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#1 Posted : 01 October 2008 13:10:00(UTC)
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Posted By Rich T I have been looking at a couple of racking contractor's (quite well known companys) risk assessments for installing and dismantling high bay racking in our warehouse and I am appalled at the lack of attention given to working at height - given that working at height seems to be their primary source of income. Am I being a bit over cautious to insist that our contractor provides a suitable and sufficient risk assessment, that includes an appropriate WAH Rescue Plan, before I will allow them to work on our site? I have looked at a few RA's now and WAH Rescue plans seem to be as rare as hen's teeth! Is anyone actually bothering to check their contractors and vetoing any that don't provide suitable RA's? I would like to think I'm not being over pedantic....
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#2 Posted : 01 October 2008 13:14:00(UTC)
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Posted By Robert K Lewis If they are using MEWPS what sort of rescue plan do you expect? Bob
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#3 Posted : 01 October 2008 13:39:00(UTC)
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Posted By Rich T All of the assessments I have seen state that they will have people climbing the racking as a matter of course. I should have made this clearer in the original post. I can't see anywhere where they have followed the standard principles of avoiding the risks associated from working at height. And if they do think that climbing of the racks is appropriate (or they are following standard practices from their trade association), then they should be considering a rescue plan. But I just get completely blank looks when I mention these things. So I suppose to clarify the question I am asking, in more general terms perhaps: If you consider that your contractor's proposed risk assessments are not suitable or sufficient - would you allow them to work on your site? If not - where would you stop? Would you keep on going until you found a contractor that met your standards? Now I'm not saying that we have to become experts in someone else's line of work - but I'm sure we should be relied upon to identify what is a broadly suitable and sufficient assessment of risk - especially if it seems to omit a fairly obvious key point, such as WAH.
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#4 Posted : 01 October 2008 14:36:00(UTC)
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Posted By Peter Rees I'd highly recommend that they have a rescue plan - its certainly a requirement from W@H regs. Secondly, we recently had two operators stuck in a MEWP basket for 90 minutes when a hydraulic system failed. Fortunately, we were able to manage the situation, but it highlighted why a rescue plan is so important.
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#5 Posted : 01 October 2008 15:06:00(UTC)
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Posted By Rich T I must admit - my first response to the previous answer about MEWPs was to say - the sort of rescue plan that takes into account the hazards associated with someone working 10 meters above the floor in a MEWP - but I thought that would be regarded as flippant! I was tempted though... You see, I am getting to the point where the department manager requesting the racking work is starting to kick up a fuss about "H&S getting in the way of real work." and that "they are not our employees and not our risk assessments - if they are not suitable, that's the contractor's problem not ours if anything goes wrong". I have just this minute received a revised set of risk assessments from one of the contractors, and it is virtually a straight lift of a rescue plan found by googling "WAH rescue plan" they did not even change some of the stuff in there to reflect our specific situation! It's laughable! Am I meant to assume competence because they know how to Google things? I'm just astounded at the lack of knowledge and awareness of WAH issues, from a number of companies that work at height as their core business! I'm now minded to reject a third contractor, which will really go down well with the relevant department, who now desperately needs some racking modifying. Do I reach a point where I just say "Sod it" and let then get on with it, or do I persist in finding a contractor who knows what I'm talking about and has actually done something about it? Yeah yeah yeah... I know the answer! :-(
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#6 Posted : 01 October 2008 15:58:00(UTC)
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Posted By Robert K Lewis If the hydrailics fail on a MEWP they can still be lowered from the ground. If they are climbing the racks I think a more basic question concerning safe systems of work is more required than a rescue plan. WAH regulations anticipate a range of rescue options but MEWPS are straightforward. Having said that I received one for rescue from a scaffold recently, that is to say and independent tied scaffold three lifts high. The rescue plan seems the least of the worries when you have a system of work that climbs the racking Bob
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#7 Posted : 01 October 2008 16:26:00(UTC)
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Posted By AlB Don't give in and don't take the "sod it" attitude - if it all goes tis up then you could well be in the line of fire when the HSE and Police come knocking. It's quite straightforward - its a high risk activity (working at height), and they should have a suitable and sufficient safe system of work and they NEED a rescue plan. They will probably take the line of "we've always done it this way", but again, DON'T let them carry out the work without the suitable documentation. And stuff lifted off Google is a clear indication that they are not a safe and competent contractor. So you have three options - either turn a blind eye and let them carry on (which would be extremely irresponsible and is NOT in the best interest of anyone - no matter what people say); bin them and get someone else in (who may have the same approach) or bring the contractor in again and work with them to resolve the situation. Bit DON'T TAKE THE CHANCE.
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#8 Posted : 01 October 2008 18:26:00(UTC)
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Posted By Dave Merchant "If the hydrailics fail on a MEWP they can still be lowered from the ground." Dangerous assumption. Suppose something in the racking slipped, crushing the basket and the operator inside it, or wedging itself under the boom. You can say "rare... forget it" but rescues from MEWPS are *always* rare. The strange incidents are just as likely as the predictable ones. I've known a MEWP operator stuck for several hours in a basket because it was trapped against a structure when something moved unexpectedly, precisely because nobody thought it could happen so didn't have a plan to deal with it.
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#9 Posted : 02 October 2008 08:29:00(UTC)
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Posted By Rich T I too have had a very dangerous incident with a MEWP, where a sprinkler engineer somehow contrived to unscrew a sprinkler head from a live pipe with 10bar pressure in it. He was blown clear out of the basket and left dangling by his work restraint. It was a Sunday, other than him, his mate (on the ground) and our site security team, there was no one else about. His was the only MEWP on site, they were working at 10 meters up, they were both crapping themselves as one continued to dangle trapped under the pressure of a open two inch pipe with 10 bar of water jetting out, and the other was in a panic about how to shut the water off - using the correct valve set this time. And all the time our warehouse was gradually filling with water... A properly considered WAH rescue plan for a MEWP? Oh I do hope so!!! One day you'll be glad you did. Thanks for all your comments though. I have resolved to maintain my resolve. Note for information. I contacted the guys at SEMA (the trade association) and they inform me that whilst they teach people how to climb racks safely - to complete installation and dismantling tasks - they teach it as a last resort measure and also to demonstrate how much slower it is than using MEWPS. SEMA agreed that some of their contractors seem to be not quite getting the message that they are not being taught how to do it - they are in fact being taught how NOT to do it. I think I need to choose the contractor I trust the most, and bring them up to safety standards that we would all agree were "up to the mark". I need to stop short of becoming their safety advisor of course, but I don't see any harm in spreading a bit of good practice.
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#10 Posted : 02 October 2008 09:06:00(UTC)
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Posted By Robert K Lewis So where was the trained operative at ground level when all this happened? A good system of work should have prevented these "unforeseen issues"! Bob
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#11 Posted : 02 October 2008 09:13:00(UTC)
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Posted By Tabs Considering the response of your colleagues, perhaps a presentation on racking safety from SEMA would help them understand things better? There is an obvious misunderstanding about responsibility that has to be addressed with that particular individual, and if he wasn't beaten down by everyone around him, it would seem to be cultural there. When things have sorted themselves out, why not plan a managerial workshop on responsibilities and accountability?
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#12 Posted : 02 October 2008 13:04:00(UTC)
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Posted By Mitch Rich, The WAH Reg's 2005, Reg 4 'planning of work includes planning for emergencies and rescue' Mitch
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#13 Posted : 07 October 2008 14:11:00(UTC)
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Posted By accessoperator Hello Rich, You are right to be concerned about the racking contractors obvious disregard to having in place an appropriate rescue and escape plan. As an independent MEWP contract operator I am always certain to have a well communicated plan in place before I even attempt to operate MEWP. Becoming stuck in an elevated position is less uncommon than people may think, though usually due to over sensitive tilt/SWL safety systems that cut out the ability to operate the MEWP from the basket when extending up/out. In brief a plan should include nominating a competent person in advance to provide assistance, who will remain on the ground at all times and who has been given prior instructions on how to operate the MEWP ground controls and emergency descent system, in the event of an incident, or as requested by the operator. A means of pre-designated communication needs to be established i.e. by verbally, cell phone or two-way radio. A system should be agreed to monitor the crew of the MEWP at regular intervals via phone/radio calls or physical checks. This should be repeated at much closer intervals if the operator is a lone worker. Just one example of a plausible scenario and the pre-communicated action to be taken could be: 'By monitoring the operation the nominated ground person observes the operator/crew have become incapacitated or unconscious and are unable to operate the upper controls. Assess the situation as this could be due to a release of poisonous fumes/gases or electrocution... Action: Do not touch the MEWP and keep others away. Do not attempt to operate the ground controls or emergency descent system, as they may become a casualty themselves. Immediately dial Emergency Services and request assistance, giving all relevant details.' If these contractors are not following the basic principals of MEWP operating it brings into question what else they are ignoring? Hope this helps, Kind Regards AL Howes HOWES Commercial & Industrial MEWP Contract Operator Specialists Telford Shropshire
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#14 Posted : 07 October 2008 14:25:00(UTC)
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Posted By accessoperator Hi again Rich, I have just been reading through your comments again, quote: 'You see, I am getting to the point where the department manager requesting the racking work is starting to kick up a fuss about "H&S getting in the way of real work." and that "they are not our employees and not our risk assessments - if they are not suitable, that's the contractor's problem not ours if anything goes wrong.' I would personaly ask the department manager to brush up on his regulations: 'The Health and Safety Work at Height (WAH) Regulations 2005 as ammended, applies to all work at height where there is a risk of a fall liable to cause personal injury. Regulation 3, places duties on employers, the self employed and any person who controls the work of others (e.g. facilities managers or building owners who may contract others to work at height) to the extent they control the work.' He may even wish to brush up on the 'Corporate Manslaughter Act aswell to get to see the bigger picture. Kind Regards AL Howes
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#15 Posted : 07 October 2008 15:14:00(UTC)
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Posted By Andrew Shaw Just passed my Nebosh Diploma but lacking real world experience. We have a small warehouse with racking that needs alterations. This thread was very interesting. Just love the internet. Andy
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#16 Posted : 07 October 2008 16:02:00(UTC)
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Posted By accessoperator Hi Andy, I found the thread very interesting also and felt the compulsion to reply. Unfortunately this case is not an isolated incident but common amongst many contractors when planning working at height. Though not necessarily intentional but more through lack of understanding. It is a difficult challenge to get the message out to the contractors them selves and also the facilities managers who employ their services. If you are ever involved in the planning of the use of MEWP (Mobile Elevating Work Platforms) use the following checklist as a guide to assist in the selection criteria of your contractors: 1. Operator must hold valid Powered Access Licence (PAL). (Commonly referred to as IPAF card/certificate which is renewed every five years). 2. Operator must hold correct categories in the type of MEWP they are operating. 3. Operator has a personal log book which records each time they operate MEWP, it is a record of their personal experience. 4. Operator must be trained in the use of suitable Harness (in boom type platforms) always ask to see training certificate). 5. In date inspection records for Harness and restraint lanyard. 6. In date inspection certificate of last thorough inspection/examination of MEWP. 7. Risk assessments undertaken. 8. Method statement undertaken. 9. Rescue and escape plan nominating a competent 'on site' person to assist in the event of an incident. 10. Other suitable P.P.E provided, (outcome of job specific risk assessment)and proof of training in the use of that P.P.E. 11. MEWP public/employer liability insurance. Most standard tradesmen liability insurances do not cover for the use of MEWP. Always check the conditions, exclusions and limitations of individual policies, i.e check for restrictions on how high they are allowed to work and whether they are excluded from operating mechanically propelled vehicles? Hope this helps, kind regards AL Howes
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#17 Posted : 07 October 2008 16:22:00(UTC)
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Posted By Mitch Al, Ref point 9, would a competent person be specifically trained in rescue at height? Mitch Apologies if I have hijacked the thread.
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#18 Posted : 07 October 2008 16:38:00(UTC)
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Posted By accessoperator Hi Mitch, The answer to this would be 'no'. I need to be very careful what I say on this point as the regulations, codes of practice etc are very vague on what or who is classed as a competent person. 'My interpretation' and general practice is that a competent person can be nominated prior/on the day to operating and from the site you are operating from. However I am most careful to select a person 18+ etc who has an applicable/associated trade or technical role as opposed to some one who has not. A brief explanation/familiarisation of the ground controls/emergency descent system is all that is normally required but most importantly is a system of communication and consequent planned action in the event of an incident. Kind Regards AL Howes
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#19 Posted : 07 October 2008 19:48:00(UTC)
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Posted By accessoperator Hi again Mitch, Maybe I was a bit forthright with my answer 'no' and I don't want to miss intentionally misguide or confuse people over the correct course of action. The regulations as stated requires duty holders to plan for emergencies and rescue when working at height and effort should always be in proportion to the risk. If the plans involve the use of alternative rescue equipment then 'yes' workers will always need to be trained in procedures and their use. The point I am trying to make is that the level and detail of any rescue and escape plan should be determined by the job specific risk assessment, (any rescue could itself have a potential risk factor to those involved). Those risks and their subsequent actioning should be highlighted as an appendix/rescue and escape plan attached to the method statement or safe system of works. (A sort of method statement within a method statement). Of course if the initial risk and method statement are assessed and carried out to a very high standard then there should never be a need for a rescue. However never say never and always plan for the unexpected. It will ultimately be down to the initial auditor to assess what could go wrong, how soon it is observed/reported and what level of expertise or equipment is needed to implement any rescue and escape. When I 'conscript' a competent person as part of my own rescue and escape plan it involves their assistance in regularly observing my operations, and should it be required the operating of the ground controls/descent, under 'my controlled guidance' only. All other possible circumstances where I may no longer have consciousness or am incapable of controlling/co-ordinating the situation, will have been identified via my risk and method statements/emergency rescue and escape plan where the competent person will then be tasked to contact either nominated trained persons or emergency services as required to assist in the first instance. I hope this goes a little further to explaining your question. Kind Regards AL Howes
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#20 Posted : 08 October 2008 08:26:00(UTC)
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Posted By Mitch Good morning Al, Thanks that does explain it a little further, my conundrum more specifically is we are just completing a high level warehouse development on site with overhead gantry cranes. The staff are currently undergoing WAH, harness training, we unload freight containers from vehicles and assemble industrial textile machinery. Sub contractors will be on site for inspection and maintenance of cranes, lighting, heating, fire detection system etc using MEWPs etc. My question, arising from your earlier posting, is should their RA and SSoW include for one of our "site" employees to be nominated for emergency response? Mitch
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#21 Posted : 08 October 2008 09:20:00(UTC)
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Posted By accessoperator Good morning Mitch, If the work you are now looking at is for scheduled/reactive long term maintenance then I would be inclined now at this stage to start looking at and drafting up formal company operating procedures on each of the tasks you have mentioned. The company should carry out their own individual risk assessments for each of the tasks, identify any potential risks including those that could instigate a rescue and escape and have well communicated plans/procedures put in place accordingly. The need to train/have available one or more of your own 'on site' employees to be on stand by or react to a potential rescue and escape will be dependent on your findings. Any contractor working on site using MEWP from then on will be subject to a formal site induction and do so in accordance with your companies operating procedures. These procedures should then be subject to review and audit as with all procedures at given intervals say every six or twelve months. Kind Regards AL Howes
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#22 Posted : 08 October 2008 10:10:00(UTC)
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Posted By Mitch Al, Thanks for that I better look at some training, particularly Managing WAH Mitch
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