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Head Protection overriding hierarchy of risks?
Rank: Forum user
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Right bear with me. a contractor argued that low hanging piping in a plant room doesn't need to be marked with tape to make it more visible because they provide head protection in the room.
We argued that this doesn't follow the hierarchy of hazard controls, I.e. minimize entry, redesign the pipes, etc.
They have now come back to say that the PPE regs and others overrule the hierarchy of hazard controls when head injury in fixed structures is a potential.
While I accept that a hard hat is a must, I think the other hazard controls are still acceptable and I can't find any legislation that says otherwise. Has anybody else come across this?
Thanks
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Rank: Super forum user
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The hierarchy of control always puts PPE or personal control measures as the last resort. The fact that they make head protection mandatory in this area does not, in my opinion, remove the need to apply the hierarchy and an engineering/admin control such as tape or warning signs takes precedence.
Eliminate
Substitute
Control
Protect
You can find the wording in Schedule 1 to the Management of Health and Safety At Work Regulations entitled "General Principles of Prevention".
Then you have to ask - whose plant room is it? Theirs or yours? If it's theirs, advise them what needs to be done in writing and walk away. If it's yours, why are you even arguing?
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Rank: Super forum user
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Your contractor's reasoning is not valid as far as I can see. Personal protective equipment is just that - personal. If it fails it always fails to danger. That is why the requirement is to manage the risk by means that do not depend upon the individual to comply.
The duty of the employer is to ensure so far as reasonably practicable that he has controlled the risk by means other than the reliance on PPE. What would happen if someone wearing a hard hat walked into the pipe at speed and damaged their neck. How would the contractor argue that they had adequately controlled the risk and that it was not practicable to apply some marking tape to the pipework?
Chris
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Rank: Super forum user
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There is so much to be said here I can't help feeling I am falling victim to another troll... CdC what is your role and what if any education have you had in h&s?.
ppe regs 4.1... Other protective measures take priority over ppe.
Hazard warning tape may ALSO be required u der the safety signs and signals regs... But wouldn't prevent injury in my experience. Good engineering would avoid or eliminate low pipes and other obstructions. What is the contractor doing? Good manageneme t controls would reduce or eliminate people needing to be in the hazard zone. Cushioned pipe wrap would reduce risk of injury where hi viz tape won't, but is not covered by signs and signals regs.... And other stuff...
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Rank: Forum user
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Thank you all for your comments. They confirmed what I was saying all along and also have stated to the contractor. You have reassured me in my confidence that what I was saying was correct.
FAO Steve E Ashton,
Definitely not a troll, but because of judgmental and rude comments like yours my forum nick does not tie back to my actual name nor would I be giving you my job role or info on any of my HSE education. Not everybody has 40+ years experience in the industry but some of us are just starting out or are working in unfamiliar areas. Hence I thought this forum was a way to support each other in our learning paths.
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Rank: Super forum user
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Cdc - Thanks for getting back in this thread - and apologies for the tone of my response. We have in the past suffered from a number of 'provocative' posters on this forum who seemed to to delight in asking questions which were intended to cause apoplexy. I'm very sorry for misreading the tone of your query although I trust the majority of my own response (PPE, Safety Signs, Engineering design, management controls and physical protection) shows I am always willing to offer help and assistance to any genuine queries. I hope you are able to persuade your contractors accordingly.
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Rank: Forum user
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ppe always last control measure
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Rank: Super forum user
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I agree with Lojikglos, Hilary and everyone else who has said that PPE is the last control.
I hate it when people ask things like that of us and it makes you question what you know by trying to call your bluff, Cdc you are not alone in this it happens to me all the time with site managers mostly. Stick by your guns, you hit the nail on the head when you said,
"We argued that this doesn't follow the hierarchy of hazard controls, I.e. minimize entry, redesign the pipes, etc. "
This is what I think this forum is great for, you can get the support you need when others are being difficult!
Let us know what this contractor comes back with, I am intrigued to hear more!
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Rank: Forum user
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Agree with many of the other posts above, PPE is always last in the hierarchy ERICPD. Another thing to bear in mind is that "collective" protective / preventative measures always take precedent over "individual" protective / preventative measures and as warning tape is there as a preventative measure for everyone it should take precedence over head protection which will only protect the wearer!
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