Posted By Crim Did anyone notice during last nights news bulletin re the bus crash when the reporter was standing in front of the camera talking about health and safety there was a guy on top of the bus, in full view of the camera, fixing a sheet to the top of the bus? I could not see any means of fall arrest and this guy could quite easily have slipped/tripped and fallen from the top. I wonder if any HSE Inspector will pick this one up and issue an I N on that guy?

Posted By db Adrian, Well done finding the cut and paste button on your pc but you didnt really contribute to the debate by doing that. There is no specific guidance as to when we should or shouldn't use stepladders - that is the problem and arguably there never can be due to the wide range of uses. However, just because the risk assessment says it is low doesnt stop HSE from arguing that is isn't (or you arguing with HSE in a tribunal) What the inspector may have a problem with here (and we have not got the whole story so can only fo from what is written in the original post) is that the work has been assessed from the point of view of using the stepladder and not the work height activity itself. That is wrong. As Adrian helpfully pointed out, reg 6(3) says that : "Where work is carried out at height, every employer shall take suitable and sufficient measures to prevent, so far as is reasonably practicable, any person falling a distance liable to cause personal injury." Ladders do not prevent people falling so any risk assessment that starts with an assessment of the work using a ladder is intrinsically wrong. However, that does not preclude a stepladder being used - if it is short duration and as I said earlier that is also open to debate if its going up and down a ladder all day for ten minutes in numerous locations. There is, as far as I'm aware, no case law which covers this point and until there is then HSE will continue to issue IN's. My point earlier still stands - there is better kit out there which does the same job better than the small three step - stepladder mentioned in the original thread. PUWER, WAH regs all contain duties to use the best bit of kit for the job.

Posted By jennifer mcgilvray Hi I'm posting on behalf of Rosalind Roberts Head of HSE's Public Services Sector - hope thats ok as she is not yet registered. I am Head of HSE's Public Services Sector and am replying to Paul's original posting of 2 January on behalf of HSE corporately, and the two HSE members of staff present at the meeting Paul mentions. A bit more on the wider context and what we are doing may be helpful. It was Humberside Fire and Rescue Service (FRS) that approached the local HSE office (in Sheffield) and asked to discuss the use of step ladders for fitting smoke alarms in domestic premises. A meeting was arranged with Humberside representatives privately, in advance of a regional Chief Fire Officers Association (CFOA) Safety Practitioners meeting. At that pre-meeting we were told that both Trade Union and Management side representatives in Humberside felt that the use of step ladders for this purpose was questionable, but that they had been unable to resolve the issues involved over a three year period. The HSE response was that we wouldn't want to see any health and safety concerns left unresolved for such a long period, and we suggested setting a time limit on reaching a conclusion (to add some urgency to resolving this outstanding issue) mentioning Improvement Notices as a possibility. Reference to a possible Improvement Notice arose in the context of the time that this issue had remained unresolved. It was suggested that if the issue couldn't be resolved by March 2007, then a Notice would be considered to promote resolution of the issue. However, any such Notice could not possibly be to ban the use of stepladders which is not HSE policy, and which we repeat over and over again. In discussing best practice, the issue of three points of contact was raised. Humberside were pleased with this discussion, and volunteered to report it to representatives of other Services in the main regional CFOA meeting that followed. The HSE inspectors had no objection to this happening and suggested that any good practice developed by Humberside could get wider publicity. As things stand now, Humberside FRS want to find out whether safer/better means of access for such work are available in the marketplace, and whether such equipment would prove practical for the range of domestic premises in which they fit smoke alarms. This seems to us to be a good thing to do, and we are very grateful to Humberside for offering to share the fruits of their research with other colleagues in other Services. Every FRS will be involved in fitting smoke alarms and there is no simple prescription which will cover all circumstances for both the task itself and how individual FRS choose to carry it out. Consequently, HSE would like to encourage discussion of this matter by national bodies to consider the issues and the range of approaches that provide compliance with the Work at Height Regulations 2005 while maintaining service to the public by the FRS and Public Safety. HSE is represented on the CFOA National Health and Safety Committee and has tabled this as an issue to be raised at the next meeting. Rosalind Roberts

Posted By Ken Taylor Yes, thanks, Jennifer. It will be interesting to see what improvement(s) the improvement notice will require should the matter remain unresolved by March as this may have implications for other work activity - particularly within the Construction Industry. With regard to the earlier suggestion for wall-fixing, ceilings are usually the optimum position but walls may be OK provided that the detector position meets published recommendations (eg not close to the ceiling/wall junction). However, should a ladder still be needed to fix the detector at the appropriate height, the same problems will apply as for ceilings if two hands are needed to fix the detector. As regards proposals for add-on fall protection to the ladder, it would still be necessary to take account of the risk of injury from falling - and 'taking the ladder with you'. Edge protection to a platform is designed to keep the operative's feet on the platform and prevent slipping off it and this cannot really be achieved with a ladder. Unless the HSE are prepared to consider the use of a ladder in the way described by Humberside to be acceptable in the circumstances, it seems to me that the operation will need to be carried out either with one hand or by use of a platform with edge protection.

Posted By Stuart Nagle Stupendous Man !!! No offence but if you don't know the anwer to this then perhaps you ought to consult the HSE Guidance available on ladder work... The three points of contact would be for balance - two feet and a direct lean against the ladder, regardless of 'D' or 'U' if fitted is aceptable and regarded as safe... Stuart

Posted By TBC Glad to see the HSE is responding to this frustrating situation. I do hope that they see sense and allow the Fire and Rescue services to get on with what is a difficult job at the best of times. TBC (Ex Humberside Fire Fighter with two sons now serving)

Posted By Crim Being en ex fire officer and having had smoke alarms fitted at my home by fire brigade personnel I can inform you that they come as a crew of 4 or 5 therefore have plenty of firefighters available to steady the ladder. They are on call at the time so no waste of manpower or labour in fact it is a useful community service! I would suggest that having a second person available would considerably reduce the risk. Bulkier equipment can not be carried on the fire appliance as space is at a premium. This point has previously been mentioned. The lowest platform available, other than step ladder, appears to be almost 1 m from the floor. This is no good inside a normal dwelling house.

Posted By Crim Andy, I agree with you but the problem is HSE Inspectors are not the "average man in the street".

Posted By Pugwash There has been a lot of interest in this thread and the contribution from a senior level in the HSE is an interesting and welcome development for the forum. Two thoughts from me. First, the amount of debate and conflicting ideas from health and safety practitioners in the thread should send a strong message to the HSE that they have not got their message across as to what WAHR is expected to deliver. Instead seeds of confusion have been sown. Second, many will perhaps now think twice before approaching the HSE for advice if the results of asking the Executive for help with a problem can be a threat of enforcement action.

Posted By Pugwash Not sure that I agree with Pete’s reading that there is no threat of enforcement action. The HSE said: “It was suggested that if the issue couldn't be resolved by March 2007, then a Notice would be considered to promote resolution of the issue.” This is not an “offer to consider use” of a Notice, rather it is the HSE saying that if the problem is not resolved by March then, at the discretion of the HSE, a notice could be issued. To me this is threat with the purpose of concentrating minds on the problem. WAHR came into effect in April 2005. The launch of the Regulations was a relatively low key affair and, at the time, the HSE said: “those following good practice for work at height now should already be doing enough to comply with these Regulations”. The guidance which has been published subsequently has come out in a somewhat piecemeal ad-hoc manner, all suggesting that these Regulations should be regarded as no big deal – just one of those sets of legislation which we have to enact to square us up with the EU directives. However it now appears, to me anyway, that the HSE want to use to the Regulations to being about a step-change in arrangements for work at heights in the UK, and particularly for work with ladders and steps. They appear however to be unwilling to come out and say this. You could not get a much simpler task involving work at heights than putting up a smoke detector in domestic premises. I feel it is rather sad state of affairs that the HSE is not able to give clear guidance as to how they expect such a simple task to be carried out. The result is continuing confusion, both among health and safety practitioners and those who have to work at heights and it will be continuing fodder for those parts of the media who are hostile to the HSE. I agree with Pete that we “share a common desire and motivation with the HSE …. to demand and achieve improvement in H&S”. My personal view is that we do want a step change in arrangements for work at heights and I would support the HSE if it came out and said this. We should then have a clear strategy for delivering it. My suggestion? The HSE should produce an Approved Code of Practice in support of the Work at Height Regulations.

Posted By Catman Hi Again Don't want to be contentious or overly negative here, just realistic. To those of you stating just get a podium etc and pay the money. Could you recommend a specific platform that can be set at the appropriate height, is not too light duty and does not create additional risk being carried around a house? Products like minimax and roommate are not realistic here (although they are great in other situations) as they are too heavy and set at the wrong height. There honestly is not a lot suitable for this job out there. The risks and problems brought by the replacement always seem to be disproportionate to the risk involved, unless the ceiling is unusually high. At one point we even had one manufactured to try out which turned out to have stability problems due to the guardrail assembly raising the centre of gravity. Any manufacturers listening? TW

Posted By Andy Brazier Granville I am not sure it was your intention, but I think you have clearly demonstrated that a step-ladder is entirely adequate for this job in most circumstances. The platform that you claim to be the 'best example' is totally over the top for this job, and so allowing me to conclude that there is no reasonably practicable option to the step-ladder. Also, I feel it necessary to point out some misgivings I have with your earlier risk assessment. 1. You seem to have taken a likelihood rating for all types of accident and combined it with a worst case scenario rating for consequence. This is not correct. You need to consider the likelihood for different severity consequences, rate the individual risk ratings and then consider what this tells you. 2. You seem to be of the opinion that because people fall off step-ladder frequently they will fall off frequently doing this task. I don't believe this is the case because to put up a smoke-detector there is no need to stretch or lean (which can cause them topple) and because it is a quick light weight job. In other words, I am sure many of the accidents with step-ladder occur because people stretch/lean or do heavy long duration work such as painting and decorating. 3. I can't see how using a platform eliminates the risk. At the very least you need to climb onto the platform. I accept the likelihood of falling may be reduced, but I believe it would introduce additional risks. Sorry for being critical, but these are (in my opinion) quite elemental errors in your approach. Overall I am pretty sure this job has been done many thousands (maybe even millions) of times by FRS up and down the country. We should have more than enough data to tell us what the risk really is.

Posted By Graham Bullough As Andy Brazier has suggested earlier, there will have been countless smoke detectors put in UK dwellings, some by firefighters under the scheme involved in this thread. Many others will have been put up by householders themselves, including readers of this forum and who probably have stepladders at home for carrying out all manner of tasks. Over this past weekend I tried out my 5 step stepladder to reach the smoke detector I fitted to my hallway ceiling some years ago. The ceiling is 8'6"/259cm high. I guess that most domestic ceiling are les than 10'/305cm high. Without stretching I could reach my detector quite comfortably and with ample stability by standing on the 2nd step (23"/59cm high) and resting my legs and knees at a slight angle against the 3rd and 4th steps. If I were short of stature or needed extra height I could do the same by standing on the 3rd step and using the 4th and 5th steps to brace my legs and knees. Have the members of the FRS forum/s who are discussing the subject of this thread tried doing the same with a stepladder to get a realistic perspective about using stepladders? If one person using a stepladder in good condition to reach a normal domestic ceiling has reasonable stability, I cannot understand why a second person is needed to help steady the stepladder. However, a second person could make the job quicker, easier and safer for the ladder user by passing up the new detector, etc. and receiving tools after use. It has transpired that the subject of this thread began because of concern expressed by some firefighters and managers about the suitability of stepladders as the means of access for fitting domestic smoke detectors. Hopefully the relevant FRS forum/s will have or be getting information as to how many firefighters and managers have expressed concern, and for what reasons. Also, have there been any significant accidents involving firefighters while fitting detectors for Humberside FRS and other FRSs? These are the sort of questions which forum readers would probably pose if they, like myself, have never worked for a FRS. Another thought, and one which is likely to be controversial but needs airing. Looking outside the field of health and safety, is it possible that this topic has arisen because a few firefighters are not keen on fitting smoke detectors in domestic dwellings? If so, might they be using "health and safety" as a means of reducing their involvement with such work or getting it done by others? Think about it. Compared with fighting fires and dealing with other emergencies, fitting detectors is routine and mundane work, even though any measures to get detectors fitted in dwellings is very worthwhile. After all, most fire-related deaths in the UK occur at home, not at workplaces. Before anyone responds to accuse me of denigrating firefighters, I should stress that this is not my intention. However, in order for readers of this forum to assess the possibility that this thread might have more to do with employee/management relations than safety, please can anyone from a FRS tell us the following: 1) How how long has their FRS had a scheme for firefighters to fit detectors in dwellings? 2) Who initiated such a scheme - i.e. did the idea come from firefighters or from management? 3) Is the scheme obligatory or optional for firefighters? 4) What activities for on-duty firefighters have been reduced or replaced by detector fitting schemes? 5) How much time on a day shift is spent by firefighters fitting detectors if they are not called to attend any emergencies? As mooted earlier in this response, getting and analysing information about accidents, if any, involving firefighters fitting detectors is vital. Some perspective about stepladders may be gleaned from another common activity, namely the replacing of light bulbs and fluorescent tubes by caretakers in school classrooms. I've dealt with local authority schools for over 20 years and in that time cannot recall receiving reports of accidents involving such work, even though it is a regular and common activity and some of the caretakers involved are not as fit or agile as firefighters. Perhaps my employer and its caretakers have been lucky, or a few accidents resulting in minor injury have not been reported. Even so, the apparent absence of accidents seems to suggest that my employer's schools and their caretakers have long understood and followed simple and basic guidance about the use of stepladders.

Posted By Alan Hoskins Most people at home (and some safety people!) just stand on the nearest chair... Alan

Posted By Granville Jenkins Contrary to Andy Braziers comments I have endeavoured to show that step-ladders are the least favoured method for access, especially in the relation to the FRS's situation. Steps (subject to risk assessment) may be ok for occasional use, but where this is a highly repetitive task, as I assume it is with the FRS then steps are not the answer - the risk assessment scenario that I provided earlier was a worst case scenario simply because of the number of smoke detectors that the FRS are likely to be fitting increases the probability factor and the likelihood cannot therefore be given a score of 1. Also, I have known people in the past who have fallen from relatively low heights, one died as a consequence of a blood clot and the other was permanently brain damaged. The problem is that some people do not appreciate how the body may react in a fall, I don't mean crumpling in a heap, rather the person falls backwards like a rod (in trying to regain their balance) and the body acts like a pivot and the head swings through an arch and hits the ground with considerable force. I guess James M comments about sum the situation up, get it wrong and you better get your personal cheque book and get out of jail card out; if the person specifying how the work is to be carried out gets it wrong its not only the employer who may find themselves in the dock! I assume that Ken Taylor is talking about the old 2 metre rule where the old WAH Regulations did not apply below 2metres, it is my opinion that this was a rule that was flouted by some (not all) contractors, and as a direct consequence the rules had to be changed (for the better in my opinion) the onus is now firmly where it deserves to be fair and squarely on the shoulders of the employer and/or his duly appointed agent. Finally, I would just like to say that it is my honest opinion that the podium steps are the best solution, they are relatively cheap, easy to handle (generally weigh around 25-28kg and can be handled by one person and the ones advertised by turner-access.co.uk have four working heights (between 250mm and 1metre)- what more could anyone ask for! Regards Granville

Posted By Ken Taylor OK, the '2m rule' was misused (as are the current Regs) and there was a case for reducing this height but we now have the situation that 100mm (4 inches) or even less is now working at height and the hierarchy of controls has to be addressed if there is a significant risk of fall injury therefrom. Serving notices regarding trained and able-bodied firefighters standing a few rungs up on a stepladder from time to time to fix a small light plastic item that will save lives seems a strange move in the light of known significant fall injuries in other employment at far greater heights. From my experience of construction and demolition sites, there's a lot more important and relevant work to be done than this.

Posted By Catman Tabs Google for jumbo safety step, I think they beat you to it. Cheers TW

Posted By Granville Jenkins Hi Had a look at the 'little jumbo' - Not Impressed, well not quite that bad, the safety rail at the top is of use, but the little jumbo is still a 'step-ladder' and in my opinion is not a touch on the 'alphastep 250. In a much wider context, the same considerations that have been discussed would equally apply to Contractors who use step-ladders on a frequent basis - food for thought!! Regards Granville

Posted By Crim I was in one of the larger stationery stores yesterday and noticed a member of staff working on a set of "Airline" steps. You know the type that are quite high with a safety rail all the way up to the top and a safety rail at the top front? This guy was operating half way up, feet approx 1 m from floor, and twisting sideways with nothing to prevent him falling backwards down the steps. It just goes to show that no matter what is provided it still gets abused and safe working practices are not followed, also workers are not supervised and forced to follow correct procedures.

Posted By Tabs Yes, I had seen that - but given the ceiling height of a modern house, I think it would be too high to stand up on. Kneeling is not good ;-)