Hi there,

I agree that 3 inches is a bit on the low side, that's more like a trip hazard than anything else. I wouldn't put any limits though, just stick to the 'is there a reasonably foreseeable risk of injury if anybody fell?' line. Most people 'falling' three inches wouldn't even really notice, so not reasonably foreseeable. If you go up to a foor though, then yes, injury is reasonably foreseeable though not inevitable. So avoid limits but ask people to think about the situation,

John

Yes, I think the idea that holes below ground level are also working at height is well understood and sensible, however there must be some sensible limit to where the working at height regs kick in. For instance kerbs at the edge of walkways (ours are over 3 inches) stepping in and out of a panel van? We also have a little podium for speakers in our presentation area which is a few inches high. All these would meet our own criteria for Working at height and by the sound of it some other peoples as well?

Edited by user 23 October 2019 07:50:48(UTC)  | Reason: Not specified

Originally Posted by: Natasha.Graham

Playing Devil's Advocate here but at a previous organisation one of our guys in the field broke an ankle getting out of his van onto uneven ground! He was at work and he was getting out of a van with two steps! It was considered working at height.

Interesting, I'd instinctively regard that as more of a slip/trip. When you say it was considered working at height does that mean it had already been considered and a work at height risk assessment had been completed or was that the conclusion of an investigation and if so was a work at height assessment subsequently completed and what addditional controls did it conclude were necessary if any?

To over egg the pudding even further another section of our documentation suggests a work permit is required for all work at height - so perhaps one must complete a permit and have it signed off before getting out of the van?

All rather silly perhaps but I have a dislike of scenarios where things are put into documents then widely ignored because they are patently impractical - it can cause the whole system to be viewed cynically or worse ridiculed.

A van has designed engineering controls such as grab handles and steps normally deemed suitable and sufficient protection negating the need for further WAH controls.

Often overlooked is why drivers need to have it stated to use 3 points of contact entering and exiting a vehicle - so we don't have to design additional WAH control measures

Originally Posted by: Roundtuit

A van has designed engineering controls such as grab handles and steps normally deemed suitable and sufficient protection negating the need for further WAH controls.

Often overlooked is why drivers need to have it stated to use 3 points of contact entering and exiting a vehicle - so we don't have to design additional WAH control measures

So what does this mean for us in the wider sense? The van manufacturer has considered the height issue and done their own assessment and provided what they deem necessary so we need do no more and rely on this?

Surely the stepladder manufacturer has also considered this and incorporated measures such as non-slip feet warning labels on the use of top steps, suitably stable design etc. so can we not rely on him in the same way and not do a WAH assessment?

Both the van and the stepladder are capable of being used/misused in ways the manufacturer has not anticipated resulting in incidents such as described by Natasha, would we not have failed then by not doing an assessment and providing additional controls (training perhaps?).

Ah you say, but the stepladder takes you to significantly greater heights from which a fall is more forseeable and the consequences more serious - which takes us in a circle back to the original question as to what height the requirement to consider kicks in.....

We have loading bays. The fall from one would be around 1.2m. We consider this working at height since a fall could cause a serious injury. I have always understood it to be any work, not at ground level, where the fall has the potential to cause a serious injury.

To be honest I don't think the definition is as important as the controls in place to stop an accident, no matter what you call the hazard. For example, if there is a risk of injury from falling you might put a barrier in, whether that fall was 50cm or 50m. But at the same time we can agree a fall restraint is not worth it on a 50cm fall.

Not that I am a great regulations guy, but if I remember correctly the Work at Height Regulations do not give a height, but say somthing along the lines around "any height where a person may be injured if they fall".  That leaves it pretty open but could also mean a couple of inches.  

Just on the side, one of the worst ankle injuries I have ever seen happend to a lady wearing flat shoes and slide off a tiny marble strip that had been installed at the bottom of a door.  

Be cautious with the description of , "work above ground level". Working on ground level near to an excavation, or events within an excavation (e.g. falling materials) should also be considered around the requirements of working at height.