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Posted By garyh
Under the new WHR 2005 handrails for new plant must be 950 mm, 910 for existing plant. So far, so good.
How about the construction of a "new" plant which actually involves one company selling a (chemical) plant to the other. The storage tanks, complete with handrails, are then resited at a new location.
So.......... is this new plant or existing? What is required 910 or 950 mm handrails height?
It is "new" in one sense however the handrails definitely are "existing".
In addition, the regs quote the above "for construction sites, surely they meant all handrails?
PS if anonyone posts "do a risk assessment" I will scream..............
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Posted By MichaelM Gary The Building Regs should help. Look at page 8. I think the work at height regs 2005 should distinguish between guard rails and handrails as they are referrring to construction work. http://www.hse.gov.uk/re...hsl_pdf/2005/hsl0510.pdfHope this helps Michael
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Posted By Paul Oliver
Hi Garyph
Is it going to be a difficult process to raise the height of the handrails?
Can you prove the cost of not doing this will outweight the risk of doing it, and I'm not asking you do a risk assessment, more of a cost benefit analysis.
:-)
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Posted By garyh
I am not an engineer but yes, the cost would be high - and would probably involve putting in new handrails, raising the existing ones would not be practicable.
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Posted By Mark Eden
Look at the Work Place Regs reg 13 - any hand rail constructed after 1991 should be at least 1100mm high along with intermeadiate rail.
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Posted By Nick Higginson
Ok, I won't advise a documented risk assessment, but lets just think about it.......
Is 40mm going to make it any less safe?
I went to a presentation on WAHR and a Principal Inspector said that HSE wouldn't be getting their tape measure out......
Regards
Nick
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Posted By MichaelM
If your 8 foot 2 inches it might.
Hail the giants!
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Posted By steve e ashton
do a risk assessment.....
(Listen for scream....)
How do I live with myself?
Its new. The new standards apply. Even if the tanks had just been relocated within a site, the 'new' standard would apply - in this case, it seems the tanks are the 'new' property of a different company.
But (as others seem to be hinting) I don't think HSE will mind hugely provided the rails are appropriate to the risk... (and if the tanks have domed tops, a footboard would also be advisable..)
Oh dear, I was about to do it again. Oh what the heck, just for the fun of it...
Do a risk assessment! (inserts fingers in ears)
Steve
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Posted By MichaelM
Prior to doing an assessment on the hand(guard) rails, do a stress risk assessment and see if your pulmonary system could take it!
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Posted By Robert K Lewis
I think it actually it means new in terms of ownership. If you think back to PUWER a similar phraseology was used in terms of roll over protection. When ownership was transferred then the standards had to be met by the new owner. This ought to have been resolved by a proper Due Diligence search prior to purchase, the costs could then have been discounted if the negotiations had taken place.
This is an area often causing problems and is one of the reasons we always recommend a H&S due diligence check to our clients in such purchase situations.
Bob
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Posted By garyh
Thanks for all the replies. I am really tickled by the idea of "due diligence". Yes it would have been great (in my capacity as a mere Safety Manager) to have been involved BEFORE contracts were signed...........instead of having to pick up the mess afterwards......is anyone starting to see my problem?
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Posted By Paul Oliver
Garyph,
I totally see where you are coming from, I get it all the time.
However as long as I Inform, Instruct and Advise on all aspects relating to the problem I can sleep at night. If your management do not want to include you when making these decision and they know of your existence then that is upto them.
I know that being pro-active is always better than fire fighting but it does happen quite often.
Paul
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Posted By Kieran J Duignan
Gary
If you want to explore possibilities or needs for adaptation, proposing a survey of fingertip and elbow heights of users of the plant is an appropriate step in the as far as reasonably practicable' framework at this stage, as far as your own role is concerned.
Relevant data may show a need for change, which can be costed against anticipated benefits and against risks of non-compliance.
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Posted By Robert K Lewis
Gary
I know exactly what you mean as companies are far too happy to purchase what they think is an operational plant without investigation.
But the duty is not a reasonably practicable one as I understand the requirements for handrail height. They either meet the criteria or they don't. If the do not then they must be modified
Bob
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Posted By Stephen Boardman
You will probably find, if you measure the handrails, midrails for permanent fixed platforms etc they will be around the 1100mm height, the problem you may find is the lateral gaps between toprail, midrail and toe board will exceed 470mm... this can be easily remided by the addition of a further midrail.
Regards
Steve
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