.
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walker wrote:Tony,
I trust you are not an IOSH member?
Because if you are, you are advertising that you willingly breach our code of conduct (code point 2).
Being too serious minded it is only recently that I realised that some of the dafter posts are put on here only to get a reaction or a laugh. So I know what you are doing Walker!
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Ok I am going to be brave and post here :)
On a site I used to work on we introduced something very similar at the direction of our insurers!!!!
We had a 1m rule though.
It went like this
-Work above 1m = full permit to work.
-work below one meter a suitable and sufficient risk assessment will suffice.
This meant lower risk work could be carried out with less paperwork, and high risk work was subject to full control.
And no breach of the regs because everything was risk assessed to a suitable level!
This all came about after a claim made by an employee who was standing on a machine access step (30cm) claiming we had breached the work at height regs..... arguments amongst insurers, our board and the HSE were entertaining to say the least!
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Tony
Hats off to you for having the neck to raise this topic as a thread.
The 1.8 metre rule does fly in the face of the W@H regulations where no limit is quantified. I doubt very much that the HSE would officially sanction your arbitrary figure of 1.8 metre (6ft in old money) and if there was a serious injury or worse, pursuant to the 1.8 metre policy, you would be in breach of legislation. After all, the HSE often quote that most falls from height injuries are sustained below 2 metres. However, as most W@H takes place below 2 metres it is not too surprising that the majority of accidents happen at that level - not particularly useful HSE information.
I don't know how you came to agree on 1.8 metres as a benchmark for W@H initiatives? Notwithstanding that, it could be a pragmatic solution. Indeed, in construction/ utilities the 2 metre rule is often used by companies as a benchmark for excavations, below 2 metres shoring up it is not required under normal conditions. It is a practical, albeit arbitrary figure which has some merit.
For me the W@H Regulations are vague and hence often poorly interpreted. Following the introduction of the regulations a number of large construction companies allegedly banned the use of ladders and step ladders. I don't know why because they are useful pieces of kit used in the right manner ad for short term work. Interesting debate.
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Just received one of the HSE bulletins including the following link, http://www.hse.gov.uk/fa...rkers&cr=29-Nov-2011From the transcript; There is no distinction made between low and high falls. So for all work at height measures must be taken to prevent the risk of any fall that could cause injury. Remember 60% of all injuries are a result of falls from below head height. Dosen't sound like the HSE would endorse the 1.8m rule !
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Where are we getting off with some of the criticism aimed at Tony? He states clearly that it is an internal interpretation that is used to give some guidance to people concerning when a risk assessment does not need to consider whether measures may include a decision not to use any means of protection. In other words above 1.8m - do not even think about not using appropriate measures. THE WAH Regulations does not prohibit the use of such ideas and it would be very difficult for the HSE to demonstrate a breach. Work has to be assessed but Tony says that at 1.8m the assessment decisions are already made
Bob
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boblewis wrote:Where are we getting off with some of the criticism aimed at Tony? He states clearly that it is an internal interpretation that is used to give some guidance to people concerning when a risk assessment does not need to consider whether measures may include a decision not to use any means of protection. In other words above 1.8m - do not even think about not using appropriate measures. THE WAH Regulations does not prohibit the use of such ideas and it would be very difficult for the HSE to demonstrate a breach. Work has to be assessed but Tony says that at 1.8m the assessment decisions are already made
Bob It is possible that a task at 1.9m could be less "risky" than a different task at 1.7m, depending on the task, operative, equipment used, duration etc. etc. I promote effective risk management, and having an arbitrary limit of 1.8m may not be the most effective form of risk management for working at height. If the task at 1.9m has a lower risk classification it follows the controls required would not be as onerous as those required for the task at 1.7m, but using the 1.8m rule the less risky task would still need more onerous controls to be implemented!
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Jake wrote:
It is possible that a task at 1.9m could be less "risky" than a different task at 1.7m, depending on the task, operative, equipment used, duration etc. etc.
I promote effective risk management, and having an arbitrary limit of 1.8m may not be the most effective form of risk management for working at height. If the task at 1.9m has a lower risk classification it follows the controls required would not be as onerous as those required for the task at 1.7m, but using the 1.8m rule the less risky task would still need more onerous controls to be implemented!
Not necessarily. If the risk assessment of such an operation ("Anything under 1.8 is subject to a Risk Assessment") is carried out correctly it should come up with 'more onerous controls'.
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Seems to be a lot of ambiguity on this thread. Why not have some clarity and base the decision on the following:-
Work at height means work in any place, including a place at or below ground level,
where, if measures required by these Regulations were not taken, a person could fall a
distance liable to cause personal injury.
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barnaby wrote:Jake wrote:
It is possible that a task at 1.9m could be less "risky" than a different task at 1.7m, depending on the task, operative, equipment used, duration etc. etc.
I promote effective risk management, and having an arbitrary limit of 1.8m may not be the most effective form of risk management for working at height. If the task at 1.9m has a lower risk classification it follows the controls required would not be as onerous as those required for the task at 1.7m, but using the 1.8m rule the less risky task would still need more onerous controls to be implemented!
Not necessarily. If the risk assessment of such an operation ("Anything under 1.8 is subject to a Risk Assessment") is carried out correctly it should come up with 'more onerous controls'. I'm trying to allude to the fact that a) having the rule may mean control measures go "too far" for lower risk tasks that happen to be above 1.8m (what about replacing a single light bulb at 1.85m? would you really need to take all necessary measures to prevent a fall? (MEWP / scaffold etc??)) and b) because a risk assessment is being carried out for tasks below 1.8m anyway, and the results of the risk assessment may require "all necessary steps" being taken to prevent a fall from occurring, it seems pointless having a 1.8m rule. I’d also be concerned of the risk the 1.8m rule could be misinterpreted at site level and persons ignoring safety precautions for those tasks below 1.8m.
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Jake, I have no problem, with what you're 'trying to allude to'. I inferred that you were saying it would need more onerous controls below 1.8m than they would provide. Perhaps you were implying they may end up with more onerous controls than they would provide above 1.8m? In which case your concern would presumably be that the blanket approach above 1.8m would lead to waste of resources (ie excessive control) in some instances.
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Properly applied standard rules such as Tony has outlined provide a very useful management tool to guide operatives in their thinking about any task. The HSE really had no major issue with the old 2m rule except that it was construction based and it would be suspect to bring it into the regulations that affected ALL work sectors. Yes in certain situations low falls can kill and as the fall height increases the probability of death increases. By stating that we need to use standard pre determined controls, ie guard rails etc above 1.8m we are actually making life less complex for the operative. If there are exceptional controls needed above 1.8m then it should have been identified by managers much earlier and arrangemnts altered to accomodate such extra measures. After all we are simply stating that below you can as an operative select the right measures for the situation you are in. Above this figure the answer is pre determined.
At the end of the day we do something similar for many a routine task with relatively low risk. We allow people to assess for themselves what is needed, eg a load is less than 15kg, but non routine matters have standard pre determined actions, eg we have a 25kg load then 2 man lift or use mechanical handling
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There is not just ambiguity on this thread there is a deal of ambiguity in the WAH regs full stop. They were without doubt the most poorly written piece of legislation ever, and my original question was based upon stats relating to falls from height.
At no time did was HSE approval sought, but just kept them informed for good manners sake.
There are no issues as far as I am concerned because both 1.8 and above are controlled. My reservations are all based around whether a person falls 1 metre and is seriously hurt and whether better control measures are available.
As stated previously, do we want to see the Head Teacher on stage with a harness on?
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Tony,
Not trying to go off thread here but if said Head Teacher were to fall from stage and suffered serious injury (head, spine etc.), how would the School stack up against the W@H Regs and prosecution?
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Surely if you are up to 1.8m tall then you wouldn't need to stand on anything to work at heights of up to 1.8m.
With arms included you could probably work to at least 2m.
Therefore the W@H Regs wouldn't apply.
Or am I missing the point.
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Big Nick wrote:Surely if you are up to 1.8m tall then you wouldn't need to stand on anything to work at heights of up to 1.8m.
With arms included you could probably work to at least 2m.
Therefore the W@H Regs wouldn't apply.
Or am I missing the point. Nick, we are talking about a platform height at 1.8m or 2m above the ground.
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I am getting a bit lost regarding the whole point of this topic? Am I missing something?? - The WAH regs. clearly make any such " rule" a nonsense as they do not consider any minimum height as "safe".ie, at any height if there is a risk of injury from a fall, then the regs apply.
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Alan-uk
I think you have misread the OP as it does not talk about any minimum height being safe!!!!!!
Bob
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barnaby wrote: In which case your concern would presumably be that the blanket approach above 1.8m would lead to waste of resources (ie excessive control) in some instances. Exactly this. Effective risk management (with the prerequisite that legal compliance is in place) is achieving the right balance between safe guarding safety / health and the associated business benefits vs cost / trouble etc. in doing so. With so much ambiguity with H&S legislation, there is a lot of scope to improve risk management in the controls we stipulate. Scale up the additional cost, say for changing a light bulb at over 1.8m, for 1000, 5000 workers, the difference between requiring "all necessary controls" to be in place, or settling for those that are deemed reasonable practicable (lean-to ladder / stepladder with associated SSOW) is massive. It is with these cost savings that the money that would have been spent can be put towards controlling higher risk activities or other promotional projects. No business as an infinite pool of money to spend on health and safety. Going slightly off topic / spirit of this thread I think though!
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Jake
Who is to say that all necessary controls for stepladder usage will be costly? Use decent stepladders on level surface capable of taking load and ensuring 3 points of contact seem to be all necessary controls unless of course you are working on the edge of a 5th floor atrium or similar. Sounds to me like standard stepladder use.
Bob
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Jake
I do believe the 1.8m rule was introduced following an incident where two managers were surveying on a roof that had no physical barriers. They completed a pre task Risk asssessment which stated that their control measure would include not encroaching 1.8m from roof edge.
Apparently several operatives were up in arms because it appeared that these managers had breached the WAH regs, but they argued that they had took all necessary measures.
After much discussion the 1.8m rule was applied and works fantastically well.....so far.
I do have reservations but I am committed to a common sense strategy and therefore I support its use.
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boblewis wrote:Jake
Who is to say that all necessary controls for stepladder usage will be costly? Use decent stepladders on level surface capable of taking load and ensuring 3 points of contact seem to be all necessary controls unless of course you are working on the edge of a 5th floor atrium or similar. Sounds to me like standard stepladder use.
Bob I was using the task of changing the light bulb, not the use of stepladders. The use of stepladders, as you describe, would fall under the "reasonably practicable" bracket, it was my example of how the task could be completed. Being pedantic, taking all "neccessary steps" (this statement does not suggest a consideration of cost / hassel etc. but purely affording the gretest possible protection against a fall) to prevent a fall when changing a light bulb would not to be use a stepladder, as there is less of a risk of falling if one were to use a stepladder with lanyard / mobile tower scaffold / MEWP etc. Clearly this would be a nonsense in many situations. If the "all neccesary steps" were exchanged for "all reasonably practicable precautions" the rule would be more logical, however I guess that would defeat the object of the rule, as that thinking is applied to task at less than 1.8m in any case. Tony, do you mean 2m from the edge at a height of 1.8m? or have I confused my self?! Also, not meaning to try and pick everything apart, just enjoy the healthy debate :) I also agree that common sense must prevail.
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A lot of people seem to be jumping to conculsions and missing this: tonymurphy wrote:Anything under 1.8 is subject to a Risk Assessment and allows a fair degree of common sense, i.e the guy stood on the back of a trailer for two minutes to tie straps doesnt have to go and purchase air bags. Therefore, I agree with boblewis, all risk management measures appear to be in place (SFAIRP), so what is the problem. It appears to be a sensible and pragmatic approach, reached after consultation with key persons. Isn't that essentiually what most users of this forum keep on pushing for?
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Jake
I think it was an 8m high roof with an access ladder. They were surveying some sheeting and agreed to tell security what they were doing and then complete a pre task RA. I think the control measures included emergency plan with use of radio and they were only looking, again the RA stated that they were only there for short duration.
They agreed not to encroach 1.8m, I presume they concocted this from the distance they would need to slip, trip or fall. They used a variety of sensible arguments when they were challenged including knowing their own capeability, not actually carrying out physical work, correct choice of non slip footwear, ensuring that they undertok the survey on a clear and bright day with no wind and they both had WAH training and a local induction on the likely state of the roof.
Sounds perfect to me.
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Further ambiguity. So it was being 8m off the ground but keeping 1.8m from the edge as opposed to standing on an unprotected platform at 1.8m high?
When accessing the ladder, did they step on to a protected area or directly on to the open roof?
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I would imagine it was directly onto the roof. There is no ambiguity. It couldnt be more simple if you follow the thread.
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tonymurphy wrote:
The 1.8 m rule was introduced so that all partners know that anybody working above that height must take all necessary measures to stop a fall
There is ambiguity, Tony as this was upour OP. Now you say it's not encroaching 1.8m from a leading edge. I'm not having a go but most people are talking about ladders and steps so, with all due respect there is ambiguity on the thread
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