Hard to judge unless we have sight of the risk assessment. What do you mean by a factory relocation? Do you mean just removing items from the building and transferring them across to a new factory or do you mean taking down the factory building and relocating it?

It really does depend Latchy. If the workers at height are behind heras fencing with signage for example. Is there an increased risk of something falling onto someone below because of the operations taking place or actually is it no more than a 'working' factory environment (where hard-hats are not common place). Don't ass-u-me construction site = hard hat. As you will recognise PPE is way down the hierarchy and don't insist on wearing where there is no hazard present - this is a poor management option (like ear-plugs when no noise).

As already stated a risk assessment should identify the relevant risks but just because working at height is taking place does no mean an automatic blacket hard hat requirement. If it's a large space and only a few MEWPS/Ladders are in use, you could corden off around them, so if anything was to fall i.e.tools etc it's within the cordened off area thus eleviating the need for all operatives across the site having to wear hard hats. If on the other hand the space is small or more significant building works are taking place at height then you may want hard hats. I recently got told I need full PPE incluing task specific gloves to go onto a site just to inspect and look around as the client. I questioned the need for task specific gloves as I am not operating tools, handling equipment or materials etc but site rules stated everyone wheres gloves.

Sometimes these things are political and the client is attempting to allay problems with his own staff and their use of hard hats. He will not normally issue them and thus wants to avoid the idea that this is a necessity because of the construction work. Just remember that if something happens it will not be the client who has to explain. The work is construction almost certainly, and thus subject to CDM07 to some extent. Bob