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#1 Posted : 14 July 2006 13:50:00(UTC)
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Posted By Mike Hann
I have just reviewed the HSE's "Example Risk Assessment in a warehouse" which forms part of the recently re-issued Five Steps to Risk Assessment".
In the example risk assessment, the scenario is given of a fall from height with "staff suffering severe or even fatal injuries if they fell whilst changing light bulbs etc in the high ceiling" of the warehouse.
It was stated that current control measures are "Proprietary fork lift cage used by maintenance worker for changing bulbs. Cage suppliers information shows it is manufactured to standard".
Suggested further action is: "Train maintenance worker to check cage is in good condition and properly secured before each use".
The information contained with this "example" appears to be directly contradictory to the advice and information contained with the HSE's own guidance note PM28 (3rd Edition) which was issued in December 2005. In this document it defines "planned /routine" maintenance tasks (changing light bulbs?) to be 'non occasional' and therefore not permitted.
Whilst we as a company have carried out detailed risk assessments of the use of fork lift trucks and cages to carry out 'non routine' tasks and drawn up Safe Systems of work for this, our general advice to site managers has been to NOT to use the cages for the replacement of light bulbs as this is, or appears to be, planned maintenance.
I plan to send this for comment to the HSE Infoline, but thought I would also ask for the views of my colleagues on the OSH forum too.

Your input would be very welcome.

Thank in advance.

Mike
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#2 Posted : 14 July 2006 14:04:00(UTC)
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Posted By RA
Mike,

Have you considered using the tilt isolation mechanism that can be obtained for FLTs (depending on manufacturer) using cages to raise manpower?

RA
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#3 Posted : 14 July 2006 14:13:00(UTC)
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Posted By Mike Hann
RA - Many thanks for your input. This is something that has been considered.
The main thing I am trying to find out is whether or not the HSE is publishing conflicting advice, which of course could cause us all a lot of problems.

Mike
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#4 Posted : 14 July 2006 14:19:00(UTC)
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Posted By Robert K Lewis
Mike

I know exactly what you mean here. The HSE will always fall back on your own risk assessment, making it clear that they were only offering some suggestions. The examples are always only for people to see what it might look like - they are not necessarily what should be there. Like all of us the HSE are not that good at the foresight of risks but 100% at hindsight. In my humble opinion any use of forklift cages needs to be assessed very carefully on a task by task basis and then rejected if at all possible.

Not only are there all the machine problems with using the cages but there are the maintenance issues. A visual inspection does not necessarily reveal the defects, except to perhaps experienced inspectors. Who is to know what has happened since the last use some months previously.

Bob
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#5 Posted : 14 July 2006 18:29:00(UTC)
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Posted By Mike Hann
Bob,

Many thanks for your input. It is appreciated.

Regards,

Mike
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#6 Posted : 16 July 2006 18:38:00(UTC)
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Posted By alex mccreadie
If these were used then the Forklift and cages would have to be inspected to the Criteria laid out in LOLER (Lifting Operations Lifting Equipment Regulations)This is due to the fact that this equipment is being used for man riding duties.
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#7 Posted : 16 July 2006 18:59:00(UTC)
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Posted By steven bentham
Mike

The conflicts by regulators is no different than the conflicts and views expresed by safety professionals.

Advice and guidance from the HSE is just that advice and guidance. It is difficult to produce this in a printed format that will suit all situations.

I accept that this is not what many safety advisers want and except that when it goes t**s up the regulator goes into enforcement mode.

As an inspector I would suggest you ask for advice from your own local inspector.

But at the end of the day, your company is the duty holder, and you assess and put in measures to control the risks. And the inspector investigates and enforces if appropriate.

P.S. If you put 10 inspectors in a room for a view or 10 safety advisers in a room will you ever get the same answer to any problem

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