Holcim Directive on OH & S

FATALITY PREVENTION ELEMENT # 1: WORKING AT HEIGHTS

1. Basis
• Holcim Group Occupational Health & Safety (OH & S) Policy, Annex 2
• Management Handbook for Occupational Health & Safety of Holcim Ltd Chapter 4

2. Approval
This directive was approved by the Holcim Executive Committee on April 26, 2007

3. Validity
This directive will come into force on July 1st, 2007

4. Replacement
This directive is new.
Fatality Prevention Element

Working at Heights

1.0 Context:
Any work or movement near a drop of 1.8 meters or more is considered a high-risk activity, as falls are a
common cause of work related injuries and fatalities. Numerous work activities conducted at Holcim
operations are performed at height. It is therefore necessary to establish strict controls in order to remove
the potential for fatal incidents resulting from falls.

2.0 Purpose:
This element further defines the requirements for the safety pyramid block “Hazardous Work Activities”
for working at heights. The element aims to ensure adequate fall prevention and protection measures are
implemented to safeguard personnel from falls and/or being struck by falling objects.

3.0 Scope:
This element applies to all Personnel and shall be imposed by appropriate contractual arrangements on
all Contractors which conduct work near a vertical drop of 1.8 meters or greater. This requires the
provision of Fall Prevention or Fall Protection to be used at all times at work areas including all
structures, facilities, vehicles and mobile equipment, which are used on or by Holcim operations either on
its premises or outside.

4.0 Element Requirements Accountable

4.1 Hazard Identification Risk Assessment and Control

A survey must be performed and documented in order to identify all routine tasks
where there is the potential to fall from a height greater than 1.8 meters. The survey
shall also include work areas with a potential to fall from heights below 1.8 meters if
the work area poses a considerable threat to worker’s safety and if applicable local
legislation requires fall protection irrespective of height. The survey must record:
• Type of tasks being performed
• Location of the tasks/activity
• Type of fall prevention or protection measures used

4.2 Selection, Training, Competency and Authorisation

A training and competency assessment program must be established to ensure
competency standards are applied for the selection, inspection, use and
maintenance of fall prevention and protection equipment used at the operation this
includes:
• Personnel required to use/wear fall protection equipment
• Personnel required to erect, inspect and dismantle scaffolding
• Personnel required to operate elevated work platforms, scissor lifts or man lifts
• Personnel required to perform maintenance on elevated work platforms i.e.
scissor lifts, power steps, cherry pickers
The training and competency assessment program requires the recording of all
training undertaken and results of competency assessments. In addition, regular re-
assessments of competencies and retraining (when required) have to be performed.

An overview of the working at heights safety requirements must be provided to all

Personnel as part of the general induction program.

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Working at Heights

4.3 Communication and Awareness

Awareness information and/or instruction must be provided periodically to personnel
who perform work at heights and must include topics on:
• Fall Prevention and Fall Protection measures
• Safety requirements for scaffolding, elevated work platforms and ladders
• Inspection and maintenance of fall protection equipment and anchor points
• Safety precautions to be applied for the protection against falling objects

Where work at heights is being carried out, information must be provided on the
potential and current hazards (potential for falls and falling objects). This shall be
achieved by:
• Placing warning signs and barricades around openings and open edges
• Placing warning signs and barricades at lower levels to restrict access
• Signage displaying fall protection requirements
• Verbal methods on safety requirements (pre-start talks etc)
• Locating tags on scaffold to indicate if it is safe to access

4.4 Design, Purchase, Fabrication, Installation and Commissioning

Purchase specifications must be developed for all working at heights equipment
including :
• Fall Prevention equipment (refer glossary of terms)
• Fall Protection equipment (refer glossary of terms)

Where required design specifications must be developed for working at heights

equipment or controls including:
• elevated walkways and fabricated work platforms (guard rails, kickboards,
minimum widths for walkways )
• fixed ladders
• man cages
• guardrails and anchor points fitted to vehicles and heavy mobile equipment

Anchorage points and static lines must be fitted by a competent person to ensure
they are installed correctly and can take the required load.

4.5 Work Method and Condition Control

Where the working at heights survey does not define the method for Fall Prevention
or Fall Protection for a task, then a task analysis must be conducted prior to any
work being performed at heights and/or at any time the scope of work changes,
which may increase the risk of a fall. The task analysis must address the following:
• Identify the hazards and their potential risk
• Define the hazard control to be used –Fall Prevention or Fall Protection
This information must be communicated to all personnel prior to the commencement
of the task.

Only Personnel with the appropriate training shall operate Elevated Work Platforms.

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Fatality Prevention Element

Working at Heights

Only Personnel with the appropriate training shall erect and dismantle scaffolding.
Access to scaffolding must be controlled by the use of a tagging system. No work
will be performed from scaffolding unless the scaffold is displaying the ‘safe for use’
tag.

All Personnel using a Safety Harness must have received training/instruction in its
use. The Safety Harness must be inspected to ensure it is serviceable prior to use
and attached to an anchor point at all times.

When using fixed or portable ladders the following precautions must be taken:
• Portable Ladders must be inspected prior to use
• Portable Ladders must be set on even footings and secured to prevent falling
• Three point contact must be maintained at all times
• A Safety Harness is to be worn when working from a ladder

When performing electrical work or when working near electrical installations only
fiberglass or wooden ladders must be used and or an access platform approved by
a competent electrical engineer

All tools, equipment and personal items must be secured against falling.

Barricading must be erected to prohibit access to the hazardous areas this includes:
• Openings in the floor and walkway in which there is a potential to fall (in
situations where this is not practical then the opening must be completely
covered with material suitable to support the intended load).
• Lower levels where there is a potential for falling objects and/or material

4.6 Maintenance
A maintenance program must be implemented for all elevated work platforms, such
programs must address and implement the following:
• Schedules for planned maintenance
• Personnel trained and deemed competent to perform the maintenance
• Maintenance and repair work undertaken in accordance with the manufacturer
specifications and operational experience
• The use of manufacturers or approved compatible parts
• The recording of all maintenance and repair work conducted

4.7 Emergency Controls

A rescue plan for personnel using Fall Protection equipment must be in place prior
to any work being undertaken.

Emergency exercise drills shall be performed for recovering a person from height to
evaluate the adequacy of recovery plans and emergency response capabilities

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Fatality Prevention Element

Working at Heights

4.8 Monitoring, Inspections and Audits

Inspection of all fall prevention and fall protection equipment must include:
• Schedules for conducting inspections
• Requirements for inspections to be undertaken in accordance with
manufacturer specifications and operational experience
• The recording of all inspections conducted
• Inspections being carried out by a competent person

All fall protection equipment must be:

• Inspected and approved for use at periods not exceeding bi-annual intervals
• Each item must be identifiable as being inspected (this can be either through a
register or a local record displaying the last inspection)

Scaffolding and components must be inspected and recorded on the scaffold tag at
the following intervals:
• Prior to initial use and after inclement weather
• Weekly while erected
• Whenever modifications are made to the scaffold

Ladders must be inspected at the following intervals

• Fixed Ladders at periods not exceeding 12 months
• Portable and Step Ladders at periods not exceeding 6 months

Task/safety observations must be performed at regular intervals on work being

performed at heights to ensure the requirements are being applied correctly:
Annual audits must be performed to verify the quality and effectiveness of the
requirements set out in this element.

4.9 Reporting, Assessment and Corrective Actions

Hazards or defects identified with working at heights equipment must be reported,
assessed and must include:
• Actions required to stand down or destroy unsafe equipment (Safety Harness,
Ladders and Scaffolding)
• The recording of actions taken to correct the hazard or defect
Note: Fall Protection equipment must be destroyed following a fall or where the
inspection has shown evidence of excessive wear or malfunction.

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5.0 Glossary of Terms

Accountable The person designated to ensure that the assigned requirement is

implemented. This person is held answerable for the level of compliance
against the stated requirement.

Anchorage Point Secure points of attachment for static/lifelines and lanyards. The anchorage
must be able to withstand a load of at least 15kN for a single person anchor
point.

At Height Determined as 1.8 meters or more and applies to an area where it is possible
for a person to fall 1.8 meters or more. This general applies to where there is
the potential to fall from a vertical drop of 1.8 meters. It also applies to work
areas with a potential to fall from heights below 1.8 meters if the work area
poses a considerable threat to worker’s safety and if applicable local legislation
requires fall protection irrespective of height.

Authorisation Permission granted by the responsible Department Manager of an operation or

nominee designated by such responsible Manager to carry out specific tasks.

Competent Person A person having a combination of training, education, experience, acquired

knowledge and skills enabling them with the capability to perform specified
tasks to a pre-determined quality, which may be assessed against, defined
criteria.

Contractor A firm or person employed under a contract to provide services to Holcim as

distinct from a contract of employment with a Holcim operation.

Department The person nominated by Holcim as a responsible manager under the

Manager organizational structure. The same term is also used to describe the most
senior position in a Contractor firm.

Elevated Work Refers to power-operated elevating work platforms where the height of the
Platform platform may be adjusted by powered means using articulation, scissors
mechanism, telescoping, boom or tower, or any combination of these, and
which are either vehicle-mounted, self-propelled, towed, or manually moved, to
provide access to work above or below ground level.

Fall Prevention Systems that incorporate mechanical assistance and/or barriers designed to
prevent falling whilst working at heights. These may include:
• elevated work platforms
• scaffolds fitted with guard rails
• fabricated work platforms fitted with handrails
• ladders – portable and fixed
• man cages
• Fall restraint – safety harness fitted with short lanyard which prevents the
person reaching the fall zone

Fall Protection Is a system to arrest their falling, and includes:

• safety harnesses
• lanyards
• retractable reels – static lines
• safety nets
• anchorage points

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Personnel Person/s with a direct employment relationship with a Holcim operation.

Essentially the term refers to all persons as defined under the HARP manual as
own personnel, personnel of subcontractors and personnel of third party service
providers.

Portable Ladders Are ladders that can readily be moved or carried, usually consisting of side rails
joined at intervals by step, rungs, cleats, or rear braces.
Step Ladder – is a folding portable ladder hinged at the top

Potential to cause a A hazard identified that if not properly controlled will potentially contribute to a
Fatality / Risk of a fatal incident. Such identification is made by reference to previous fatal
incidents and to the respective assessments of such fatal injuries.
fatality
A health & safety record is a record of “evidence”. Health & Safety records do
Records not need to be included in a document control system. Once they are
generated, they cannot be changed or updated. Records provide evidence of
the status of the system at any given time.
It is essential that all Holcim operations have an effective records management
system. As a minimum, records need to be held for:
• Risk assessments (e.g. studies surveys, risk assessments etc);
• Health & safety training;
• Calibration and maintenance of monitoring equipment;
• Incidents, hazard reports, follow up actions;
• Inspections (pre operation, equipment, pre commissioning)
• Task/safety observations
• Supplier and contractor information; and
• Health & safety audits.
Note: records are not subject to government document requests without
authorisation by Holcim legal counsel

Safety Harness Is a restraining device worn for the purpose of stopping the wearer from falling
to the floor and/or enabling retrieval of a person from a confined space.

Scaffold A temporary construction, which consists of a framework and an elevated

working platform for supporting personnel and materials.
Any person who has not carried out a full induction and is only at the operation
Visitor for a period of less than 5 working days. This person is prohibited from being
engaged in manual or operational tasks.

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