All you have to answer is the following and if the answer to any of these is yes you are then working at height.

Could you fall a distance liable to cause personal injury (That is any distance whatsoever) Excluding fixed staircases.

Is gaining access to, or egress from, such a place of work, either above or below ground level.

I the work being carried out upon a scaffold, mobile elevating work platform (MEWP), staging or trestles, using a mobile work tower, ladders or stepladders.

Is the work being carried out upon the back of a lorry

Is the work being carried out close to an excavation or cellar/basement opening

I would say the answer you are looking for is yes.

Kate of course is correct in what she has written, but I believe she may have taken the word unavoidable in your case in the wrong context. e.g., the removal of the handrails is unavoidable as opposed to the boat yard beleiving that working at height is unavoidable.

To expand on the answer that Kate kindly give as it didnt actually give you any advice is this. Is there a way to avoid working at height all together e.g. the equipment being lowered safely to ground level to be worked upon, or lowered into the ground such as a dry dock and fully decked out between the land and the vessel to prevent any possibility of falling through a gap with a safe engineered certified decking solution. (Normaly its just scaffold put up around the vessel which isnt the same).

In your case being a boat yard, I have assumed its a smaller operation and that you have the vessel lifted out of the water and sat upon a stand on the ground as opposed to its being in a dry dock on on the water and you are having to climb up onto the vessel and work with the hand rails removed.

The way I worded my first post is the questions I ask my engineers in order for them to recognise that they are actually at height. They are also the most common recognised engineering control measures used for working at height operations to be conducted in a safe manner.

You have to knowledgable enought to be able to pick which one is the most reasonably practicable in you case to be used and put the additional control measure in place to use such equipment e.g. licences, cerification safety harnesses and other PPE it goes on and on.

They are all still classed as working at heigh,t it’s just that these are the types of equipment normaly used as an engineering control method to enable such operations to be conducted in a safe manner, and each method also has additional controls required to be put in place in order to use the equipment safely.

Using any of those methods in my first post hasnt removed the need to work at height and I  am assuming there is no other reasonably practicable way of removing (Eliminating) the actual risk so you must consider one of those engineering control methods.

I hope that is a little bit clearer.

Edited by user 07 September 2022 19:26:03(UTC)  | Reason: Not specified

Many thanks for theinteresting comments to my concern. Just to claify , this is a small working boat yard where boats are often stored in cradles as well as being moored to pontoons. Staff work on the decks in either situation and often the edge guide wires are in place but in reality offer little in terms of edge protection. Accepting that these wires are used by owners in leisure activities I further feel that they are not acceptable at a place of work. So in reality there is nothing to prevent a worker falling from the deck ( which may be many ,eters above ground) , Staging is not an option due to space restriction therefore prevention seems key but there is a lack of tether points . Just wondered if anybody had seen industry specific fall arrest type controls ( boatyards) . Many thanks again for your valuable comments - much appreciated