Posted By Chris Jerman Ellen, the really simple answer to this would be "utter tosh". However, I'm don't wish to appear to be making rash judgments and a little explanation is in order. A permit - for using a step, certainly not. Of course if the person were on the step breaching containment on a live gas valve it would be a different matter - but the permit would still not relate to the steps. If the step is simply to give the 'less tall' person a hop up to reach something, very basic instruction would be more than sufficient. Eg how to check it periodically, how to report defects, what to do if it goes missing etc etc. Training? Sorry, I would not confuse training with information and instruction. I would not train someone in going up a caravan step. If I did, I would have to include training for using stairs! Unfortunately, the 2005 regs have made some of this more pragmatic view a little more tricky. Personally, I would not describe a shop assistant stepping up onto a step stool as 'working at height'. Unfortunately, the regs quote this example as precisely that! So using a step or hanging off the Forth Bridge are now in the same frame? I'm sure that this should not be the true interpretation. I would also have to say that this needs to be set into context. If you represent a small office based company, I would really not be fretting about its use. If however, you are part of a huge national organisation - whilst the level of risk involved would probably be no different, the fact is that you have the resources to be 'more bothered' and therefore be thinking harder about it. Well what a long answer. Short answer now. If this is an occasional hop up for someone, simply to reach something - I would ensure that the step is a good one, stored sensibly and some basic information given to the user. (consider pregnancy and using steps too of course) If the task performed off the step is pretty involved and lengthy, you have to ask why you are doing it this way. But is it work at height? Not in my book. I would love to have given the simple answer on it's own, but I'm sure that someone would have seen the other angle - which is the whole point of having these forums. Chris

Posted By Dave Merchant It's not as simple as "utter tosh". Working from a kickstep is indeed covered by the WAHR, and while 'training' is not required for such a task, the worker must be 'competent' under the WAHR. How that competence is proven is entirely up to the company, and if yours has decided that it requires formal training, then you could argue it's overkill but equally it works. No training = no kickstep = no problem of non-competence. People shouldn't be sent on a 3-day course, but the Shattered Lives campaign shows that doing nothing isn't an option either. Permit systems are again not mandated by law, but are one *possible* way of relating authority over a task. If you have some competent people and some not, then you could get into difficulty if you didn't restrict the work to the right selection of people. A permit will do that - again it's arguably overkill, but it's a proven solution to the problem of task control. So is locking the steps in a cupboard, but it's up to company policy to decide how much trust they give their staff to follow the rules. If you're concerned the policy in this case is overkill, then ask for the reasoning behind it. You may find there used to be a more relaxed policy, but it was being abused.

Posted By Mitch Ellen, Agree with Dave, H&S punishment being retrospective doing too much doing too little, flip a coin! As he suggested clarify the requirement of who/what organisation is requiring the permit and training. Then assess who is carrying out what tasks with the equipment and introduce and controls identified as necessary. Personally I do not like 'caravan type' steps there are much better/safer/easier to use product on the market.

Posted By jayjay Guys ! INDG402 states the following: HSE believes that misuse of ladders at work can be partly explained by the way they are used in the home. As with all work equipment, users need adequate information and training to be able to use ladders and stepladders safely. Adequate supervision is needed so that safe practices continue to be used. So as you can see training is required as it is covered by both PUWER and the WAHR. Regards, JJ

Posted By Tabs I agree with some instruction. I do not agree with Permit to Work. Basic instruction regarding safe use and inspection is a good idea but we are not talking about a half-day course of law slides and team exercises. 10-15 minutes for the average person I would guess. Permits are to add intensive control to high risk tasks. Apply them to kicksteps and you may as well apply them to DSE use, cleaning, photocopier unjamming, etc.

Posted By Jimmy R Hi, We use kick stools and do not provide training. I can just imagine the response if we were to tell staff how to put one foot in front of the other and step up! Inspections and maintenance of the kick stools are carried out by our maintenance team on a regular basis.

Posted By Kenneth Patrick In a recent speech to the RoSPA conference the Chair of the HSC stated this opinion: "Competence of health and safety advice should be measured not only in knowledge but also in ability to provide that proportionate and relevant advice which I mentioned earlier that keeps health and safety real not turning it into a bureaucratic paper process."

Posted By David Bannister Kenneths's response above had me looking for the button to click to recommend that post to others. An idea perhaps for the webteam and this forum. This may then possibly reduce the number of postings saying the same thing.

Posted By Andrew M There seems to be a big divide here. I have worked on a site where Permits were issued for step ladders, and it was not the use of the step ladders that really required the permit. it was the environment they were used in. As for training it is a must and not just from a claims management perspective. The user of the equipment must be able to assess whether the equipment is suitable for the task intended, and if it is in a fit state of repair. I have seen domestic steps used in an industrial environment - not pretty. Training IMO should be about 1-2 hours max. As for high heels on a kickstool :-O

Posted By Dave Merchant Nobody on here is saying that to use a stepladder you need to go off on a 2-week residential course. We're saying that the law is perfectly clear - **to work at height you must be competent**. Proving competence is most easily done by a record of formal training. I don't care if that's a 5-minute video or a 3-year PhD - but to show your staff have been given instruction in the safe use of work equipment is a legal duty, and if you can't see that you shouldn't be in H&S. As I said before, if you think kicksteps are a stupid thing to 'instruct', then look at the HSE accident figures. Trivial slips and trips account for more RIDDOR events than anything else, and falls from a lot less than 2m regularly kill people. Saying an employer needs to have a formal policy to manage the risks is not "safety specs for conker matches" - it's attitudes like that which mean each year there are a few hundred less of us around to talk about it.

Posted By Jimmy R Nobody is talking about step ladders, we are talking about caravan type steps. We all should have arrangements for step ladders etc. How many of those slips and trips you mentioned involved kicksteps? I would imagine the vast majority had little to do with them. If you are saying you must have a formal training programme and records kept for stepping onto a kickstep then I can imagine several people would question whether you should be in H&S. Conkers Bonkers mate. I'm off home to write a H&S policy on walking across our playing field.

Posted By Pete48 There we go again. A simple task with some major consequence of variable probability, fill your boots. The law says this, the solicitors will have your shirt, make sure you have enough paper to keep you safe, I despair sometimes at the modern world. If you don't already know it, I would suggest that the vast majority of undertakings in the UK do not comply fully with basic H&S duties. The smaller the undertaking, the higher the percentage. So you may be correct in your assertions and you may feel validated in your position because it is irrefutable. I just fail to see how it helps to improve H&S if we have those same undertakings spending time training people on how to use steps in the office environment. One other point, why do we always see training as "given" to people; that it must contain instruction as well as information, must have an explicit audit trail? Isn't it just as easy to assess their ability to do these everyday things in the manner you would expect by observation and counsel if you see otherwise? Doesn't that provide a SSOW in the end, in fact I might argue a safer SOW.

Posted By db Let's forget about whether the WAH regs apply or don't apply. It's just putting up a smokescreen to the issue. Irrespective of what equipment you use to carry out a task (any task), the question has to be: Is it appropriate for the task? Is it in good working order? If the answer to these is yes and someone still has an accident, I doubt HSE will start charging you with a breach of reg 4 et al. I was in HSE just as the regs came out and kick stools were not considered a big issue and were not what HSE were concerned with.

Posted By GeoffB4 Steve, you can apply that to any work situation you can think of. But if we go round trying to avoid every risk situation because we fear being sued, what's next?

Posted By Steve Cartwright You do not require a permit for working from steps in an office environment.

Posted By GeoffB4 Spot on Eddie, I share your sentiments. A common sense approach that should be adopted.

Posted By Pete48 So is that a 1-1 draw or a win on penalties(sic)? Guess what, isn't this just another of those "the only right answer is the one you choose to adopt" situations. I love these exchanges even if they drive me to despair on occasions. Have a good weekend.