Professional Diploma in

Occupational Safety
and Health
OSH 3200
Occupational
Safety I
 OSH3200

Occupational Safety I

School of Continuing Education

Hong Kong Baptist University

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Version July 2020 (Updated March 2021)

Copyright
All rights reserved. This publication, or parts thereof, shall not be reproduced in any form or by any means, electronic
or mechanical, including photocopying, recording or any information storage and retrieval system now known or to be
invented, without the prior written permission from the Hong Kong Baptist University.

Disclaimer
While the Hong Kong Baptist University School of Continuing Education believes that all the contents in the course
materials are correct, the users must rely upon their own skill and judgment when making use of it. The Hong Kong
Baptist University School of Continuing Education does not assume any liability to anyone for any loss or damage caused
by any error or omission in the course materials. Any and all such liability is disclaimed.

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 Content
1 Working at Height; Safety in the Use of Scaffolding and Elevating Working Platforms ...… 5

2 Safety in Confined Space Operation ………..……………………………………………….. 35

3 Excavation Safety; Protection of Electricity Supply Lines …………..……………………… 58

4 Abrasive Wheels ………………………………………………………………….……….….. 80

5 Guarding and Operation of Machinery ……………….………..……………….………….. 96

6 Woodworking Machinery ………….………………..……………………………………… 147

7 Protection Against Falling Objects; Safety in the Use of Ladders………………………… 160

8 Safety in Cargo and Container Handling …………………………………………….….... 169

9 Goods Lift Safety; Quarry Safety; Boiler and Pressure Vessel Ordinance and Subsidiary
Regulations; Shipbuilding and Ship Repairing; Work Over/Near Water …………..…..... 189

10 Dangerous Goods Ordinance (Cap. 295) and Regulations; Gas Safety Ordinance
(Cap. 51) and Regulations.……………………………………………………...…….……. 211

11 Roadwork Safety……………………………………………………………………….…… 218

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 Course Aims and Objectives

Whilst introducing the legal system in Hong Kong and exploring both the interpretation and application of
its relevant ordinances, this course covers the essential legislation that govern the occupational safety and
health practice in Hong Kong, which includes the Occupational Safety and Health Ordinance, the Factories
and Industrial Undertakings Ordinance and their subsidiary legislation. Emphasis will be placed on
understanding the regulations in a broader perspective. The minimum legal requirements of an effective
safety management system for an organization will also be highlighted.

By the end of the course, students should be able to:

 Identify relevant legislation applicable to different industries, trades and operations;

 Appreciate the legal status and application of codes of practices issued by the Labour Department,
HKSAR;
 Recognize occupational safety and health offences in workplaces;
 Advise the proprietor of an organization on ways to comply with legal requirements; and
 Guide people to work safely under the legal framework.

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 Chapter 1
Working at Height; Safety in the Use of Scaffolding and Mobile
Elevating Working Platform

Provisions of CSSR Related to Working at Height

Working at height includes work that poses a risk of a fall of 2m or above. The greatest
risks involved in working at height are a person falling, injury caused by a falling object
and collapse of a structure or equipment such as a tower crane, scaffold, ladder or working
platform etc. In recent years, the Labour Department had imposed more stringent
requirements on above-ground work, which include working at height as well as work that
involve a risk of falling less than 2m. Using the concept of “risk”, in comparison with
working at ground level which only involves a chance of slipping and falling on floor, both
the probability and the consequence of a fall from height are much greater and hence the
resulting a much higher risk.

1.1.1 Duty of Contractor Responsible for a Construction Site and

Any Contractor who has Direct Control over Any
Construction Work to Ensure the Safety of Places of Work
(38A and 38AA)

Regulation 38A is targeted at the contractor responsible for the site, who is commonly
taken to be the main contractor. Regulation 38AA is targeted at any contractor who has
direct control over the construction. Principal contractor and its sub-contractor can also be
prosecuted under this Regulation. The Regulations require the contractor to conduct hazard
identification and control, provide safe access and egress to every place of work.

1.1.2 Prevention of Falls (38B)

It should be noted that “Adequate Steps” to prevent a fall do not include the wearing of
safety harnesses and use of safety nets.

1.1.3 Requirements with which Certain Safety Equipment Must

Comply (Schedule 3)

This part states the specifications for the width, height and other design metrics of a proper
working platform.

1.1.4 Safe Means of Support (38C)

Where work cannot be safely done on or from the ground or from part of a permanent
structure, the contractor shall provide and ensure the use of a scaffold, ladder or other
means of support, they shall be safe for the purpose having regard to the work to be done.

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The first consideration should be given to whether the work can be safely done on or from
the ground or from part of a permanent structure, and only if it is not feasible to do so will
the use of a scaffold, ladder or other means of support be considered. This fits the spirit of
the Hierarchy of Fall Protection.

1.1.5 Defences to R. 38B(1) and (1A) and 38 C (38H)

If a contractor is charged under Reg. 38B(1), 38B(1A) or 38C, it is a defence that if using
of proper working platform is not feasible, the contractor can provide safety belt or safety
net to protect workers.

This section is on the use of safety belts and safety nets. The anchorage for securing the
lanyard of the safety belt should be able to withstand 6kN.

1.1.6 Boatwain’s Chairs (Not Power Operated) (38G)

A manual type Boatswain’s Chair (or sometimes called Bosun Chair) is prohibited from
being used. However, raising or lowering by a power driven lifting appliance ones is
allowed.

1.1.7 Duty to Wear Safety Belt (38I)

When safety belt and secure anchorage are provided to worker, the worker has to wear the
safety belt and attach it to the secure anchorage when working-at-height.

A safety belt of the harness type is considered to provide better protection than a waist belt.
The fall arrestor of the safety harnesses should be attached to an independent lifeline or a
secure anchorage having a minimum strength of 6 kN.

1.1.8 The Hierarchy of Risk Control and the Hierarchy of Fall

Protection

The concepts of fall prevention, fall restraint and fall arrest are sometimes treated as
equivalent in regard to the protection of fall from height. However, there are basic
distinctions amongst them. First, hazard elimination and substitution should be considered,
then fall prevention by preventing access to a place of fall, e.g. using a guardrail as a
physical barrier that stands in between the worker and the fall hazard. Next along the line
is fall restraint whereby the equipment is configured to restrain the worker from accessing
the fall hazard. There is no barrier between the worker and the fall hazard, but the fall
protection equipment will not allow the worker to reach the hazard, e.g. using a 2 m lanyard
connected to an anchorage 2.5 m away from the fall hazard so that the full length of the
lanyard will not allow the worker to reach the hazard. Rescuing a fallen worker can also
be potentially dangerous. Forms of administrative control include putting up a warning
sign or tape, or assigning a safety monitor. Only failing this will fall arrest be considered,

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using equipment configured to catch the worker in the event of a fall. Arresting a fall
sometimes exposes the worker to painful forces and hence PPE is considered as the last
resort.

Source: Wikipedia: Hierarchy of hazard controls

In Hong Kong, the main method to protect persons from a fall at the workplace is by
applying the principles of Hierarchy of Risk Control: to prevent them from falls or to catch
them from falling further down if they do fall. The Hierarchy of Risk Control is
summarized in the following table:

Control Sections in Brief descriptions

measures CSSR
Identification of 38A(1) Identify and rectify any hazardous conditions which can
hazards and RA 38AA(1) cause persons to fall.
Risk controls by
Eliminating of 38C Ladders, scaffolds and other means of support are not
Hazards required if work can be safely done on or from the ground or
from part of a permanent structure
38G Prohibition on use of non power-operated boatswain’s chairs

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Substitution 38C Design equipment and processes such that work can be
safely done on or from the ground or from part of a
permanent structure
Isolation 38A(3) Take steps to ensure no person can gain access to places with
38AA(3) hazardous conditions (e.g., by physical barriers)
38B Take adequate steps to prevent persons falling from a height
of 2 m or more by
▪ guard-rails, barriers, toe-boards and fences
▪ coverings for openings
38H Safety nets and safety belts are suitable and adequate if
provisions of scaffolds and platforms are impracticable
Engineering 38C Provide ladders, scaffolds and other means of support for
controls: working at height
(i) Through 38B Take “adequate steps” to prevent persons falling from a
Design and height of 2 m or more
Provision 38D The design, construction and material strength of ladders,
scaffolds and other means of support must be sufficient to
maintain stability
rd
3 Schedule The safety requirements of scaffold and platforms
(ii)Through 38A(2) Access and egress to place of work
Maintenance 38AA(2)
and Repair 38B(1) On scaffolds, platforms, etc.
38D On scaffolds, platforms, etc.
38H On safety nets and safety belts and anchorages
Administrative
Controls
(i) Through 38A(3) and Take the necessary steps to prevent persons from gaining
Supervision, 38AA(3) access to dangerous places
Information and 38E(1)(b) Immediate supervision of trained workmen by a competent
Instruction person
38H Ensure workmen use safety belts provided
rd
3 Schedule The safety requirements of scaffold and platforms.
(ii)Through 38E(1)(a) Use trained and experienced workmen in scaffolding work
Training 38H Proper use of safety belt and anchorages

(iii)Through 38F Checking and inspection of scaffolds, etc, with Form 5

Checking signed by competent persons
PPE 38H If providing of working platform is not practicable,
contractor shall provide safety belt and safety net. When
provision of safety nets is impracticable, suitable safety belts
and anchorages have to be provided and maintained

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Legal Requirements on Scaffolding Safety (38D to 38F)

1.2.1 General Introduction

There are many types of scaffolding materials used around the world, including bamboo,
metal, glass reinforced plastic (GRP), wood, or a combination of these. The predominant
ones in use in Hong Kong are bamboo and metal. The Labour Department has established
Codes of Practice to provide general safety guidelines in their safe use.

1.2.2 Construction and Maintenance of Scaffolds, etc. (38D)

The scaffold, ladder or other means of support should be:

 of good design and construction to avoid collapse, overturning or accidentally
moving;
 Made of sound materials of sufficient strength and capacity; and
 properly maintained, securely supported or suspended to ensure stability.

1.2.3 Trained Workmen to Erect Scaffold under Supervision

(38E)

No scaffold should be erected on the site or existing scaffold substantially added to, altered
or dismantled except by workmen who are:
 adequately trained and possess adequate experience of such work; and
 under the immediate supervision of a CP.

1.2.4 Inspection of Scaffold (38F)

A scaffold where a person is liable to fall for 2 m or more should not be used unless:
 it has been inspected by a CP before the first use, after substantial addition, partial
dismantling or other alteration, after exposure to weather conditions likely to have
affected its strength or stability, and at regular intervals not exceeding 14 days,
and certified safe by the person carrying out the inspection in an approved form
(CSSR Form 5)
 the contractors at all times must keep the report, or a copy thereof, on the
construction site and at all reasonable times make that report or copy available for
inspection by any OSO or by any other person who is lawfully on the site
(including any person using or proposing to use the scaffold).

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Source from https://www.info.gov.hk/cgi-bin/forms (The form is available at this website).

Introduction to Bamboo Scaffolding

Bamboo scaffolding is a type of construction methodology specific to the eastern world, in

particular Hong Kong and Macau, and has been around for many decades. Similar to
tubular scaffolding used in the western world, bamboo scaffolding provides temporary
access and is used as a platform for work to be carried on for a great variety of construction
activities, ranging from construction to maintenance, and from tiling to external wall
finishing and cleaning.

Although suspended working platforms, mobile elevated working platforms and mobile
scaffolds are commonly used for external and internal cleaning, minor fitting out and repair,
etc., nowadays, bamboo scaffolding is still largely adopted for renovation and maintenance
work, in particular in outdoor work involving the building façade.

The main advantages of using bamboo poles as construction material is that they are
economical, flexible in terms of their adaptability to the majority of building forms, their
usage in limited working space and their ability of being erected as catch fan, their lighter
weight in comparison with tubular scaffolding members which give them more merits in
terms of manual handling, and the ease and efficiency of being installed and dismantled.
On the other hand, bamboo suffers from the disadvantage of being non-standard in terms
of strength and durability, and able to change and deteriorate with the environment, such
as the effect of wind.

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Sources (Issued by Labour Department): A Brief Industrial Safety Guide to Bamboo Scaffolding Work (n.d.);
Building Repair Bamboo Scaffolding Works Safety (2007); Code of Practice for Bamboo Scaffolding Safety
(2017); Safety Guide for Bamboo Scaffolding Work (2018)

Sources (Issued by Buildings Department): Guidelines on the Design & Construction of Bamboo Scaffolds
(n.d.); Make Sure Bamboo Scaffolds are Safe Against Strong Winds (n.d.)

Sources (Issued by Construction Industry Council): Guidelines on Planking Arrangement for Providing
Working Platforms on Bamboo Scaffods (Version 2) (2017); Technical Guidelines on the Design, Installation
& Maintgenance of Cast-in Anchors at External Walls of New Buildings (Version 1) (2011); Guidelines on
|Work-Above-Ground Safety (Version 1) (2016).

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Introduction to Metal Scaffolding

Metal scaffolding is used for different purposes in different construction activities. It is

commonly used as the supporting scaffolding in a falsework system. Collapse of falsework
due to insufficient strength to carry the imposed loads or inadequacy in design and
construction frequently occurs and has inflicted heavy casualties to workers working on it.

Sources (Issued by Labour Department): Code of Practice for Metal Scaffolding Safety (2011); Overview of
Work-at-Height Safety (2018); A Guide to the Provisions for Safe Places of Work under Part VA of the
Construction Sites (Safety) Regulations (2017); Safety Guide on Use of Light-duty Working Platform and
Mobile Working Platform (2016).

Code of Practice for Bamboo and Metal Scaffolding

The CoP for Bamboo Scaffolding Safety and the CoP for Metal Scaffolding Safety issued
by the Labour Department cover the following areas:

1.5.1 Requirements for Competent Person

 A competent person, in relation to any duty to be performed by such a person under

the CS(S)R, means a person who is:
 appointed for that purpose by the contractor as required by the CSSR to ensure
that the duty is carried out by a competent person; and
 by reason of substantial training and practical experience, competent to
perform the duty.
 For bamboo scaffolding, “substantial training and practical experience” of a
competent person in respect of a bamboo scaffold refers to a person:
 who has satisfactorily completed formal training in bamboo scaffolding work
such as an apprenticeship in the trade of bamboo scaffolder under s. 28 of the
Apprenticeship Ordinance (Cap. 47) or a 1-year full-time basic craft course on
construction scaffolding work of the CICTA (formerly CITA), or other similar
bamboo scaffolding training courses / programmes, or has satisfactorily passed
the trade test for bamboo scaffolder of the CICTA;

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  who possesses experience of 10 years or more in bamboo scaffolding work
(inclusive of experience under the formal training period); and
 who has the ability to read and understand the scaffolding plan, design
drawings, specifications and method statement of the scaffolding work in order
to competently supervise the scaffolding work and certify that the scaffolding
is in safe working order. He should also be capable of identifying existing and
predictable hazards in the surrounding area as well as working conditions that
are unsanitary or hazardous to employees.
 For metal scaffolding, “substantial training and practical experience” of a
competent person in respect of bamboo scaffold refers to a person:
 who has satisfactorily completed full-time formal training in metal scaffolding
work organized by the CICTA or other similar metal scaffolding training
courses/programmes and possesses experience of 4 years or more in
scaffolding work (inclusive of experience under any formal training period); or
who has at least a higher certificate in civil or structural engineering and has
satisfactorily completed a metal scaffolding training course/programme
organized by the CICTA or other similar metal scaffolding training
courses/programmes and possesses experience of 1 year or more in scaffolding
work (inclusive of experience under any formal training period); or
who has satisfactorily passed the Trade Test on Metal Scaffolding of the
CICTA and possesses experience of 4 years or more in scaffolding work
(inclusive of experience under any formal training period), and
 who has the ability to read and understand the scaffolding plan, design
drawings, specifications and method statement of the scaffolding work in order
to competently supervise the scaffolding work and certify that the scaffolding
is in safe working order. He should also be capable of identifying existing and
predictable hazards in the surrounding area as well as working conditions that
are unsanitary or hazardous to employees.

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Sources (Issued by Labour Department): Guidance Notes on Work Safety & Health of Air-conditioning
Works (2015); Information for Owners Friendly Reminder for Working at Height (n.d.); Prevention Against
Fall from Height (2001); Safety Requirements for Cleaning Outward-facing Windows (n.d.)

Sources (Issued by Occupational Safety & Health Council): Construction Industry Guidance on Fall
protection at Edges of Top-Most Floors of Structures Under Construction (1991); Construction Working at
Height Safety Checklist (1998); Safety Hints for Working at Height in the Construction Industry (2003).

1.5.2 Requirements for Trained Workman

 A trained workman in respect of bamboo scaffolding refers to:

 a scaffolder who is responsible for on-site erection, addition, alteration and
dismantling of bamboo scaffold under the immediate supervision of a
competent person, and has satisfactorily completed formal training in bamboo
scaffolding work equivalent to any of those for a competent person or has
satisfactorily passed the intermediate trade test for bamboo scaffolder of the
CICTA and possesses at least 1 year of experience in bamboo scaffolding work
(inclusive of experience under the formal training period); or
 a scaffolder who is a registered skilled, semi-skilled, skilled (provisional) or
semi-skilled (provisional) worker under the Construction Workers Registration
Ordinance (Cap. 583) for the trade of bamboo scaffolder.
 A trained workman in respect of metal scaffolding refers to a scaffolder who is
responsible for on-site erection, addition, alteration and dismantling of metal

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 scaffold under the immediate supervision of a competent person, and has
satisfactorily completed formal training in metal scaffolding work equivalent to any
of those for a competent person and possesses at least 2 years of experience in metal
scaffolding work (inclusive of experience under the formal training period).

1.5.3 Design and Initial Planning

During the design of a scaffold, either bamboo or metal, attention should be paid to the
following areas:
 The strength and stability of the scaffold throughout all stages should be ensured.
The strength of scaffolding members, such as bamboo and log for bamboo
scaffolding or tubes and couplers for metal scaffolding, should be ensured.
Reference should be made to the procedures laid down in relevant ISO standards or
equivalent procedures for their sampling and mechanical testing.
 Realistic assessment of loadings on the scaffold at all work stages should be made,
including the wind load by making reference to the Code of Practice on Wind
Effects, Hong Kong, 2004. For bamboo scaffolds, the maximum imposed loads
laid down in the Code of Practice for Bamboo Scaffolding Safety issued by the
Labour Department should be observed for the type of work activity being carried
on.
 Safe access and egress from the working places, attachment points for ladders,
working platforms, guardrails and toe-boards should be provided.
 The scaffolder should be provided with safety nets and safety harnesses for
protection.
 Scaffolding components / materials / equipment should be handled, lifted, stored,
stacked and transported safely.
 The time for erecting and dismantling the scaffold should be decided in the design
and planning stage. The scaffold should be dismantled as soon as it is no longer
required to be used.
 The scaffolding contract document should incorporate specifications for particular
requirements and essential information for the scaffolding work to be planned and
implemented safely (e.g., the provision of design drawings and method statement;
phasing of work particularly with other contractors; periodic maintenance; and
repair of scaffold). Special requirements relating to compliance with safety
legislation should be included in the Bills of Quantities (BQ).
 Effective lines and systems of communication should be devised for each stage of
the scaffolding work and a person should be assigned to maintain effective
communication.
 For a metal scaffold, an effective bonding system to the earth should be provided
to the scaffold.
 In the initial planning stage,
 Potentially hazardous site features and other aspects likely to impair safe
scaffolding should be identified and evaluated. These include:

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  the existence of overhead electric power lines;
 the existence of overhead signboards or projections, particularly those in
urban areas;
 the existence of buried services including underground electric cables, gas
or other fuel pipelines;
 the existence of storage tanks;
 restricted access to and onto the site;
 restricted space for erection, maneuvering, storage and, if required, for on-
site pre-assembly or fabrication;
 low ground bearing pressures that may be due to made ground or existing
underground services or structures;
 the proximity and condition of other buildings and premises that may by
itself or through the induced special wind effect (e.g. funneling effect) affect
the planned method of scaffolding;
 the shape and structure of the building;
 the juxtaposition of the public and the site;
 the activity of other contractors; and
 the existence of noxious gases, chemicals, fluids or dust emitted from
processes on or around the site; and
 for metal scaffolding, the proximity of the site to the seashore where the
strength of the scaffolding may be affected by seawater.
 A preliminary method statement should be prepared which includes:
 the arrangement for coordination and the responsibilities and authority of
supervisory personnel during scaffolding work;
 the scaffolding sequences including erection and dismantling;
 the methods for ensuring stability with due consideration of future
construction activities (e.g. trench work, external building services /
facilities installation);
 the detailed scaffolding work method which should ensure that the work can
be carried out safely;
 the construction tolerance;
 the assessed maximum allowable loading (including vertical and lateral
loads) on the scaffold / working platform;
 the provisions for preventing falls from height, including safe means of
access and egress and safe places of work;
 protection from falling materials, tools and debris, and the provision of
catch-fans and protective screens at the scaffold;
 the provision of suitable plant, tools and equipment;
 the arrangements for delivery, stacking, storing and movement on site for
scaffolding components, materials and equipment;

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  the details of site features, layout, and access; and
 the contingency arrangements.

1.5.4 Selection of Scaffolding Contractor

 Depending on the size of the project and/or complexity of the work involved,
tenderers for the scaffolding work should be required to submit an outline
scaffolding plan at the tendering stage, giving preliminary information to
demonstrate their intended safe system of work by describing the safety
organization, communication, monitoring, equipment, facilities, emergency
procedures, accident reporting, and accident investigation procedures.
 After appointment, the successful contractor should be required to finalize a
detailed scaffolding plan on the basis of the outline scaffolding plan for agreement
in writing. The detailed scaffolding plan should spell out the ways and means to
carry out work safely and effectively, and be incorporated into the safety plan of
the main project.

1.5.5 Site Management and Procedures

 A detailed method statement should be prepared, used, periodically reviewed and

updated as necessary.
 Active coordination, liaison and effective communications between parties both on
and off site should be established and maintained. Any changes in previously
agreed procedures must be verified by the person responsible for coordination as
being safe before they are implemented. Matters that will contribute to safe
scaffolding work on site, including the availability of information, plant and
manpower; and the quality and supply of materials should also be coordinated.
 The lines of communication should be clearly designated with the responsibility for
implementing the method statement well defined.
 If a decision is made to stop work due to adverse weather conditions such as rain,
high wind, lightning, typhoon, fog, mist or glare, then measures should be taken to
maintain the stability of the scaffold and the plant, equipment and works erected on
the scaffold. Also, all personnel should be safely and efficiently evacuated from
the scaffold. After the adverse weather, the scaffold and all the plants, equipment
and works erected on the scaffold should be inspected and certified in safe working
order by a competent person before work is to be restarted.
 No scaffold shall be erected on the site or substantially added to, altered or
dismantled except under the immediate supervision of a competent person and by
trained workmen possessing adequate experience of such work.
 Suitable protective equipment such as safety harnesses with suitable anchorage, and
/ safety nets should be provided where necessary.
 Plans and drawings should be checked before work is started on site.
 Personnel who are not required in the scaffolding areas should be excluded.

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  Site inspection should be conducted to check the physical conditions, the hazards
involved and other special features.
 The ground condition should be made firm, level and suitable.
 The maximum safe loading, including vertical and lateral loads, imposed on the
scaffold should be assessed, and strictly adhered to.
 The scaffolding members should be checked for their fitness before dispatching to
the site. Defective materials should be prohibited to be used and should be properly
labelled as defective and be removed from the site as soon as possible.
 A suitable place, clearly shown on the site plans, should be provided at the site for
the storage of scaffolding members and the associated materials, tools or equipment.
They should be properly stacked and tied to prevent accidental displacement and
collapse. To avoid decay, bamboo scaffolding members should be stored in a dry
area, in a vertical position to prevent the accumulation of wastewater inside.

1.5.6 Working Places and Access

 A method statement for the construction of a working platform should be devised.

 Guardrails and toeboards complying with the legal specifications should be
installed at edges where persons are liable to fall from height. Where this is not
practicable, safety nets and safety belt should be provided and where this is also not
practicable, safety harnesses with an effective anchorage system should be used.
 Ensure that the plank laying work for bamboo scaffolding is carried out safely and
properly on site in accordance with the guidelines in CIC’s Planking Arrangement
for Providing Working Platforms on Bamboo Scaffolds by laying a working
platform on every lift of a bamboo scaffold, or erecting a suitable working platform
at every working location on a lift where the entire scaffold is designed as a closely
spaced bamboo scaffold.
 At the very least, a sloping catch-fan at not more than 15 m vertical intervals and
giving a minimum horizontal projection coverage of 1.5 m should be provided. The
sloping catch-fan should consist of timber boarding and a layer of galvanized metal
sheeting, both of adequate thickness to capture and retain falling objects.
 A suitable receptacle should be provided with each catch-fan to trap falling objects.
The weight of the receptacle should not affect the stability of the catch-fan.
 Both the sloping catch-fan and receptacle should remain in place until all works are
completed.
 On the face of the scaffold, a suitable protective screen of fire retardant material
should be provided to confine falling objects.

1.5.7 Monitoring Safety Performance

 Requirements for health and safety should be incorporated into the conditions of
contract for engagement of contractors for the scaffolding work or other contractors

18
 using the scaffold. A monitoring system should be implemented to check the safety
performance of these contractors.
 Regular records on the safety conditions of the scaffolding, including work hazards,
precautions taken, accident analysis and recommendations, should be kept.
 Workmen’s feedback on the safety conditions of the site should be obtained and
documented.

1.5.8 Inspection, Maintenance and Dismantling of Scaffolds

 A scaffold should be inspected by a competent person before being taken into use
for the first time and at regular intervals not exceeding 14 days, after its exposure
to weather conditions likely to have affected its strength or stability, such as heavy
rainstorm, and reported in CS(S)R Form 5, after substantial addition, partial
dismantling or alteration.
 If a scaffold is defective, it should be made good before dismantling commences.
 Dismantling shall be planned in advance and done by trained workmen under the
immediate supervision of a competent person. No components, which endanger
the stability of the remaining structure, should be removed. Unless necessary
precautions have been taken, all the ties and bracings should remain secured in
position.
 If dismantling has reached the stage in which a critical member has to be removed,
e.g., a tie or a brace, the stability of the structure should be assured by fixing a
similar or adequate member in place lower down before the member to be taken out
is removed.
 All the stacked materials and debris placed on the scaffold should be removed.
 Scaffolds should not be dismantled in vertical sections from one end towards the
other unless special consideration is given to ties and bracings.
 A scaffold might have been temporarily stabilized by rakers during construction but
subsequently removed. Temporary rakers or other means of support should be
provided.
 Safe access and egress should be provided.
 The work area of the scaffold to be dismantled should be fenced off at the ground
level and warning notices should be posted up in the vicinity to prevent
unauthorized entry.
 Steps should be taken to ensure that scaffolding materials are not thrown, tipped, or
shot down from a height. They should be properly lowered in a safe manner. All
materials should be lowered to the ground and not stored on the scaffold. In the
case where the pavement is not to be obstructed and scaffolding materials have to
be stored on the lowest lift awaiting collection, this lift should be stiffened and fully
braced or propped by rakers, by using the materials recovered from the upper lifts.
 Every scaffolder involved in the dismantling work at height should wear safety
harnesses attaching to suitable and sufficient anchorage and suitable fixings, e.g.,

19
 the provision of an independent lifeline. Scaffold members should not be used for
anchorage purposes.

Mobile Metal Towers

A mobile metal tower is one of the commonly used types of free-standing metal towers in
Hong Kong. They are fitted with castors at the bottom of the standards. The castors should
be of the swivel type and fixed to the standards of the scaffold so that they cannot fall off
if the leg is out of contact with the ground. Always refer to the manufacturer’s instructions
on erection, use and dismantling of the tower.

Safety precautions include:

 When used indoor, the height to the least base dimension ratio should be limited to
3.5. When used outdoor, the height to the least base dimension ratio should not be
greater than 3.
 Mobile towers should only be used on even ground, never on a slope which is
sufficient to allow them to run away. Castors should normally be kept locked
except when the tower is being relocated. When used on surfaces which have a
cross fall and/or a longitudinal fall, the user should be particularly careful to see
that the brakes are on at all times other than whilst moving the tower. If there is
any doubt as to the adequacy of the brakes, the wheels should be chocked.
 No worker or heavy material should be permitted on any mobile scaffold during
movement. The force to achieve resitting should be applied at the base.
 The scaffold depends for its stability either on its self-weight or on additional
outriggers. The factor of safety of scaffold structures, i.e. the ratio of the
overturning moment to the stabilizing moment, should be not less than 1.5. The
overturning moment is due to eccentric weight and imposed and environmental
loads. The stabilizing moment is due to the self-weight, if suitably center, and
added outriggers if any.
 No more than one working platform should be permitted on all mobile metal
scaffolds at any one time.
 Access to and egress from the top of the tower should be by stairs / ladder.
 The working deck should be of adequate thickness. If boarded with scaffold boards,
the supports of the boards should be prevented from sliding by battens nailed
beneath the deck. The deck should be provided with top and intermediate guard-
rails and toe-boards. Generally, the deck should have at least one edge in the same
vertical plane as one side of the tower base so that this edge can be placed up against
the work to be done. The worker is thus not required to lean out over the guard-
rail.

20
Truss-out Bamboo Scaffold

 Truss-out bamboo scaffolds are commonly used in the renovation of external walls
and installation of air conditioners. The scaffold is supported by metal brackets
secured by bolts to the external walls.
 Improper erection and use of the scaffolds often give rise to fatal accidents due to
falls from height.
 The following should be observed:
 The design of the truss-out scaffold and the relevant working procedures should
be drawn up by a competent person, taking into consideration the loading on
the scaffold. The structure of the scaffold, type of anchorage system and
method of erection should also be specified.
 The scaffold should be firmly fixed in a suitable location. The construction
materials of the external walls should be examined to ensure that they can
support the design loading on the scaffold.
 Reference should be made to the operational manual of the manufacturers regarding
the length and installation procedures of anchor bolts.
 Each bracket should be fitted with three or more anchor bolts. The number of
brackets should meet the design and loading requirements of the scaffold.
Currently, the design and construction are modified to ‘T’ shape to facilitate the
fitting of three anchor bolts to wall.

Sources (Issued by Buildings Department): Guidelines on the Design & Construction of Bamboo
Scaffolds (n.d.).

 Safe means of access should be provided to facilitate the movement of workers

between the working platforms on the scaffold and the building.
 After erection, the scaffold and the anchorage system should be inspected and
certified safe by a competent person before use.
 The scaffold and anchorage system should be regularly inspected, maintained
and certified safe by a competent person, and to be re-inspected and repaired
immediately after inclement weather.

21
Sources (Issued by Labour Department): A Casebook of Occupational Fatalities related to Truss-out Bamboo
Scaffolding Works (2017); Safety Guide for Truss Out Scaffolding (2002); Safety Measures for Use of Truss-
out Bamboo Scaffold (2011); (Issued by Occupational Safety & Health Council): Basic Safety in the Erection
and Dismantling of Truss-out Scaffold (2006).

New Development

While wooden scaffolding that are being used in countries like U.S.A. and Japan is
uncommon in Hong Kong and hence there is no specific CoP dealing with it, there are
others that demand more detailed safety guidelines, such as GRP scaffolding and Mixed
Bamboo and Metal Scaffolding System (MBMSS), as well as such non-traditional usage
as the Climbing Scaffolding System which is closely related to the use of MBMSS. Since
there are very prescriptive yet different legal requirements in the CoPs on the qualifications
of competent persons involved in checking and verifying the safety of bamboo scaffolding
and metal scaffolding respectively, there is a need to clarify how such checking and
verification can be safely accomplished for a MBMSS, taking into consideration that a
veteran bamboo scaffolding expert may not be that proficient when it comes to calculations
on the strength and stability of metal scaffolding, and vice versa. A similar paradox exists
for a RPE who checks and certifies the safety of a MBMSS exceeding a certain height, say
15 m. As for a GRP scaffold, although its external features and methods of erection and
dismantling are very similar to a metal scaffolding, their use in an external environment is
more prone to wind effect than a metal one. It may be more appropriate to implement a
self-regulatory approach, i.e. requiring the supplier of a MBMSS or a GRP scaffolding to
undertake checking and examination based on the manufacturer’s design specifications.

1.9 Mobile Elevated Working Platform (MEWP)

1.9.1 Introduction to MEWP

Power-operated mobile elevated working platform (MEWP) is commonly used for

working at height in construction sites, shopping centres and other cleaning or installation
works. Some other names for this include cherry pickers or aerial platforms. They can be
vehicle-mounted, self-propelled, towed or manually-moved. If driven on a public or

22
private road, the owner has to apply for a vehicle registration or a movement permit from
the Transport Department.

1.9.2 Legal Safety Requirements

Safety legislations applicable to the use of EWP are:

 General Duties under OSHO and FIUO
 CS(S)R Regulation 45: No person under 18 years of age is allowed to operate a
mechanical equipment (such as MEWP) or give signals to the operator of the
equipment.

1.9.3 Classification of MEWP

MEWP are classified into the following types according to their:

 Mode of operation:
 Articulating boom type
 Telescopic boom type
 Scissor type
 Vertical mast type

Source (Issued by Labour Department): Guidance Notes on Safe Use of Power Operated Elevated Working
Platforms (2007).

 Driving mode:
 Chassis-mounted type
 Self-propelled type
 Non self-propelled type

23
Source (Issued by Labour Department): Guidance Notes on Safe Use of Power Operated Elevated Working
Platforms (2007).

1.9.4 Safe System of Work Required

 Risk assessment: To identify all potential hazards by considering the working

environment, the ground condition, the limitations of the MEWP, unauthorized
operation, the width and gradients of the slope, ineffective maintenance,
overloading or misuse of the MEWP and weather conditions.
 Planning the operation: This includes identification and description of working
locations, scale and duration of work, use of an access road and possible route of
travelling or moving within an IU or workplace. Where the MEWP using an
internal combustion engine is to be operated in confined areas, the F&IU (Confined
Spaces) Regulation should be followed.
 Safety working procedures: An effective communication arrangement should be
established.
 Implementation.
 Review: Particular attention should be paid to the feedback from operators and
workers regarding the acceptance of the selected MEWP.
 Auditing.

1.9.5 Selection of Machine

It is essential that a suitable MEWP should be selected depending on the nature and location
of work. Points to be considered include:
 the working height and horizontal reach required;
 the weight to be carried by the machine, including weight of persons, materials and
equipment;
 working conditions such as unrestricted open grounds or congested areas with
narrow operating paths;
 working environment such as indoor, outdoor and ventilation of workplace; and

24
  whether warning and safety devices including reversing alarm and CCTV device,
flashing lights and horns are provided.

1.9.6 Markings and Documentation

A MEWP must have visible permanent markings or notices to indicate:

 manufacturer’s name;
 machine model;
 serial number;
 year of manufacture;
 safe working load (SWL);
 number of persons that can be carried by it; and
 maximum reaching height and radius.

1.9.7 Workplace Conditions to be Considered

The following should be considered during the planning stage:

 Protecting pedestrians: Suitable walkways for pedestrians, physically segregated
from the operating area, should be provided. Suitable direction and warning signs
should be clearly marked or posted at these crossing points.
 Work areas: Restricted or prohibited areas including operating areas and traffic
routes should be set up or fenced off. Warning notices on prevention of
unauthorized entry should also be posted. Ensure no one is below the platform
before it is being lowered.
 Maximum gradient: Avoid using the MEWP on grades, slopes, ramps or cambers
with gradient exceeding the manufacturer’s recommended limit.
 Parking areas: It should be parked in a designated area out of traffic and on level
ground, and at a supervised area to prevent easy access by unauthorized persons.
 Surfaces or floors: They should be smooth, level, of adequate load-bearing capacity
and free from debris, bumps, objects, potholes or loose materials.
 Public utilities: Avoid any danger to operators or workers from any public utilities
in the vicinity of the work area, including overhead cables and gas pipes by
rendering dead the power supply or by placing barriers etc.
 Lighting: Arrange to avoid glare. Avoid extremes of light and dark between
adjacent areas, to which the eyes cannot adapt quickly enough due to the sudden
change.
 Ventilation: Particularly when a MEWP with an internal combustion engine is used
in a confined area, the level of oxygen and carbon monoxide in the air should be
monitored due to engine exhaust or other gases.
 Wind and weather conditions: Pay particular attention to thunderstorm warnings,
rainstorm warnings, typhoon signals, flooding signals and strong monsoon signals.

25
  Hazardous location operation: Operation in a hazardous area having potentially
flammable or explosive gases or particles should be avoided.

1.9.8 Construction and Safety Features

In terms of good construction, the following should be considered:

 Control:
 A MEWP should have 2 sets of control, one on the platform and the other at
ground or chassis level. The one below should be able to override the one
above by clearly marking the overriding lowering control for lowering the
platform in an emergency.
 Every control should be of the “dead man” type, i.e. it automatically returns to
a neutral or off position when released. The controls should be positioned or
protected against accidental operation or damage.
 The function of each control should be clearly marked.
 Power system:
 Electrically-driven MEWP for use in open space should be provided with
weatherproof electrical fittings.
 Fuel lines of internal combustion engines must be protected from engine and
exhaust heat.
 An emergency stop should be fitted at a prominent position to enable power to
all systems to be cut off.
 The engine should be shut down while fuel tanks are being filled. The fueling
areas should be well ventilated, free of flame, sparks or other hazards that may
cause fire or explosion.
 Batteries should be charged in a well-ventilated area free of flame, sparks or
other hazards that may cause fire or explosion.
 Warning signals: An alarm should be fitted on the MEWP to warn the operator
when the machine’s base is out of level. The operator should be allowed to restore
the machine to a safe condition when the drive and lift functions are disabled.
Another audible warning device should be fitted to give warnings to nearby persons
when the machine is moving.
 Safety devices:
 All dangerous parts including rotating shafts, gears and sprockets should be
guarded.
 The machine should be fitted with an effective lock-on brake or other means to
hold the unit on the maximum slope it is designed for while loaded with its
SWL.
 A suitable safety device such as a captive chock should be built within the
scissor mechanism of a scissor lift to prevent trapping of persons during
maintenance.

26
  The lifting mechanisms must be interlocked to the outriggers.
 A MEWP with a tilting mast should have means to secure the mast in both the
transport and working positions. It should not be possible to move the work
platform in its working position until the mast is in its working position.
 Trapping and shearing points between parts of the extending structure, the
chassis and the work platform should be avoided by providing guarding or safe
clearances. Where neither safe clearance nor guarding is possible, warning
notices should be displayed.
 Attachment.
 Hydraulic equipment: Should be built for fail-safe operation, i.e. free descent or
retraction of hydraulically-positioned outriggers or stabilizers will not occur in case
of a hose or fitting failure.
 Working platform:
 Safe means of access to and egress from the platform should be provided.
 The platform should be slip-resistant and have effective means to drain off
water.
 The platform should be fitted with suitable guardrails and toe-boards on all
sides, i.e. top guardrail 900-1150 mm; intermediate guardrail 450-600 mm; toe-
board min. 200 mm high.
 Its SWL and the max. number of persons permitted should be marked.
 Braking system:
 For raising movements, the braking system should be an automatic lock or self-
sustaining device. It should be automatically applied when the drive is no
longer energized.
 The braking system should ensure that the work platform can be stopped and
held at any position under all possible conditions of operation. Unintentional
releases of these devices should not be possible.

1.9.9 Safe Operation

Before Operation, ensure that:

 the machine is inspected, deficiencies reported and fixed and all systems are in good
operating condition;
 low reservoirs of all fluids in the brake, transmission, power steering, engine
coolant and hydraulic system are filled up to the proper level;
 all operating and shutdown controls are checked;
 all outriggers are fully extended and levelled within the manufacturer’s tolerances,
or where necessary, suitable support materials placed under the outriggers to
provide a firm base;
 the machine is protected by barricades in a public place with warning signs;
 pedestrians do not have to walk near the platform;

27
  lights are used during night time or in a dark area to illuminate the workplace and
to warn the travelling public;
 all protective and safety devices are in place and working properly;
 all operators on the MEWP wear a safety harness with its lanyard anchored to a
manufacturer-specified anchorage point on the work platform;
 A MEWP with an internal combustion engine used in a confined area should
observe the F&IU (Confined Spaces) Regulation; and
 Operators wear reflective vests at low visibility locations.

During Operation, ensure that the following procedures are followed:

 never exceed the SWL;
 never position the machine over persons or allow workers to go under the platform;
 never move the machine until the way is clear;
 never override safety devices;
 never move the machine close to overhead power cables unless the power company
has permitted a closer approach in writing;
 check the service brakes in both forward and reverse operation on level ground;
 operate the machine slowly to avoid sudden starts, stops or turns;
 ventilation is sufficient for effective dispersion of the engine exhaust;
 the machine is operated on a firm and level ground. Stop operating if the ground is
too slippery under wet or rainy conditions;
 never operate the machine too close to an overhang, deep ditch or hole and be alert
to potential caving edges, falling rocks and slides, rough terrain and any obstacles;
 never leave the machine unattended while the engine is running and the ignition
key is on the machine;
 never use the machine for a purpose other than those it is designed for;
 only properly secured tools and materials which are evenly distributed and can be
safely handled by the operators should be moved;
 never carry materials outside the work platform except if it is done according to
manufacturer’s instructions.

For Travelling, ensure that:

 a non self-propelled or chassis-mounted MEWP should not be moved or transported
with workers on it. The work platform should be lowered to the cradle position
before it is moved;
 for a self-propelled MEWP, ensure that the chosen route is firm and level and
workers should not push off or pull toward any object outside of the platform;

28
  while travelling, ensure the operator has a clear view of the ground, a safe distance
is kept from overhead cables, obstacles, debris, holes, depressions, ramps and other
hazards, and there is no slewing of the work platform.

For Parking, ensure that:

 the MEWP is parked in a designated area on level ground with its boom lowered or
retracted, the engine is switched off, the parking brake applied and the wheels are
blocked;
 all controls are placed in a neutral position, with the ignition key removed from the
platform for safe custody by the controlling party.

1.9.10 Maintenance and Inspection

Pre-operation Inspection

The operator should check that:

 tyre pressure is normal, if pneumatic tyres are fitted, and tyres are not damaged;
 all brakes are working efficiently and the brake fluid level is correct;
 the fuel, water and oil levels are adequate;
 the batteries, if battery-operated, are charged;
 hydraulic lines have no leaks and damage and the hydraulic fluid level is adequate;
 the supporting structure is sound and free from distortion or cracking;
 the power mechanism is working properly;
 the communication system between the platform and the ground functions correctly;
 emergency controls function correctly and the safety equipment is in good condition;
 if electrically insulated, the insulated section is not bridged by any residue; and
 signaling/warning lights or devices are functioning effectively.

The principles on the design of safety measures for MEWP are quite similar to other plant
and equipment used for lifting, such as cranes, SWPs.

29
Source (Issued by Labour Department): Safety at Work - A Guide to Ladders & Elevated Working Platforms
(2008).

1.10 Case Study

You are the safety officer of an exhibition

booth fitting contractor. A mobile metal
tower was brought to the site, as shown in
the attached photograph. What are your
opinions on the safety of this tower?

Source (Issued by Labour Department): Overview of Work-at-Height Safety (2018).

1.11 Suggested Answer

It appears to be lacking a proper access ladder, and that the height to base ratio probably
exceeds 3.5 times (when used indoors) or 3 times (when used outdoors). It is suggested
that outriggers be added to increase its stability.

1.12 Concept Checklist

This chapter is about working at height, including the safe use of scaffolding and MEWP.
Key points to note include:

30
 Provisions of CSSR related to working at height
 Legal requirements on scaffolding safety
 Introduction to bamboo scaffolding
 Introduction to metal scaffolding
 CoP on bamboo and metal scaffolding
 Mobile metal towers
 Truss-out bamboo scaffold
 New development
 Mobile elevated working platform (MEWP)

1.13 Further Thinking

Apart from GRP scaffolds, some countries such as Canada and Singapore use timber
scaffolds. Do you think it worthwhile to issue different CoPs to control different types of
scaffolding designs and uses? If not, how can the authorities control their safe usage?

Source from https://www.worksafebc.com/en/resources/health-safety

31
Source from https://www.wshc.sg/files/wshc

References

Buildings Department (n.d.a) “Guidelines on the Design and Construction of Bamboo

Scaffolds”, Government Printer, Hong Kong.
Buildings Department (n.d.b) “Make Sure Bamboo Scaffolds are Safe against Strong
Winds”, Government Printer, Hong Kong.
Chan A. and Tang W.S. (n.d.) “A Holistic Approach on Fall Prevention and Protection in
Hong Kong”, OSHC. Hong Kong.
Chan A.P.C., Wong F.K.W., Yam M.C.H., Chan D.W.M, Kwok A.W.K., Chan E.H.W.,
Yiu E.C.Y., Lam E.W.M. and Cheung E. (2006) “Construction Safety Involving
Working at Height for Residential Building Repair and Maintenance”, July 2006,
Final Report of the CII-HK Research Project, Hong Kong Polytechnic University.
Chang C.C. and Au M.K. (2006) “An Engineering Study for Safety and Reliability of
Truss-out Metal Bracket Bamboo Scaffolding”, Summary Report Submitted to
OSHC, OSHC, Hong Kong.
Chang C.C. and Yu T.-X. (2002) “An Engineering Study for Improving Safety and
Reliability of Bamboo Scaffoldings”, Final Report Submitted to OSHC, OSHC,
Hong Kong.
Construction Industry Council (2011) “Technical Guidelines on the Design, Installation
and Maintenance of Cast-in Anchors at External Walls of New Buildings”,
Version 1, July 2011, CIC, Hong Kong.
Construction Industry Council (2016) “Guidelines on Work-Above-Ground Safety”,
Version 1, November 2016, CIC, Hong Kong.
Construction Industry Council (2017a) “Guidelines on Planking Arrangement for
Providing Working Platforms on Bamboo Scaffolds” Ver. 2, September 2017, CIC,
Hong Kong.
Construction Industry Council (2017b) “Guidelines on the Design, Installation and
Maintenance of Cast-in Anchors at External Walls of New Buildings”, Version 2,
September 2017, CIC, Hong Kong.
Construction Industry Institute (2009) “Developing a Prototype for the Rapid Demountable
Platform [RDP]”, Stage II of CII-HK Research on ‘Construction Safety Involving

32
 Working at Height for Residential Building Repair and Maintenance’, April 2009,
CII, Hong Kong.
Construction Sites (Safety) Regulations 1978, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap59I (Accessed on 31 December 2019).
Health and Safety Authority (n.d.) “Code of Practice for Access and Working Scaffolds”,
Republic of Ireland.
Health and Safety Executive (2014) “The Selection, Management and Use of Mobile
Elevating Work Platforms” The Stationery Office. U.K.
Hong Kong University of Science and Technology (2006) “Follow-up Study on Safety and
Reliability of Truss-out Metal Bracket Bamboo Scaffoldings”, Report Submitted
to OSHC, OSHC, Hong Kong.
Kwong V.C.L. (n.d.) “Progress Safety Enhancement for Working at Height”, Aedifice, pp.
22-24.
Labour Department (2001) “Code of Practice for Metal Scaffolding Safety”, Printing
Department, Hong Kong.
Labour Department (2002) “Safety Guide for Truss Out Scaffolding”, Printing Department,
Hong Kong.
Labour Department (2007a) “A Casebook of Occupational Fatalities Related to Truss-out
Bamboo Scaffolding Works”, Government Logistics Department, Hong Kong.
Labour Department (2007b) “Building Repair Bamboo Scaffolding Works Safety”,
Government Logistics Department, Hong Kong.
Labour Department (2007c) “Guidance Notes on Safe Use of Power-Operated Elevating
Work Platforms”, Government Printer, Hong Kong.
Labour Department (2010) “Beware of Fall at Work”, Government Printer, Hong Kong.
Labour Department (2011) “Safety Measures for Use of Truss-out Bamboo Scaffold”,
Government Logistics Department, Hong Kong.
Labour Department (2017a) “A Guide to the Provisions for Safe Places of Work under Part
VA of the Construction Sites (Safety) Regulations”, Government Printer, Hong
Kong.
Labour Department (2017b) “A Casebook of Occupational Fatalities related to Truss-out
Bamboo Scaffolding Works”, Government Logistics Department, Hong Kong.
Labour Department (2017c) “Code of Practice for Bamboo scaffolding Safety”,
Government Logistics Department, Hong Kong.
Labour Department (2018) “Overview of Work-at-Height Safety”, Government Printer,
Hong Kong.
Labour Department (n.d.a) “A Brief Industrial Guide to Bamboo Scaffolding Work”,
Government Printer, Hong Kong.
Labour Department (n.d.b) “A Brief Industrial Guide to Working at Height”, Government
Printer, Hong Kong.
Labour Department and MTRC (n.d.) “Information for Owners: Friendly Reminder for
Working at Height”, MTRC, Hong Kong.
Labour Department and Occupational Safety and Health Council (2001) “Prevention
Against Fall from Height”, Government Printer, Hong Kong.
Labour Department and Occupational Safety and Health Council (2015) “Guidance Notes
on Work Safety and Health of Air-Conditioning Works”, Government Printer,
Hong Kong.

33
Labour Department and Occupational Safety and Health Council (2016) “Safety Guide on
Use of Light-duty Working Platform and Mobile Working Platform”, OSHC,
Hong Kong.
Labour Department and Occupational Safety and Health Council (2018) “Safety Guide for
Bamboo Scaffolding Work”, Government Logistics Department, Hong Kong.
Labour Department and Occupational Safety and Health Council (n.d.) “Safety
Requirements for Cleaning Outward-facing Windows”, Government Printer,
Hong Kong.
London Underground Ltd. (2013) “Glass Reinforced Plastic (GRP) Towers”, Safety
Bulletin, London.
Occupational Safety and Health Council (1991) “Construction Industry - Guidance on Fall
Protection at Edges of Top-Most Floors of Structures Under Construction”, OSHC,
Hong Kong.
Occupational Safety and Health Council (1998) “Construction Working at Height Safety
Checklist”, OSHC, Hong Kong.
Occupational Safety and Health Council (2003) “Safety Hints for Working at Height in the
Construction Industry”, OSHC, Hong Kong.
Occupational Safety and Health Council (2006) “Basic Safety in the Erection and
Dismantling of Truss-out Scaffold”, OSHC, Hong Kong.
Occupational Safety and Health Council (2014) “Analysis of Coroner’s Court Cases
Caused by Fall from Height in Hong Kong Construction Industry”, OSHC, Hong
Kong.
Occupational Safety and Health Council (2016) “Study on Safe Usage of Bamboo and
Mixed Scaffoldings”, OSHC, Hong Kong.
Occupational Safety and Health Council (2017) “Study on Redesign of the I-Shape Metal
Bracket for Truss-out Bamboo Scaffolding”, OSHC, Hong Kong.
Wong F., Chan A., Yam M., Wong E., Tse K. and Yip K. (2005) “A Study of the
Construction Safety in Hong Kong- Accidents Related to Fall of Persons from
Height”, Hong Kong Polytechnic University.
Wong F.K.W. (1998) “Bamboo Scaffolding – Safety Management for the Building
Industry in Hong Kong”, Hong Kong Polytechnic University, April 1998, Hong
Kong.
Worksafe New Zealand (2014) “Mobile Elevating Work Platforms”, Best Practice
Guidelines, Wellington, New Zealand.

34
 Chapter 2
Safety in Confined Space Operations

2.1 Introduction to Confined Space Safety

The topic of confined space safety appears to be rather basic to most workers, and by the
same token, familiar to every safety practitioner as a part of the safety officer training
course curriculum. In addition, registered safety officers in Hong Kong can be competent
persons if they possess one year relevant confined space risk management experience. Yet,
confined space fatalities happen every now and then, irrespective of whether the worker or
the competent person possesses a secondary school science background or not, though
possession of a secondary-school science background could be helpful in understanding
confined space safety to a certain extent, because realizing the chemical properties of
different substances may contribute to the adoption of a correct preventive measure.

Sources (Issued by Labour Department): A Guide to the F&IU (Confined Spaces) Regulations (1995); Safety
Guide to Working in Confined Space (1994); Hazards Commonly Encountered in Confined Spaces; Safety
in Confined Spaces; Safety Hints for Manhole Work (n.d.); Safe Work in Confined Spaces (2010); A Brief
Guide to the F&IU (Confined Spaces) Regulations (2009); CoP Safety & Health at Work in Confined Spaces
(2000); Simple Guide on the Prevention of Gas Poisoning in Drainage Work (2007); Prevention of Gas
Poisoning in Drainage Work (2007); Safety Guide for Work in Manholes (2006); (Issued by Fire Services
Department): Fire Protection Notice No 08 Precautions When Working in Confined Spaces Containing Gases
other than Air (n.d.).

35
2.2 Particular Concern over Confined Space Safety

2.2.1 Introduction

What is so special about confined space safety that demands specific control? The answer
is multi-faceted. Very often, the killer is silent. A lot of toxic gases, including carbon
monoxide and methane, are colorless and odorless. Even if detected, normal precautions
may not be effective. Death could be slow and caused by factors other than gassing, such
as heat stroke and oxygen deficiency. Also, accidents do not necessarily take place inside
every confined areas such as manholes. At other times, accidents could happen in a sudden
and violent manner, such as an explosion in a gas leakage scenario, so as to cause multiple
fatalities to the workers as well as to members of the public in the vicinity.

2.2.2 Confined Space Hazards

The hazards to be considered should include those hazards:

 arising from the materials and substances present, or likely to be present in the
confined space concerned, its previous uses and the work to be done;
 which may be present by its proximity to other plants, processes and operations;
 Other work-related hazards:
 arising out of, e.g., electricity, welding, dangerous substances, noise and dust,
etc.
 having regard to the usually restrictive, and sometimes electrically conductive,
nature of a confined space.

2.3 Interpretation of F&IU (Confined Space) Regulations

(Cap. 59AE) (s. 2)

The Code of Practice for Safety and Health at Work in Confined Spaces issued by the
Labour Department defines confined spaces as places having an enclosed nature, such as
ducts, vessels, culverts, boreholes, bored piles, manholes, ship cargo holds/tanks, ballast
tanks, double bottoms, ships’ engine room, buildings, building voids, some enclosed rooms
(particularly plant rooms) and compartments within them, including some cellars and
interiors of machines, plant or vehicles, and other places such as open-topped tanks and
vats, wells, hatches, caissons, shafts, closed and unventilated or inadequately ventilated
rooms, or construction, may by reason of the work done, location or contents give rise to
the specified risks.

Therefore, the scope of a confined space is very broad and may even include a bore pile,
excavation, freight container, building void, and a plant room. In particular, a confined
space does not need to be enclosed on all four sides, or at the top, because confined space
also includes a tunnel, a bore pile, a caisson, an excavation etc. There are a lot of

36
misunderstandings here. Some supervisors, and even engineers think that by converting
the hard metal cover of a confined space to a grilled cover, the space will be naturally
ventilated and would not be considered as confined. To qualify to be considered a confined
space, a space also does not need to have only one point of entry. Using excavation as an
example, a space can have an infinite number of entry points but yet can be considered to
be a confined space.

In the Court of Appeal case Lee Yu Kee Ltd v. The Attorney General CACC000325/1981,
it was necessary to establish that dangerous fumes were liable to be present and that the
extent of their presence was such as to create a risk that persons would be overcome. This
is particularly difficult in the case of fatal accidents inside a manhole as the atmosphere
inside are likely to be disturbed by rescue personnel, be they the site emergency response
team or firemen.

2.4 Application (s. 3)

The F&IU (Confined Spaces) Regulation applies to work in an IU that takes place within
the immediate vicinity of, and is associated with work occurring within, a confined space.
Hence, it will apply to the personnel and equipment on the street level above underground
water and sewage manholes.

2.5 CW and CP to Complete an Approved Course (s. 4)

The CP course covers the content of the CW course. In comparison with a CW, the CP has
the additional duty of conducting risk assessments.

Sources (Issued by Occupational Safety & Health Council): Working in Confined Spaces (2001); Prevention
of Confined Space Accident (1998); Knowing the Hazards of Confined Space (1998); Confined Space
Promotional Activity (n.d.).

37
2.6 Risk Assessment and Recommendations (s. 5)

2.6.1 Confined Space Access and Egress

The size and number of access and egress points should be assessed individually dependent
upon:
 the activities to be carried out and the number of people involved;
 occasions when access and egress is so tortuous that temporary openings may be
needed;
 spacing of manholes on sewers and the absence of such access over considerable
lengths or height, as in the case of sewers, pipes, culverts, small tunnels or shafts,
affecting both the degree of natural ventilation and the efficiency to rescue.

2.6.2 Risk Assessment Process

According to the Code of Practice for Safety and Health at Work in Confined Spaces, the
process of a risk assessment should include:
 a systematic examination and careful consideration of all the work activities
required to be done,
 the previous contents in the confined space,
 the methods by which the work could be done, and
 the hazards inherent in the confined space in relation to the work, to the method
proposed and to the design or construction of the confined space itself, including
the layout and location of the confined space.

2.6.3 Confined Space Information and the Work Undertaken

All information about the confined space and the work to be taken in it should be gathered,
such as:
 engineering drawings;
 working plans, figures, photos or reports about relevant soil or geological
conditions;
 where necessary, a proper site investigation should be arranged on the actual spot
of the confined space so as to have a more thorough knowledge about the nature
and circumstances, in particular its effect on safety and health matters.

2.6.4 Heat Stress

A thermometer can only measure the ambient temperature which does not take into account
of the humidity. A heat stress monitor should be used instead. Moreover, heat stroke is

38
only one of the risks to be assessed. As a safety officer, a variety of other confined space
risks need to be assessed.

2.6.5 Oxygen Depletor

In the summertime when working inside a sewage manhole filled with slurry human faeces,
the smell is extremely offensive and unbearable. Some workers may use chemicals to mask
or remove the pungent smell to make the environment fresher, such as using fragrant
alcoholic perfume to mask the smell, or activated charcoal to absorb the smell. It is not the
smell that causes danger but the presence of toxic or flammable vapour that could be
generated by the sewage decomposition. The summer heat will accelerate the
decomposition of human faeces to generate an abundance of carbon dioxide, ammonia and
methane. Alcoholic perfume could be flammable and, although dry activated carbon is a
good smell absorbent, wet activated carbon will rapidly absorb ambient oxygen, resulting
in oxygen deficiency. Therefore both alcoholic perfume and activated carbon can create
dangers in a confined space. Other oxygen depletory activities include arc and gas welding,
as well as the use of an internal combustion engine to supply power to lighting and other
equipment.

2.6.6 Risk Assessment Report

The risk assessment report should also cover:

 the recommendations on the measures required, including whether or not the use of
an approved breathing apparatus is necessary, having regard to the nature and
duration of the work to be performed therein;
 consideration on how the worker can be safely rescued from the confined space in
the case of emergency;
 the period during which workers may remain safely in the confined space.

2.6.7 Confined Space Hazardous Gases

Gas Testing: A competent person performing gas testing of a manhole needs to conduct
the gas testing at both the high, middle and low levels of the manhole in question because
toxic or explosive gas can exist at all levels of the manhole. However, some safety
practitioners are not familiar with which gas is heavier or lighter than air. From the periodic
table H=1.00794 C=12.0107 N=14.0067 O=15.9994 S=32.065 approximated to H=1 C=12
N=14 O=16 S=32

Since air is 78% N2, 20.9% O2, 0.03% CO2, the vapour density of air is
78% x 2 x 14 + 20.9% x 2 x 16 + 0.03% x 44 = 28.54 (sometimes roughly estimated as 0.8
x 28+0.2 x 32 = 28.8)

Hence, based on the relative density of these gases:

 Methane (CH4): 12 + 1 x 4 = 16, is lighter than air
 Ammonia (NH3): 14 + 1 x 3 = 17, is lighter than air

39
 Carbon Monoxide (CO): 12 + 16 = 28, is almost the same as air
 Hydrogen Sulphide (H2S): 2 x 1 + 32 = 34, is heavier than air
 Carbon Dioxide (CO2): 12 + 2 x 16 = 44, is heavier than air
 Nitrogen Dioxide (NO2): 14 + 2 x 16 = 46, is heavier than air
 Sulphur Dioxide (SO2): 32 + 2 x 16 = 64, is heavier than air
 LPG (Propane C3H8 + Butane C4H10):
3 x 16 + 8 x 1 =56 to 4 x 16 + 10 x 1 = 74, is heavier than air

Gases heavier than air, such as CO2, will displace O2 at a low level while gases lighter than
air will rise to attack the attendant above the confined space. There has also been some
confusion over what “marsh gas” is. Surfing on the net, the answer can be very
contradictory. Some say that it is lighter than air while others say it is heavier than air.
Some say that it is colorless and odorless, while others say it smells like rotten eggs. The
former is usually used to describe the chemical properties of methane while the latter
hydrogen sulfide. In fact, “marsh gas” in itself is not a chemical name, but is a common
name given to the gas that occurs in marsh lands. Hence “marsh gas” should basically be
methane, but can be hydrogen sulfide or other sewage gas emanating from rotten leaves
and foul water.

Flammability vs Toxicity: Another point often overlooked even by safety practitioners is

what alarm levels should be set for a multi-gas detector that senses the hazards posed by
gasoline or LPG inside a manhole: the 10% lower explosive limit (“LEL”) (flammability)
or the Occupational Exposure Level (OEL on the toxicity)? It is common sense knowledge
that both LPG and gasoline are highly flammable and hence usually the 10% LEL would
be used for calibration. However, the following calculation should be done before making
this judgment.

A multi-gas detector should be so calibrated that the alarm will sound when:
 either <19.5% or >23% oxygen, or
 >10% LEL of any explosive gas or vapour, or
 toxic gas in excess of the occupational exposure limit (OEL), whichever is the less
for (b) and (c) if the gas is both flammable and toxic.

For LPG (a mixture of butane and propane) occupational exposure limit (“OEL”) = 1,000
ppm and the flammability limits of butane and propane are 1.8%-8.4% and 2.1%-9.5% by
volume respectively, meaning that the 10% LEL of butane and propane are 0.18% and 0.21%
(or 1,800 ppm and 2,100 ppm) by volume respectively.

For gasoline, OEL = 300 ppm and the flammability limits are 1.2%-7.1%, hence the 10%
LEL is 0.12% or 1,200 ppm.

So, while the emphasis on the fire and explosion hazards posed by these two chemicals is
genuine, the toxicity of these chemicals should not be overlooked.

40
Continuous Monitoring of the Atmosphere inside a Confined Space: During the risk
assessment, if the competent person considers that there is a known possibility of adverse
changes to working conditions, he should recommend continuous monitoring or periodical
monitoring of the working environment. The purpose is to ensure that the ventilation is
adequate and that the atmosphere remains safe for working inside the confined space. The
exact testing, retesting and monitoring requirement should be determined by the competent
person. All the monitoring equipment used in connection with atmospheric monitoring
should be properly maintained and be calibrated periodically as per the recommendation
of the manufacturer or supplier for accurate testing functions.

A multi-gas detector would give a reading on the level of toxic or flammable gas detected,
or oxygen level in case of oxygen deficiency. Hence, when such a detector is used by
confined space workers, they need to be carefully trained in how to respond to the alarm
of this detector, because when the alarm sounds or blinks, they would be tempted to look
at the display to find out what has gone wrong, instead of evacuating. Either use duct tape
to blank off the displays, so that when the alarm sounds or blinks for whatever reason, the
workers inside the confined space will not be tempted to read the displayed information,
or train them to immediately evacuate the confined space when they hear the alarm
sounding or see the visual alarm flashing, instead of trying to find out what has caused the
alarm. Equipment with displays are for the use of the investigator and/or safety officer,
not the workers inside the confined space.

Ventilation of Confined Space: Even if the gas testing of a manhole using a multi-gas
detector has indicated no accumulation of toxic gas, flammable gas, and the equipment
does not show oxygen deficiency inside that space, and an assessment of the plant and
material and the work method to be used in the confined space revealed no particular risk,
a permit-to-work or certificate still cannot be safely issued because a confined space
usually needs to be vented with forced ventilation. In a manhole, most of the time, this is
achieved using a blower with flexible air ducting. The positioning of the fresh air supply
hose as well as an air extraction hose (if any) is crucial for providing effective air change
inside the manhole. The Code of Practice on Safety and Health at Work in Confined Spaces
issued by the Labour Department section 7.5.4 requires the fresh air supply air-line or
trunking to be extended to the bottom of the confined space for removal of gases or vapours
for effective air circulation and for removal of gases or vapours heavier than air. However,
whether this is the most effective means of removing such gases or vapours still needs to
be subject to further investigation.

41
Source (Issued by Workplace Safety & Health Council, Singapore): Technical Advisory on Working Safely
in Confined Spaces (2010).

2.6.7.5 Changes that Necessitate Re-assessment

The risk assessment for confined space work should be repeated whenever necessary. The
proprietor or contractor shall appoint a competent person to carry out a fresh risk
assessment and make recommendations whenever there has been a significant change in
the conditions of the confined space or of the work activities therein to which the previous
assessment relates, or where there is reason to suspect that such change may occur, and that
the change is likely to affect the safety and health of the workers therein. Changes in the
condition of the confined space may include an increase in the level of sewage or storm-
water, e.g. for sewers, due to:

42
  sudden rainfall;
 increase in tide level;
 evolution of toxic gas due to disturbance of sludge or deposits in the space, etc.

Source (Issued by Health & Safety Executive, U.K.): Confined Spaces - A Brief Guide to Working Safely
(2013).

2.7 Issue of Certificate of Safe Operation / Permit-to-work

(s. 6)

A certificate (or permit-to-work “PTW”) should be issued by the proprietor or contractor

responsible for the confined space operation, but it is common practice for the competent
person to issue this certificate. This should not be considered a condoned practice, unless
the competent person has been delegated with the authority by the proprietor or contractor
to issue this certificate. The ultimate responsibility for safety should still rest on the
proprietor or contractor responsible for the confined space operation.

The certificate should state that all necessary safety precautions in relation to the hazards
identified in the risk assessment report have been taken; and the period during which
workers may remain safely in the confined space. It should be displayed in a conspicuous
place at the entrance of the confined space, and should automatically become invalid if
there is a need for a fresh risk assessment. This certification procedure can be developed
into a “permit-to-work” system.

According to the CoP for Safety and Health at Work in Confined Spaces AI.3, a PTW
certificate should record the following:
 the findings in the risk assessment report completed by the competent person;
 the effectiveness of the isolation and withdrawal from service;
 the amount of sludge or other deposits (if any) after cleaning;
 the results of atmospheric testing;
 the nature of work to be done;
 the conditions and features of the confined space; and
 the period during which workers may remain safely in the confined space.

If the work has not yet been completed by the expiry of the PTW certificate, an extension
of the certificate is required. The proprietor or contractor or persons authorized by him
should visit the confined space and satisfy himself (by testing if necessary) that the
conditions have not materially altered since he first issued the certificate. If the conditions

43
have materially altered, the proprietor or contractor should cause the CP to re-assess the
situation, specify what further precautions are required to ensure the safety and health of
the workers and state in the PTW certificate the extended time of expiry.

In case an extension of time for the certificate is required, an application for extension of
time should be made before the certificate is expired. In no way should a blanket approval
be given beforehand or retrospectively.

A PTW certificate should be properly cancelled when the work activities in the confined
space to which it refers have been completed and the confined space is cleared of workers,
equipment and spare material.

When work in the confined space is completed, the PTW certificate should be returned to
the proprietor or contractor by the person to whom it was issued. This person should sign
a declaration that all personnel and equipment have been removed from the site, and the
personnel have been warned that the confined space is no longer safe for entry.

A proprietor or contractor should check that the work covered by the PTW certificate has
been properly completed. He should then sign a final confirmation of the cancellation of
the certificate to confirm that the work activities in the confined space have been completed
and that another certificate will be required for entering the confined space again. Effective
measures should be taken to ensure that no worker will enter the confined space during the
period when the completed PTW certificate is being delivered to the proprietor or
contractor for proper cancellation.

The records of all PTW certificates should be properly maintained for one year after the
certificates have been cancelled and be available for inspection.

2.8 Safety Precautions Before Work Begins (s. 7)

The safety precautionary measures are particularly useful where the confined space has
previously contained toxic or explosive chemicals (such as fuel tanks).

Isolation includes:
 isolating the confined space from all unnecessary sources of power or heat,
 shutting or blanking off of all pipelines;
 closing of all connected valves;
 sealing of ends of service pipes which are connected to sources of dangerous fumes.

Purging refers to such suitable methods to remove an explosive mixture with air which may
be formed by flammable gas or vapour inside:
 Steam Cleaning to remove steam-volatile substances.
 For removal of corrosive materials, or materials which are not readily volatile,
preliminary treatment by repeated washing with water, or with other suitable
solvents or appropriate neutralizing agent should be applied prior to steaming.

44
  It may be necessary to re-steam where the confined space has been left for more
than a few hours after steaming.
 During steaming, adequate outlets for steam and condensate should be
provided so that no dangerous pressure should build up inside the confined
space.
 After steaming, adequate air inlets should be provided so that there should not
be any vacuum being caused in the confined space by cooling and condensation.
 To prevent any heat stress problem, sufficient cooling of the confined space to
room temperature is essential before allowing entry.
 When purging has been completed, all liquid remaining in the confined space
should be drained away or pumped out as appropriate, and the confined space
should be opened to allow ventilation.
 Inert Gas Purging using e.g. nitrogen, carbon dioxide.
 If persons have to enter or approach a confined space which has been purged
by an inert gas, the confined space should be purged again by fresh air so as to
provide adequate oxygen into the confined space to support life. Thereafter,
all parts of the air-purged confined space should then be thoroughly tested
against the deficiency of oxygen to make sure that there is adequate oxygen to
support life.
 Forced ventilation may be required instead of natural ventilation.
 In deciding the ventilation air exchange rate, the decision should take into
account the fact that some tasks, e.g. gas welding, consume oxygen and while
other tasks, e.g. paint spraying, contaminate the atmosphere. It is necessary to
provide adequate air change to remove the hazardous substances that may have
evolved and maintain sufficient fresh air supply while work is in progress.
 The provision of ventilation to a confined space should not be considered as an
alternative to the use of a breathing apparatus where the atmosphere inside is
likely to cause safety or health hazards to the workers therein.
 Under no circumstances should oxygen be introduced into a confined space
which would create a danger of oxygen enrichment in the atmosphere.

2.9 Safety Precautions When Work is Being Undertaken (s. 8)

Based on the definition of the scope of the applicability of the F&IU (Confined Space)
Regulation, the person stationed outside (look-out man) is also required to have a CW
qualification. A safe system of work needs to be implemented during work.

2.10 Use of PPE (s. 9)

According to the CoP for Safety and Health at Work in Confined Spaces Chapter 9, the
following safety precautions need to be taken:

45
  Underground pipework may involve additional hazards arising from accidental
leakage from underground pipes, e.g. flammable gases, fuel oil, sewage, hazardous
substances etc. Hence, the use of a breathing apparatus (“BA”) is recommended.
Only those who are medically fit for using a BA should be allowed to enter into and
work in this type of confined space. The service time of a self-contained BA
(SCBA) should be estimated having regard to the entry time, the consumption rate,
the maximum working period, the estimated escape time and other relevant factors.
 For an air-line type of BA, the air supply rate should be so adjusted that a positive
pressure is always maintained inside the facepieces. To avoid contamination of the
supply of air, the air intake should be properly located to avoid sucking in
contaminated air such as engine exhaust.
 The air supply equipment used should be designed for supplying breathing air.
Those designed for industrial purposes are not allowed.
 An air hose which may be oil impregnated or otherwise contaminated should not
be used.
 A sufficient number of persons should be available outside the confined space for
holding the free ends of the lifelines and, as far as practicable, suitable and sufficient
mechanical aid such as a tripod for lifting and rescue should be provided.
 The safety harness and rescue life-line should be so adjusted and worn such that the
wearer can be drawn up head first through any manhole or opening of the confined
space.

2.11 Emergency Procedures (s. 10)

According to the CoP for Safety and Health at Work in Confined Spaces Chapter 10, the
following emergency preparedness should be in place:
 Account has to be taken not only of accidents arising from a specified risk, but also
any other accident, e.g., incapacitation after a fall.
 A rescue team consisting of a sufficient number of trained persons, should be
readily available. They should readily reach the confined space in time.
 All members of the rescue team should have been properly and adequately trained
in the related emergency rescue procedures, including the detailed particulars of an
emergency rescue plan with full knowledge on how to properly use all rescue
equipment.
 Even in case of an emergency, the standby person should not enter the confined
space. He should remain stationed outside the confined space and summon
assistance from the rescue team and public emergency services (i.e. the Police and
the Fire Services). He should stay outside the confined space and brief the rescue
personnel on the relevant circumstances of the incident upon their arrival.
 Suitable and sufficient rescue equipment, including a standby approved BA, safety
harness, life-lines, reviving apparatus and emergency lighting, and properly trained
rescue personnel should be readily available for rescue purposes at all times when

46
 workers are working inside a confined space. Where practicable, appropriate
lifting equipment, e.g. rescue hoist or winch, a split-leg tripod with a frame-
mounted hoist and a one-man access cradle should be available for rescue purposes.
 Drills for rescue and emergency procedures should be conducted periodically for
testing the emergency response plan, and for practising the procedures and use of
rescue equipment.

2.12 Provision of Information, Instruction, etc. (s. 11)

According to the CoP for Safety and Health at Work in Confined Spaces Chapter 11, the
following information, instructions and training requirements should be observed:
 The management should provide adequate and suitable training to all persons
involved, directly or indirectly, in confined space work, including workers working
in a confined space, supervisors, management staff, standby persons, all members
of the rescue team and other workers assisting with such work in the immediate
vicinity of the confined space, so as to ensure the safety and health of all persons
involved in the confined space work activities.
 All the workers involved in confined space work should be provided with adequate
and suitable safety and health training when they are recruited and when they are
exposed to new or increased risks due to a change of responsibilities, introduction
of a new work equipment or introduction of a new system of work.
 The safety training provided should include, but is not limited to:
 Induction safety training for all new employees;
 On-the-job safety training for those who have received induction safety
training;
 Refresher safety training which should be conducted periodically and as
frequently as needed. Re-training should also be provided to workers whose
safety performance in working in a confined space is found to be unsatisfactory.
 The relevant information or instructions to be given to the workers should be in
written form, symbols, diagrams, notices or any other forms as appropriate, so long
as they can be clearly understood by the workers and are relevant to the concerned
confined space work.
 Training should involve demonstrations and practical exercises. It is particularly
important that workers are familiar with both the equipment and the procedures in
the confined space work.
 Standby persons should be trained on how to maintain communication with the
workers inside the confined space and to call for support in case of emergency.
 Members of the rescue team should be adequately and properly trained in rescue
arrangements, emergency procedures, associated risks and correct use of all rescue
equipment. They should also be instructed that oxygen gas should not be used to
improve oxygen content inside a confined space in all situations. It is recommended
that some members of the rescue team be provided with first-aid training including

47
 cardiopulmonary resuscitation.

2.13 Approval of Breathing Apparatus (s. 12)

Only approved BA are allowed to be used.

2.14 Duties of CW (s. 13)

All CWs should observe safety procedures and make full and proper use of the safety
equipment.

2.15 Case Study on Confined Space

Case 1: Does the F&IU (Confined Spaces) Regulation apply to a worker who is not
required to enter a confined space and only works outside the entrance to the confined
space? An extension of this question is whether the look-out man who stays at the top of
a manhole needs to be a certified worker (CW)? In a fatality case in Hong Kong, a
technician for an environmental consultant company opened the last manhole of an
underground sewer to take a water sample for examination of its oil and grease content,
biochemical oxygen demand, chemical oxygen demand and heavy metal content etc. The
sample was taken at street level by lowering a small bottle tied to a string without the need
to go down into the manhole. Naturally, he did not take any safety precautionary measures
including gas testing or wearing a breathing apparatus. However, he was overcome by the
rising toxic gas inside the manhole when he looked down the manhole from the street to
ascertain that the bottle had reached beneath the water level inside the manhole. He fainted
and fell down the manhole to his death.

Does the F&IU (Confined Spaces) Regulation apply to this case? Explain why? Does this
technician need to be a CW? What would you recommend to prevent a recurrence of a
similar accident?

48
Case 2:
You are the new safety officer for a
construction company engaged in
clearing sewage blockage. You are
also assigned as the competent person
undertaking risk assessment of the
manhole operation. Attached is a Risk
Assessment cum Permit-to-work
(Certificate) Form used by the
company for confined space
operations. Comment on whether you
consider this Form suitable for your
use.

2.16 Suggested Solution

Case 1: The F&IU (Confined Spaces) Regulation applies to work that is within the vicinity
of and is related to a confined space and is hence applicable in this case.

Case 2: Hazards are not limited to toxic and explosive gases. Risk assessment should also
be conducted for plant and equipment, materials, work method, possibility of in-rush of
liquid or free flowing solid, possibility of fire and explosion from sources other than
explosive gases, as well as the possibility of workers suffering from heat stroke. Also, the
person signing the permit-to-work (certificate) should be the contractor, and if the CP were
to sign this permit, he/she needs to be authorized by the contractor.

49
2.17 Concept Checklist

This chapter is on safety in confined space operations. Key points to note include:
 Introduction to confined space safety
 Particular concerns over confined space safety
 Interpretation of F&IU (Confined Spaces) Regulation
 Application
 CW and CW have to complete an approved course
 Risk assessment and recommendations
 Issue of certificate of safe operation / permit-to-work
 Safety precautions before work begins
 Safety precautions when work is being undertaken
 Use of PPE
 Emergency procedures
 Provision of information, instruction, etc.
 Approval of BA
 Duties of CW

2.18 Further Thinking

A certain overseas governmental jurisdiction is considering to amend the construction

safety law requiring those who undertake the risk assessment, sign the permit-to-work, and
enter a confined space must be a CP. Comment on the advantages and disadvantages of
this proposed 3-in-1 approach from the point of view of professionalism and simplicity vs
check and balance.

50
 Appendix
A2.3 Interpretation (s. 2)

“Certified worker” (核准工人，CW) means a person:

(a) who has attained the age of 18 years; and
(b) who holds a certificate issued by a person whom the Commissioner has authorized
to certify workers as being competent to work in a confined space.

“Competent person” (合資格人士，CP) means a person:

(a) who has attained the age of 18 years;
(b) who is either:
i) a safety officer registered under the F&IU (SOSS) Regulations (i.e. a RSO);
or
ii) a person who holds a certificate issued by a person whom the Commissioner
has authorized to certify persons as being competent to prepare risk
assessment reports; and
(c) who has at least one year’s relevant experience, after obtaining the registration or
certification, in assessing risk to the safety and health of workers working in
confined spaces.

“Confined space” (密閉空間) means any place in which, by virtue of its enclosed nature,
there arises a reasonably foreseeable specified risk, and includes any chamber, tank, vat,
pit, well, sewer, tunnel, pipe, flue, boiler, pressure receiver, hatch, caisson, shaft or silo in
which such risk arises.

“Risk assessment report” (危險評估報告) means an assessment and recommendations

carried out by a competent person.

“Specified risk” (指明危險) means a risk of:

(a) serious injury to any person at work arising from a fire or explosion;
(b) the loss of consciousness of any person at work arising from an increase in body
temperature;
(c) the loss of consciousness or asphyxiation of any person at work arising from gas,
fume, vapour or the lack of oxygen;
(d) the drowning of any person at work arising from an increase in the level of liquid;
or
(e) the asphyxiation of any person at work arising from a free flowing solid or the
inability to reach a respirable environment due to entrapment by a free flowing
solid.

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A2.4 Application (s. 3)

The F&IU (Confined Space) Regulation applies to work in an IU

(a) that takes place within a confined space; and
(b) that takes place within the immediate vicinity of, and is associated with work
occurring within, a confined space,
and the duties imposed on a proprietor or contractor under the F&IU (Confined Spaces)
Regulation are in respect of work in confined spaces within the IU for which he is such
proprietor or contractor.

A2.5 CW and CP to Complete an Approved Course (s. 4)

(a) Where a person has been authorized by the Commissioner for Labour to issue
certificates to CWs, he shall not issue a certificate unless the worker has
successfully completed a course that has been approved by the Commissioner in
respect of safety and health while working in confined spaces.
(b) Where a person has been authorized by the Commissioner for Labour to issue
certificates to persons certifying them to be competent to prepare risk assessment
reports, he shall not issue a certificate unless the worker has successfully
completed a course that has been approved by the Commissioner in respect of
preparing risk assessment reports.

A2.6 Risk Assessment and Recommendations (s. 5)

A2.6.1 Risk Assessment Process

(a) When work is to be undertaken in a confined space, a proprietor or contractor shall

appoint a CP to carry out an assessment of the working conditions in the confined
space and make recommendations on measures to be taken in relation to safety
and health of workers while working in that space.
(b) The assessment and recommendations shall be in writing and shall identify the
hazards likely to be present in the confined space, evaluate the extent of the risks
arising from such hazards and cover the following:
i) assessment of:
1. the work method to be used and the plant and materials to be used in work
activities;
2. whether or not there is any hazardous gas, vapour, dust or fume present
or there is any deficiency in oxygen;
3. the possibility of:
A) ingress of hazardous gas, vapour, dust or fume;
B) sludge or other deposits being present that are liable to give off
hazardous gas, vapour, dust or fume;
C) in-rush of free flowing solid or liquid;

52
 D) a fire or explosion in the confined space; and
E) loss of consciousness of a CW arising from an increase in body
temperature;
ii) recommendations on the measures required, including whether or not the use
of approved breathing apparatus (BA) is necessary to render the space safe
for workers, having regard to the nature and duration of the work to be
performed therein; and
iii) the period during which workers may remain safely in the confined space.
(c) Where sludge or other deposits are present and a CP considers that there is a
possibility that they will give off hazardous gas, vapour, dust or fume, he shall
recommend the use of approved BA.
(d) Where a CP, in evaluating the extent of the risks in a confined space, is of the
opinion that there is a substantial likelihood of a change in the environment
leading to an increased risk from one of the above hazards during the course of
the work in such confined space, he shall recommend the use of such monitoring
equipment as he considers appropriate in the circumstances and shall specify the
manner of its use.
(e) A proprietor or contractor shall appoint a CP to carry out a fresh assessment and
make recommendations whenever there has been a significant change in the
conditions of the confined space or of the work activities therein to which the
previous assessment relates, or there is reason to suspect that such change may
occur, and that the change is likely to affect the safety and health of workers
working therein.
(f) A CP shall, when requested to do so by a proprietor or contractor:
i) carry out an assessment of the working conditions that will occur in a confined
space for which such proprietor or contractor has made a request; and
ii) make recommendations on measures in relation to safety and health of
workers while working in that space,
and shall submit the assessment and recommendations to such proprietor or
contractor within a reasonable period of time after the request has been made.

A2.7 Issue of Certificate of Safe Operation / Permit-to-Work (s. 6)

A proprietor or contractor shall ensure that no worker

(a) enters a confined space for the first time until the proprietor or contractor:
i) has received, in respect of such confined space, a risk assessment report;
ii) has verified that such risk assessment report covers all matters referred to
in the CP’s risk assessment; and
iii) has issued a certificate stating
1. that all necessary safety precautions in relation to the hazards identified in
the risk assessment report have been taken; and

53
 2. the period during which workers may remain safely in the confined space;
or
(b) enters or remains in a confined space unless all recommendations in the risk
assessment report have been complied with.

A proprietor or contractor shall keep a certificate and risk assessment report for one year
after the work in the confined space to which they relate has been completed and shall
make them available, on request, to an OSO.

A2.8 Safety Precautions Before Work Begins (s. 7)

A proprietor or contractor shall ensure that no worker enters a confined space for the first
time unless:
(a) every piece of mechanical equipment in the confined space, which is liable to
cause danger, has been disconnected from its power source, with its power source
locked out;
(b) every pipe or supply line whose contents are liable to create a hazard has been
properly blanked off;
(c) the confined space has been tested to ensure the absence of any hazardous gas and
no deficiency of oxygen;
(d) the confined space has been adequately purged and sufficiently cooled and
ventilated, having regard to the circumstances of the particular confined space, to
ensure that it is a safe workplace;
(e) an adequate supply of respirable air and an effective forced ventilation have been
provided inside the confined space; and
(f) effective steps have been taken to prevent
i) an ingress to the confined space of hazardous gas, vapour, dust or fume; and
ii) an in-rush into the confined space of free flowing solid or liquid.

A2.9 Safety Precautions When Work is Being Undertaken (s. 8)

When work is being carried out in a confined space, a proprietor or contractor shall ensure
that:
(a) no workers enter or work in the confined space other than certified workers;
(b) a person is stationed outside the confined space to maintain communication with
the workers inside;
(c) the risk assessment report and the related issued certificate are displayed in a
conspicuous place at the entrance of the confined space; and
(d) the safety precautions undertaken continue to be effective.

54
A2.10 Use of PPE (s. 9)

Where:
(a) a risk assessment report recommends the use of an approved BA; or
(b) a person has to enter a confined space for underground pipework,
a proprietor or contractor shall, in addition to the safety precautions listed above, ensure
that:
i) a person entering or remaining in that particular confined space is properly
wearing an approved BA of a type that gives appropriate protection given the
nature of the confined space; and
(ii) a person referred to in above is wearing a suitable safety harness connected to a
lifeline that is strong enough to enable him to be pulled out, and that the free end
is held by a person outside the confined space who has sufficient physical strength
to be capable of pulling the person out of the confined space.

A2.11 Emergency Procedures (s. 10)

(a) A proprietor or contractor shall formulate and implement appropriate procedures

to deal with any serious and imminent danger to workers inside a confined space.
(b) A proprietor or contractor shall provide and keep readily available in a satisfactory
condition a sufficient supply of:
i) approved BA;
ii) suitable apparatus for reviving an unconscious worker;
iii) vessels containing oxygen or air;
iv) safety harnesses and ropes; and
v) an audio and visual alarm by which the workers inside the confined space can
alert those outside.
(c) When work is taking place in a confined space, a proprietor or contractor shall
ensure that a sufficient number of persons, commensurate with the scale of the job,
are present who know how to use the safety equipment referred to in above.

A2.12 Provision of Information, Instruction, etc. (s. 11)

(a) A proprietor or contractor shall provide, to all workers working within a confined
space or assisting with such work from immediately outside the confined space,
such instructions, training and advice as are necessary to ensure the safety and
health of all workers in the confined space.
(b) A proprietor or contractor shall provide all necessary equipment to ensure the
safety and health of workers in a confined space.

55
A2.13 Approval of Breathing Apparatus (s. 12)

The Commissioner for Labour may approve any type of breathing apparatus for the
purposes of the F&IU (Confined Spaces) Regulation and, where he does so, he shall publish
in the Gazette the name or description of the type of breathing apparatus that he has
approved.

A2.14 Duties of CW (s. 13)

A certified worker, while working in a confined space, shall:

(a) observe such procedures as may be implemented by a proprietor or contractor;
(b) observe such instructions and advice and attend such training as may be provided
by a proprietor or contractor;
(c) make full and proper use of, and forthwith report to the proprietor or contractor
any fault or defect in, any safety equipment or emergency facilities provided under
the F&IU (Confined Spaces) Regulation.

References

Factories and Industrial Undertakings (Confined Spaces) Regulation 1999, Hong Kong,
Available at http://www.elegislation.gov.hk/hk/cap59AE (Accessed 31 December
2019)
Fire Services Department (n.d.) “Fire Protection Notice No. 8: Precautions When Working
in Confined Spaces Containing Gases Other than Air”, Government Printer, Hong
Kong.
Labour Department (1994) “Safety Guide to Working in Confined Spaces”, Government
Printer, Hong Kong.
Labour Department (1995) “A Guide to the Factories and Industrial Undertakings
(Confined Spaces) Regulations”, Government Printer, Hong Kong.
Labour Department (2000) “Code of Practice Safety and Health at Work in Confined
Spaces”, Government Logistics Department, Hong Kong.
Labour Department (2006) “Safety Guide for Work in Manholes”, Government Logistics
Department, Hong Kong.
Labour Department (2007a) “Prevention of Gas Poisoning in Drainage Work”,
Government Logistics Department, Hong Kong.
Labour Department (2007b) “Simple Guide on the Prevention of Gas Poisoning in
Drainage Work”, Government Logistics Department, Hong Kong.
Labour Department (2009) “A Brief Guide to the Factories and Industrial Undertakings
(Confined Spaces) Regulation”, Government Logistics Department, Hong Kong.
Labour Department (2012) “Safe Work in Confined Spaces”, Government Logistics
Department, Hong Kong.
Labour Department (n.d.a) “Hazards Commonly Encountered in Confined Spaces”,
Government Printer, Hong Kong.
Labour Department (n.d.b) “Safety Hints for Manhole Work”, Government Printer, Hong
Kong.

56
Labour Department (n.d.c) “Safety in Confined Spaces”, Government Printer, Hong Kong.
Occupational Safety and Health Council (1998a) “Know the Hazards of Confined Space”,
OSHC, Hong Kong.
Occupational Safety and Health Council (1998b) “Prevention of Confined Space Accident”,
OSHC, Hong Kong.
Occupational Safety and Health Council (2001) “Working in Confined Spaces”, OSHC,
Hong Kong.
Occupational Safety and Health Council (n.d.) “Confined Space Promotional Activity”,
OSHC, Hong Kong.
WSH Council (2010) “Technical Advisory on Working Safely in Confined Spaces”,
WSHC, Singapore.
Wong F.K.W. (1998) “Bamboo Scaffolding – Safety Management for the Building
Industry in Hong Kong”, Hong Kong Polytechnic University, April 1998, Hong
Kong.
Worksafe New Zealand (2014) “Mobile Elevating Work Platforms”, Best Practice
Guidelines, Wellington, New Zealand.

57
 Chapter 3
Excavation Safety; Protection of Electricity Supply Lines

3.1 Introduction to Excavation Safety and Protection of

Electricity Supply Lines

Excavation and trenching are amongst the most dangerous operations in a construction site.
An excavation is commonly identified as a man-made cut, cavity, trench, or depression in
the earth’s surface formed by earth removal while a trench is defined is a narrow
underground excavation that is deeper than its width. Dangers include cave-ins, falls,
falling objects, hazardous atmosphere, and incidents involving mobile earthmoving heavy
equipment. Trench collapses usually cause fatalities and major injuries. Regular pre-work
inspections should be able to identify the hazards and reduce the serious risk of injury.
Safety inspection includes checking of support and warning systems, access and egress,
weather conditions, heavy equipment and PPE. The Construction Sites (Safety)
Regulations (Cap. 59I) R. 39-41A lay down the basic requirements for the safety of
excavations on construction sites and is enforced by the Labour Department while the
Electricity Supply Lines (Protection) Regulation (Cap. 406H) is enforced by the Electrical
and Mechanical Services Department (EMSD). This chapter also discusses Section 10T of
the Land (Miscellaneous Provisions) Ordinance (Cap. 28) on the provisions of safety
precautions and support for excavation to ensure public safety.

3.2 Safety of Excavations (CS(S)R R.39-41A)

For excavation or earthwork operations of more than 1.2m, the contractor shall:
 erect a shoring made of timber or other material to prevent danger from fall or
displacement of earth, rock or other material including waste and debris adjacent to
or forming the side of the excavation or earthwork;

Source from www.housingauthority.gov.hk/mini-site/site-safety

 assign a CP to examine the excavation or earthwork at least weekly and certify it to

be safe on CS(S)R-Form 4 before carrying out work thereat, except where the slope
of the sides of the excavation or earthwork forms a safe angle of repose. In granular

58
 soils, the angle of slope should be less than the natural angle of repose of the
material being excavated. In wet ground a considerably flatter slope is required;

Source from https://www.info.gov.hk/cgi-bin/forms (The form is available at this website)

 erect a suitable barrier to the edge of the excavation, shaft, pit or opening of a
depth of 2m or more or otherwise have it securely covered;
 ensure that no material is placed or stacked close to the edge of the excavation,
shaft, pit or opening;
 no material, load or plant is placed or moved near the edge of the excavation, shaft,
pit or opening; and
 ensure adequate means of emergency escape from rising water or from an
irruption of water or material or toxic gas.

Source (Issued by Highways Department & Civil Engineering Department): Guide to Trench
Excavations (Shoring Support & Drainage Measures) (2003).

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In accordance with Section 10(1) of the Land (Miscellaneous Provisions) Ordinance (Cap.
28) which is enforced by the Director of Lands, a person shall not make or maintain any
excavation in unleased land unless he is, or he is the contractor of, the holder of an
excavator permit or emergency excavation permit. Under Section 10T of this Ordinance,
the permittee of the excavation permit or emergency excavation permit shall:
(a) adopt all necessary safety precautions to protect the public or any person making
or maintaining an excavation to which the permit relates from any danger of
injury;
(b) provide adequate support for the structural stability of buildings, roads, slopes,
structures, pipes, lighting posts, utility services or similar installations adjacent to
the excavation so as to prevent the public or any person from being endangered
by a fall or displacement of earth, rock or other material.
Where contravention with the above is trialed in court, the court may take into
consideration that the defendant has:
(a) hired a competent person to supervise the excavation concerned;
(b) a documented system for supervising the excavation concerned, including but not
limited to a system which is managed by a competent person; and requires
inspection of the excavation to ensure compliance with duties imposed and keeps
records of such inspection;
(c) a documented system to ensure his contractor complies with the duties imposed;
(d) taken other reasonable steps.

Under Section 10T(6)(d) of the Land (Miscellaneous Provisions) Ordinance, Cap. 28,
“Competent person” (合資格人士) includes a person who is registered as a safety officer
under the Factories and Industrial Undertakings (Safety Officers and Safety Supervisors)
Regulations with at least 3 years’ relevant experience in supervising excavations which is
similar to the excavation concerned or in case of a documented system, has at least 3 years’
experience in managing a documented system which is similar to a documented system for
supervising the excavation concerned.

3.3 Electricity Supply Lines (Protection) Regulations (Cap.

406H)

3.3.1 Main Provisions

The main provisions under the Electricity Supply Lines (Protection) Regulation (Cap.
406H) (“ESLPR”) are summarized as follows:
 The ESLPR prohibits the carrying out of certain works in the vicinity of an U/G
electricity cable or O/H electricity line unless all reasonable steps have been taken
to ascertain the existence of the cable or line together with certain information
relating to it. In the case of an U/G electricity cable, reasonable steps shall not be
regarded as having been taken unless a competent person has undertaken an

60
 investigation to ascertain the existence of any U/G electricity cable within the
proposed work site or its vicinity together with the alignment and depth of the cable,
and has provided a written report of the findings of his investigation.
 The ESLPR requires that, in carrying out work in the vicinity of electricity supply
lines, all reasonable measures shall be taken to prevent the occurrence of an
electrical accident or an interruption to the supply of electricity arising from the
work done.
 The ESLPR empowers the Director of Electrical and Mechanical Services
(“DEMS”)to serve on a person, whom DEMS believes to be contravening the
ESLPR, a remedial notice directing the person to remedy that contravention within
a period specified in the notice. It also enables DEMS, in the interests of safety, to
intervene where there is a failure to comply with a remedial notice by prohibiting
further work on the site in the vicinity of the electricity supply lines or by remedying
the contravention himself if necessary.
 The ESLPR empowers DEMS to issue and approve a Code of Practice (CoP) for
the purpose of providing practical guidance in respect of any requirement under the
ESLPR.
 The ESLPR empowers DEMS to approve a person to be a competent person subject
to the compliance of certain training (the person has attended and passed a course
approved by DEMS in the locating of U/G electricity cables) and/or experience
requirements (during the period of 3 years immediately preceding his application
as CP, the person has had not less than 6 months’ practical experience in locating
U/G electricity cables, or has had such other practical experience as DEMS may
consider relevant and equivalent for the purposes of the ESLPR, or in the opinion
of DEMS, the person is by reason of his knowledge and practical experience
capable of carrying out the work of locating U/G electricity cables in a competent
manner) necessary for carrying out the work of locating U/G electricity cables in a
competent manner. In the interests of regulating the quality of work performed by
the competent persons, DEMS is empowered to suspend or revoke the certificate of
approval granted to the person concerned.
 If charged with failure to take reasonable steps to ascertain the alignment or other
relevant particulars of an electricity supply line, or with failure to take reasonable
measures to prevent the occurrence of an electrical accident or interruption to the
electricity supply, the charged person shows suitable defence if he can demonstrate
that he has complied with the relevant provisions of the COP. In addition, under
section 18 of the ESLPR, if charged with failing to take all reasonable measures to
ensure that work in the vicinity of electricity supply lines can proceed safely and
without interruption to the electricity supply, the charged person shows suitable
defence if he can demonstrate that the failure in question was due to reliance on
information provided by a competent person or an electricity supplier.

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3.3.2 Code of Practice

A Code of Practice, which prescribes the standard practices with detailed technical
guidelines and working procedures on how the legislative requirements can be met, has
been drawn up by the EMSD in consultation with the parties concerned. The CoP has been
approved by the Director pursuant to regulation 15(1)(a) of the ESLPR.

62
Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

3.3.3 Requirements Relating to Work in Vicinity of Electricity

Supply Lines (s. 10)

A person who carries out any underground work in the vicinity of an underground
electricity cable or an overhead electricity line shall take all reasonable steps, including
having a CP undertake an investigation to ascertain the existence within the proposed work
site and its vicinity of any such underground electricity cable and its alignment and depth
or of any such overhead electricity line and its alignment, distance from the ground and
voltage, and has provided a written report of his findings; as well as to take all reasonable
measures to prevent the occurrence of an electrical accident or an interruption to the supply
of electricity arising from the work done.

3.3.4 Application and Exclusion

The CoP on Working Near Electricity Supply Lines applies to all work carried out in the
work site or in its vicinity where U/G cables or O/H lines may be found. However, the
following work need not follow the safe system of work set out in the CoP unless probable
damage to U/G cables is seen:
 the milling of paved surface up to 120 mm below ground level in carriageways for
the purpose of road resurfacing; and
 the replacement of existing an paving block up to 120 mm below ground level.
Moreover, the CoP does not apply to dredging work and extraction of material from the
seabed.

3.3.5 Interpretation of Terms

“Hand tool” means a non-mechanized tool designed for operation by hand including, but
is not limited to spades, shovels, picks or forks.

“Hand-held power tool” means a hand-held mechanized tool designed for operation that
utilizes electrical or pneumatic power.

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"Minor shallow excavation" means an excavation limited to 2 sq. m x 450 mm in depth
and dug using hand tools with the exception that hand-held power tools can be used to
break the paved surface up to a depth of 150 mm in a footpath or 450 mm in a carriageway
and, in both cases, with at least 250 mm of clearance from any cable alignment.

"Trial hole" means an excavation for exposing part of the target cable, carried out under
the supervision of a competent person at the point of works where the working personnel
use hand tools for digging with the exception that hand-held power tools can be used to
break the paved surface up to a depth of 150 mm in a footpath or 600 mm in a carriageway
and, in both cases, with at least 250 mm of clearance from any cable alignment.

“Works in the vicinity of overhead lines” means any works, except for blasting works,
found within a horizontal distance of 9 m from the outermost conductor of an O/H line.
Blasting works are considered as works in the vicinity of O/H lines if any blasting point is
within a horizontal distance of 25 m from the nearest conductor of an O/H line or radial
distance of 50 m from the centre of any O/H line footing.

“Works in the Vicinity of U/G Cables” are defined in the following table.
Type of works below ground level Distance
Trench or other excavation works in stable ground conditions up 3m
to 1.5 m in depth
Trench or other excavation works in stable ground conditions 5m
over 1.5 m and up to 5 m in depth
Trench or other excavation works in stable ground conditions 10 m
over 5 m in depth
Vertical penetration including sheet piling, ground investigation 3m
and any kind of drilling or core sampling or ramming
Welding or other hot works near exposed U/G cables 10 m
H-Piling, percussion moling or pipe jacking 15 m
Any form of tunnelling, boring, construction of caverns, driving Always Consult
headings, cable jacking Electricity Supplier
Use of explosives 60 m
Works below ground level in the vicinity of U/G cables

3.4 Safe System of Work for Working Near Underground

Electricity Cables or Overhead Lines

3.4.1 Safety Precautions Before Commencement of Works

Except for works which involve only minor shallow excavation, the working party shall
consult or request new cable plans from the electricity supplier 14 working days before
commencement of works in the vicinity of U/G cables or O/H lines if the plans in hand
have been provided for more than 3 months. For all works in the vicinity of U/G cables,
the working party shall appoint a CP for cable detection work and proposing trial hole

64
locations. The working party shall ensure that personnel at the works site are fully aware
of the details of the U/G cables. For works in the vicinity of O/H lines, the working party
shall ensure that personnel at the works site and the appointed signaller fully understand
all necessary safety precautions to be taken.

In an emergency involving works in the vicinity of electricity supply lines, the working
party shall contact the 24-hour emergency service of the electricity supplier by telephone.
The electricity supplier shall provide immediate advice as far as practicable by telephone,
fax or other electronic means. In addition, if the electricity supplier is aware of an imminent
danger arising from the electricity supply lines, emergency personnel shall be immediately
despatched to the site. The electricity supplier shall provide cable plans / alignment
drawings and safety advice to the working party at the site. In case of works in the vicinity
of U/G cables, the working party shall arrange a competent person to ascertain the position
of the U/G cables by conducting passive detection before commencement of works. In an
emergency situation, the electricity supplier shall offer assistance to the working party.

Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

3.4.2 Safety Precautions During Works

In the course of works in the vicinity of electricity supply lines, the working party shall
adopt reasonable measures appropriate to the nature of the works. The safe system of work,
together with the safety guidelines on handling accidents or emergencies, shall be
effectively communicated to all persons likely to be engaged in the works in the vicinity
of electricity supply lines. According to the nature of the works, the electricity supplier
shall attend site meetings and provide safety advice to the working party as necessary.
When the electricity supplier believes that the electricity supply lines may be susceptible
to damage, the working party shall take additional safety precautionary measures against
the cable damage, and report to the DEMS. An arrangement of additional site patrol is
required when the electricity supplier believes that it is necessary to monitor the electricity
supply lines so as to prevent them from being susceptible to damage.

65
Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

3.4.3 Locating Underground Cable Alignment (Passive

Detection)

If the cable plans supplied by the electricity supplier indicate that there are U/G cables
within the works site and/or the area of the specified distance from the works site, the
working party shall appoint a CP to carry out the cable detection work. Before the cable
detection takes place, the CP shall be provided with the electricity supplier’s cable plans
and works site drawings. The cable detection device to be used by the competent person
shall be non-destructive and calibrated as per the manufacturer’s requirements. In the
course of cable detection, the competent person shall repeatedly refer to the cable plans to
pinpoint as accurately as possible the alignment of any U/G cables. If the cable alignment
cannot be detected by means of 50 Hz passive detection, the competent person can switch
to the following alternative forms of detection:
 Radio frequency passive detection - Another passive mode selected at the cable
detection device, this method provides less definite alignment detection than 50 Hz
passive detection because other utilities with metallic objects may also re-emit the
radio frequency signal.
 Inductive detection - This detection mode requires the use of a signal generator (the
transmitter) and a separate receiver. This method can only be used when certain
parts of the U/G cable alignment is accurately known so that the transmitter can be
properly positioned right above it. The accuracy of this method is very much
affected by other utilities with metallic objects close to the target cable.

The competent person should be able to detect the most probable alignment of the U/G
cables identified on the cable plans if the current carrying cables are properly laid out with
an adequate horizontal clearance. However, if the U/G cables are very close to each other
or crossing each other or laid in different layers (e.g. cables in the same alignment but at
different depths), the competent person will not be able to detect the most probable
alignment for each U/G cable. Instead, he can locate a peak signal for the group of U/G
cables and record its alignment and note the number and voltage level of the cables that it
may represent.

66
Upon completion of passive cable detection, the competent person shall prepare a proper
record form. This form should make reference to the format of the sample form and shall
bear the heading “Cable Alignment Record” and include the following details:
 name and approval number of CP;
 name of the site contractor or other working party;
 location, date and time for which the work on locating the U/G cable alignment was
carried out;
 U/G cable alignment (for each U/G cable or for each group of cables) based on
common reference points (e.g. lamp pole, traffic light post or hydrant, etc.)
 brand name, model number, serial number, calibration record and mode of
operation of the U/G cable detection device used for the detection;
 proposed trial hole locations; and
 photos showing site markings for cable alignment and proposed trial hole locations.

At the time of submission of the Cable Alignment Record to the working party appointing
him, the competent person should remind the working party, if active cable detection has
not yet been completed, to ascertain the depth and alignment of the U/G cables.

The competent person shall propose trial hole locations according to the detected alignment
or, in case the alignment cannot be located due to de-energized or current-balanced cables,
by referring to the electricity supplier’s cable plans. The proposed locations at appropriate
intervals shall be, as far as practicable, convenient for the working party to expose as many
U/G cables as possible for the purpose of toroidal active detection.

The competent person is responsible for marking the alignment at the location and its
vicinity where the trial hole is to be opened. This marking should be done with waterproof
crayon, paint or self-adhesive temporary road marking tapes on paved surfaces, or with
wooden pegs in grass or unpaved areas.

The competent person should brief the working party on the content of the cable alignment
record, with particular reference to the locations of the proposed trial hole openings and
the number of target U/G cables to be exposed.

In case of a minor shallow excavation, the working party shall appoint a competent person
to carry out cable detection work. The CP shall be personally on site for direct supervision
of cable detection works and mark the cable alignment, if any, within and in the vicinity of
the works site and submit the Cable Alignment Record to the working party appointing
him.

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Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

3.4.4 Trial Holes (Exposing Cable and Active Detection)

The working party shall proceed with the following reasonable steps except for works
which involve only minor shallow excavation:
 Trial Hole Excavation
Great caution has to be exercised when exposing the target U/G cable. The
excavation of the trial hole shall be supervised by the competent person personally
on site until the target cable is exposed or the excavation work of the trial hole is
completed. The competent person should repeatedly use a cable detection device
and frequently update the site personnel as to the most accurate cable location until
the target cable is exposed. The site personnel shall only use hand tools for digging.
Hand-held power tools can only be used to break the paved surface up to a depth of
150 mm in a footpath or 600 mm in a carriageway and, in both cases, with at least
250 mm of clearance from any cable alignment. Mechanical excavators and other
machinery (with the exception that hand-held power tools for breaking the paved
surface) shall not be used for trial hole excavation. The working party should avoid
digging a trial hole inside a manhole. In carrying out the works, apart from ESLPR,
there may be other legislation and guidelines which the working party is required
to comply with, and appropriate safety measures should be adopted in accordance
with the relevant legislation and guidelines to avoid accidents.

68
Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

 Toroidal Active Detection

The target cable inside the trial hole is adequately exposed so as to permit the
competent person to place a signal clamp around it. A known high frequency signal
is injected into the cable by electromagnetic induction through the signal clamp. As
only the target cable carries this high frequency signal, the competent person can
use a receiver selected to this signal frequency to detect at appropriate intervals (say,
1-3 m) the alignment and depth of the unexposed part of the target U/G cable,
starting from the trial hole. For U/G cable of voltage 132kV or above, the electricity
supplier shall be consulted before excavating the trial hole and toroidal active
detection work.

Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

69
Trial hole excavation shall be carried out when:
 the alignment of any U/G cable is ascertained to be within the works site and/or
within the area 500mm away from the boundary of the works site; or
 the alignment of any peak signals for a group of U/G cables is located within the
works site and/or within the area 3m away from the boundary of the works site.

Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

If the alignment of the peak signals is located between the area 500 mm and 3m away from
the works site and it is not practicable to open a trial hole within that area (e.g. the works
site is at a footpath whereas the alignment is located at a carriageway), the competent
person should propose the following:
 open a number of trial holes along the boundary of the works site opposite the
alignment of the peak signals. The competent person shall determine the size, depth
and number of trial holes based on the alignment, the type and the number of cables
within the group. In principle, the closer the alignment and/or the greater the
number of cables within the group, the more trial holes will be required.
 The trial holes should be proposed at the locations where the peak signals are closest
to the works site.
 The trial hole should be excavated at a right angle to the alignment and extended
500 mm away from the works site.
 The alignment and depth of any cables found in the trial holes shall be ascertained
by means of toroidal active detection.

70
Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

Before commencing trial hole excavation, the working party shall inform the electricity
supplier of the nature of the intended works if:
 the target cables are of voltage 132kV or above; or
 the works involve trenchless excavation or horizontal drilling such as tunnelling,
percussion moling, pipe jacking and soil nailing, etc.

The electricity supplier may deem the excavation of a trial hole unnecessary if the works
involved are below ground level, where U/G cables would not be affected or where U/G
cables do not exist. Any agreement between the electricity supplier and the working party
shall be properly signed and recorded for inspection upon request by EMSD.

If the works site is not large but heavily congested with many U/G cables and/or other
utilities (e.g. in a rear lane), the working party should consider conducting a risk assessment
and adopting reasonable precautionary measures accordingly, and the competent person
should, apart from supervising the excavation of the trial hole, consider also supervising
the excavation until all U/G cables are exposed within the works site.

If the CP encounters genuine difficulty in locating the U/G cables shown in the electricity
supplier’s plans, he shall seek necessary assistance from the electricity supplier. The
electricity supplier shall provide advice on reasonable alternatives to help the competent
person locate the cables and/or send technical staff to the site, not more than 3 working
days after receipt of the request, to assist with locating U/G cables as necessary without
charge.

Should there be any doubt regarding discrepancies between the cable detection results and
the electricity supplier’s cable plans, the competent person shall repeat the cable detection
and/or contact the electricity supplier for clarification on site.

71
Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

3.4.5 Competent Person Written Report

Upon completion of the active cable detection, the CP should prepare a ‘Competent Person
Written Report’ to the working party appointing him.

The Competent Person Written Report should include the following details:
 name and approval number of competent person;
 name of the site contractor or other working party;
 location, date and time for which the active detection was carried out;
 the cable layout plan detailing the alignment of each U/G cable based on common
reference points (e.g. lamp pole, traffic light post, or hydrant, etc.) and any cable
sections in shallow depth. A cable alignment band can be used to represent a group
of U/G cables of which the ascertained alignment are very close to each other. The
alignment and size of the band shall be dimensioned and the number of U/G cables
that the band represents shall be specified;
 depth profile of each U/G cable (i.e. cable depth corresponding to each
measurement point along the cable alignment);
 voltage level of each U/G cable;
 electricity supplier’s advice, such as advice sought from the electricity supplier
upon detecting major deviations of cable alignment on site from the electricity
supplier’s cable plans, if any;
 photos showing the toroidal active detection and site markings for cable alignment
and depth; and
 brand name, model number, serial number, calibration record and the adopted
frequency of the U/G cable detection device used for the detection.

The relevant working party (e.g. the main contractor, subcontractor, site contractor, etc.)
shall provide the site personnel concerned with a copy of the Competent Person Written
Report. In addition, the working party should arrange a site briefing given by the competent
person to ensure that the site personnel, such as the operators of the excavator/machine and

72
workers engaged in excavation work, are conversant with the contents of the Report,
including the meanings of markings at site, and are aware of the potential danger as a result
of cable damage and the required safety precautions. The competent person should clearly
record the attendance of the site personnel participating in the site briefing in the Competent
Person Written Report for record purposes.

Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

The working party should keep a copy of the Cable Alignment Record, and Competent
Person Written Report on site and make available the relevant document for inspection,
upon request by the DEMS until the works are completed without occurrence of any cable
damage. The Cable Alignment Record/Competent Person Written Report should be posted
on the barrier or railing on the site.

The competent person is responsible for marking the alignment and depth of all U/G cables
with waterproof crayon, paint or self-adhesive temporary road marking tapes on paved
surfaces or with wooden pegs in grass or unpaved areas. Steel pins, spikes or long pegs,
which could damage U/G cables laid at shallow depth, must not be used. Any section of
the U/G cable with a sudden reduction of buried depth shall be clearly marked along the
alignment.

The working party shall ensure that the markings (both alignment and depth) identified by
the competent person are available at the site before the commencement of works. To
avoid confusion to drivers, markings on carriageways should only be laid after the area is
fenced off from traffic. Such markings should be completely removed before the area is
re-opened to traffic.

After the removal of a road surface or pavement cover, if further works are required at the
concerned working area, the working party should repaint/retain cable markings in
accordance with the Competent Person Written Report, so as to alert the engaged site
personnel, such as the operators of excavators/machines and workers, on the alignment and
depth of U/G cables.

After completion of works, the working party should erase any residual markings on paved
surfaces and not deface any road marking.

73
3.4.6 Safe Excavation

Other than minor shallow excavation, the electricity supplier shall be informed before
commencing any excavation in the vicinity of underground cables of 132kV or above. The
site personnel should always refer to the Competent Person Written Report in the course
of excavation, and be vigilant for signs, alignment and depth of U/G cables. A mechanical
excavator shall not be used too close to the underground cables. Adequate clearance shall
be kept between a mechanical excavator and any underground cables - 1 m in any direction
for underground cables below 132 kV and 3 m for 132 kV or above. Hand-held power
tools shall be used at a distance of not less than 500 mm in any direction from any
underground cables, except when breaking out a paved concrete surface where a horizontal
safe working distance of 250 mm is required. Hand tools are commonly used for exposing
U/G cables. Every effort shall be made to excavate alongside the service rather than
directly above it. Spades and shovels shall be used rather than other tools. Picks or forks
may be used with care to free lumps of stone, etc. and to break up hard layers of earth.
Picks should not be used in soft clay or other soft soils near to U/G cables.

Whenever the excavation involves the removal of hard materials (e.g. concrete, bitumen
and the like) in which the U/G cable is covered or embedded, the electricity supplier should
be consulted before commencement of work.

74
Source (Issued by Electrical & Mechanical Services Department): Cocde of Practice on Working near
Electricity Supply Lines (2018).

3.4.7 Safe Backfilling

All warning tapes, tiles, protection plates or other protection materials shall be reinstated
to their original position by the working party. The electricity supplier should be
approached to make up cable protection materials if they are found to be damaged or
missing before the backfilling.

The same backfilling materials should be used unless otherwise agreed with the electricity
supplier. In general, cement bonded sand or sieved soil of suitable fineness shall be used
as covering material for the backfilling.

Unsuitable materials which are likely to cause damage or reduce the rating of the
underground cables (e.g. rock, rubble, bituminous material, brick, stone, timber, rubbish
and other materials of high thermal resistivity) must not be used. The backfill shall be
adequately compacted, particularly beneath the cable, to prevent any settlement which
would subsequently damage the cable. No power compaction should take place until a
150mm cover of selected fine fill or sieved soil has been suitably compacted above the U/G
cable. Hard materials (e.g. concrete, bitumen and the like) shall not be used for backfill
within 300mm of an U/G cable in any direction.

75
Source from www.housingauthority.gov.hk

3.5 Concept Checklist

This chapter is about excavation safety, including protection of electrical supply lines. Key
points to note include:
 introduction to excavation safety and protection of electrical supply lines
 safety of excavations
 Electrical Supply Lines (Protection) Regulations
 Safe system of work for working near underground electricity cables or overhead
lines

3.6 Further Thinking

Excavation is normally taken to be digging down into the ground to form a cavity and the
displacement of rock is construed as a collapse of the sides of the excavation. However,
there was a court case in which the excavation was up above (in what’s called a borrow
area, i.e. removal of the soil on a hillside for reclamation purposes) in which a rock above
was disturbed, rolled down and crushed a worker to death. The summons, originally laid
as a falling object, was subsequently amended to failure to prevent displacement of rock in
an excavation, i.e. CS(S)R Regulation 39 instead of CS(S)R Regulation 49. The Judge
considered that the rock that crushed the victim in this case was displaced and resulted in
its rolling down, not falling. What is your opinion on what constitutes a “fall” of an object?
Does it need to be free fall?

76
 Appendix
A3.2 Excavation Safety Measures

A3.2.1 Safety of Excavations (R. 39)

(a) The contractor responsible for any construction site at which excavating or
earthworking operations are being carried on and any contractor who has direct
control over the operations shall cause a structure made of suitable timber or other
suitable material to be erected in connexion with the operations as soon as may be
necessary after their commencement so as to prevent workmen employed on the
site from being endangered by a fall or displacement of earth, rock, or other material
(including waste material and debris) adjacent to or forming the side of the
excavation or earthwork.
(b) The contractors shall:
(i) cause every part of the excavation or earthwork where workmen are employed
to be examined by a competent person at least once in every period of 7 days
after the commencement of the excavation or earthwork until it is completed
or abandoned; and
(ii) ensure that after any such examination no further work in respect of the
excavation or earthwork is carried on until there has been obtained from that
person in respect of the examination, or in respect of any further examination
that may be necessary, a report in the approved form (CS(S)R Form 4) which
includes a statement to the effect that the excavation or earthwork, and every
structure erected is safe and secure.
(c) A report of an examination and the results thereof, signed by the person carrying
out the examination, shall be:
(i) made in the approved form and contain the prescribed particulars; and
(ii) delivered forthwith to the contractor responsible for the construction site
concerned and the contractor who employs that person to carry out the
examination.
(d) This regulation shall not apply:
(i) to an excavation or earthwork where, having regard to the nature and slope
of the sides of the excavation or earthwork and other circumstances, no fall
or dislodgment of earth, rock, or other material is liable to occur so as to
bury or trap a workman or other person employed in or near the excavation
or earthwork; or so as to strike any such workman or person from a height
of more than 1.2 metres; or
(ii) in relation to a workman actually engaged in the erection of any structure or
in rendering any excavation or earthwork safe, or to a person engaged in
examining any such structure, if other precautions which are reasonably
adequate to ensure his safety are taken.

77
A3.2.2 Fencing of Excavations, etc. (R. 40)

(a) The contractor responsible for any construction site where there is an excavation,
shaft, pit, or opening in the ground into or down the side of which a workman or
other person lawfully on the site is liable to fall a distance of more than 2 metres
and any contractor who has direct control over the excavation or any construction
work in the shaft, pit or opening shall, for the purpose of preventing any such fall,
so far as practicable ensure that either:
(i) a suitable barrier is erected as close as is reasonably practicable to the edge
of the excavation, shaft, pit or opening; or
(ii) the excavation, shaft, pit, or opening is securely covered.
(b) The above shall not apply to any part of an excavation, shaft, pit or opening while
(and to the extent to which) the absence of such barrier and covering is necessary
for the access of persons or for the movement of plant or equipment or materials or
while (and to the extent to which) it has not yet been practicable to erect such barrier
or covering since the formation of that part of the excavation, shaft, pit or opening.

A3.2.3 Safe Guarding the Edges of Excavations, etc. (R. 41)

The contractor responsible for any construction site at which there is an excavation, shaft,
pit or opening in the ground, and any contractor who has direct control over the excavation
or any construction work in the shaft, pit or opening, shall ensure that:
(a) no material is placed or stacked close to the edge of the excavation, shaft, pit, or
opening so as to endanger any person who is working in it; and
(b) no load or plant is placed or moved near the edge of the excavation, shaft, pit or
opening if it is likely to cause the side of the excavation, shaft, pit, or opening to
collapse and thereby endanger any person.

A3.2.4 Requirements for Emergency Escape (R. 41A)

The contractor responsible for any construction site, at which there is an excavation, shaft,
tunnel, pit or opening in the ground and where there is reason to apprehend danger to
persons employed therein from rising water or from an irruption of water or material and
any contractor who has direct control over the excavation or any construction work in the
shaft, tunnel, pit or opening, shall ensure that adequate means are provided, so far as
practicable, to enable such persons to reach positions of safety in the event of emergency.

References

Construction Sites (Safety) Regulations 1978, Hong Kong, Available at

http://www.elegislation.gov.hk/hk/cap59I (Accessed 31 December 2019).
Electrical and Mechanical Services Department (2018) “Code of Practice on Working Near
Electricity Supply Lines”, Government Logistics Department, Hong Kong.

78
Electrical and Mechanical Services Department (n.d.a) “Avoiding Danger from
Underground Gas Pipes and Electricity Cables”, Government Logistics
Department, Hong Kong.
Electrical and Mechanical Services Department (n.d.b) “Avoid Damage to Concealed
Pipes and Conduits”, Government Logistics Department, Hong Kong.
Electrical and Mechanical Services Department (n.d.c) “Avoidance of Damage to
Underground Gas Pipes and Electricity Cables”, Government Logistics
Department, Hong Kong.
Electrical and Mechanical Services Department (n.d.d) “Approved Competent Person: 8
Steps for Underground Cable Detection”, Government Logistics Department,
Hong Kong.
Electrical and Mechanical Services Department (n.d.e) “Cable Detection Procedure for
Approved Competent Person”, Government Logistics Department, Hong Kong.
Electrical and Mechanical Services Department (n.d.f) “For Safety, Arrange Power
Suspension before Electrical Work”, Government Logistics Department, Hong
Kong.
Electrical and Mechanical Services Department (n.d.g) “For Your Safety, Switch Off
Electricity Supply before Electrical Work”, Government Logistics Department,
Hong Kong.
Electrical and Mechanical Services Department (n.d.h) “For Your Safety, Maintain Your
Electrical Installations”, Government Logistics Department, Hong Kong.
Electrical and Mechanical Services Department (n.d.i) “For Your Safety, Test Your
Electrical Installations Periodically”, Government Logistics Department, Hong
Kong.
Highways Department and Civil Engineering Department (2003) “Guide to Trench
Excavations (Shoring Support and Drainage Measures”, Hong Kong.
Hong Kong Construction Association (2018) “Guide to Best Practice on Safety and Health
of Hand-Dug Tunnelling Works”, HKCA, Hong Kong.

79
 Chapter 4
Factories and Industrial Undertakings (Abrasive Wheels)
Regulations (Cap. 59L)

4.1 Introduction to Abrasive Wheels

Abrasive wheels are used extensively in industries for grinding of tools such as cutters and
drill bits. Bursting of wheels occasionally occur due to:
 Defective wheel;
 Overspeeding;
 Faulty mounting;
 Misuse, including grinding on the side instead of the perimeter of the wheel.
Other dangers include contact with the wheel and injury to the eyes from flying particles.

Source (Issued by Labour Department): Safety in the Use of Abrasive Wheels (2008).

80
4.2 Interpretation of Terms (R. 2)

An abrasive wheel that is regulated under this piece of legislation needs to be power driven.
Hence, a manual foot-operated grinding wheel (for sharpening kitchen choppers) is not
within the purview of these Regulations. An abrasive wheel must also contain abrasives.
Hence, a buffing wheel does not contain any abrasives and is hence not considered an
abrasive wheel.

4.3 Application (R. 3)

Apart from grinding, some abrasive wheels, such as abrasive cutters, are used for cutting,
which, according to the definition of abrasive wheels, is a legitimate use and not misuse.
This is also true for a portable grinder used for cutting cleats, though by its very name, it
is also used for grinding.

4.4 Speeds of Abrasive Wheels (R. 5)

A reduction in diameter could be the result of wear and tear.

Increased speed in r.p.m. = Original speed in r.p.m. x Original dia. / Reduced dia.

The maximum permissible speed of a wheel may also change upon the aging of the
bonding material of the wheel after prolonged use. The manufacturer or supplier should
be consulted in case of doubt.

4.5 Speeds of Spindles (R. 6)

The conversion formula between ft / min or m/s to r.p.m. is:

Speed in r.p.m. = (Peripheral speed in ft / min. x 12)/(3.1416 x dia. in in.)
or = (Peripheral speed in m/s x 1,000 x 60)/(3.1416 x dia. in mm).

A suitable pressure reducing regulator shall be fitted between the governor and the air
supply outlet if the working pressure of the outlet is greater than that of the grinding
machine. Where a filter is incorporated in the air supply system, it should be properly
maintained to prevent clogging by dust or grits. To prevent accidents caused by snaking
hoses when severed under high pressure of air, it is also recommended that an automatic
hose brake valve be fitted to the hose before joining the grinder.

81
4.6 Mounting (R. 7)

The following guidelines on mounting should also be observed:

 A wheel should not be mounted on a machine for which it is not intended and
certainly not on any make-shift apparatus or where there is vibration of the machine.
 The soundness of the wheel should be checked before it is mounted.
 Washers, either paper or other compressible material, should be used with all
bonded abrasive wheels, except tapered wheels, threaded-hole wheels, discs,
cylinder wheels, and the hub section of depressed-centre wheels.
 Washers should be slightly larger than the flanges and there should be no wrinkles
in them.
 The bush, if any, should not project beyond the sides of the wheel.
 The wheel should fit freely but not loosely on the spindle.
 Clamping nuts and screws should be tightened uniformly in pattern formation
(diametrical sequence) and only sufficiently to hold the wheel firmly.
 Screws for inserted nuts for the mounting of discs, cylinders or cones should be
long enough to engage a sufficient length of thread, but no so long as to contact the
abrasive material.
 When re-mounting factory-mounted wheels and points, the overhang (distance
between end of support and base of wheel) for a particular diameter of mandrel,
speed and size of a wheel should not be exceeded. Also there should be sufficient
length of the mandrel in the collet or chuck. The manufacturer should be consulted
for details of overhang permissible for a particular wheel.
 For depressed-centre wheels, when the adaptor has been tightened, there should be
a slight clearance between the flange and the wheel to ensure that the clamping
pressure is exerted only at the centre of the hub centre. The outer part of the face
of the flange adjacent to the wheel should be tapered to allow the full width of the
flange to support the wheel during the grinding operation.

82
Source (Issued by Labour Department): Safety in the Use of Abrasive Wheels (2008).

4.7 Provision of Guards (R. 8)

In a High Court Magistracy Appeal case Tom K. Engineering and Construction Co. Ltd. v.
The Queen (CACC000002/1978), an abrasive wheel was provided with a piece of fibre
board, 3/4'” thick, 6’ long by 3’ wide which, according to the witness, was used to protect
the eyes of the workman. The appellant was prosecuted under Regulation 8(1) of the F&IU
(Abrasive Wheels) Regulations for failure to provide a guard and Regulation 7(1) for
failing to mount properly an abrasive wheel. The Judge ruled that the guard required by
Regulation 9 of this piece of legislation is “more than something to protect the eyes. In
fact it is very difficult to protect the eyes other than with goggles when grinding and I have
no doubt that goggles ought to have been provided if they were not. The purpose of the
guard envisaged by these Regulations is to protect the workmen against the very thing
which happened in this case, namely, the shattering of the wheel - a thing which apparently
happens not infrequently. This guard was obviously something which was totally
inadequate for the purpose for which it should have been intended. It did not protect this
workman ... it must be apparent to everybody that the guard provided was not in compliance
with Regulation 9”. Since there was a guard, the Judge considered that the prosecution
failed to establish beyond reasonable doubt that there was no guard and hence quashed the
conviction.

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4.8 Construction, Maintenance, etc. of Guards (R. 9)

The guard should be of rigid construction, proper dimensions and securely anchored to the
machine frame. It also serves to prevent an oversized wheel from being fitted.

Source (Issued by Labour Department): Safety in the Use of Abrasive Wheels (2008).

4.9 Tapered Wheels and Protection Flanges (R. 10)

The following should also be considered:

 Flanges should not be less than one-third of the diameter of the wheels and their
bearing surfaces should be true and free from burrs.
 With the exception of the single flange used for threaded-hole wheels, all flanges
should be properly recessed or undercut.
 Flanges on both sides of the wheel should have the same outside diameter and
diameter of recess.

84
Source (Issued by Labour Department): Safety in the Use of Abrasive Wheels (2008).

4.10 Selection of Abrasive Wheels (R. 11)

In case of doubt, the manufacturer may be consulted on the proper type of wheels to suit a
particular job. Generally, soft wheels are more suitable for hard materials and hard wheels
for soft materials. Defective wheels should not be used. The soundness of wheels can be
checked by a ‘ring test’ (suspend the wheel vertically and tap the two opposing positions
on the same side of the wheel with a light non-metallic tool, such as a wooden screwdriver
handle. A clear ring indicates that the wheel is healthy. Wheels should be kept dry, not
exposed to extreme temperatures and be stored properly in suitable racks.

Source (Issued by Labour Department): Safety in the Use of Abrasive Wheels (2008).

85
4.11 Machine Controls (R. 12)

This concerns fitting an emergency stop switch to the wheel.

4.12 Rest (R. 13)

For bench and floor stand grinders, the clearance between the work-rest and the wheel
should not exceed 3.2 mm (1/8 in.). Lack of adjustment is the cause of many serious
accidents in that the workpiece is jammed between the wheel and the work-rest which
forces the operator’s fingers against the wheel face.

Source (Issued by Labour Department): Safety in the Use of Abrasive Wheels (2008).

4.13 Warning Notice (R. 14)

The approved warning notice accepted for posting up must be approved by the Labour
Department.

4.14 Condition of Floor (R. 15)

The floor should be even and clear of material to avoid slipping, tripping and falling on the
machine.

4.15 Responsibilities of Employees (R. 16)

Some operators take the guard down and grind at the side of the abrasive wheel. This
weakens the integrity and uniformity of the wheel and may result in the shattering of the
wheel. An unbalanced wheel should be properly trued and dressed, or disposed of if truing
and dressing cannot provide a useful remedy.

86
4.16 Safety and the Operator

The following should be followed:

 Do not grind on the sides of straight-sided wheels.
 Install protective screen or wear eye protectors.
 Do not apply sudden pressure to the wheel.
 Do not allow the wheel to revolve unattended.
 The wheel should be trued or dressed when necessary to remove loading or glazing
at the wheel surface, both of which reduce the cutting action. Eccentric force will
be created at wheels used for hand grinding rendering them out of balance if not
trued, and if the force becomes excessive, it may damage the spindle and cause the
wheel to burst.

4.17 Case Study

A 100cm-diameter wheel with maximum

permissible speed of 3,000 r.p.m. was mounted
on an abrasive wheel machine with a spindle
speed of 2,500 r.p.m. When used for some
time, the wheel exploded resulting in injury to
the operator. The diameter of the shattered
wheel was found to have been reduced to
80cm. Based on the formula on the increase in
speed due to reduction in the diameter of the
wheel, establish whether there is any
overspeeding of the wheel.

Source (Issued by Labour Department): Safety in the Use of Abrasive Wheels (2008).

87
4.18 Suggested Solution

Increased speed in r.p.m.

= original speed in r.p.m. x original diameter / reduced diameter
= 2,500 x 100 / 80
= 3.125 r.p.m.

Since the maximum permissible speed of the wheel is 3,000 r.p.m., there was overspeeding
that might have caused the wheel to shatter as a result of the increased centrifugal force.

4.19 Concept Checklist

This chapter is on the safety of abrasive wheels. Key points to note include:
 Introduction to abrasive wheels
 Interpretation of terms
 Application
 Speeds of abrasive wheels
 Speeds of spindles
 Mounting
 Provision of guards
 Construction, maintenance, etc. of guards
 Tapered wheels and protection flanges
 Selection of abrasive wheels
 Machine controls
 Rest
 Warning notice
 Condition of floor
 Responsibilities of employees
 Safety and the Operator

4.20 Further Thinking

 There has been a general consensus that an abrasive wheel is used for grinding
only, but in fact such a wheel can also be used for cutting, e.g. an abrasive cutter.
It is rather uncommon to find abrasive cutters that have notices stipulating the
maximum wheel speed, spindle speed and the name of the assigned mounting
person. Displaying the abrasive wheel poster in the vicinity is also uncommon.
 There has also been a general consensus that the F&IU (Abrasive Wheels)
Regulations is NOT applicable to a portable grinder or cutter (when the abrasive
disc is replaced by a stainless-steel disc used for cutting aluminium strips or angle-
iron, or cutting wood. However, the exception in Regulation 4(4) of this piece of
regulation is only applicable to a portable grinder that is manufactured of rubber.

88
 And as said above, the disc of a portable grinding machine with a stainless-steel
cutter is definitely not made of rubber and apart from rubber, there are a lot of
bonding materials including glass, resin, silicate, metal alloys, oxohalide etc. Do
you think the above-mentioned legal requirements on stipulating the speeds of the
wheel and spindle, name of mounting person and the display of the abrasive wheel
poster should apply to this type of portable machine?

Source from Michael Leung

89
 Appendix
A4.2 Interpretation of Terms (R. 2)

“Abrasive wheel” (砂輪) means:

(a) a wheel, cylinder, disc or cone which consists wholly or partly of abrasive particles
held together by mineral, metallic or organic bonds whether natural or artificial;
(b) a
(i) mounted wheel or point; or
(ii) wheel or disc, having separate segments of abrasive material;
(c) a wheel or dis
(i) made of metal, wood or rubber; and
(ii) having any surface consisting wholly or partly of abrasive material; and
(d) a wheel, disc or saw to any surface of which, in each case, is attached a rim or
segments consisting of diamond abrasive particles,
and which is, or is intended to be, power driven and which is for use in any grinding or
cutting operation;

“Employee” (僱員) means a person who in an industrial undertaking is employed in using

any abrasive wheel in any grinding or cutting operation;

“Mounted wheel or point” (嵌固輪子或端點) means a wheel or point consisting in either

case of abrasive particles held together by mineral, metallic or organic bonds whether
natural or artificial and securely and permanently mounted on the end of a mandrel or quill;

“Overhang” (外露軸段), in relation to a mounted wheel or point, means that part of the
mandrel or quill which is exposed between the collet in which the mandrel or quill is held
and the part of the abrasive material nearest to that collet.

A4.3 Application (R. 3)

The F&IU (AW) Regulations shall apply to any abrasive wheel used for any grinding or
cutting operation in any IU.

A4.4 Speeds of Abrasive Wheels (R. 5)

(a) No abrasive wheel having a diameter of more than 55 mm shall be taken into use
in any IU for the first time in that IU unless the abrasive wheel or its washer is
clearly marked, in English or Chinese, with the maximum permissible speed in
revolutions per minute (r.p.m.) specified by the manufacturer of that wheel.
(b) No abrasive wheel having a diameter of 55 mm or less shall be taken into use in
any IU for the first time in that IU unless there is kept permanently fixed in the
room in which grinding is ordinarily carried out with that wheel a notice, in

90
 English or Chinese, stating the maximum permissible speed in revolutions per
minute (r.p.m.) specified by the manufacturer for that wheel or for abrasive wheels
of the class to which that abrasive wheel belongs and, in the case of mounted
wheels and points, the overhang permissible at that speed:
Provided that when grinding with such an abrasive wheel is not ordinarily carried
out in any one room the notice shall be kept posted at a place and in a position
where it may easily be read by employees employed in grinding with that abrasive
wheel.
(c) No abrasive wheel shall be operated at a speed in excess of the maximum
permissible speed in r.p.m. specified for that wheel:
Provided that where the diameter of an abrasive wheel has been reduced its said
maximum permissible speed may be increased to that speed which bears the same
proportion to the said maximum permissible speed as the original diameter of the
abrasive wheel bears to its reduced diameter.

This Regulation shall not apply to any abrasive wheel:

(a) manufactured of metal, wood or rubber and having any surface consisting wholly
or partly of abrasive material;
(b) which does not exceed 235 mm in diameter, is manufactured of rubber and has
any surface consisting wholly or partly of abrasive material, when that abrasive
wheel is used n a portable machine; or
(c) having separate segments of abrasive material.

This Regulation shall not apply to any wheel, disc or saw to any surface of which, in each
case, is attached a rim or segments consisting of diameter abrasive particles.

A4.5 Speeds of Spindles (R. 6)

(a) There shall be securely affixed to every power driven machine having any spindle
on which an abrasive wheel is, or is intended to be, mounted a notice, in English
and Chinese, specifying:
i) in the case of each such spindle (other than a spindle to which sub-paragraph
(ii) or (iii) applies), its maximum working speed;
ii) in the case of any such spindle for which there are provided arrangements for
operating the spindle at more than one specific working speed, each specific
speed; and
iii) in the case of any such spindle for which there are provided arrangements for
operating the spindle at an infinite number of working speeds within a
specified range, the maximum and minimum working speeds of the spindle.
(b) No spindle shall, while an abrasive wheel is mounted on it, be operated at a speed
in excess of the maximum working speed specified for that spindle.
(c) The proprietor of an IU shall, when so required by an OSO, provide the OSO with
all such facilities and information as are necessary to enable him to determine the

91
 working speed of any spindle, shaft, pulley or other appliance which is used to
operate an abrasive wheel.
(d) The speed of every air driven spindle on which an abrasive wheel is mounted shall
be controlled by a governor or other device so that the speed of the spindle does
not at any time exceed the maximum working speed specified for that spindle.
(e) Every governor or other device used for controlling the speed of an air driven
spindle on which an abrasive wheel is mounted shall be properly maintained.

This Regulation shall not apply to any abrasive wheel:

(a) manufactured of metal, wood or rubber and having any surface consisting wholly
or partly of abrasive material;
(b) which does not exceed 235 mm in diameter, is manufactured of rubber and has
any surface consisting wholly or partly of abrasive material, when that abrasive
wheel is used in a portable machine; or
(c) when it is used for the grinding of glass.

This Regulation shall not apply to any wheel, disc or saw to any surface of which, in each
case, is attached a rim or segments consisting of diameter abrasive particles.

A4.6 Mounting (R. 7)

(a) Every abrasive wheel shall be properly mounted.

(b) An abrasive wheel shall not be mounted except by a person who:
i) has been appointed in writing for that purpose by the proprietor of an IU; and
ii) is, by reason of training and practical experience, competent to perform that
operation.

A4.7 Provision of Guards (R. 8)

A guard shall be provided and kept in position at every abrasive wheel in motion except
where, by reason of the work being done, or of the work which is ordinarily done (or, in
the case of a new wheel, is intended ordinarily to be done), or the nature of the wheel, the
use of a guard is impracticable.

This Regulation shall not apply to any abrasive wheel:

(a) which does not exceed 235 mm in diameter, is manufactured of rubber and has
any surface consisting wholly or partly of abrasive material, when that abrasive
wheel is used in a portable machine;
(b) when it is used for the grinding of glass.

92
A4.8 Construction, Maintenance, etc. of Guards (R. 9)

Every guard provided shall:

(a) so far as is reasonably practicable, be of such design and construction as to contain
every part of the abrasive wheel in the event of fracture of the abrasive wheel or
any part thereof occurring while the abrasive wheel is in motion;
(b) be properly maintained and so secured as to prevent its displacement in the event
of fracture; and
(c) enclose the whole of the abrasive wheel except such part as is necessarily exposed
for the purpose of work being done at that abrasive wheel or, where a guard which
is not adjustable is used, for the purpose of the work which is ordinarily done
thereat (or, in the case of a new abrasive wheel, is intended ordinarily to be done
thereat).

R. 9(a) and (b) shall not apply to any abrasive wheel:

(a) manufactured of metal, wood or rubber and having any surface consisting wholly
or partly of abrasive material;
(b) which consists wholly of abrasive particles held together by natural bonds.

The entire R. 9 does not apply to any abrasive wheel:

(a) which does not exceed 235 mm in diameter, is manufactured of rubber and has
any surface consisting wholly or partly of abrasive material, when that abrasive
wheel is used in a portable machine; or
(b) when it is used for the grinding of glass.

A4.9 Tapered Wheels and Protection Flanges (R. 10)

(a) Where the work which is ordinarily done (or, I the case of a new abrasive wheel,
is intended ordinarily to be done) at any abrasive wheel requires that the exposed
area of the wheel shall exceed 180o measured at the centre of the wheel then, where
practicable, the wheel shall be tapered from its centre towards its periphery by at
least 6% on each side and shall be mounted between suitable protection flanges.
(b) Protection flanges between which any abrasive wheel is mounted shall be of
substantial construction and properly maintained and shall have the same degree
of taper as the wheel and shall:
i) in the case of a wheel of 300 mm or less in diameter, be of a diameter equal
to at least half the diameter of the wheel;
ii) in the case of a wheel of more than 300 mm but not exceeding 750 mm in
diameter, be of a diameter equal to at least the diameter of the wheel less 150
mm; and
iii) in the case of a wheel of more than 750 mm in diameter, be of a diameter
equal to at least the diameter of the wheel less 200 mm.

93
This Regulation shall not apply to any abrasive wheel:
(a) manufactured of metal, wood or rubber and having any surface consisting wholly
or partly of abrasive material;
(b) which consists wholly of abrasive particles held together by natural bonds;
(c) which does not exceed 235 mm in diameter, is manufactured of rubber and has
any surface consisting wholly or partly of abrasive material, when that abrasive
wheel is used in a portable machine; or
(d) having separate segments of abrasive material;
(e) when it is used for the grinding of glass.

This Regulation shall not apply to any wheel, disc or saw to any surface of which, in each
case, is attached a rim or segments consisting of diameter abrasive particles.

A4.10 Selection of Abrasive Wheels (R. 11)

All practicable steps shall be taken to ensure that any abrasive wheel used is suitable for
the work for which it is used to the extent necessary to reduce the risk of injury to
employees.

A4.11 Machine Controls (R. 12)

No abrasive wheel shall be used in a machine unless the machine is provided with an
efficient device for starting and cutting off the power to the machine and the control of the
device shall be in such a position and of such design and construction as to the readily and
conveniently operated by the person operating the machine.

A4.12 Rest (R. 13)

(a) Where at an abrasive wheel there is a rest for supporting a workpiece, that rest
shall at all times while the wheel is in motion be properly secured and adjusted so
as to be as close as practicable to the exposed part of the abrasive wheel.
(b) Every rest shall be of substantial construction and properly maintained.

A4.13 Warning Notice (R. 14)

A warning notice, in English and Chinese and in a form approved by the Commissioner,
concerning the dangers arising from the use of abrasive wheels and the precautions to be
observed shall be affixed in every room in which grinding and cutting by means of abrasive
wheels is ordinarily carried out, or, where such grinding or cutting is not ordinarily carried
out in a room, at a place and in such a position where it may be easily read by employees.

A4.14 Condition of Floors (R. 15)

(a) The floor immediately surrounding every fixed machine on which an abrasive
wheel is, or is intended to be mounted shall be maintained in good and even

94
 condition and shall, so far as practicable, be kept clear of loose material and
prevented from becoming slippery.
(b) All reasonably practicable steps shall be taken to ensure that the floor of any room
or place in which any portable machine on which an abrasive wheel is mounted is
in good and even condition, is kept clear of loose material and is prevented from
becoming slippery.

A4.15 Responsibilities of Employees (R. 16)

(a) No employee shall willfully misuse or remove any guard, or willfully misuse any
protection flange, machine control, governor or other device provided in pursuance
of the F&IU (AW) Regulations or any rest for a workpiece.
(b) Every employee shall make full and proper use of guards, protection flanges,
machine controls, governors and other devices provided in pursuance of the F&IU
(AW) Regulations and of rests for work-pieces and if he discovers any defect in
the same shall forthwith report such defect to the proprietor.

References

Factories and Industrial Undertakings (Abrasive Wheels) Regulations 1976, Hong Kong,
Available at http://www.elegislation.gov.hk/hk/cap59L (Accessed 31 December
2019).
Health and Safety Executive (2011) “Safety in the Use of Abrasive Wheels”, 3rd edition,
HSE Books.
Labour Department (2005) “A Guide to the Factories and Industrial Undertakings
(Abrasive Wheels) Regulations”, Government Printer, Hong Kong.
Labour Department (2008) “Safety in the Use of Abrasive Wheels”, Government Printer,
Hong Kong.

95
 Chapter 5
Guarding and Operation of Machinery

5.1 Factories and Industrial Undertakings (Guarding and

Operation of Machinery) Regulations (Cap. 59Q)

The F&IU (Guarding and Operation of Machinery) Regulations state that proprietors of
notifiable workplaces must effectively guard dangerous parts of every piece of machinery
and plant which is driven by mechanical power. Effective guarding would be much cheaper
if incorporated at the design stage of a machine while modification after a machine has
been introduced may be technically difficult or even impracticable. Under the F&IU (GOM)
Regulations, dangerous parts of machinery are classified into 17 types.

The management of an organization should state clearly the specifications of guarding

standards when they place orders for new machinery with their machine makers or
suppliers. Statistics on machinery accidents indicate that not many of the machinery
accidents involve prime movers or transmission machinery. Moreover, access to prime
movers or transmission machinery is unnecessary and adjustments are rarely needed when
the machine is in operation.

On the other hand, access to points of operation of a machine is frequent and often
inevitable. Particular attention should therefore be paid to the design, construction,
installation and maintenance of guards provided for points of operation.

Injuries resulting from machinery accidents are often serious and lead to amputation of
fingers, hands or arms resulting in permanent disability for the injured. Nevertheless, the
absence of injury from operating an unguarded or inadequately guarded machine for a
length of time is by no means proof that its moving parts are not dangerous. A mere
reliance on the operative’s training, skill or constant attention as a substitute for effective
guarding is dangerous because human nature is unpredictable and not constant. Even the
most reliable and careful operative can make mistakes, especially with familiar work.
Moreover, it is essential to provide safeguards not only for the careful but also for the
careless. Proper guarding can ensure safe operation at all times and gives confidence to
operatives. Guards which are properly designed, installed and maintained can help to
increase the production capacity of the machine.

5.2 Safety by Position

The basic principles of Safety by Position are:

 Access to dangerous parts are prevented by physical barriers, e.g. other machines,
structural items or by its height.

96
  Such arrangement should only be treated as temporary because of the following
reasons:
 A physical barrier or height could be overcome during cleaning/maintenance.
 An irrational approach to dangerous parts by workers.
 Barrier or height may no longer prevent access if the layout of the workplace
is altered.

5.3 Principles of Machine Guarding

The basic principles of Machine Guarding are:

 Machine design should enclose all dangerous parts.
 Render dangerous parts inaccessible to people by:
 installing the right guard;
 ensuring the guard is in position and not defective;
 ensuring that no secondary hazard is being posed by the guard; and
 “Simplicity is beauty” - first priority is given to a fixed guard.
 Train the operator to work with safe operating procedures.
 Supervisor should ensure the proper use of the guard.

5.4 Ergonomic Consideration

Design of the guard should take into consideration the relevant physical characteristics of
members of the workforce that the guards are intended to protect. These characteristics
include the following:
 Body height
 Reach
 Hand and finger size
 Speed of movement

5.5 Fixed Guard

5.5.1 Design and Construction

A fixed guard by its design and construction prevents access to the dangerous part for which
it is provided. Such a guard has no moving parts associated with or dependent upon the
machine to which it is fitted. It is a reliable guard and requires little maintenance.

97
A fixed guard:
 shall be of robust construction, e.g. solid metal guards are preferable. If in need, a
robust transparent material is also acceptable;
 shall be securely anchored to the machine;
 shall be fitted as close as possible to the moving part of the machine;
 shall fully enclose the dangerous part;
 shall provide access for routine machine lubrication so that the guard need not be
removed;
 shall only be removed by special tools which are only available to authorized
persons; and
 so designed that any opening in the guard is constructed to prevent access by
limiting the size of the opening and maximizing the distance between the guard
opening and the dangerous part.
Under ordinary circumstances the fixed guard principle is a simple matter understood
equally by the worker and by the employer, a virtue not enjoyed by any other type of
safeguard. The underlying idea behind this principle is that matters shall be so arranged
that hand manipulation between any trapping parts is eliminated.

5.5.2 Distance of Fixed Guard Opening from Dangerous Part

The application of a fixed guard, however, is limited to guarding prime movers,

transmission machinery and points of operation where the feeding of material and
withdrawing of components are achieved mechanically or by means of specially designed
aids. However, if manual feeding and withdrawal are necessary, the opening in the fixed
guard must be limited in size relative to the distance between such an opening and the
dangerous part of the machinery. Where an opening in a fixed guard is required to be of
such a size as to allow the entry of fingers or hands, then such an opening must be situated
sufficiently far away from any trapping point as to prevent finger tips reaching it, or
alternatively, indirect methods of entry must be used.

A Table showing the distance of the guard from any dangerous parts against the size of
opening measured at the widest point is prescribed in Schedule 3 of the F&IU (GOM)
Regulations as follows:

98
 Size of opening measured at the widest point Distance of guard from any
dangerous part
(mm) (mm)
More than But not more than Not less than
6 40
6 10 40
10 12 65
12 15 90
15 20 140
20 22 165
22 30 190
30 40 320
40 50 400
50 55 450
55 150 800
150 800

This table is a direct copy of Figure 5 of BS 5304: 1975 which has now been withdrawn.

Picture (Issued by British Standards Institution) BS PD 5304:2019 Guidance on Safe Use of Machinery;
(Issued by American National Standards Institution) ANSI 11.0-2015 Safety of Machinery.

The table shows the distance of the guard from any dangerous part vs the size of opening
(presented in a range). A variant of this table is presented in Table O-10 to the U.S. Federal
Law Title 29 (Labor) CFR Part 1910 (OSH Standards) Subpart O (Machinery and Machine
Guarding), Section 1910.217 (Mechanical Power Presses) which shows, on the contrary,
the maximum width of the opening vs the distance of the opening from the point of
operation hazard (presented in a range).

In the older version of this Table, for a distance of opening from point of operation hazard
exceeding 31½ in., the maximum width of the opening was set at 6 in. When plotted on a
x-y plane, a step function results. This appears to be based on the cross-sectional profile
of a human hand.

99
Sources (Issued by Health & Safety Executive, U.K.) Procedures for Daily Inspection & Testing of
Mechanical Power Presses & Press Brakes (2003); & from
https://www.ehstoday.com/safety/article/21915342.

100
The same consideration applies to the same set of figures in other jurisdictions, such as
B.C. Canada:

Source (Issued by Worksafe BC) Safeguarding Machinery & Equipment (2017).

There are yet considerations other than purely the size of the guard opening vs the distance
of the guard from the danger zone, such as the reach of the upper limbs vs reach of the
lower limbs as well as other parts of the body.

There are other corresponding tables in the Australian and New Zealand Standard, etc.
which show a similar step function. A useful tool to gauge whether the size of the opening
matches that required under the law is to use a guard opening scale:

101
Source from www.osha.gov

The revised U.K. standard PD 5304:2014 as well as the European Standard all consider not
only the size of openings, but also the shape of the openings (slot, square or circle):

Source (Issued by IRSST) Machine Safety - Prevention of Mechanical Hazards: Fixed Guards & Safety
Distances, IRSST Guide RG-59 (2009)

Hence, the relationship between the size of guard opening vs distance of the guard from
the danger zone could be complicated by the shape of the guard opening.

102
Source (Issued by IRSST) Machine Safety - Prevention of Mechanical Hazards: Fixed Guards & Safety
Distances, IRSST Guide RG-597 (2009).

Apart from the size and shape of guard openings, ergonomic design should also take into
consideration how the danger zone can be reached. While under Regulation 4 of the F&IU
(GOM) Regulations, a dangerous part which by reason of its position, its construction, or
the nature of the work being performed does not give rise to any reasonably foreseeable
hazard to the safety of any person present at a notifiable workplace need not be guarded,
i.e. “safety by position” is a legitimate defence. The onus of proof that by way of such
position there is no reasonably foreseeable hazard rests with the proprietor. Some
quantitative metrics are still needed to determine the extent of reaching upward, reaching
over, reaching round or reaching through.

103
Examples of such reaches are illustrated in Annex A (normative) Ergonomic data of PD
5304:2005:

 Reaching Upwards

Source (Issued by British Standards Institution) BS PD 5304:2019 Guidance on Safe Use of Machinery

 Reaching Over Protective Structures

Source (Issued by British Standards Institution) BS PD 5304:2019 Guidance on Safe Use of Machinery

104
  Reaching Round

Source (Issued by British Standards Institution) BS PD 5304:2019 Guidance on Safe Use of Machinery

 Reaching through regular openings:

105
Source (Issued by British Standards Institution) BS PD 5304:2019 Guidance on Safe Use of Machinery

Sometimes, a static or movable feeding mechanism can be built on the fixed guard so that
the hand or finger need not enter the danger zone. This includes:
 Chute feed

Sources from www.iloencyclopaedia.org and www.osha.gov

106
  Plunger feed
 Plunger and magazine feed
 Dial feed

Sources from www.osha.gov

 Sliding bolster
 Sliding die

 Hinged Feeding Gate

Source (Issued by Department of Employment, U.K.) health and Safety at Work No. 14: Safety in the Use of
Mechanical Power Press (1974)

107
It must be remembered that the use of a feeding mechanism and/or tools are not considered
as guarding methods, and they are always used complimentary to the guards, not replacing
them.

5.6 Trip Guard

5.6.1 Introduction to Trip Guard

A mechanical trip guard consists essentially of a pivoted grid or frame connected to a

mechanism which can stop the machine by throwing out the clutch or belt-striking gear and
applying a brake. The frame is mounted in front of the point of operation of the machine
so that if any part of the hand or arm is in the danger zone as the point of operation begins
its motion, the frame will be struck and will stop the machine. A trip guard is also called
a presence sensing device. As its name implies, a presence sensing device detects the
presence of an individual, which could be the pressure either from the hand or other parts
of the body including the entire body, and trips the mechanical movement of the press
before trapping occurs. A primitive design is in the form of a distance bar, trip bar or trip
wire, while more recent novel designs include a pressure sensing mat, photoelectric device
or radiofrequency / field sensing device etc.:

They ensure that an approach to a dangerous region beyond a safe limit stops a machine.
Pre-conditions include:
 Good maintenance.
 Efficient braking system.
 Adequate safe-distance of trip barriers to prevent access to the danger zone.

5.6.2 Distance Bar Trip Guard

A distance bar trip guard incorporating a distance bar, with a screen to prevent access from
below, which ensures that the operator must be placed at a safe distance from the danger
area before the clutch can be engaged, and which will if pushed towards the machine,
disengage the clutch and apply the brake.

108
Source (Issued by Department of Employment & Productivity, U.K.) 7th Report of the Joint STANDING
Committee on Safety in the Use of Power Press: Safety in the Use of Press Brakes (1969)

5.6.3 Sensing Field

The second type of trip guard is a presence-sensing safety device which is designed to
automatically stop the machine if the sensing field is interrupted. Examples of presence-
sensing devices include the safety light curtain, safety field, safety mat etc. The device
shall be interfaced with the control circuit to prevent or stop the machine motion if there
are objects within the sensing field of the hazardous portion of the machine. The device
should be located or adjusted such that it always responds to any intrusion at or before the
safety distance. Since it would be very difficult to immediately stop the motion of a full-
revolution clutch machine, this type of device should not be used on this type of machine.

 Light Curtain: The photoelectric (optical) presence-sensing device uses a system of

light sources and controls that can interrupt the machine’s operating cycle. If the
light field is broken, the machine stops and will not cycle. This device must be
used only on machines that can be stopped before the worker can reach the danger
area. The device requires frequent maintenance, cleaning and alignment.

Sources from www.worksafe.govt.nz.

109
Sources from www.oshatrain.org and www.iloencyclopaedia.org.

 Radiofrequency Presence-Sensing Device: The radiofrequency (capacitance)

presence-sensing device uses a radio beam that is part of the machine control circuit.
When the capacitance field is broken, the machine will stop or will not actuate.
Like the photoelectric device, this device must only be used on machines that can
be stopped before the worker can reach the danger area. This requires the machine
to have a friction clutch or other reliable means for stopping.

Sources from www.oshatrain.org.

5.6.4 Distance of Trip Guard Opening from Dangerous Part

Apart from using the human hand profile as a model in static fixed guard, the safety
distance for a trip guard may also be calculated. There are two groups of standards that
have proliferated in such a calculation. The first one is the ISO and European ones ISO
EN (ISO 13855 and EN 999) while the second is the US and Canadian ones (ANSI B11.19,
ANSI RIA R15.06 and CAN/CSA Z434-03) using different but similar formulae:
ISO EN: S= Kx T+C
US CAN: Ds = K x (Ts + Tc + Tr + Tbm) + Dpf

Where
 Ds or S is the minimum safe distance from the danger zone to the closest detection
point;
 K is a speed constant which is dependent on movements of the operator (i.e. hand
speeds, walking speeds, and stride lengths), and the hand speed of an operator with

110
 a stationary body is normally taken as 1600 mm / sec or 63 in / sec. which may vary
up to 2500 mm / sec (i.e. 100 in / sec);
 T is the overall stopping time of the system starting from the initiation of the stop
signal to the cessation of the hazard, which can be broken down to its incremental
parts Ts, Tc, Tr and Tbm where Ts is the worst stopping time of the machine /
equipment, Tc is the worst stopping time of the control system\, Tr is the response
time of the safeguarding device, including its interface, and Tbm is the additional
stopping time allowed by the brake monitor before it detects stop-time deterioration
beyond the end users’ predetermined limits;
 C or Dpf are the Depth penetration factors which are the maximum travel towards
the hazard before detection by the safeguarding device, and they will change
depending on the type of device and application. For a normal approach to a light
curtain or area scanner, whose object sensitivity is less than 64 mm (2.5 in), the
ANSI and Canadian standards use:
Dpf = 3.4 x (Object Sensitivity - 6.875 mm), but not less than 0. For a normal
approach to a light curtain or area scanner, whose object sensitivity is less than 40
mm (1.57 in), the ISO and EN standards use C = 8 x (Object Sensitivity - 14 mm),
but not less than 0. As shown in the chart below, for object sensitivity less than
19.3 mm, the US CAN approach is more restrictive, as the light curtain or area
scanner must be set back further from the hazard. For object sensitivities greater
than 19.3 mm, the ISO EN standard is more restrictive. Machine builders, who
want to build machines for use throughout the world, must take the worst case
conditions from both equations.

111
112
Source (Issued by American National Standards Institution) ANSI B11.19-2010 Performance Criteria for
Safeguarding.

5.7 Automatic Guard

5.7.1 Introduction to Automatic Guard

An automatic guard is designed to automatically prevent an operator or his hands from

coming into contact with the dangerous part of a machine when that part is in motion. The
movable part of the guard should be positively actuated by the movement of the dangerous
part of the machinery. It may take the form of a sweeping motion from side to side in front
of the point of operation, or of an outward and upward push-away motion from the side of
the machine, or of a pullout action which removes an operator's hands from the point of
danger. An automatic guard is suitable for use on a machine whose cycles of operation are
interspaced by manual feeding of materials, e.g. power presses and drop hammers. It relies
on a mechanical linkage which derives its motion from the movement of the point of
operation. The movement, so transmitted, is multiplied so that the guard moves at a rate
faster than the point of operation. The mechanisms of automatic guards must be carefully
adjusted in relation to the movement and physical characteristics of the dangerous parts,
and frequently examined to ensure that the safeguard is properly maintained and used. In
certain fast acting machines, it is not advisable to adopt this type of guard because of the
high speed with which the guard is inevitably involved, thus becoming a potential danger
in itself.

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5.7.2 Principle of Operation of Automatic Guard Installed on a
Power Press

A sweep-away guard operates by physically sweeping a barrier across the danger area, thus
pushing any exposed part of a person out of the way. Depending on the type of machine,
it may deflect hands, or the whole body.

Using the guarding of a power press as an example, in America, as a safeguard it is

classified as ‘sub-standard’ so that OSHA 29 CFR 1910.217(c)(3)(v) specifically directs
that “the sweep device may not be used for point of operation safeguarding”.

There are different ways an automatic guard for a power press operates, including ‘push-
away’ (via a ‘rising screen’ or ‘push-out safety bar’), ‘pull-out’ or ‘pull-back’, and ‘sweep-
away’. No matter how it operates, an automatic guard should be:
 so designed and adjusted as to ensure that the operator’s hands will be withdrawn
from the space between the trapping surfaces before trapping can occur, should the
ram come into operation from any cause;
 actuated in a positive way, no linkage depending on frictional grip being used in the
design;
 used in conjunction with adequate fixed guards to prevent access through any area
not protected by the moving part of the automatic guard;
 tested after each re-setting and at frequent intervals thereafter. A second opinion
on the setting is often worthwhile, especially where operators set their own
machines.

5.7.3 Contribution of Automatic Guard in Guarding Power

Presses

Despite the above limitations, there remains a field of usefulness for this guard which has
one great virtue; it functions every time that the press makes a stroke irrespective of
causation. The automatic guard can be combined with an interlocking guard to give extra
protection against repeated or unconvenanted stroke. By a combination of interlocking and
automatic actions, the operator is prevented from making an ordinary stroke of the press
until the guard is in the closed position, and is safeguarded against the risk of trapping
during a repeat or uncovenanted stroke by the automatic action.

5.7.4 Limitation of Automatic Guard used on a Power Press

While this form of safeguarding power presses is substandard in both the U.K. and in
America, it is considered one of the acceptable forms of safeguards in Hong Kong. The
answer lies not in the basic difference between the way the automatic guards operate, i.e.
‘push-away’, ‘pull-out’ (‘pull-back’) or ‘sweep-away’, but in the anthropometric analysis
of the daylight (clearance between the tool and die) and the distance of the body part from
the danger zone. Ergonomics here comes in play.

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This guard is actuated by the movement of the press and its motion is irrevocably bound
up with the movement of the parts from which it has to safeguard the operator.
Fundamentally this guard suffers from a severe handicap in that its action does not
commence until the dangerous parts have begun to move. Thereafter the guard must make
contact with the operator, accelerate the hand and arm from a state of rest and withdraw it
from danger. During this time the punch of the press is moving with increasing velocity
towards the middle position of its stroke. There is a race in progress, a race in which too
often the guard, and consequently the operative, can be the loser. These effects are most
serious in short stroke presses for here, there is a combination of small clearance (or
daylight between the tools) and high speed of guard operation. The first feature means that
there is only a small movement of the press tool before the trapping of the fingers occurs
and the second feature is undesirable as it tends to put high stress on the working parts in
addition to tending to inflict injury upon the operative through violent action.

An automatic guard should only be used on a press with a speed not exceeding that
specified in the following table:
Length of Stroke The speed should not be
more than the equivalent of:
Single-acting presses More than 200 mm 30 strokes / minute
Between 150 and 200 mm 25 strokes / minute
Double or multiple More than 150 mm 15 strokes per minute
acting presses

5.7.5 The Rising Screen or Push-Away Guard (HSE)

The moving screen and fixed side guards should prevent access to the trapping area
between the tools before the space between the nearest trapping surfaces is less than 50
mm (including the component at any stage of its entry or withdrawal). A safe distance is
considered to be within the range of relative distances shown in the diagram (The distances
are measured from the top of the outward and upward moving member of the guard). Also,
the access to the trapping area(s) from beneath the outward/upward moving member of the
guard is prevented at all parts of the press stroke by a suitable screen. There should be no
trapping point created between the guard itself and any moving part of the machine or
adjacent equipment.

The Rising Screen or Push-Away guard incorporates an outward and upward moving
member, the top of which must not be less than 42 in. (1,066 mm) above the standing level
of the operator. This should be carefully maintained, otherwise the operator may
overbalance and fall into the press. This outward and upward moving member extends for
the full width of the press bed and is positively driven from the press ram (or other part of
the press motion) in such a way that it pushes the operator’s body away from the tools
before the space between trapping surfaces is small enough the trap the hand or arm. A
suitable screen prevents access to the tools below this member.

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This type of guard was originally intended for use on heavy presses (with over 15-in. (381
mm) stroke) but was subsequently adapted, with modified performance specification, for
sub-heavy (under 15-in. (381 mm) stroke) presses also. There is now no longer any
distinction between heavy and sub-heavy presses; the guard may be used on any
mechanical press other than a variable-stroke one, provided compliance with the following
specifications for press speed, stroke and guard construction and performance is possible
and is achieved, whatever the type of clutch fitted. These specifications are as follows:
 Press Speed: For single-acting presses, the speed should not be more than 30 strokes
per minute, i.e., each single stroke is to take 2 seconds or more. On double-acting
and multiple-acting presses, the speed should not be more than the equivalent of 15
strokes per minute, i.e., each single stroke is to take 4 seconds or more.
 Length of Press Stroke: The length of the press stroke should not be adjustable. On
single-acting presses the stroke should not be less than 8 in. (203 mm), on double-
acting and multiple-acting presses the stroke should not be less than 6 in. (152 mm).
(In the case of double-acting and multiple-acting presses, ‘stroke’ means the stroke
of the slide or ram which has the least movement).
 The guard should be of a type incorporating an outward and upward moving
member, the top of which is never less than 42 in. (1,066 mm) above the floor or
platform on which the operator stands. Access to the trapping area below this
member should be effectively prevented at all parts of the press stroke by a suitable
screen. This member is positively driven from the press slide or associated
mechanism, the drive being designed so that the member attains a safe position
before the space between trapping surfaces (including the component at any stage
of its entry or withdrawal) is less than 2 in. (50 mm). A safe position is deemed to
be within the following range of relative distances:
Distance in inches (mm) horizontally 36 33 28 24 18
from nearest trapping position (914) (838) (711) (609) (457)
Distance in inches (mm) vertically 48 54 58 60 63
above standing place of worker (1,219) (1,371) (1,473) (1,524) (1,600)

Source (Issued by Health & Safety Executive, U.K.): Procedures for Daily Inspection & Testing of
Mechanical Power Presses & Press Brakes (2003).

The construction of the guard should be such that it is not possible for any person to
be trapped between the tools, or between the moving guard and any fixed or moving
part of the press, whether associated with the tools or not. The design should be such

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 as to give the correct movement of the guard relative to the movement of the press
slide, whether the press crankshaft rotates in the normal direction or in reverse.

A push-away guard without a rising feature has been devised for the short strokes and
special conditions applicable to mechanical press brakes.

Where there is an automatic guard fitted to each side of the press, and the press can be
started from either side, provisions should be made to lock out the start button on the side
of the press not in use.

An automatic guard shall not be used on the following classes of press:

 Variable stroke presses.
 Presses with less than 5 in. stroke. In the case of drawing and multiple acting
presses the expression “stroke” means the stroke of that member which has the least
movement.
 Presses in which the crankshaft speed is greater than the equivalent of 50 r.p.m. or
25 r.p.m. in the case of multiple acting presses.
 Presses on which the conditions are such that the distance between any parts where
trapping can occur is less than one-half of the stroke. Account shall be taken in the
determination of this distance, of the minimum distance between trapping parts
when inserting or removing the component.

The use of automatic guards on presses not subject to the above prohibitions shall be
determined by reference to the following specification:
 For presses of 6 in. stroke and less an automatic guard shall be a pull-out guard of
the type which, when the guard operates, the hand or arm is gripped between an
outer frame and inner moving gate and removed from the trapping area.
 For presses of more than 6 in. stroke the automatic guard shall be either:
 A pull-out guard as specified above, or
 A push-out guard of a type allowing access only to the trapping area of the
punches and dies through a rectangular hole not deeper than 6 in. and of a width
not greater than is necessary for the feeding of the component to the die. The
frame shall be connected positively to the ram or slide movement so that it has
an outward movement as near as possible horizontally from the press table
towards the operative and shall remove the hand or arm from the trapping area
by a push-out action. The frame of the guard shall be positioned on each press
so that it is at least 12 in. from the nearest trapping point towards the operative.
The guard shall be designed so that there is no access to the trapping area of
the punch and die except through the framework of the guard. Side screens
shall be fitted to prevent access behind the moving part of the guard when the
guard is in its outward position. This type of guard shall not be used on a press
having a crankshaft speed greater than the equivalent of 30 r.p.m. or, in the case
of a multiple acting press, greater than 15 r.p.m.

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  Heavy Presses: A push-away guard shall be fitted. Such guards are suitable for
presses with a stroke of not less than 15 in. and which have a crankshaft speed
equivalent to not more than 30 r.p.m. or in the case of a multiple-acting press not
more than 15 r.p.m.
 Sub-heavy Presses: Presses with a stroke of less than 15 in. should be fitted with a
guard which should be of a type incorporating an outward and upward moving
member and should be designed so that the member attains a safe position before
the space between the punch and die is less than 2 in. or one-fifth of the stroke
whichever is the greater. A safe position is deemed to be within the following range
of relative distances:
Distance in inches horizontal from nearest trapping position 36 33 28 24 18
Distance in inches vertically above standing place of worker 48 54 58 60 63
The movement of the guard should be such that it is not possible for any person to
be trapped between the moving guard and any fixed or moving part of the press,
whether associated with the tools or not. This type of guard should not be fitted to
presses which have a crankshaft speed greater than the equivalent of 30 r.p.m. or in
the case of a multiple-acting press greater than 15 r.p.m.

5.7.6 Automatic Guard Conforming to AS 1219

Under the Australian Standard AS 1219, an automatic guard refers to either the rising
screen or push-out safety bar. The rising screen type guard should be used wherever
practicable and in preference to the push-out safety bar. The push-out safety bar should
only be used when access under the guard is required for ancillary equipment such as
conveyors and loading devices. Care should be taken that during the movement of the
guard no trapping point is created between the guard and any ancillary equipment or
material used in conjunction with the press operation.

This type of guard may be used on slow-moving presses where the operator requires
unrestricted access to the trapping space between strokes of the press. A guard of this type
shall only be used when it forms part of a total system of protection which is designed to
ensure the safety of the press operator and which incorporates the following features:
 Dual air valves for clutch operation.
 Dual buttons, requiring two-handed operation for all operators. The term ‘operator’
is any person who is required to insert or remove material from the trapping space.
 In-built anti-repeat circuits in controls.
 In-built safeguards against relay failure, i.e. 2 or more relays have to fail
simultaneously for a repeat stroke to occur.
 Adequate counter-balancing of the ram and top die.
 Use of interlocked safety blocks.

An automatic guard shall not be used on the following class of press:

 Variable stroke press.

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  Press with less than 200-mm stroke; in the case of a drawing and multiple acting
press the ‘stroke’ means the stroke of that member which has the shortest movement.
It is considered that the press operating rate should not exceed 30 strokes per minute
and the maximum average velocity of the guard during its outward stroke should
not exceed 0.8 m/s. This operating speed must be designed to provide smooth
action to prevent bounce and associated strain on the guard members.

The design of the guard shall comply with the following requirements:
 The guard shall consist of a movable gate, frame or member allowing access to the
trapping space over, through or past it in its retracted position. It shall be connected
to the ram, crankshaft or other driving mechanism in such a manner that on
commencing a stroke it removes any part of a person from the trapping area before
trapping can occur. The guard should preferably be connected to a non-adjustable
part of the drive.
 The guard shall be rigid and of adequate strength.
 The guard shall be attached to the press and so constructed that it cannot be adjusted
or detached without the aid of tools.
 The guard shall not, by its motion, create any hazard.
 The operating mechanism and the locking devices attached to the movable gate,
frame or member, shall be so designed that its performance is unaffected by
reasonable wear or strain. The driving mechanism shall be positive and not
dependent on friction grip.
 The operating mechanism shall be designed such that the guard operates effectively
whether the press is operated in the forward or reverse direction.
 In conjunction with the rising screen or push-out safety bar, side screens should be
attached to the press to prevent access around the rising screen or push-out bar and
to guard against the action of the rising screen or push-out bar. Side screens should
be fixed but if hinged shall be interlocked with the operating controls. Access to
the dangerous parts not protected by the rising screen or push-out bar shall be
prevented by fixed or interlocked guards. Side screens shall be so designed as not
to provide a trapping point between the side screen and the moving part of the guard.

5.7.7 Rising Screen Guard

In addition to the general design requirements mentioned above, the following shall apply:
 A suitable screen guard attached to a moving member shall prevent access to the
trapping space below such member during all parts of the press stroke.
 The screen guard may be constructed of any suitable material such as metal rod,
wire mesh or shatter-resistant material.
 The rising screen guard shall be positively driven from the press slide or associated
mechanism, the drive being designed so that the member attains a safe position
before the space between trapping surfaces (including the component at any stage

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 of its entry or withdrawal) is less than 50 mm or one-fifth of the stroke, whichever
is the greater. A safe position is deemed to be within the following range of relative
distances:
Distance in mm horizontally from 900 850 700 600 450
nearest trapping position
Distance in inches (mm) vertically 1,200 1,350 1,450 1,500 1,600
above the standing place of the worker

The construction of the guard should be such that it is not possible for any person
to be trapped between the tools, or between the moving guard and any fixed or
moving part of the press, whether associated with the tools or not.

Note: A trapping point need not always be the mating faces of a die. Special care
is required to observe if guide pins, air clamps or panel unloaders present nearer
trapping points.

5.7.8 Push-out Safety Bar

In addition to the general design requirements mentioned above, the following shall apply:
 The safety bar shall be approximately 65 mm in diameter. It shall be actuated by a
mechanism connected to the crankshaft or other part of the press drive. The
mechanism shall be so designed as to give a smooth action to the bar without undue
strain being applied. There should be no dwell period before the bar begins its
outward movement.
 The top of the moving member shall never be less than 1,060 mm and should
preferably be not greater than 1,200 mm above the floor or platform on which the
operator stands.
 The horizontal distance of the top member when in the extended position shall be
set to a minimum of 900 mm before trapping can occur. The stroke of the guard
shall be sufficient to ensure that the 900-mm dimension can be achieved over the
full range of dies in that particular press.
 The push-out safety bar shall be so designed that the return by gravity to its position
of rest is achieved without creating a hazard.
 Secondary supports should be fitted to push-out bars and means shall be provided
to lock all fastening screws.

5.7.9 Pull-Back Device

 Operation of Pull-Back Device:

Pullback devices utilize a series of cables attached to the operator’s hands, wrist
and/or arms. This type of device is primarily used on machines with stroking action.
When the slide/ram is up, the operator is allowed access to the point of operation,
so he/she can feed material by hand into the point of operation.

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When the slide/ram begins to descend, a mechanical linkage automatically ensures
withdrawal of the hands from the point of operation. The advantage of this type of
device is that it eliminates the need for auxiliary barriers or other interference at the
danger area. However, this type of device must be carefully adjusted to fit each
operator. Other limitations of a pull-back device include limiting movement of the
operator, and may obstruct the workspace around the operator. Adjustments must
be made for specific operations and for each individual. It requires frequent
inspection and regular maintenance, and also close supervision of the operator’s use
of the equipment.

According to The Safety Code # 10 Power Presses and Foot and Hand Presses
issued by the State of Arkansas Department of Labor Paragraph 5.6 “Pull-out
guards shall be so constructed as to be attached to the operator’s hands or arms and
connected to the ram, plunger, or outer slide of the press in such a way that the
operator’s hands or fingers will be withdrawn from the danger zone as the ram,
plunger, or outer slide descends. Where the open distance between the top of the
work and the lower extremity of the punch is less than 2 inches the multiplying
action of this guard shall be such that the hands will be withdrawn a safe distance
from the nip point during the first quarter of the stroke”.

The horizontally hinged gate of the pull-out device is crankshaft driven and moves
within a frame. Hence, it broadly resembles an interlocked guard, but its method
of work is quite different; the gate moves towards the frame as the press makes a
stroke, gripping a hand or arm which may be within the trapping area, between the
gate and frame and pulling it clear. According to the HSE’s “Safety in the Use of
Mechanical Power Presses (HSW 14)” (p. 44), the pull-out principle is not
recommended for new guards. The logic behind this may be explained in the
“Report of the Committee on Safety in the Use of Power Presses” (1945) paragraph
9 (p. 5) issued by the Ministry of Labour and National Services, Great Britain, in
that “With regard to the pull-away tethering device, this consists of wrist bands
worn by the operatives which are connected to the mechanism of the press so as to
ensure that when the ram descends the hands are pulled away from the trapping
area. The device requires adjustment for each operator and operation and is
unreliable on a short stroke press; further, no protection is provided for any person
other than the operator. It has been used to a very limited extent in this country but
even so accidents have occurred during its use. We reject this device not only
because of its mechanical imperfections but also because its use would introduce a
new system into industry in this country, that is, the fixing of an operative to the
machine”.

Even when being considered in the application of this old type of guard, the guard
should not be used:
 at variable-stroke presses;

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  at presses with less than 5 in. (127 mm) stroke. It should be noted that in the
case of double- and multiple-acting presses, the expression ‘stroke’ means the
stroke of that member which has the least movement;
 at single-acting presses in which the crankshaft speed is greater than the
equivalent of 50 strokes per minute, or 25 strokes per minute in the case of
double- or multiple-acting presses;
 at presses on which the conditions are such that the distance between any parts
where trapping can occur is less than one half of the stroke. Account should
be taken, in the determination of this distance, of the minimum distance
between trapping parts when inserting or removing the component.

 Performance and Testing:

According to the HSE publication “Safety in the Use of Mechanical Power Presses
(HSW 14)” (p. 44), the following standards are recommended for the testing of the
performance of the pull-out guard:
 The guard, when tested with a solid test piece of 1¼ in. (31 mm) in thickness,
should have a pull-away of at least 8 in. (203 mm) in the first two-fifths of the
stroke and of at least 12 in. (305 mm) in the first three-fifths of the stroke.
 When the gate of the guard is open, the distance between the bottom bar of the
gate and the corresponding pull-away bar of the frame should be so set as to be
as small as possible consistent with feeding and removing the workpiece. The
object of this is to prevent the operator from reaching so far into the press that
the guard would fail to comply with the specification in that it would be unable
to remove his hand or arm in time to prevent it being trapped. It may also be
necessary, however, to provide a screen behind the tools in order to prevent
over-reaching, but this must not create a trap as the ram ascends.
 The setting of the guard in relation to the tools in use must always be such that
trapping of the operator’s hand or arm cannot occur between the moving guard
and any part of the press or tools.
 The outer frame must be checked to ensure that it hangs freely. It must never
be secured to the press frame or otherwise restrained in any way.

.
Sources from https://www.iloencyclopaedia.org & https://www.osha.gov/SLTC/etools.

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5.7.10 Restraint (Hold-out) Device

As stated in paragraph E2.10.3 of ANSI B11.1, a restraint or hold-out is likened to a

nonmoving pull-back (out) device, the restraint (holdout) device utilizes cables or straps
that are attached to the operator’s hands and to a fixed point. The cables or straps must be
adjusted to let the operator’s hand travel within a predetermined safe area. Consequently,
hand-feeding tools are often necessary if the operation involves placing material into the
danger area. The restraint device must also be carefully adjusted to fit each operator. Apart
from the need for regular maintenance, all the limitations of a pull-back device apply to a
restraint device.

Pull-back and Hold-out devices restrict the operator’s mobility; the operator may not be
able to react to emergency situations, and the worker might lose his balance from incorrect
adjustment of cables. Moreover, they may not be worn by the workers or worn on one
hand only. A regular schedule of inspection and maintenance is necessary for these devices
to insure effective operation. Defective pull-back and hold-out devices have contributed
to severe and costly accidents. Pull-back devices are also not effective on short stroke or
high speed presses.

5.7.11 Sweep Type Devices

According to the U.S. Department of Labor OSHA Directive No. STD 01-12-021, sweep
type devices consist of single or double arm or rod attached to the slide of the press so that
it will push the operator's hands away from the point of operation as the slide descends.
However, this device cannot be used as a single safeguard for point of operation guarding
after December 31, 1976 (29 CFR 1910.211(d)(16); 1910.217(c)(3)(v) and (c)(3)(i)(o)).

Automatic guards are understood as guards that are associated with, and dependent upon,
the mechanism of the machinery and operate so as to remove physically from the danger
area any part of a person exposed to danger. This form of guard incorporates a device so
fitted in relation to the dangerous parts that the operator is automatically prevented from
coming into contact with same. Typical machines using this system of guarding are power
presses, press brakes and certain types of guillotine. Here the guard is totally independent
of the operator, and the function of the guard is to remove the operator from the dangerous
action of the machine by means of a moving barrier or arm which sweeps outwards. There
may be some degree of risk in that the operator can be injured by the moving barriers, and
this type of guard is only suitable for large, slow-moving barriers, as with presses. These
guards operate on a side-to-side, sweep-away or push-out motion.

On the other hand, sweep guards can either sweep out or sweep sideways. According to
State of Arkansas Department of Labor’s Safety Code # 10 on Power Presses and Foot and
Hand Presses (1959) Section A4.6 (p. 18), “In theory, the guard will push the operator’s
hand out of the way, the sweep guard being activated by the motion of the ram. The best
use of these guards is on small presses and dies (not over 6 inches wide)”. However, such
guard suffers from the following “limitations”:

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  If the guard swings in arc and the radius of arc is small compared to the length of
the front of the die, there is a space which is never guarded at the end of the stroke.
 When not properly designed or adjusted and the sweep moves quickly, it may be
possible to reach into a nip point after the sweep passes, or if it moves slowly, the
sweep may not clear the danger zone in time.
 If the die is large and the arm of the operator is struck by the sweep, there is a
possibility the elbow will bend and the hand will remain in the danger zone.
 It is easy to reach around the guard into the point of operation.
 If barriers are used to prevent reaching around the sweep, the barrier may prevent
the sweep from clearing the hand in case of need.
 If a hand were in deep indention of the die, the sweep would not remove it”.

5.7.12 Single-Arm Sweep-Away Guard

It is stated in the U.K. Health and Safety Executive’s Engineering Sheet No. 30 (1999)
entitled “Safety in the Use of Hand- and Foot-operated Presses” paragraph (c) that “Where
none of the above-mentioned guards and safety devices are practicable, other devices, such
as sweep-away guards, may be used. These should be set so that the arm sweeps across
the front of the tools as they begin to close and either sweeps the employees’ fingers out of
the way, or stops the press. So despite the disadvantages in general of automatic guards,
and the apparent substandard nature of this type of guarding method, a single-arm sweep-
away guard is currently still acceptable for use in the U.K. for the safeguarding of
machinery”.

In Taiwan, the Safety Standard for Mechanical Equipment 2014 (機械器具安全防護標準)

No. 14 prescribes the following safety standards regarding sweep devices:
 The construction should enable adjustment of the length and sweep span of the
sweep-arm.
 The sweep-arm should be fitted with a protection board to ensure the safety of the
hand during a sweep.
 The dimensions of the protection board (防護板) should be

 Width(寬度): More than half of the width of the die(金屬模寬度), but not less
than 100 mm.
 Height(高度): More than the length of the daylight ( 行程長度, distance
travelled by the tool), but not more than 300 mm.
 Span of the Sweep(振幅): More than the width of the die.
 Sweep-arm and protection board should minimize the impact when in contact
with the hand or other parts of the human body.

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The pre-requisites for installing sweep devices are:
 Authorized to be used on positive clutch machinery only, and should be operated
by the hand(s) when the machine is to be started.
 The daylight should be at least 40 mm and be less than the width of the protection
board.
 The number of strokes per min. should be less than 120. Not suitable for higher
speed presses.
If the machine specification cannot meet the above, the sweep device should not be
installed, except when in conjunction with an interlocking guard, a two-hand control device,
a presence sensing device, or a pullback or sweep device. It has also been noted that there
were accidents where the operator was hurt through entry on the side of the danger zone,
whereas the sweep-arm operates on the front of the danger zone.

The Industrial Technology Research Institute of Taiwan, in its “Things to Note Regarding
Measures to Improve Safety of Mechanical Presses (衝剪機械改善安全設施注意事項)”
further identified the following points:
 Suitable for second additional work on small objects. Not suitable for large objects
or first additional work on small objects.
 Unbalanced levelling of the metal wire attached to the protection board will result
in an unsuitable span of the sweep.
 Should be properly adjusted to avoid the hand being trapped between the die and
the sweep-arm.
 The hand should be swept away from the danger zone when the die is about to be
totally closed.

5.7.13 Limitations of Single-Arm Sweep Device

A single-arm sweep device would start from an area of safety at the right moving towards
the danger zone in the middle. During its travel, it meets the right hand of the operator and
sweeps it clear of the danger zone towards another area of safety on the left before trapping
can occur in the middle. The disadvantage of such a design lies in the fact that it requires
very precise adjustment because the operator’s hand is swept across the danger zone. This
is particularly dangerous if the operator inadvertently places his right hand into the danger
zone after the operation of the sweep-arm, or if the operator is a left-hander in which case
his left hand may be carried by the returning sweep-arm into the danger zone in the middle.
Even in a correct setting, the time taken to sweep the left hand clear of the danger zone will
be double that for the right. Taking this into consideration, the use of a double-arm sweep
device, which starts from the danger zone in the middle to sweep both hands to either sides
is more preferable.

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5.7.14 Double Arm Sweep Away Guard

The use of double-arm sweep device, according to the definition of a sweep device in both
the U.K. and U.S. laws, was in existence long ago. However, such use has not been popular,
at least not as popular as that used in Hong Kong, where such device is termed “Double-
Arm Sweep-Away Guard” which is typical of the design of an automatic guard. Because
of its greater visibility of the point of operation and the ease of feeding and extraction of
the workpiece, double-arm sweep-away guard and two-hand control devices are more
welcome by press operators than fixed guards or interlocking guards. However, there are
certain limitations in their application.

5.7.15 Double-Arm Sweep-Away Guard Used in Hong Kong

According to information from the Labour Department, Hong Kong, the double-arm
sweep-away guard shall consist of two independent arms mounted at both ends of a
horizontal bar attached to the top of the press frame. When the ram descends, the two
connecting rods attached to it pull down the crank rods of the sweeping arms, causing them
to sweep across the bolster and beyond its sides. The sweeping action shall remove in good
time the operator’s hand away from the danger zone between the closing tool and die. On
return of the arms, the spring will give way and avoid the trapping danger of misplaced
hands … The lower parts of the two sweeping arms are designed to superimpose in two
different planes so as to ensure the view of the operator is unobstructed. The sweeping
arms should sweep towards the sides in front of the bolster. A soft rubber sleeve should be
attached to the hand sweeping portion of the arm to eliminate shock on contact … The
sweeping angle should be adjusted in accordance with the dimensions of the tool. This can
be achieved by altering the position of the clip at the crank-rod of the sweeping arm and
the length of the connecting rod attached to the ram.

For fear of being beaten intermittently by the sweep-arms, some press operators tend to sit
sideways and feed and extract workpieces from the side. This act renders the double-arm
sweep-away guard useless and accidents may ensue. Though the press operator may be
held liable for contributory negligence under common law, the employer will be statutorily
totally at fault. This imposition of strict liability is illustrated in the case So Kwok-yau v.
The Queen(HCMA000260/1986). Though the guard, as claimed by the inspector who gave
evidence, was invented, approved and recommended by the Labour Department, and that
the span of sweep (2 inches beyond the bolster) was considered sufficient, the proprietor
was still convicted of the offence of failure to effectively guard the dangerous part created
by the closing tool and die of the power press. The minimum span of sweep of the sweep-
arms is not stipulated in the Labour Department’s guidebook entitled “Safe Practices in the
Operation of Power Presses 啤機安全操作守則” paragraph 7(3), which says that the
sweep-arms should sweep beyond the two sides of the bolster, which implies that this is
the acceptable standard. In the case of the accident, the sweep-arms swept 2 inches beyond
the bolster and hence were considered properly installed. However, the guide further
warned that if the operator was not sitting in the correct position, then the guard will lose
its effect. Hence the appeal against the conviction by the proprietor failed.

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5.7.16 Double-Arm Sweep-Away Guard Designed Outside Hong
Kong

Though it was claimed by the Labour Department factory inspector in the High Court
Magistracy Appeal 260/1986 that the double-arm sweep-away guard was invented by the
Labour Department, coincidentally a similar design was already registered in the U.S.
Patent Office in 1942 which bore relatively similar features except that the double-arms of
this patented design look more like a pair of chopsticks.

Details of the design are recorded in the application for the patent as follows:
“Referring to the drawing in detail, the numeral 10 designates a power press having the
usual vertically extending frame arms 11 in which is journaled a crank shaft 12 provided
with a pulley wheel 13 adapted to be connected to a source of power to rotate the shaft 12.
Connected to the crank portion of the shaft is a ram or tool 14 slidably mounted to vertical
guides 15 for reciprocation with respect to a bed plate 16 to operate upon the work disposed
upon the latter. A foot pedal 17 operates the clutch mechanism on the shaft 12 in the usual
manner to control rotation of the crank shaft and thus each stroke of the ram 14.

For mounting the guard upon the press, a horizontal cross bar or other form of support 18
is bolted to the vertically extending arms 11 of the press 10. Pivotally suspended as at 19
at their upper ends are a pair of vertical depending oscillatable arms 20 which are each
composed of a pair of sections 21 and 22 adjustably connected together with bolt and slot
connections 23 whereby the arms may be lengthened or shortened for any size press or to
alter the extent to which the two arms reach outwardly in opposite directions as will be
apparent as the description proceeds.

A pair of guard arms 24 and 25 are vertically adjustably mounted in fittings 26 secured to
the lower ends of the arms and in spaced parallel relationship adjacent the middle of the
forward edge of the bed of the press. A set screw 27 is associated with each fitting 26 so
that after the guard arm has been adjusted with respect to its supporting arm 22, the set
screw may be tightened to securely fix the guard arm with respect to its respective arm 22.
The lower end of each arm 22 is provided with a pin or roller 28 extending rearwardly
thereof to operate in a cam slot provided in a plate 30 secured to the ram of the press by
means of the bolts 31. A cam slot or way 29 is provided in the plate 30 for each guard arm
24 and 25, and as best shown in Figs. 3 and 4, these cam slots are inclined downwardly and
inwardly in a converging relationship to cause the arms 24 and 25 to move outwardly in
opposite directions across the ram or tool as it begins to descend to cooperate with the die
on the bed plate 16 and thereby sweep the operator’s arms clear of the descending tool.
The upper ends of the slots 29 extend vertically and are substantially parallel to permit the
ram or tool to complete its downstroke without further moving the guards 24 and 25
outwardly after they have reached their outermost positions as shown in Fig. 4. It will be
obvious that the shape and angularity of the cam ways 29 can be varied to cause the arms
24 and 25 to move outwardly in opposite directions at any speed and at any stage. The
descent of the ram will insure the safest operation of the press. Also, by changing the
length of the arms 20 and the position of securement of the cam plate 30 to the press, the
extent of oscillation of the arms 20 can be accurately controlled to adapt the attachment to

127
any kind of press. Upon elevation of the ram or tool together with the cam plate 30, it will
be seen that the guard arms 24 and 25 will be automatically moved inwardly to their normal
position shown in Figs. 1 and 3 by the rollers 28 entering the inclined portions of the slots
29 after the ram has been elevated to a certain extent, so that when the ram or tool is
completely elevated and all danger to the operator is past, the guard arms will be disposed
reasonably close together as shown in Fig. 3, thereby opening the throat of the press and
permitting the operator to remove and insert work in perfect safety.

It will be understood from the foregoing description that very few parts are necessary to
provide a very efficient safety guard, and if desired a lazy tong structure can connect the
guard arms 24 and 25 so as to protect the operator from inserting his hand under the ram in
between the two arms during their separation or retraction.

Sources (Issued by U.S. Patent Office) Safety Guard for Power Presses &
https://patentimages.storage.googleapis.com.

128
5.7.17 Effectiveness of the Double-Arm Sweep-Away Guard Used
in Hong Kong

Since a sweep-arm is normally of an inverted L-shape and not straight, a question arises:
how high up the middle should the sweep-arms be bent for a maximum sweep? How could
a greater span of sweep be achieved?

Source. Photos by Michael Leung

An interesting result is that the sweep of both double-arm sweep-away guards is the same
no matter how high up the middle is the sweep-arm bent. This is shown by the following
model.

Now joining the pivot to the tip of sweep-arm by an imaginary line (marked green), the L-
shaped sweep-arms depends on the lengths of c and d, i.e. if d is longer, then c will be
shorter, but in case of a swing, all that matters will be the segment of an arc swung out by

129
this imaginary green line, which is z=2f sin Φ. But the two triangles CDE and CFG are
congruent (Side-Angle-Side) and hence ∠DCE (i.e. 2θ+γ) = ∠FCG (i.e. 2Φ+γ), giving Φ=
θ, meaning the span of the sweep is z=2f sin θ which is independent of the length of the
sweep-arm components a, b and c.

This can also be deduced from the original bent sweep-arm diagram as follows:
x = 2b sin θ sin α + c sin 2θ
y = c - 2b sin θ cos α - c cos 2θ

Squaring and adding gives

z2 = x2 + y2
= (4b2 sin2 θ sin2 α + 4bc sin θ sin 2θ sin α + c2 sin2 2θ) + (c2 + 4b2 sin2 θ cos2 α
+ c2 cos2 2θ - 4bc sin θ cos α - 2c2 cos 2θ + 4bc sin θ cos α cos 2θ)
= 4b2 sin2 θ (sin2 α + cos2 α) + (c2 + c2 sin2 2θ + c2 cos2 2θ - 2c2 cos 2θ)
+ 4bc sin θ [sin 2θ sin α + (cos α cos 2θ - cos α)]
= 4b2 sin2 θ + (2c2 - 2c2 cos 2θ) + 4bc sin θ [2 sin θ cos θ sin α + cos α (cos 2θ -
1)]
= 4b2 sin2 θ + 2c2 (1 - cos 2θ) + 4bc sin θ (2 sin θ cos θ sin α - 2 sin2 θ cos α)
= 4b2 sin2 θ + 4c2 sin2 θ + 8bc sin2 θ (cos θ sin α - sin θ cos α)
= 4(b2 + c2) sin2 θ + 8bc sin2 θ sin (α - θ)
= 4(d2 + e2 + c2) sin2 θ + 8cd sin2 θ
= 4(c2 + 2cd + d2 + e2) sin2 θ
= 4[(c + d)2 + e2] sin2 θ
= 4f2 sin2 θ
z = 2f sin θ

5.7.18 Maximization of Amplitude of Sweep of Double-Arm Sweep-

Away Guard

Since the daylight (distance between tool and die) of a power press is usually fixed and
hence θ is fixed, to maximize the sweep, the toolsetter should increase f (the distance
between the pivot and the tip of the sweep-arm), by either increasing the distance between
pivots (hence increasing e and thereby f increased), or increasing the vertical length of the
sweep-arm to as low as possible (hence increasing c+d and thereby f increased)

On the other hand, a shorter c but longer d will minimize the chance of the operator
reaching his hand into the danger zone from the middle at the commencement of the sweep.

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5.8 Two-Hand Control Device

5.8.1 Introduction to Two-Hand Control Device

A two-hand control device is so designed that the operator's hands must continuously
engage the controls of the machine in order that its cycle of operation can be completed
and if one or both of the operator's hands cease to engage the controls, the machine stops
immediately. A two-hand control system can be pneumatic, hydraulic, electric or
mechanical. For guarding against the perverse ingenuity of some operators, it is important
to install in a two-hand control device a timer mechanism which permit no more than a few
milliseconds so that the controls must be engaged simultaneously before a cycle of
operation can be set in motion.

5.8.2 Principle of Operation of Two-Hand Control Device

A two-hand control device works on the principle of protecting the hands of a machine
operator by engaging his two hands continuously to press two adequately spaced buttons
for each operation. It should only be considered when guarding is impracticable, e.g. large
paper guillotine.

5.8.3 Limitations of Two-Hand Control Device

Paragraph 7 and 8 of the Report of the Committee on Safety in the Use of Power Presses
(1945) made the comment that “Methods of prevention of accidents between punches and
dies may be divided into three well defined classes: … (c) Systems intended to ensure that
the hands of persons working at a press are so engaged that they cannot be within the
trapping area when the punch comes into dangerous proximity with the die. Two hand
lever devices and multiple press-button controls fall within this category. Many efforts
have been made to develop successfully devices of this type referred to in paragraph 7(c)
which are intended to occupy the operative’s hands during the closure of the punch and
die. These devices have ranged from simple arrangements consisting of one lever
interlocking with a clutch actuating lever, to elaborate systems whereby the operative was
compelled to manipulate two levers, each of which gave independent control of the clutch
and which were of such a nature that they had to be operated simultaneously and
continuously until the tools were closed. The more primitive forms of these devices have
proved themselves totally inadequate to safeguard the operative for they can be easily
defeated in a number of ways. Moreover they do not give protection in the event of a repeat
stroke or an uncovenanted stroke produced by a machine fault. Even the arrangement
seen … cannot safeguard a person other than the operator. Similar devices apply to
multiple push-button control. In our opinion all such devices falls short of the requisite
standard of safety and we reject them.

Despite the above, a two-hand control device is accepted as a valid form of safeguarding
machinery under the Factories and Industrial Undertakings (Guarding and Operation of
Machinery) Regulations. However, it is not acceptable in guarding the tool and die of a

131
positive-clutch power press because when the hands are released, the tool will still descend
once the clutch is engaged. The ANSI B11.1 Standard makes a difference between Two-
Hand Trip and Two-Hand Control Device: “A Two-Hand Trip requires only a momentary
concurrent application to push buttons (or other operating mechanism) to set the slide
ultimately into motion. Instantaneous removal of the hands cannot recall the action or stop
the motion. A Two-Hand Control Device requires holding the buttons depressed for a
portion of the downward stroke of the slide. Premature removal of hands results in a
stopping action. A Two-Hand Trip is usually applicable to full-revolution clutch
equipment, and a Two-Hand Control Device is possible only with part-revolution clutch
equipment”.

5.8.4 Minimum Ram Speed

The formula in ANSI B11.1 gives

Dm = 63 inches / second (hand-speed constant) x Tm, where
Dm = minimum safety distance between the two-hand trip and the point of operation (in.)
Tm = the maximum time the press takes for the die closure after it has been tripped (sec)

For full-revolution clutch presses with only one engaging point, Tm is equal to the time
necessary for 1.5 revolutions of the crankshaft. For full-revolution clutch presses with
more than one engaging point,
Tm = [0.5 + 1 / (Number of engaging points / rev)] x time necessary to complete one rev
of the crankshaft (sec)

For a full-revolution clutch press, there are usually 3 engaging points per revolution,
nicknamed the three-stars. Assuming the safety distance Dm = 31.5 inches, which is the
maximum allowable safety distance of the hand, Tm = 31.5 / 63 = 0.5.

Substitute into the formula,

Time to complete one rev of the crankshaft (sec) = 0.5 / [0.5 + 1/3] = 3/5

Hence, the minimum ram speed = 1 / [Time to complete one rev. of the crankshaft]
= 100 rev/min
which is just the minimum ram speed stipulated in paragraph 7(4) of the Code of Practice
on Power Press Safety issued by the Hong Kong Labour Department when a two-hand
control device is used on a positive clutch power press. It means that a hazard would occur
for a slower power press as it will allow enough time after the two-hand control buttons
are pressed and the hand leaves the button to reach into the trapping zone.

Other ideal features for a two-hand control device include the need to fit a timer so that
when one of the control devices is being engaged for some time, the machine cannot be
actuated. This prevents the operator from permanently engaging one of the control buttons
(using a tape or other adhesive material) thereby turning the two-hand control mechanism
into a single-hand control mechanism. Moreover, the control buttons should be spaced
some distance apart, and be either countersunk or shrouded to avoid the control devices
being tampered with.

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5.8.5 Separation Distance Between Control Buttons

For two-hand control devices, according to the design criteria laid down in BS EN
574:1996 + A1:2008 Safety of Machinery - Two-hand Control Devices – Functional
Aspects – Principles for Design, the control actuating devices should be separated by at
least 260 mm. to avoid the operator pressing both devices with one hand.

Separation by Distance
Source (International Organization for Standardization): ISO13851:2019 Safety of Machinery - Two-Hand
Control Devices: Principles for Design & Selection

An alternative is to provide one or more shields or an elevated area between the control
actuating devices so that the devices are separated by a distance of at least 260 mm around
the shields.

Separation by an Elevated Area

Source (International Organization for Standardization): ISO13851:2019 Safety of Machinery - Two-Hand
Control Devices: Principles for Design & Selection

Sometimes, to prevent defeat by using the hand and elbow of the same arm, the control
actuating devices have to be separated by at least 550 mm. For ergonomic reasons,
however, this distance should not exceed 600 mm.

Separation by Distance
Source (International Organization for Standardization): ISO13851:2019 Safety of Machinery - Two-Hand
Control Devices: Principles for Design & Selection

Alternatives include similar shields or an elevated area between the devices so designed
that the devices cannot be touched by the elbow and the tips of the fingers of the same arm
at the same time.

133
 Separation by Shield
Source (International Organization for Standardization): ISO13851:2019 Safety of Machinery - Two-Hand
Control Devices: Principles for Design & Selection

Other alternatives include covers so designed that the devices cannot be operated by the
elbow, or devices with different directions of operation, or a combination of these.

Separation by Collars and by Orientation Separation by Collar and by Shield

Separation by Collar, by Shield and by Orientation

Source (International Organization for Standardization): ISO13851:2019 Safety of Machinery - Two-Hand
Control Devices: Principles for Design & Selection

Measures to prevent defeat by using other parts of the body such as the knee or hip, in
conjunction with one hand include arranging the control actuating devices on a horizontal
surface which is at least 1,100 mm above the floor or level of access.

Prevention of Defeat by Position Separation by Collars and by Position

Source (International Organization for Standardization): ISO13851:2019 Safety of Machinery - Two-Hand
Control Devices: Principles for Design & Selection

A safe distance should also be maintained between the control actuating devices and the
danger zone, e.g. by a distance ring.

134
Source (International Organization for Standardization): ISO13851:2019 Safety of Machinery - Two-Hand
Control Devices: Principles for Design & Selection

This safety distance has to take into consideration the following factors:
 Hand/arm speed.
 The shape and arrangement of the two-hand control device.
 The response time of the two-hand control device.
 The minimum time taken to stop the machine, or remove the hazard, following
cessation of the output signal of the two-hand control device.
 The intended use of the machine.

5.9 Interlocking Guard

5.9.1 Introduction to Interlocking Guard

An interlocking guard is designed to operate in such a manner that the machine on which
it is installed cannot be operated unless the interlocking guard is in a closed position; and
the guard cannot be opened unless the machine is not in motion or its removal from a closed
position causes the machine to immediately cease its motion. The interlocking features are
normally achieved by means of a combination of electrical interlock to control the
operation of the machinery and mechanical interlock to control the opening of the guard.
An interlocking guard is most useful for guarding points of operation where the feeding of
material and withdrawing of components are required in every cycle of operation and for
guarding heavy rotating parts of a machine to which access is required on regular occasions.
The interlocking devices should be so constructed and located that they cannot be readily
tampered with or defeated. If a component of the interlocking mechanism fails, the machine
should not be capable of being set in motion. Certain electrical limit switches can easily
be defeated by depressing a contact button. Interlocking arrangements which are not
reliable are known as 'fail to danger type' and those which are reliable are known as 'fail to
safety type'. Interlocking guards require a high degree of maintenance and a reliable system
of regular testing and inspection.

5.9.2 Interlocking Mechanism

The interlocking mechanism can be achieved by the following means:

135
  Electrical
 Mechanical
 Hydraulic
 A combination of the above

5.9.3 Criteria to be Fulfilled by an Interlocking Guard

The interlocking mechanism would involve the following criteria:

 The machine cannot operate unless the guard is closed.
 The guard cannot be opened until the dangerous operation has ceased, or opening
the guard disengages the machine and promptly stops the hazardous operation.
 Where overrun creates a danger, a time delay must be incorporated in the interlock
so that the guard cannot be opened until the dangerous movement has stopped.

5.9.4 Examples of Interlocking Mechanism

The application of an interlocking mechanism to safeguard health and safety can be found
in household commodities as well as industrial applications in the following appliances and
provisions:
 Microwave oven
 Washing machine
 Lift doors
 X-Ray equipment
 Laser equipment
 Hoistway gates

5.9.5 General Safety Features of the Interlocking Guard of a

Power Press

An interlocking guard can be perceived as provision of an interlocking mechanism to a

Fixed Guard to the danger zone caused by the closing tool and die of a power press, which
was spelt out in Section 15 of the Report of the Committee on Safety in the Use of Power
Presses (1945) as “There is, however, another type of fixed guard which we term the
interlocked fixed guard. It is based on two principles: (i) When the guard is open and
access is allowed to the dangerous parts, the driving mechanism of the press is so controlled
that a stroke cannot be made. (ii) When the dangerous parts are in motion, the guard is
kept shut so that access to these parts is not possible”.

The interlocking feature should be applied both to the clutch movement as well as the
crankshaft movement, as indicated in Sections 19 and 23 of the above Report: “In terms of
machine design, the application of the interlocked fixed guard involves two factors: (a) the
design of the clutch, and (b) the design of the safeguard. We have concluded firstly that
each clutch design should be so arranged as to incorporate interlocking devices which

136
secure effective control over the clutch movements and secondly, that a guard should be
fitted which forms part of the machine and which is positively linked to the interlocking
devices. Certain other controls to deal with over-run and gravity strokes are necessary.
We use the expression “over-run” to mean a movement of the crankshaft with the clutch
disengaged beyond the position at which the crankshaft normally comes to rest … The
practical interpretation of our conclusions in this connection emerges as a guard consisting
of a fixed frame with a movable shutter to which the linkage leading to the interlocking
device is connected. It is our view that a guard typified by a cage construction, which is
not related to and incorporated with a fixed framework, is one which cannot be
recommended”.

5.9.6 Additional Safety Features of Interlocking Guard of Power

Press

In Appendix II of the First Report of Proceedings of the Joint Standing Committee on

Safety in the Use of Power Presses (1950), the safety features are further guaranteed by
designing “1. Failure to Safety: Interlock guards should be so designed and constructed
that in the event of interruption of the connections between the guard and the interlocking
mechanism, the clutch will be automatically locked to prevent engagement until the
connections have been made good … 2. Toolsetter disconnection: Where a guard has to be
disconnected from the interlocking mechanism for the purpose of tool setting, any
disconnecting device should be so designed and constructed that no part thereof can be
detached from the guard mechanism, and it should not be capable of disconnection by hand
only”. Appendix V of the above Report further imposes Specification for Interlocking
Guards on Friction Clutch Operated Presses as “specification for interlocked fixed guards
for friction clutch operated presses … should include: (a) Means of interlocking to prevent
clutch engagement until the guard is fully closed, and either (b) means to ensure that the
guard shall not be opened (i) while the clutch is in engagement and (ii) until all possibility
of continued further movement by reason of brake failure or of re-engagement of the clutch
is past, or (c) Means to ensure that whenever the guard is open the crankshaft and suspended
gear shall be prevented from making a movement sufficient to cause danger, irrespective
of the causation of such movement”.

In Appendix III of the Second Report of Proceedings of the Joint Standing Committee on
Safety in the Use of Power Presses (1953), additional safety features would also be
provided by “engagement of the clutch to follow closure of the guard by the operator …
define this method of working as ‘sequential operation’ … (i) the operator is required only
to close the guard, instead of both closing the guard and engaging the clutch as two
independent operations; (ii) the operator is prevented from attempting to engage the clutch
before the guard is closed. This mode of working is commonly referred to as ‘riding the
pedal’. This imposes undue strain on the interlocking mechanism and if this should fail,
causes the press to make a power stroke when the guard is open; (iii) wear on the guard
mechanism, especially the interlocking parts, is reduced; (iv) reduction of operator
fatigue … Sequential operation may be achieved in a number of ways … Hand operation

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of guard: In this method, the operator closes the guard by hand and on attainment of closure,
an overlapping movement, beyond that normally required for an interlocking guard, is used
to operate the clutch engaging device, e.g., a valve controlled air cylinder … Pedal
operation of a guard: The guard is closed by a pedal, and clutch operation follows by
actuation of a valve or switch to operate the clutch engaging device … Power operation of
a guard: Both guard and clutch are operated by power. In a typical example, where
compressed air is used, a foot switch admits air to the guard operating cylinder and on
attainment of the closed position a further switch or valve for clutch actuation is operated
automatically by the guard screen … The use of an effective single stroke device is
desirable in every case, so as to avoid damage to tools which might arise from repeat
strokes”.

5.9.7 Effect on Production Rate

One disadvantage of the use of an interlocking guard in power press operation is spelt out
in Section 7 of the First Report of Proceedings of the Joint Standing Committee on Safety
in the Use of Power Presses (1950). “The normal interlock guard, by reason of its
mechanical features, requires the operator to close the guard by hand as a preliminary to
clutch engagement. This, altogether with the fact that the guard does not open until the
completion of the upstroke, impairs the productive capacity of the machine”. This can be
overcome, as remarked in Section 14 of the Third Report of Proceedings of the Joint
Standing Committee on Safety in the Use of Power Presses (1957), by the use of Early
Opening Guards: “It has been pointed out by many interested people that the conventional
interlocking guard which remains closed throughout the full cycle of the press imposes
certain limitations on production rates because the operator is anxious to reach in to the
danger area at the earliest possible moment. There is in consequence a case for suggesting
that guards should open at or immediately after the commencement of the return stroke so
that as the tools open the operator may have access to them … The first is to provide an
arrestor brake of such a character that there is no possibility of the press making a repeat
or uncovenanted stroke … The second method is one in which interlocking and automatic
actions are combined … There is, however, a range of presses with strokes of 7 inches to
10 inches, some of which are operated by positive clutches, and whose speed is such that
an automatic guard action can be successfully used. By a combination of interlocking and
automatic actions, the operator is prevented from making an ordinary stroke of the press
until the guard is in the closed position, and is safeguarded against the risk of trapping
during a repeat or uncovenanted stroke by the automatic action.

5.10 Concept Checklist

This chapter is on guarding and operation of machines. Key points to note include:
 F&IU (GOM) Regulations
 Safety by position
 Principles of machine guarding
 Ergonomic consideration

138
 Fixed guard
 Trip guard
 Automatic guard
 Two-hand control device
 Interlocking guard

5.11 Further Thinking

The desired mode and speed of operation of a machine is not explicitly spelt out in the
F&IU (GOM) Regulations, but should be taken into account when considering the best
type of guarding method, e.g. a two-hand control device and a trip guard should preferably
not be used to guard the tool and die of a positive-clutch power press because of the
possibility of an unconvenanted stroke, or of a slow-acting power press because of a
possible race with the hand when the workpiece is misplaced onto the die. Do you think
such limitations should be more explicitly spelt out in the law?

139
 Appendix
A5.1 F&IU (GOM) Regulations

A5.1.1 Interpretation (R. 2)

“Automatic guard” (自動式護罩) means a guard which automatically prevents an operator

of any machinery or plant from coming into contact with a dangerous part when that part
is in motion.

“Fixed guard” (固定式護罩) means a guard which by its design and construction prevents
access to a dangerous part of machinery or plant and which has no moving parts associated
with or dependent upon the machinery or plant to which the guard is fitted.

“Interlocking guard” (互鎖式護罩) means a guard which is connected with machinery or

plant so that the machinery or plant cannot be operated unless the guard is in a closed
position, and the guard cannot be opened unless the machinery or plant is not in motion or
its removal from a closed position causes the machinery or plant to cease operating
forthwith.

“Prime mover” (原動機) means any engine, motor, or other appliance, which provides
mechanical energy derived from any source;

“Striking gear” (撥動裝置) means a device designed for moving a driving belt to and from
fast and loose pulleys, and includes a belt shifter.

“Transmission machinery” (傳動機械) includes every shaft, counter-shaft, wheel, drum,

pulley, system of fast and loose pulleys, coupling, clutch, driving belt or other device by
which the motion of a prime mover is transmitted to or received by any machinery or plant.

“Trip guard” (觸覺式護罩) means a guard which is connected with machinery or plant so
that upon its activation the machinery or plant stops before a person can come into contact
with a dangerous part thereof.

“Two-hand control device” (雙手控制裝置) means a device which is so designed that the
operator’s hands must continuously engage the controls of the machinery or plant if it is to
complete its cycle of operation and that if one or both of the operator’s hands cease to
engage the controls thereof the machinery or plant stops instantly.

A5.1.2 Application (R. 3)

The F&IU (GOM) Regulations shall apply to machinery or plant in a notifiable workplace.
However, these regulations shall not apply to any:
(a) machinery or plant whose cycle of operation does not involve the use of a prime
mover and is dependent solely upon manual labour;

140
(b) machinery or plant that is portable and is designed for carrying about by manual
labour and for operation while held by hand; and
(c) machinery or plant of the parts and description set out in column A of the Second
Schedule and to which the regulations opposite thereto in column B apply.

A5.1.3 Guarding of Dangerous Parts (R. 4)

A dangerous part shall be effectively guarded. However, a dangerous part which by reason
of:
(a) its position;
(b) its construction; or
(c) the nature of the work being performed,
does not give rise to any reasonably foreseeable hazard to the safety of any person present
at a notifiable workplace need not be guarded.

A5.1.4 Method of Guarding (R. 5)

Effective guarding of a dangerous part shall be achieved either by any one of the following
methods or by a combination of any of them:
(a) by a fixed guard;
(b) by an interlocking guard;
(c) by an automatic guard;
(d) by a trip guard;
(e) by a two-hand control device.

Every guard or device used shall be:

(a) of substantial construction;
(b) maintained in an efficient condition; and
(c) kept in its proper position while the machinery or plant is in motion.

However, a guard or device may be removed or rendered inoperative while the machinery
or plant is in motion and a dangerous part is necessarily exposed for the purpose of any
examination, being an examination which can only be made with the machinery or plant in
motion, or of any lubrication or adjustment shown by an examination to be immediately
necessary, being a lubrication or adjustment which can only be done with the machinery
or plant in motion. A guard or device removed or rendered inoperative shall be
immediately replaced or rendered operative upon completion of the purpose for which it
was so removed or rendered inoperative.

A5.1.5 Fixed Guards may have Openings (R. 6)

(a) An opening may be provided in any fixed guard for the insertion and withdrawal
of material from machinery or plant.
(b) An opening in a fixed guard shall:

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 i) in the case of a fixed guard used in connexion with an automatic feeding
device or any gravity feeding system, be as small as is practicable having
regard to the operation of the machinery or plant;
ii) in every other case, conform to the Table set out in the Third Schedule to
the F&IU (GOM) Regulations so that the distance of the fixed guard from
any dangerous part shall be not less in any case than the distance set out in
column B opposite to the size of opening set out in column A.

A5.1.6 Young Persons Working at Machines (R. 7)

A young person shall not work at or operate any machine specified in the Fourth
Schedule to the F&IU (GOM) Regulations unless he has been fully instructed as to the
dangers arising in the use of the machine and the precautions to be observed, and he has
either been given training to the extent that he is proficient in work at and the operation of
the machine or he is under supervision by a person who has a knowledge of and is
experienced in work at and the operation of the machine.

A5.1.7 Starting and Stopping Devices (R. 8)

Machinery or plant shall be equipped with an efficient starting and stopping device and the
controls of the device shall be designed and constructed with proper regard to the safe
working of the machinery or plant and so placed as to be readily and conveniently operated.

A5.1.8 Push Button Controls to have Emergency Stopping Devices (R. 9)

Machinery or plant driven by 2 or more motors with separate push button controls shall be
equipped with one or more overriding stopping devices by means of which the machinery
or plant can be stopped forthwith and, where there is more than one stopping device, such
devices shall be so spaced as to enable their effective and convenient operation.
`
A5.1.9 Stock-Bars (R. 10)

Any part of a stock-bar which projects beyond the headstock of a lathe shall be effectively
guarded unless it is in such a position as to be as safe to every person present at the
notifiable workplace as it would be if effectively guarded.

A5.1.10 Belts and Pulleys (R. 11)

(a) Machinery or plant not directly driven by an individual motor or other prime
mover but driven through a system of belt, pulley and shaft or counter-shaft shall
be equipped with:
i) a clutch;
ii) a loose pulley; or
iii) other adequate means readily accessible to an operator for the effective
starting and stopping of the machinery or plant.

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(b) No driving belt shall rest or ride upon a revolving shaft forming part of any
transmission machinery.
(c) For the purposes of moving a driving belt to and from fast and loose pulleys
forming part of any transmission machinery, suitable striking gear shall be
provided and shall be constructed, placed and maintained so as to prevent the
driving belt from creeping back or shifting on to a fast pulley while the driving
belt is in motion on a loose pulley.
(d) Where a foot pedal forms part of any transmission machinery for the purpose of
operating a clutch, it shall be effectively guarded against being unintentionally or
accidentally struck so as to operate the clutch.

A5.1.11 Responsibilities of Proprietors, Employees and Other Persons (R. 12)

(a) No proprietor, employee or other person shall wilfully and without reasonable
cause, remove, render inoperative, misuse, damage or interfere with any guard or
device provided.
(b) Every employee shall make full and proper use of any guard or device provided.
(c) Every employee shall report forthwith to the proprietor any fault or defect in any
guard or device provided.

A5.1.12 Dangerous Parts of Machinery or Plant (Schedule 1)

1. Revolving shafts, couplings, spindles, mandrels, bars and flywheels.

2. In-running nips between pairs of rotating parts.
3. In-running nips of the belt and pulley type.
4. Projections on revolving parts.
5. Discontinuous rotating parts.
6. Revolving beaters, spiked cylinders and revolving drums.
7. Revolving mixer arms in casings fitted with openings.
8. Revolving worms and spirals in casings fitted with openings.
9. Revolving high-speed cages in casings fitted with openings.
10. Revolving cutting tools.
11. Reciprocating cutting tools.
12. Reciprocating press tools and dies.
13. Reciprocating needles.
14. Closing nips between platen motions.
15. Projecting belt fasteners and fast running belts.
16. Nips between connecting rods or links, and rotating wheel cranks or discs.
17. Traps arising from the traversing carriages of self-acting machines.

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A5.1.13 Parts of Machinery or Plant to Which the F&IU (GOM) Regulations do not Apply
(Schedule 2)

A B
Parts and Description Applicable Regulations
F&IU (WWM) Regulations
Circular saw, the blade Reg. 10
Swing saw, the blade Reg. 12
Pendulum saw, the blade Reg. 12
Plain band saw, the blade Reg. 13
Planing machine, the cutter Reg. 14
Vertical spindle moulding machine, the cutter Reg. 15
Chain mortising machine, the chain Reg. 16
CSSR
Every flywheel and moving part of any prime mover Reg. 44
Every part of transmission machinery Reg. 44
Every dangerous part of other machinery (whether or Reg. 44
not driven by a prime mover)
F&IU (AW) Regulations
Abrasive wheel Reg. 8 and 9

A5.1.14 Openings in Fixed Guards (Schedule 3)

A B
Size of opening measured at the widest point Distance of guard from any
dangerous part
(mm) (mm)
More than But not more than Not less than
6 40
6 10 40
10 12 65
12 15 90
15 20 140
20 22 165
22 30 190
30 40 320
40 50 400
50 55 450
55 150 800
150 800

A5.1.15 Machines Not to be Worked at by Young Persons Unless Trained or Supervised

(Schedule 4)

1. Power presses, including hydraulic and pneumatic presses.

2. Loose knife punching machines.
3. Milling machines, other than those used in tool-room operation.

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4. Dough brakes.
5. Dough mixers.
6. Hydro-extractors.
7. Calenders.
8. Washing machines.
9. Garment presses.
10. Paper baling presses.
11. Guillotines.
12. Hand fed platen printing machines.
13. Hand fed embossing machines.

References

American National Standards Institute (2003) “ANSI B11.19-2003: American National

Standard for Machine Tools - Performance Criteria for Safeguarding”, The
Association for Manufacturing Technology, Virginia.
British Plastics Federation (1997) “Safety Guidance on the Guarding and Use of Injection
Moulding Machines in the Plastics and Rubber Industries”, Publication No. 238/3,
The BPF, London.
British Standards Institution (2010) “BS EN ISO 13855:2010 Safety of Machinery -
Positioning of Safeguards with respect to the Approach Speeds of Parts of the
Human Body (ISO 13855:2010)”, BSI Standards Ltd., U.K.
British Standards Institution (2013a) “BS EN 61496-1:2013 Safety of Machinery - Electro-
Sensitive Protective Equipment Part 1: General Requirements and Tests”, BSI
Standards Ltd., U.K.
British Standards Institution (2013b) “BS EN ISO 14119:2013 Safety of Machinery -
Interlocking Devices Associated with Guards - Principles for Design and
Selection”, BSI Standards Ltd., U.K.
British Standards Institution (2014) “PD 5304: 2014 Guidance on Safe Use of Machinery”,
BSI Standards Ltd., U.K.
CSST (2009) “Machine Safety: Prevention of Mechanical Hazards - Fixed Guards and
Safety Distances”, IRSST Guide RG-597, Quebec.
Factories and Industrial Undertakings (Guarding and Operation of Machinery) Regulations
1977, Hong Kong, Available at http://www.elegislation.gov.hk/hk/cap59Q
(Accessed on 31 December 2019).
Health and Safety Executive, U.K. (1998) “Safe Use of Power Presses”, HSE Books,
Suffolk.
Health and Safety Executive, U.K. (1999) “Safe in the Use of Hand- and Foot- Operated
Presses”, Engineering Sheet No. 30, HSE Books, Suffolk.
Health and Safety Executive, U.K. (2003) “Procedures for Daily Inspection and Testing of
Mechanical Power Presses and Press Brakes”, HSE Books, Suffolk.
Health and Safety Executive, U.K. (2009) “Application of Electro-Sensitive Protective
Equipment Using Light Curtains and Light Beam Devices to Machinery”, HSE
Books, Suffolk.

145
Health and Safety Executive, U.K. (2010) “Health and Safety in Engineering Workshops”,
HSE Books, Suffolk.
Health and Safety Executive, U.K. (2014) “Safe Use of Work Equipment: Provision and
Use of Work Equipment Regulations 1998 - Approved CoP and Guidance”, 4th ed.,
HSE Books, Suffolk.
Health and Safety Executive, U.K. (2015) “Safety at Injection Moulding Machines”,
Plastics Processing Sheet No. 4 (Rev. 1), HSE Books, Suffolk.
Labour Department (1996) “Code of Safe Practice on Power Press Operation”,
Government Printer, Hong Kong.
Labour Department (2003) “Handbook on Guarding and Operation of Machinery”,
Government Logistic Department, Hong Kong.
Occupational Safety and Health Council (2000) “Safety Hints on Machinery Safety”,
OSHC, Hong Kong.
Oregon OSHA (2015) “Machine Safeguarding at the Point of Operation: A Guide for
Finding Solutions to Machine Hazards”, Oregon.
OSHAcademy (2017) “Introduction to Machine Guarding”, OSH Academy Course 726,
Oregon.
Workplace Health and Safety Queensland (2019) “Guide to Machinery and Equipment
Safety”, PN10596, Ver. 3, Queensland.
Worksafe BC (2017) “Safeguarding Machinery and Equipment”, BK101, Canada.
WorkSafe New Zealand (2014) “Best Practice Guidelines: Safe Use of Machinery”, May
2014, WorkSafe NZ, Wellington.

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 Chapter 6
Woodworking Machinery

6.1 Introduction to the Factories and Industrial

Undertakings (Woodworking Machinery) Regulations
(Cap. 59G)

There is a high risk of accident from the use of unguarded woodworking machinery. The
Factories and Industrial Undertakings (Woodworking Machinery) Regulations impose
certain duties on proprietors with regard to the standard of machine fencing, lighting,
ventilation and cleanliness in industrial undertakings. At the same time, the Regulations
also place an obligation on workers to use guards and other safety devices provided for
them by proprietors.

6.2 Application of the F&IU (WM) Regulations (R. 2)

As an example, since construction sites are classified as IUs, this piece of legislation covers
the use of circular saws used in cutting timber formwork inside construction sites.

6.3 Interpretation of Terms (R. 3)

"Circular Saw" must be used on a bench for this piece of legislation to be applicable,
meaning that it is not applicable to a portable circular saw, such as one used for the
trimming of tree branches.
“Woodworking Machine" means circular saw, swing saw, pendulum saw, plain band saw,
planing machine, vertical spindle moulding machine or chain mortising machine that
operates on wood, so other machines that operate on wood will not be within the scope of
this piece of legislation, such as a wood lathe.

6.4 General Safety Requirements (R. 4-9)

General safety requirements include:

 Provision of an efficient stopping and starting appliance conveniently located.
 Maintenance of sufficiently clear and unobstructed space at WM in motion.
 Maintenance of the floor surrounding a WM to be level and non-slippery and, so
far as practicable, free from chips and other loose material.
 Provision of adequate lighting, with artificial lighting so placed or shaded as to
prevent direct rays of light from impinging on the eyes of the operator, and the
work area should have, at a minimum, illumination of 160 lux.

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  No WM is allowed to be worked in any underground room certified by the
Commissioner for Labour to be unsuitable as regards height, construction, light,
ventilation or in any other respect.
 Full and careful instruction of WM trainee on the dangers arising in connexion with
such machine and the precautions to be observed.
 No person under 16 shall be employed on any WM.

6.5 Fencing of Circular Saw (R. 10)

The circular saw should be fenced as follows:

 Protected underbench with 2 plates of metal or other suitable material, one on each
side of the saw not more than 150 mm apart, extended from the axis of the saw
outwards to not less than 50 mm beyond the teeth of the saw. Metal plates, if not
beaded, shall be at least 2 mm thick or if beaded, at least 1 mm thick.
 Behind and in direct line with the circular saw there shall be a riving knife, which
having a smooth surface, strong, rigid and easily adjustable, be so positioned that
the edge of the knife nearer the saw forms an arc with a radius not exceeding the
radius of the largest saw used on the bench, be maintained as close as practicable
to the saw so that the distance between the front edge of the knife and the teeth of
the saw does not exceed 15 mm, for a circular saw not less than 600 mm diameter,
extends upwards from the bench table to within 25 mm of the top of the saw, for a
circular saw of 600 mm or more diameter, extends upwards from the bench table
to a height of not less than 250 mm. The purpose of a riving knife is to separate
the piece of wood after it passes through the sawblade to prevent it from contact
with the revolving sawblade which may result in “kickback” of the wood.
 The top should be covered by a strong and easily adjustable crown guard, with a
flange at the side of the saw furthest from the fence extending below the roots of
the teeth of the saw, and extend from the top of the riving knife to a point as low as
practicable at the cutting edge of the saw.

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Source (Issued by Labour Department) A Guide to the F&IU (Woodworking Machinery) Regulations (2006).

Under-bench fencing may be excluded for sawblades that are not exposed, such as a
portable circular saw being mounted upside down on a workbench to become a table saw.

6.6 Push-sticks (R. 11)

The law specifically asked for a push-stick, though the use of a push block or jig appears
to serve the same purpose.

Source (Issued by Labour Department) A Guide to the F&IU (Woodworking Machinery) Regulations (2006)
& www.osha.gov.

6.7 Guarding of Swing and Pendulum Saw (R. 12)

 A swing saw or pendulum saw shall be so guarded that it automatically returns to

the back position when released at any point in its travel.
 A swing saw or pendulum saw shall be provided with limit chains to prevent the

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 front edge of the saw from being pulled out in front of the work table.

Source (Issued by Labour Department) A Guide to the F&IU (Woodworking Machinery) Regulations (2006).

6.8 Guarding of Plain Band Saw (R. 13)

A plain band saw shall have:

 A bottom pulley completely encased by sheet metal or other material;
 A top pulley covered with sheet metal or other suitable material;
 the blade enclosed or securely guarded, except the part between the bench table and
the top guide.

Source (Issued by Labour Department) A Guide to the F&IU (Woodworking Machinery) Regulations (2006).

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6.9 Guarding of Planing Machine (R. 14)

 Hand-fed planing machine used for overhand planing fitted with a cylindrical cutter
block shall be provided with a “bridge” guard covering the full length or breadth of
the cutting slot in the bench, and adjustable both in a vertical and horizontal
direction.
 The feed roller of a planing machine used for thicknessing, except a machine used
both for overhand planing and thicknessing, shall be provided with an efficient
guard.

Source (Issued by Labour Department) A Guide to the F&IU (Woodworking Machinery) Regulations (2006).

There is contention that the “lamb leg-shaped” guard is an acceptable alternative to the
“bridge” guard as this guard though capable of covering the full length and breadth of the
cutting slot at the start, will be moved out of position when the workpiece is passed over
the cylindrical cutter block so that part of the cutting slot will be exposed, coupled with the
fact that most “lamb-shaped” guards are fixed onto a pivot rendering them incapable of
being adjusted in a vertical and horizontal direction. Nonetheless, this form of guarding
appears to be acceptable in some overseas jurisdiction.

Source from https://www.iloencyclopaedia.org/contents.

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6.10 Guarding of Vertical Spindle Moulding Machine (R. 15)

 The cutter of a vertical spindle moulding machine shall be efficiently guarded.

Where it is not practicable to be guarded, a jig or holder should be used.
 A suitable “spike” or push-stick shall be kept available for use at the bench of a
vertical spindle moulding machine.

Source (Issued by Labour Department) A Guide to the F&IU (Woodworking Machinery) Regulations (2006).

6.11 Guarding of Chain Mortising Machine (R. 16)

The chain of a chain mortising machine shall be provided with a guard that encloses the
cutters so far as practicable.

Source (Issued by Labour Department) A Guide to the F&IU (Woodworking Machinery) Regulations (2006).

6.12 Maintenance (R. 17)

This Regulation requires:

 the tools, blades and cutting instruments of a WWM and other machines operating

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 on wood to be defect free, properly maintained, clean and properly ground,
sharpened and set;
 circular saws should not be cracked; and
 guards to be maintained and kept in position.

The scope of this Regulation 17 is contentious. Wood lathe, portable circular saw, vertical
panel saw, horizontal beam panel saw, radial arm saw, rise and fall saw, tenoner, spindle
sander, belt-disc sander, 3D CNC wood carving machine, wood chip grinding machine,
chain saw, mitre saw, jig saw / scroll saw etc. may be considered as “other machines
operating on wood” and hence should have their safe state of repair and maintenance
legislatively controlled, but the whole set of Regulations is only applicable to WWM which,
however, have very limited definition to include only circular saw, swing saw, pendulum
saw, plain band saw, planning machine, vertical spindle moulding machine and chain
mortising machine.

6.13 Duties of Persons Employed (R. 19)

Employees should use and maintain in proper adjustment the guards together with the
“spikes” or push-sticks and jigs or holders provided.

6.14 Concept Checklist

This chapter is about safety in the use of woodworking machinery. Key points to note
include:
 Introduction to the F&IU (WM) Regulations
 Application of the F&IU (WM) Regulations
 Interpretation of terms
 General safety requirements
 Fencing of a circular saw
 Push-sticks
 Guarding of a swing and pendulum saw
 Guarding of a plain band saw
 Guarding of a planning machine
 Guarding of a vertical spindle moulding machine
 Guarding of a chain mortising machine
 Maintenance
 Duties of persons employed

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6.15 Further Thinking

Many safety practitioners do not know why there is a riving knife at the very end of the
circular saw because it is not spelt out in the law. Do you think there is a need to add this
in?

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 Appendix
A6.1.2 Application of the F&IU (WW) Regulations (R. 2)

The F&IU (WW) Regulations apply to any IU in which any woodworking machine is used.

A6.1.3 Interpretation of Terms (R. 3)

"Circular Saw" (圓鋸，俗稱風車鋸) means a circular saw working in a bench (including

a rack bench) for the purpose of ripping, deep-cutting or crosscutting; but does not include
a swing saw or other saw which is moved towards the wood;

"Plain Band Saw" (普通帶鋸) means a band saw, other than a log saw or a band re-sawing
machine, the cutting portion of which runs in a vertical direction;

"Planing Machine" (刨床) includes a machine for overhand planing or for thicknessing or
for both operations;

"Swing Saw" (搖擺鋸) or "Pendulum Saw" (鐘擺鋸) means a revolving saw mounted in a
frame, column or chassis which is suspended from a pivot above the table, bench or other
support on which the wood is placed and which is operated by being pulled across the table,
bench or other support on which the wood is placed;

“Underground room” (地下室) means a room any part of which is so situated that half or
more of the whole height thereof measured from the floor to the ceiling is below the surface
of the footway of the adjoining street or of the ground adjoining or nearest to the room;

"Woodworking Machine" (木工機器) means any circular saw, swing saw, pendulum saw,
plain band saw, planing machine, vertical spindle moulding machine or chain mortising
machine that operates on wood.

A6.1.4 General Safety Requirements

A6.1.4.1 Stopping and Starting Devices (R. 4)

A woodworking machine shall be provided with an efficient stopping and starting

appliance whose control is in such a position as to be readily and conveniently operated by
the person in charge of the machine.

A6.1.4.2 Clear Space (R. 5)

Sufficient clear and unobstructed space shall be maintained at a woodworking machine

while in motion to enable the work to be carried on without unnecessary risk.

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A6.1.4.3 Floors (R. 6)

The floor surrounding a woodworking machine shall be maintained in good and level
condition, and, so far as practicable, free from chips and other loose material, and shall not
be allowed to become slippery.

A6.1.4.4 Lighting (R. 7)

(a) Adequate lighting shall be provided for a woodworking machine.

(b) Artificial lighting shall be so placed or shaded as to prevent direct rays of light
from impinging on the eyes of the operator while he is operating such machine.
(c) No illumination will be considered adequate which provides less than 160 lux of
light of working area.

A6.1.4.5 Underground Rooms (R. 8)

No woodworking machine shall be worked in any underground room which is certified by

the Commissioner for Labour to be unsuitable for the purpose as regards height,
construction, light, ventilation or in any other respect.

A6.1.4.6 Training (R. 9)

(a) A person while being trained to work a woodworking machine shall be fully and
carefully instructed as to the dangers arising in connexion with such machine and
the precautions to be observed.
(b) No person under 16 years of age shall be employed on any woodworking machine.

A6.1.5 Fencing of Circular Saw (R. 10)

(a) The part of a circular saw below the bench table shall be protected by fencing it
with 2 plates of metal or other suitable material, one on each side of the saw and
such plates shall not be more than 150 mm apart and shall extend from the axis of
the saw outwards to a distance of not less than 50 mm beyond the teeth of the saw.
(b) If metal plates are used for the purpose mentioned in (1), the plate shall:
i) if not beaded, be of a thickness not less than 2 mm;
ii) if beaded, be of a thickness not less than 1 mm.
(c) Behind and in direct line with the circular saw there shall be a riving knife, which
shall:
i) have a smooth surface;
ii) be strong, rigid and easily adjustable;
iii) be so positioned that the edge of the knife nearer the saw shall form an arc of
a circle having a radius not exceeding the radius of the largest saw used on
the bench;

156
 iv) be maintained as close as practicable to the saw, having regard to the nature
of work being done at the time, and, at the level of the bench table, be so
positioned that the distance between the front edge of the knife and the teeth
of the saw does not exceed 15 mm;
v) for a circular saw of a diameter of less than 600 mm, extend upwards from
the bench table to within 25 mm of the top of the saw;
vi) for a circular saw of a diameter of 600 mm or more, extend upwards from the
bench table to a height of not less than 250 mm.
(d) The top of a circular saw shall be covered by a strong and easily adjustable guard,
with a flange at the side of the saw furthest from the fence; and such guard shall:
i) be kept so adjusted that the flange shall extend below the roots of the teeth of
the saw;
ii) extend from the top of the riving knife to a point as low as practicable at the
cutting edge of the saw.
The above shall not apply to a WWM where it can be shown that other safeguards are
provided and maintained, which render the machine equally safe as it would be if guarded
in the manner specified in the F&IU (WWM) Regulations.

A6.1.6 Push-sticks (R. 11)

A suitable push-stick shall be kept available for use at the bench of a circular saw that is
fed by hand so as to enable the work to be carried on without unnecessary risk.

A6.1.7 Guarding of Swing and Pendulum Saw (R. 12)

(a) A swing saw or pendulum saw shall be guarded as far as practicable and shall be
so designed and maintained that it automatically returns to the back position when
released at any point of its travel.
(b) A swing saw or pendulum saw shall be provided with limit chains or other
effective devices to prevent the front edge of the saw being pulled out in front of
the work table; and such chains or devices shall be maintained in good working
order.

A6.1.8 Guarding of Plain Band Saw (R. 13)

A plain band saw shall have:

(a) both sides of the bottom pulley completely encased by sheet metal or other
material;.
(b) the front of the top pulley covered with sheet metal or other suitable material;
(c) all portions of the blade enclosed or securely guarded, except the portion of the
blade between the bench table and the top guide.

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The above shall not apply to a WWM where it can be shown that other safeguards are
provided and maintained, which render the machine equally safe as it would be if guarded
in the manner specified in the F&IU (WWM) Regulations.

A6.1.9 Planing Machines (R. 14)

(a) No planing machine, which is not mechanically fed, shall be used for overhand
planing unless it is fitted with a cylindrical cutter block.
(b) A planing machine used for overhand planing shall be provided with a “bridge”
guard capable of covering the full length or breadth of the cutting slot in the bench,
and shall be so constructed as to be easily adjusted both in a vertical and horizontal
direction.
(c) The feed roller of a planing machine used for thicknessing, except a machine used
both for overhand planing and thicknessing, shall be provided with an efficient
guard.
(b) and (c) above shall not apply to a WWM where it can be shown that other safeguards
are provided and maintained, which render the machine equally safe as it would be if
guarded in the manner specified in the F&IU (WWM) Regulations.

A6.1.10 Vertical Spindle Moulding Machine (R. 15)

(a) The cutter of a vertical spindle moulding machine shall, where practicable, be
provided with the most efficient guard having regard to the nature of the work
being performed.
(b) For such work as cannot be performed with an efficient guard for the cutter, the
wood being moulded at a vertical spindle moulding machine shall, where
practicable, be held in a jig or holder of such construction as to reduce as far as
possible the risk of accident to the person working on the machine.
(c) A suitable “spike” or push-stick shall be kept available for use at the bench of a
vertical spindle moulding machine.

A6.1.11 Chain Mortising Machine (R. 16)

The chain of a chain mortising machine shall be provided with a guard that shall enclose
the cutters so far as practicable.

A6.1.12 Maintenance (R. 17)

(a) All tools, blades and cutting instruments of a woodworking machine and other
machines operating on wood shall be:
i) kept free from patent defect;
ii) properly maintained;
iii) kept clean;
iv) properly ground, sharpened and set.

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(b) No saw that is cracked shall be used in a circular saw.
(c) The guards and other appliances required under these regulations shall be:
i) maintained in an efficient state;
ii) constantly kept in position when the machine is in motion, except when,
owing to the nature of the work being done, the use of the guards or
appliances is rendered impracticable;
iii) so adjusted as to enable the work to be carried on without unnecessary risk.

A6.1.13 Duties of Persons Employed (R. 19)

A person employed on a woodworking machine shall:

(a) use and maintain in proper adjustment the guards provided;
(b) use the “spikes” or push-sticks and jigs or holders provided,
except when, owing to the nature of the work being done, the use of the guards or
appliances is rendered impracticable.

References

Factories and Industrial Undertakings (Woodworking Machinery) Regulations 1971, Hong

Kong, Available at http://www.elegislation.gov.hk/hk/cap59G (Accessed on 31
December 2019).
Health and Safety Executive (2004) “Safe Working at Woodworking Machines”, HSE
Information Sheet WIS 15, HSE, U.K.
Health and Safety Executive (2008) “Example Risk Assessment for a Woodworking
Company”, HSE, U.K.
Health and Safety Executive (2014) “Retrofitting Woodworking Machine Brakes”, HSE,
U.K.
Health and Safety Executive (2015) “Safe Use of Woodworking Machinery: Provision and
Use of Work Equipment Regulations 1998 (as applied to Woodworking
Machinery); Approved Code of Practice and Guidance”, HSE, U.K.
Labour Department (2006) “A Guide to the Factories and Industrial Undertakings
(Woodworking Machinery) Regulations”, Government Printer, Hong Kong.
Labour Department (n.d.) “Code of Safe Practices in the Woodworking Industry”,
Government Printer, Hong Kong.

159
 Chapter 7
Protection against Falling Objects; Safety in the Use of Ladders

7.1 Introduction

A falling object is one of the major causes of workplace fatalities in construction sites. It
normally occurs when there is work to be carried out at height, in particular from working
platforms on external wall scaffolding or internal high-level maintenance and renovation
jobs. Most of the time, it is due to the negligence of the workers working aloft, but
sometimes materials such as handtools or dismantled bamboo pieces are purposely thrown
down for convenience sake.

Ladders are used widely in the construction industry and in facilities management
operations. However, a lot of construction workers tend to misuse ladders as mobile
working platforms. Ladders are basically designed for access and egress, because the
worker will usually work with both hands on the ladder resulting in two- and not three-
point contact. In general, work at a height less than 2 m above the ground is called work-
above-ground while work at 2 m or more above the ground is called work-at-height.

According to the Labour Department, where it is necessary to work at height, the use of
bamboo scaffolds, metal scaffolds, truss-out bamboo scaffolds, suspended working
platforms and power-operated elevating working platforms should be considered. In no
case shall a ladder be used for work at 2 m or more above the ground. For work-above-
ground, workers should use a mobile working platform or light-duty working platform,
which includes a step platform and hop-up platform.

A stepladder should also not be used unless there are very exceptional circumstances and
after having conducted a task-specific risk assessment. If the use of a stepladder is
unavoidable, stringent control, such as a permit-to-work system, should be implemented to
ensure that adequate and suitable control and safety measures are in place. In general,
ladders can be only be considered for work-above-ground when the workplace makes it
infeasible to erect any working platform, such as inside a room with limited space.

7.2 Legal Requirement on Protection against Falling Objects

(CS(S)R R. 49)

 The contractor shall take precautions to prevent any workman from being struck by
any falling material or object.
 The contractor shall ensure that scaffolding materials, tools or other objects and
materials are not thrown, tipped, or shot down from a height liable to cause injury
to any person on or near the site, and where practicable, properly lowered in a safe
manner by means of a lifting appliance or lifting gear.

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7.3 Safety Precautions against Falling Objects

A safe system of work should be implemented to ensure that safety measures have been
taken to protect against falling objects which include:
 Provision of toe-boards on working platforms, gangways, floor edges and floor
openings.
 Provision of tool bags and/or hand-strings for workers who are required to work at
height.
 Refuse should be tipped down from refuse chutes.
 Ensure safe lifting of all plant and materials. Use guide ropes for lashing where
practicable.
 Loose rocks or mud on slopes and near excavation edges should be removed. Erect
proper warning signs and demarcation where loose rocks that are likely to topple
cannot be removed.
 Ensure proper stacking of materials.
 Ensure proper loading and unloading of cargo and goods.
 Erection of nets and catch fans outside scaffolding or other structure when there is
a risk of objects falling from above, and wearing of safety helmets are statutorily
required safety precautions which, however, are not controlling the hazard at
source.

7.4 Legal Requirements on the Safe Use of Ladders (R. 38C

and 38D)

Ladders are only used for access, and are not allowed to be used for work except where it
is not practicable to use a proper working platform. Risk assessment must be made to
substantiate such impracticability. Where the work involves a fall of 2 m or more, a proper
working platform must be erected for use.

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Sources (Issued by Labour Department): Overview of Work-at-Height Safety (2018); Safety Guide on Use
of Light-duty Working Platform and Mobile Working Platform (2016); (Issued by Occupational Safety &
Health Council): Safe Use of Movable Ladders (2006).

7.5 Stepladder with Rungs on Both Sides and Placement of

Stepladder Against a Wall

A usual practice is that a ladder should not have more than one person standing on it to
avoid the ladder being overloaded, and also to prevent the person below from being hurt if
the person above slips or falls down the ladder. However, a question of whether a
stepladder with rungs on both sides is designed to allow persons to be aloft simultaneously
on these two sides will arise. If not, then why would it be designed to have rungs on both
sides? It appears that the first concern can be addressed by the robust construction of some
heavy-duty ladders to cater for the weight and movement of two persons on it, and the other
concern would only exist for a straight ladder, not a stepladder.

According to HSE, when working on a stepladder, it should be placed perpendicular to a

wall instead of leaning parallel to the wall. However, this will require more space and as
said above, the use of a stepladder will only be considered in exceptional circumstances
such as limited space where erection of a mobile working platform or light-duty working
platform is not feasible. Taking this into consideration, there is almost no safe way to use
a stepladder for work except in very rare circumstances, such as work at the junction point
of a T-shaped passageway.

7.6 Load Capacity

The load capacity of a ladder depends on its type (ANSI Code) / Grade (CSA Code) and
its usage:
 Type / Grade III, Light Duty Household: 200 lb;
 Type / Grade II, Medium Duty Commercial: 225 lb;
 Type / Grade I, Heavy-duty Industrial: 250 lb;
 Type / Grade IA, Extra Heavy-duty Industrial: 300 lb;
 Type / Grade IAA, Special Heavy-duty Rugged: 375 lb.

On the other hand, the classification in the BS2037 / EN131 system is different:
 Class III, Domestic: 125 kg
 Class EN131 (replaces BS2037 Class II, Trade), Professional: 150 kg
 Class I, Industrial: 175 kg.

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7.7 Safe Angle of Erection of a Straight Ladder and a
Stepladder

A straight ladder is usually set at 70-75 degrees to the ground, which is considered to be
the safe angle. This amounts to a ratio of 1:4 (1 m out from the base of the wall for every
4 m rise). This also applies to the slope of the sides of a stepladder. Hence the metal hinges
on both sides of a stepladder should be so fixed that when the hinges are fully extended,
the safe ratio will be maintained on both sides.

However, originally this 1:4 meant 1 m out from the base for every 4 m length of the ladder,
which is the slant side (hypotenuse) and not the vertical rise. The safe angle will then be
75.5 degrees. It is impracticable for a worker to bring a protractor to work in order to set
the straight ladder at the correct angle against a wall. As indicated above, he/she can
estimate by having the ladder set at a ratio of 1:4, but again, he/she is still making an
estimation of this ratio. One good suggestion for a ladder with rectangle stiles is to use a
protractor to set the ladder at the safe angle, then with the help of a leveler mark a horizontal
and a vertical line on one side of the stiles and then join them together so that the slant side
is parallel to the surface of the erected ladder. The next time the ladder is erected, the
worker can use his eyes to judge whether these lines are level and plumbed.

Another approximating method is to stand with the tip of the shoes touching the base of
the stiles. If the ladder is so erected that when the extended hands are laid flat and they are
just touching the rung, the slope of the surface of the ladder is roughly set at the safe angle.
This is called the ANSI A14 Anthropometric Method which closely resembles the
Fireman’s Method.

A more scientific method is to either fit a proprietary leveler (called a 755 leveler) onto the
side of the ladder, or to use a NIOSH Apps which will give visual and audible indication
if the angle setting is not correct.

7.8 Three-Point Contact

Three Point Contact is commonly understood as having three of the limbs of a person
always in contact with the ladder. These three limbs are either two hands and a foot (left
or right), or one hand (left or right) and two feet.

There are a lot more safety concepts that can be deduced from Three Point Contact. These
include:
 Do not extend the body, in particular overreaching one hand, beyond the stiles of
the ladder, because this may entail lifting the opposite foot off the rung of the ladder
on which the foot rests, in order to keep the body balanced. This would result in
only Two Point Contact.

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  Do not take any tool or material up or down a ladder, because this would also result
in repeated Two Point Contacts when a hand or foot is moved when ascending or
descending the ladder.
 Also face the ladder when descending a straight ladder / cat ladder, because if the
person backs the ladder during descent, it would be impracticable for him/her to
hold the ladder and thus unable to maintain Three Point Contact.
 When a person is ascending or descending a ladder, or temporarily working on a
ladder and another person is holding the stiles of a ladder on the ground, the person
on the ground should also position one foot on the bottom rung of the ladder to
effect a Three Point Contact in order to prevent the ladder from slipping.
 When a person is using a stepladder as a temporary working platform for light work,
this person should press or anchor his/her belly on the ladder to maintain Three
Point Contact on the stepladder.

7.9 Safe Climbing Up and Down a Cat Ladder and Two-Point

Contact

Workers are rarely trained in how to safely climb a cat ladder. Should the stiles or rung be
held when climbing up or down a cat ladder? Also, when the left hand is raised to hold the
higher level of either the stile or rung, then should the left or the right foot be ascended?
Research has shown that the climber can have a firmer grip when the rung instead of the
stiles is held when climbing a ladder because if the stiles are held, the hand may slip and
slide if the foothold is lost or missed.

In addition, in order to minimize the sway in the centre of gravity (C.G.) of the climber
during ascent or descent, when the left hand is raised and the upper rung is held, the left
foot should be ascended instead of the right foot but this needs to be done at the same time,
and hence only two-point contact can be achieved. The rationale behind this is that the
C.G. of the climber is at the centre of ladder only if the 4 points of contact (both hands and
feet) of the climber form a rectangle- or parallelogram-shaped quadrilateral on the ladder
and if any limb is moved up, then the quadrilateral will become a trapezium whose C.G. is
either on the left side or right side of the centre line on the ladder. As such, the C.G. of the
climber will sway to the left and when another limb is moved up, to the right of the centre
of the ladder.

It is easy to visualize that in order to maintain the C.G. of the climber to stay on the centre
line of the ladder all the time, it will require, when settled on the ladder stiles and/or rungs,
the 4 limbs of the climber to form either a rectangle or parallelogram on the ladder. Moving
any one limb, so as to keep Three Point Contact on the ladder, will undoubtedly render this
balanced quadrilateral to become a trapezium, whose C.G. must be either on the left or on
the right of the centre line of the ladder. The result is the same as in the above, i.e. the C.G.
of the climber will sway to and from the left and right of the centre line of the ladder. On
the contrary, to maintain the C.G. at the centre of ladder when ascending the ladder, the
hand and foot on the same side must be moved simultaneously, and hence the climber can

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only maintain Two Point Contact instead of Three. The same applies when descending the
ladder. This method of climbing is called the Fireman’s Ladder Climbing Method and has
been adopted by many fire bureaus around the world.

7.10 Top of Ladder/Stepladder

For a straight ladder used for access, it is necessary to have the top of the ladder protruding
about 1 to 1.05 m above a landing place, so that the ladder will not slip down the wall
during ascent or descent, and that the protrusion can act as a handhold when alighting the
ladder. When performing light work on a ladder or stepladder, it is prudent to avoid
standing on the top 3 steps so that the body can lean against the ladder for better stability.

7.11 Other Safety Precautions

Other safety precautions in the use of ladders include:

 Choose the correct ladder for the job. An insulating ladder, such as a wooden or
fiberglass one with rubber footings, should be used for electrical works. Make sure
the ladder is of sufficient length and never extend its height by putting it on boxes
or other objects, or joining two ladders together.
 Make sure the ladder is set on a firm and level ground.
 Folding stepladders should be fitted with metal hinges at the sides which are fully
opened when in use.
 Only one person should stay on the ladder at any one time, unless otherwise
explicitly permitted for a stepladder.
 Wear safety shoes or other anti-slip shoes when climbing up or down a ladder.
 Do not move a stepladder by body motion, e.g. clipping the ladder with the legs to
reach another position.
 Ladders should not be painted so that cracks can be masked.
 Defective ladders should not be used.
 Make sure the footwear is free from mud or grease before climbing up a ladder.
 Ensure there is sufficient space behind the steps to provide a proper footing.
 Be aware of overhead objects or electric cables while ascending or using a ladder.
 Properly store and maintain a ladder. A straight ladder should either be laid flat
against the footing of a wall, or if vertically laid against a wall, be fastened properly
by chains or ropes secured to the wall to prevent it from toppling over.
 Do not use makeshifts, such as chairs, cylinders or boxes, to replace a ladder.
 Do not join short ladders together to form long ones.
 Do not paint a wooden ladder since the paint may cover up cracks and defects in
the ladder.

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  Fixed access ladders (sometimes called cat ladders) are widely used as means of
access to and egress from tower cranes, overhead structures in construction works
(e.g. flyovers), water tanks in buildings, lift machine rooms, shafts, etc. For cat
ladders reaching a height of 3 m or more, the following points should be noted:
 suitable safety hoops should be installed;
 the spacing of the safety hoops should not exceed 1 m;
 the lowest safety hoop should be installed at a height not exceeding 3 metres
above the ground;
 the highest safety hoop should be installed 1 m above the upper end of access
and egress. If it is a working platform, the hoop should be connected to the
guard-rail of the platform; and
 there should be a suitable landing place or rest platform at an interval not
greater than 9 m along the fixed access ladder. The landing place or rest
platform should be fitted with suitable guard-rails.
 consideration should be given to the provision of a personal fall-arrest system.
This is a mandatory requirement by OSHA for ladders over 24 feet high.

7.12 Concept Checklist

This chapter is about protection against falling objects and safety in the use of ladders. Key
points to note include:
 Introduction
 Legal requirement on protection against falling objects
 Safety precautions against falling objects
 Legal requirements on the safe use of ladders
 Stepladder with rungs on both sides and placement of stepladder against a wall
 Load capacity
 Safe angle of erection of a straight ladder and a stepladder
 Three-point contact
 Safe climbing up and down a cat ladder and two-point contact
 Top of ladder / stepladder
 Other safety precautions

7.13 Further Thinking

In some jurisdictions, there is a distinction between 3-point contact and 3-point control.
The latter is considered more secure in that the contact point can slip (e.g. the garbage
collector standing on the rear of a garbage truck with his palm pressing onto the base of the
ceiling in his standing position without a firm grip can easily lose his balance and fall off
when the garbage truck makes a sharp turn). Do you agree with this?

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References

Campbell A.O. and Pagano C.C. (2014) “The Effect of Instructions on Potential Slide-out
Failures during Portable Extension Ladder Angular Positioning”, Accident
Analysis and Prevention 67 (2014) 30-39.
Construction Sites (Safety) Regulations 1978, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap59I (Accessed on 31 December 2019).
Health and Safety Executive (2005) “Safe Use of Ladders and Stepladders: An Employer’s
Guide”, INDG 402, HSE Books, U.K.
Health and Safety Executive (2014a) “Safe Use of Ladders and Stepladders: A Brief
Guide”, INDG 455, HSE Books, U.K.
Health and Safety Executive (2014b) “Working at Height: A Brief Guide”, INDG 401,
HSE Books, U.K.
Hsiao H. (2014) “Fall Prevention Research and Practice: A Total Worker Safety
Approach”, Industrial Health 52 (2014) 381-392.
Hsiao H., Simeonov P., Pizatella T., Stout N., McDougall V. and Weeks J. (2008)
“Extension-ladder Safety: Solutions and Knowledge Gaps”, International Journal
of Industrial Ergonomics 38 (2008) 959-965.
Labour Department and Occupational Safety and Health Council (2008) “Safety at Work:
A Guide to Ladders and Elevated Working Platforms”, Government Printer, Hong
Kong.
Labour Department and Occupational Safety and Health Council (2017) “Safety Guide on
Use of Light-duty Working Platform and Mobile Working Platform”, OSHC,
Hong Kong.
Lombardi D.A., Smith G.S., Courtney T.K., Brennan M.J., Kim J.Y. and Perry M.J. (2011)
“Work-related Falls from Ladders - A Follow-back Study of US Emergency
Department Cases” Scandinavian Journal of Work Environment and Health 2011
37(6):525-532.
McIntyre D.R. (1983) “Gait Patterns During Free Choice Ladder Ascents”, Human
Movement Science 2 (1983) 187-195, North-Holland.
NIOSH (2013) “Ladder safety App User’s Manual (Android OS)”, DSFederal Inc.
Partridge R.A., Virk A.S. and Antosia R.E. (1998) “Causes and Patterns of Injury from
Ladder Falls” Acad. Emerg. Med. 1998 (5):31-34.
Phelan D. and O’Sullivan L. (2014) “Should Muscle Loading and Task Performance for
Overhead Work on Ladders versus Mobile Elevated Work Platforms” Applied
Ergonomics 45 (2014) 1384-1391.
Pliner E.M., Seo N.J. and Beschorner K.E. (2017) “Factors Affecting Fall Severity from a
Ladder: Impact of Climbing Direction, Gloves, Gender and Adaptation”, Applied
Ergonomics 60 (2017) 163-170.
Schnorenberg A., Campbell-Kyureghyan N.H. and Beschorner K.E. (2015)
“Biomechanical Response to Ladder Slipping Events: Effects of Hand Placement”,
Journal of Biomechanics 48 (2015) 3810-3815.
Simeonov P., Hsiao H., Powers J., Ammons D., Kau T., Cantis D., Zwiener J. and Weaver
D. (2017) “Evaluation of a ‘Walk-through’ Ladder Top Design During Ladder-
roof Transitioning Tasks”, Applied Ergonomics 59 (Pt. A) (2017) 460-469.

167
Simeonov P., Hsiao H., Powers J., Kim I.-J., Kau T.-Y. and Weaver D. (2013) “Research
to Improve Extension Ladder Angular Positioning”, Applied Ergonomics 44
(2013) 496-502.
Simeonov P., Hsiao H., Powers J., Kim I.-J., Powers J.R. and Kau T.-Y. (2012) “Factors
Affecting Extension Ladder Angular Positioning”, Human Factors: The Journal of
the Human Factors and Ergonomics Society 54 (2012) 334-345.
Workplace Safety and Prevention Services (WSPS) (2014) “Ladder Safety”, WSPS,
Ontario.

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 Chapter 8
Safety in Cargo and Container Handling

8.1 Introduction

Handling of cargo at docks, quays and wharves and the handling of containers in container
yards can be very hazardous. Dock and container work involve many different
stakeholders, including contractors, self-employed persons, port authorities, stevedoring
company staff, transport and logistics company staff, custom officials, terminal operators,
shipping agents and ships’ crews carrying out work simultaneously at the same or nearby
locations. Hence the management of health and safety requires good coordination and
cooperation amongst these parties.

As for container handling, Hong Kong is one of the busiest container handling ports in the
world. Since heavy mechanical equipment such as rubber-tyre gantry cranes, reach
stackers, heavy-duty fork-lift trucks are commonly used in this trade, serious accidents
have happened in operating the equipment. The Labour Department has also issued a Code
of Practice on Mechanical Handling Safety in Container Yards (“the CoP”) that control the
safe handling of containers and mechanical equipment in container storage areas and
container yards, including container terminals, mid-stream container ports, river-trade
terminals, public cargo working areas, docks, quays, wharfs etc., in which container
handling takes place.

Safety requirements on the handling of cargo and/or containers on board any floating
vessels, or the use of lifting appliances or lifting gear on any vessel afloat, are however
handled by the Marine Department. Apart from the hazards involved in cargo and/or
container handling, there exist other general and specific hazards in the shipbuilding and
ship-repairing industry. General hazards include those involving paint spraying, working
at height, arc and gas welding, entry into a confined space, use of corrosive or flammable
chemicals, electrical work etc. Apart from these, there are specific hazards that are not
commonly found in other trades and which will be discussed later. A permit-to-work
system should be applied to some works that involve general hazards such as entry into a
confined space, certain electrical work, as well as to all works that involve specific hazards.

Both the handling of cargo at docks, quays and wharves and the handling of containers in
container yards may involve working over or near water as the cargo or containers are
delivered by sea on barges or cargo ships. During loading and unloading of cargo to and
from these sea-going vessels, the worker is liable to fall into the sea. Apart from this, some
construction activities may also take place over or near the sea, such as reclamation,
construction of piers, building of bridges that span across the waterway.

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Source (Issued by Labour Department): A Guide to the F&IU (Cargo & Container Handling) Regulations
();A Guide to the F&IU (Cargo & Container Handling) Regulations (); A Guide to the F&IU (Cargo &
Container Handling) Regulations.

8.2 Factories and Industrial Undertakings (Cargo and

Container Handling) Regulations (Cap. 59K)

In general, this piece of legislation requires the proprietor to ensure:

 every regular approach over a dock, quay or wharf and every work place is safe;
 all breaks, dangerous corners, and other dangerous parts or edges of the dock, quay
or wharf are, so far as practicable securely fenced to a height of at least 750 mm;
 adequate provisions for the rescue from drowning of persons employed is made and
maintained, including life-saving appliances;
 all work places and any dangerous parts of the regular road or way over a dock, quay
or wharf, forming the approach from the nearest highway, are efficiently lighted;
 electrical equipment and circuits are designed, constructed, installed, protected and
maintained to prevent danger from contact and fire by cutting off all pressure from
every part of the system in case of accident or to prevent danger;
 electrical equipment for use in places with an explosion risk is of a suitable
flameproof type;
 electrical equipment exposed to the weather is adequately protected against wetness
or corrosion;
 portable electric equipment is inspected by a CP at least once in each day of use;
 portable or flexible electric conductors are kept clear of loads, running gear and
moving equipment;
 portable electric lamps are used only where adequate permanent fixed lighting cannot
be provided; and at a pressure safe in the particular conditions.

The owner of a fork-lift truck shall not use the truck, or cause or permit it to be used, for
cargo or container handling unless it is properly maintained, and the person operating it is
trained and competent to operate it. “Owner” includes the person by whom the truck is
kept and used and, if the truck is the subject of a hiring agreement or hire purchase
agreement, means the person in possession of the truck under that agreement.

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No person shall, unless he is authorized by the proprietor or except in case of necessity,
remove or interfere with any fencing, life-saving means or appliances, light or other thing.
If anything is removed, such thing shall be restored, at the end of the period during which
its removal was necessary, by the person last engaged in the work that necessitated such
removal.

Where cargo or goods are placed on a dock, quay or wharf, a clear passage leading to the
means of access to a vessel which is lying at the dock, quay or wharf shall be maintained,
and if any space is left along the edge of the dock, quay or wharf, it shall be at least 900
mm wide and clear of all obstructions other than fixed structures, plant and appliances in
use.

Where stacking or unstacking of cargo or goods, or handling in connexion therewith,

cannot be safely carried out unaided by some method of securing the cargo or goods,
reasonable measures to guard against accident shall be taken by shoring or otherwise.

The proprietor shall, so far as reasonably practicable, ensure that:

 the stacking, unstacking and handling of containers is safely carried out;
 containers are stored, stacked to cause no danger; and
 containers are stacked on level and firm ground.

The proprietor shall take all reasonable steps to ensure that adequate fall protection is
provided to persons working on top of a container.

Sources from https://www.labour.gov.hk/eng/public/content2_8.htm

Source from www.oshc.org.hk

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8.3 Interpretation of Terms on First Aid Facilities (R. 11-15)

The requirements for a first aider and first aid box or cupboard, and the requirement for an
exemption where a first aid room is provided, are similar to those in the CS(S)R.

The proprietor shall provide and maintain one first aid box or cupboard for each 100
persons or part thereof employed in the workplace.

8.4 Safety Requirements Specific to Container Handling

8.4.1 Interpretation of Terms related to Container Handling

(FIUO s. 2; CoP MHSCY s. 2)

The sizes of containers are standardized for easy handling and stacking.

8.4.2 Layout of Container Yard (CoP MHSCY s. 5.1)

 Except at the waterside, the perimeter of an IU for container handling using

mechanical equipment should be fenced. The purpose of the fencing is to ensure that
all people who want to enter the IU are directed to the appropriate entry point, thereby
facilitating control of people, particularly those who may have no appreciation of the
hazards associated with container handling.
 The different areas for container handling such as container storage areas, work areas,
passageways and pedestrian walkways in a container yard should be clearly
designated by floor lines or traffic signs.

Sources (Issued by Labour Department): Overview of Work-at-Height Safety (2018); Safety Guide on Use
of Light-duty Working Platform and Mobile Working Platform (2016); (Issued by Occupational Safety &
Health Council): Safe Use of Movable Ladders (2006).

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8.4.3 Traffic and Pedestrian Control (CoP MHSCY s. 5.2)

 Only authorized vehicles or persons should be allowed to enter into the container
yards.
 Flow pattern of mechanical equipment and vehicles handling containers should be
carefully planned in order to minimize any conflict and potential hazards.
 Proper traffic control measures for mechanical equipment, vehicles and people
should be established to minimize the possibility of accidents.
 Notices requiring pedestrians to use the designated walkways should be prominently
displayed in suitable locations.
 The travelling speed of mechanical equipment and vehicles should be specified and
restricted to ensure traffic safety.
 Safe speed limit signs should be prominently displayed so as to ensure the operators
are aware of them.
 Yard-based vehicles including mechanical equipment should be equipped with
suitable yellow flashing warning lights which should be turned on whenever they are
utilized in a container yard.

8.4.4 Mechanical Equipment (CoP MHSCY s. 5.3)

 Mechanical equipment frequently used in container yards include forklift truck, front
loader, reach stacker, gantry crane, tower crane, mobile crane and similar container
handling equipment.
 To ensure the safety in using mechanical equipment, the equipment should be
frequently inspected, regularly tested, examined and properly maintained so as to
keep it in good working order. Any lifting appliances (LA) used should be tested and
thoroughly examined by a competent examiner in accordance with the F&IU (LALG)
Regulations.
 Mechanical equipment should only be operated by operators who are competent and
authorized to do so, and who have received proper training in the operation of the
equipment. Operators of cranes should hold valid certificates as required under the
F&IU (LALG) Regulations. Operators of forklift trucks should hold valid certificates
as required under the F&IU (Loadshifting Machinery) Regulation.
 Mechanical equipment should not be used to handle a load greater than its safe
working capacity.
 Proper measures should be implemented to prevent unauthorized personnel from
operating mechanical equipment.
 Before operating mechanical equipment, operators should make an inspection with
reference to a checklist to ensure that the equipment is in safe working condition.
 Operators should observe special operating conditions and restrictions in accordance
with those stipulated in the operation manual of mechanical equipment.
 When operating mobile mechanical equipment, special care should be taken:

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  if the ground is slippery;
 to avoid any loose dunnage or waste;
 when passing by or passing through walkways used by personnel;
 when rounding a corner where vision is restricted; or
 in any place where the overhead clearance is limited.
 If the visibility or range of sight of the operator is impaired by adverse weather
conditions, strict supervision of the mechanical equipment operation should be
exercised. Mechanical equipment operations rendered unsafe should be temporarily
suspended.
 Operators should immediately stop operating any mechanical equipment and report
to supervisors if any major malfunction is found or any warning device is out of order.

Sources (Issued by Labour Department): Guidance Notes for Safe Use of Forklift Trucks (2006); Safe
Practices in Operating Fork Lift Trucks (2004); Safe Practices in Operating Fork Lift Trucks (2011); (Issued
by Occupational Safety & Health Council): Safety Hints for Fork Lift Truck Operator (2000); Safety Hints
for Fork Lift Truck Operator (2016).

8.4.5 Forklift Truck (CoP MHSCY s. 5.4)

 The responsible person for a forklift truck should ensure the provision to each of
his employees who is instructed (whether directly or indirectly) by him to operate
a forklift truck of a training course conducted for the type of forklift truck to which
that truck belongs.
 For safe operation of a forklift truck in handling containers, the following safety
precautions should be observed:
 only containers provided with forklift pockets should be lifted by a forklift
truck and the forks should be fully inserted into the pockets. Under no
circumstances should containers, with or without forklift pockets, be lifted by
forks under the base;
 the truck should be fitted with an overhead guard of sufficient strength to
protect the operator from the detachment of loads;
 the fork should be so designed as to prevent accidental detachment or lateral
displacement when in use;

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  any trapping points between fork arm mechanisms and fixed parts of the truck
should be suitably guarded;
 seat belts should be fastened all the time during operation;
 tyre pressures should be checked daily, if appropriate;
 no load should be carried or raised with the mast tilting forward;
 when travelling the fork arms should be lowered to the lowest practicable
position;
 when the load obscures the operator’s forward vision, the truck should be
driven in reverse;
 a safety device when the truck is driven in reverse direction should be provided;
 no person should be allowed to stand or pass under the elevated forks;
 only one container should be handled by the truck at a time unless otherwise
recommended by the manufacturer, and no container should be handled by
more than one forklift truck at any one time;
 fork arms should be fully lowered when the truck is parked; and
 when it is necessary for the operator to leave the truck unattended, the engine
should be turned off with the brakes applied, the ignition and other keys
removed, the fork tilted forwards flush with the floor and clear of the
passageway; and, if the vehicle is on an incline, the wheels should be blocked.

8.4.6 Front Loader and Reach Stacker (CoP MHSCY s. 5.5)

 Lift trucks with special container handling attachments for handling containers are
widely used in Hong Kong. Front loaders and reach stackers are the most common
of these lift trucks.
 For safe operation of a front loader or a reach stacker, the following safety
precautions should be observed:
 seat belts should be fastened all the time during operation;
 tyre pressures should be checked daily;
 where the operator does not have a clear and unrestricted view to ensure safe
operation of the equipment, a signaler should be arranged to give him signals;
 the front loader or reach stacker should be equipped with suitable yellow
flashing warning lights. Safety devices to give out visible and audible warning
signals when it is driven in reverse direction should also be provided;
 only container handling attachments recommended by the manufacturer should
be installed on the equipment;
 for transporting containers with the front loader, the load should be carried with
the main mast tilted backwards, the load carried close to the main mast and as
low as possible to obtain the greatest stability, or in a manner as recommended
by the manufacturer;

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  for transporting containers with the reach stacker, the load should be carried as
close as possible to the truck, i.e. with the boom retracted as far back as possible;
 when it is necessary for an operator to leave the front loader or the reach stack
unattended, it should be parked on level ground with the parking brake applied,
the transmission gear placed to neutral, the ignition key removed, and the
driving cabinet locked. For a front loader, the lifting attachment should be
lowered to the ground. For a reach stacker, the boom should be lowered and
retreated as far back as possible.

8.4.7 Cranes and Other Mechanical Equipment (CoP MHSCY s.

5.6)

 Cranes, except those with a maximum safe working load (SWL) less than 1 tonne
or operated with a grab or any electromagnetic leans, should be fitted with
automatic safe load indicators that function properly.
 For safe operation of a rail-mounted gantry crane (RMGC) or a rubber-tyred gantry
crane (RTGC), the following safety precautions should be observed:
 A suitable spreader should be installed on the gantry crane for the handling of
containers;
 tyre pressures of the RTGC should be checked daily;
 a container should be lifted off from the chassis of a lorry only when the locks
on the chassis are ensured to be disengaged;
 the container should be raised to a height well above the top of the adjacent
stacks of containers before the carriage of a gantry crane or the crane itself
starts to travel;
 a safety device to give out visible and audible warning signals when the gantry
crane is travelling should be provided;
 wheel guards should be in position and properly maintained;
 every control lever and device for controlling the operation of any part of the
equipment should be clearly marked to indicate its purpose and the mode of
operation;
 the SWL of the equipment should be clearly marked;
 care should be taken to avoid jerking actions and abrupt operation of the
equipment. Brakes should not be applied suddenly;
 adequate supervision should be exercised to ensure that the operators follow
safe operating procedures for the equipment; and
 when it is necessary for an operator to leave the gantry crane unattended, it
should be parked at its parking bay, with its power turned off and the driver
cabinet locked. The spreader should be retreated and raised to its topmost
position.

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  For safe operation of tower cranes and mobile cranes, reference should be made to
the respective CoP for Safe Use of Mobile Cranes and Tower Cranes issued by the
Labour Department.

8.4.8 Handling of Containers (CoP MHSCY s. 5.7)

 Before a container is being handled, it is important that the container is safe to be

handled, e.g. the locks for securing the container to the trailer has been completely
unlocked.
 The actual weight of all loaded containers should be ascertained before handling.
 Containers exceeding the safe working load (SWL) of the mechanical equipment
should not be handled.
 Suitable equipment and lifting method for the load should be chosen to ensure the
safe handling of containers.
 A container should normally be lifted with suitable mechanical equipment which
applies a vertical force to the 4 top corner fittings. Examples of such a method
include utilizing the top lift spreader of a gantry crane, or the top lift attachment of
a front loader / reach stacker. The hoisting of a container using the 4 corners is
especially important for handling loaded containers of nominal length of 6 m (20
ft) or more.
 In some container yards, the lifting of containers with a 4-legged sling hooked to
the top corner fittings is adopted. For this method of lifting, the hooks used should
always be placed in an inward to outward direction.
 Every lifting gear (LG) such as a sling or hook used should be of good construction,
sound material, adequate strength, and is free from patent defect.
 It should be tested and thoroughly examined by a competent examiner in the manner
as required by the F&IU (LALG) Regulations, and should not be used to handle
any load exceeding its SWL.
 It should be noted that when a multi-legged sling is used with the sling legs at an
angle, the load in the legs increases as the angle between the legs increases. In all
circumstances, the angle between any 2 legs should not exceed 120o.
 Every LG should be inspected by a competent person before use on each occasion.
Defective gear should be discarded immediately. Cutting the tip of a hook to speed
up the hooking/de-hooking process should not be allowed.
 Lifting containers with forklift trucks or front loaders with side lift attachments is
allowed only if the containers and the equipment are designed for such a purpose.

8.4.9 Landing and Supporting of Containers (CoP MHSCY s. 5.8)

 To avoid any possibility of damage to the containers, containers should be unloaded

carefully.
 Containers should not be dragged or pushed over any surface.

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  A firm, flat, well-drained surface, clear of obstructions and projections on the
ground for supporting containers should be provided.
 On the ground, containers should be directly supported by their 4 bottom corner
fittings only.
 To unload containers onto vehicles, containers should be supported by their corner
fittings only.

8.4.10 Ground Condition of Container Yard (F&IU (CCH) R. 10A(c);

CoP MHSCY s. 5.9)

 Containers should only be stacked on a firm and level ground. In particular no

ground area should be used for container stacking unless:
 it is suitable for the purpose as regards its location, geological, drainage and
ground water conditions;
 it is free from any soft or weak spots;
 it is provided with sufficient drainage system to ensure that it remains firm and
stable at all times;
 where it is formed by filling, it has been adequately compacted and
consolidated to avoid any loose and soft spots;
 it has sufficient load bearing capacity for the purpose and that the imposed load
is uniformly distributed; and
 it has been assessed and certified safe and sufficiently firm and stable by a
qualified geotechnical engineer, if necessary.
 The container yard should be properly maintained. Any unsafe or unusual ground
conditions should be made good immediately.

8.4.11 Stacking of Containers on Ground (CoP MHSCY s. 5.10)

Safe procedure for container stacking, unstacking and handling should be exercised in the
container yard:
 Containers should always be properly stacked and where necessary secured with
stacking cones.
 When stacking containers, adequate contact between the top and bottom corner
fittings should be ensured.
 The stacking height of containers should be as low as possible in accordance with
determinant factors of ground condition, plant and machinery, competency of
workers and the needs of the business.
 Stacks of empty containers should be clustered at all times; whenever there is an
isolated stack, it should be re-shaped to even stacks.

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  If containers are to be stacked in clusters, the ends of rows of stacked containers
should be stepped to improve visibility for container handling equipment moving
onto the avenue from a lane.

8.4.12 Special Precautions for High Wind Conditions (CoP

MHSCY s. 5.11)

 Special consideration should be given to the high wind conditions and the wind
induced funnel effect which may lead to sliding or toppling of containers; large and
empty containers are more likely to be affected by wind. The critical wind pressure
is lower for multiple rows than for single row.
 The following factors should be taken into consideration in order to reduce the wind
effect on containers:
 limiting the stacking height;
 block stowage;
 stacking on a ground area with sound conditions;
 block stowage with loaded containers in the uppermost tier; and
 use of stacking fittings or lashings, in particular for the exposed rows.
Furthermore, containers should be stacked so that the longitudinal axis is in line
with the predominant wind direction. In the case of a storm or typhoon warning,
the containers at the corners of the block should be secured.
 No person should be permitted to enter or remain in a container stacking area if
there is a reason to anticipate container movement due to wind.
 Containers should be lashed in strong winds and container lifting operations should
be suspended in adverse weather conditions.
 The selective closing of certain stack areas in stages must be coordinated to prevent
mechanical equipment working in the same areas where men are applying lashings.
Similar precautions must be taken when the stacks are being unlashed afterwards.

8.4.13 Overhead Electric Lines and Cables (CoP MHSCY s. 5.12)

 Where mechanical equipment in a container yard has a chance of coming close to

any live overhead electric lines or cables, the proprietor should liaise with owners
of the overhead lines, e.g. the power companies, to work out the exact safety
requirements and in devising the safe work plans. Reference should be made to the
Electricity Supply Lines (Protection) Regulation (Cap. 406) and the CoP on
Working near Electricity Supply Lines issued by the EMSD.
 All overhead lines or other electric apparatus should be treated as live unless
declared dead and safe by the relevant authority.

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8.4.14 PPE (CoP MHSCY s. 5.13)

 All workers inside the container yard should wear suitable safety helmets, high
visibility or reflective jackets and safety shoes when working in the container yard.
 Other suitable PPE should be provided to workers in case necessary. Such
equipment includes:
 eye protectors required under the F&IU (Protection of Eyes) Regulations;
 ear protectors required under the F&IU (Noise at Work) Regulations;
 protective clothing and equipment required under the F&IU (Dangerous
Substances) Regulations;
 respirators or breathing apparatus for the protection of workers against all
fumes, dust and other impurities that may be injurious to health; and
 safety harness of a suitable design for the protection of workers against the
hazard of falling from height.
 Training on the proper usage of PPE should be provided to workers who are
required to use the equipment. Supervision should also be made on the proper
usage of this equipment.
 PPE provided should be properly maintained to ensure that they function properly.
They should be replaced periodically in accordance with the manufacturers’
recommendation, or whenever they are found defective.

Sources (Issued by Labour Department): Code of Safe Practices in the Ship-building & Ship-repairing
Industry (n.d.); Codes of Safe Practice for Ship Building and Ship Repairing Industry (1986); (Issued by
Occupational Safety & Health Council): Safety and Health Hints for Shipbuilding and Ship-repairing
Industry (2006).

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8.5 Concept Checklist

This chapter is about safety in cargo and container handling. Key points to note include:
 Introduction
 F&IU (Cargo and Container Handling) Regulations
 Interpretation of terms on first aid facilities
 Safety requirements specific to container handling

8.6 Further Thinking

The F&IU (Cargo and Container Handling) Regulations as well as the CoP on Mechanical
Handling Safety in Container Yards do not particularly specify the maximum number of
containers that can be safely piled. So what do you think the number should be: 3 high? 4
high? 5 high? Or another figure?

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 Appendix

A8.2 Factories and Industrial Undertakings (Cargo and Container Handling)

Regulations

A8.2.1 Interpretation of Terms (R. 2)

“Cargo handling” (貨物搬運) means the loading, unloading or handling of cargo or goods
at a dock, quay or wharf;

“Person employed” (受僱的人) means a person employed in cargo handling;

“Proprietor” (東主) means a proprietor in relation to an industrial undertaking or cargo or

container handling;

“working place” (工作地方) means any place on a dock, quay or wharf in which persons
are employed in cargo handling.

A8.2.2 Access over Docks, etc. (R. 3)

(a) A proprietor shall ensure that every regular approach over a dock, quay or wharf
which persons employed have to use for going to or from a working place and
every working place is maintained with due regard to the safety of the persons
employed.
(b) A proprietor shall ensure that all breaks, dangerous corners, and other dangerous
parts or edges of the dock, quay or wharf are, so far as practicable having regard
to the traffic and cargo handling operations, securely fenced so that the height of
the fence is in no place less than 750 mm, and that the fencing is maintained in
good condition ready for use.

A8.2.3 Rescue from Drowning (R. 4)

(a) A proprietor shall ensure that the provision for the rescue from drowning of
persons employed is made and maintained.
(b) The provision required to be made shall:
i) include life-saving appliances;
ii) be reasonably adequate having regard to all the circumstances; and
iii) be readily accessible for use on the dock, quay or wharf.

A8.2.4 Lighting (R. 5)

A proprietor shall ensure that all working places and any dangerous parts of the regular
road or way over a dock, quay or wharf, forming the approach to any such place from the
nearest highway, are efficiently lighted whenever natural lighting is inadequate.

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A8.2.5 Electrical Equipment (R. 6)

(a) A proprietor shall ensure that a every dock, quay or wharf which is used for cargo
handling:
i) electrical equipment and circuits are of such design, construction and so
installed, protected and maintained as to prevent danger from contact and fire;
ii) electrical equipment and circuits are efficient, and suitably located means are
provided for cutting off all pressure from every part of the system in case of
accident or to prevent danger;
iii) electrical equipment for use in places where there is an explosion risk is of a
suitable flameproof type for the atmosphere in question;
iv) electrical equipment exposed to the weather is adequately protected against
wet or corrosion;
v) portable electric equipment is inspected by a competent person at least once
in every day of use;
vi) portable or flexible electric conductors are kept clear of loads, running gear
and moving equipment;
vii) portable electric lamps are used only:
 where adequate permanent fixed lighting cannot be provided; and
 at a pressure safe in the particular conditions of work.
(b) A proprietor shall not use, or cause or permit the use of, any electric equipment
which does not comply with the above safety requirements or which is defective
or otherwise unsafe.
(c) In the above:
“competent person” (合資格的人) means a person who is:
i) appointed in writing by the proprietor to inspect portable electrical equipment;
and
ii) by reason of training and practical experience, competent to perform the
inspection;

“pressure” (電壓) means the difference of electrical potential between any 2

conductors through which a supply of energy is given, or between any part of either
conductor and the earth.

A8.2.6 Maintenance and Use of Fork-lift Trucks (R. 7)

(a) The owner of a fork-lift truck shall not use the truck, or cause or permit it to be
used, for cargo or container handling unless:
i) it is properly maintained; and
ii) the person operating it is trained and competent to operate it.

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(b) “owner” includes the person by whom the truck is kept and used and, if the truck is
the subject of a hiring agreement or hire purchase agreement, means the person in
possession of the truck under that agreement.

A8.2.7 Removal of Safety Appliances, etc. (R. 8)

(a) No person shall, unless he is authorized by the proprietor or except in case of

necessity, remove or interfere with any fencing, life-saving means or appliances,
light or other thing whatsoever required to be provided.
(b) If any thing is removed, such thing shall be restored, at the end of the period during
which its removal was necessary, by the person last engaged in the work that
necessitated such removal.

A8.2.8 Stacking at Docks, etc. (R. 9)

Where cargo or goods are placed on a dock, quay or wharf:

(a) a clear passage leading to the means of access to a vessel which is lying at the dock,
quay or wharf; shall be maintained on the dock, quay or wharf, and
(b) if any space is left along the edge of the dock, quay or wharf, it shall be at least
900 mm wide and clear of all obstructions other than fixed structures, plant and
appliances in use.

A8.2.9 Safe Means of Stacking or Unstacking (R. 10)

Where stacking or unstacking of cargo or goods, or handling in connexion therewith,

cannot be safely carried out unaided by some method of securing the cargo or goods,
reasonable measures to guard against accident shall be taken by shoring or otherwise.

A8.2.10 Stability of Stacks of Containers (R. 10A)

The proprietor shall, so far as reasonably practicable, ensure that:

(a) the stacking, unstacking of containers, or the handling in connection therewith, is
carried out in a safe and secure manner;
(b) containers are stored, stacked or otherwise arranged in such a manner that no
danger is caused to any person; and
(c) the ground upon which containers are stacked is maintained in a level and firm
condition.

A8.2.11 Safety of Persons on Container Top (R. 10B)

The proprietor shall take all reasonable steps to ensure that no person works on top of a
container unless adequate precautions have been taken to prevent persons falling therefrom.

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A8.2.12 Interpretation of Terms on First Aid Facilities (R. 11)

(a) “person trained in first aid” (曾受急救訓練的人) means a person who:

i) holds a current certificate of competency in first aid issued by the St. John
Ambulance Association;
ii) is a registered nurse within the meaning of the Nurses Registration Ordinance;
or
iii) has otherwise completed a course of training in first aid approved by
certificate under the hand of the Commissioner for Labour.
(b) The number of persons employed in a working place shall be taken to be the
number of persons actually working therein at any one time.

A8.2.13 Provision of First Aid Box or Cupboard (R. 12)

(a) A proprietor shall provide and maintain in every working place so as to be readily
accessible a separate first aid box or cupboard for each 100 persons or part thereof
employed in the working place.
(b) Every first aid box or cupboard shall be of adequate capacity and shall contain the
items specified in Part 1, II, or III, as the case may be, of the Schedule and any
additional items required to be provided by the Commissioner for Labour.
(c) The Commissioner for Labour may be notice in writing require a proprietor to keep
all or any of the following items in a first aid box or cupboard:
i) a sufficient supply of assorted sizes of waterproof adhesive wound dressings;
ii) a sufficient supply of waterproof adhesive plaster;
iii) a sufficient supply of eye baths.
(d) All items kept in a first aid box or cupboard in accordance with this regulation
shall be in good condition at all times.
(e) Nothing except appliances and requisites for first aid shall be kept in a first aid box
or cupboard.
(f) Every first aid box and cupboard shall be marked plainly “FIRST AID” in English
and “急救” in Chinese.
(g) The Commissioner for Labour may by notice in writing require a proprietor to
provide a stretcher for any working place.
(h) A stretcher provided in accordance with a requirement under the above paragraph
shall be:
i) kept alongside the first aid box or cupboard provided under this regulation;
and
ii) maintained in good condition at all times.

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A8.2.14 Standards of Dressings (R. 13)

A proprietor shall ensure that all materials for dressings kept in a first aid box or cupboard
are those designated in, and of a grade or quality not lower than the standards specified by,
the British Pharmaceutical Codex or any supplement thereto.

A8.2.15 Persons Trained in First Aid (R. 14)

(a) Where 30 or more but less than 100 persons are employed in a working place, a
proprietor shall ensure that at least one person trained in first aid is always readily
available during working hours.
(b) Where 100 or more persons are employed in a working place, a proprietor shall
ensure that at least 2 persons trained in first aid are always readily available during
working hours.
(c) A proprietor shall affix to every first aid box or cupboard provided by him a notice
in English and Chinese specifying the names of the persons trained in first aid who
are available and the places where they can be found.

A8.2.16 Exemption where First Aid Room Provided (R. 15)

(a) If a proprietor provides a room on the dock, quay or wharf for the sole purpose of
providing first aid or medical treatment, and makes arrangements so as to ensure
the treatment therein of all injuries occurring in any working place on the dock,
quay or wharf, the Commissioner for Labour may by notice in writing exempt the
proprietor from the requirements to such extent and subject to such conditions as
the Commissioner for Labour may specify in the notice.
(b) A notice of exemption shall be prominently exhibited by a proprietor in the room
provided.

A8.2.17 Exhibition of Notices (R. 16)

Notices in English and Chinese shall be exhibited by a proprietor in prominent positions at

every dock, quay and wharf which is used for cargo handling stating:
(a) the location of the rescue and life-saving appliances provided;
(b) the location of first aid boxes or cupboards provided;
(c) the position of the stretcher, if one is required to be provided;
(d) where the relevant regulation applies, the location of the room provided for the
treatment of injuries.

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A8.3 Safety Requirements Specific to Container Handling

A8.3.1 Interpretation of Terms related to Container Handling (FIUO s. 2; CoP MHSCY

s. 2)

According to the s. 2 of the F&IU Ordinance as well as the Code of Practice on Mechanical
Handling Safety in Container Yards,
“container” (貨櫃) means an article of transport equipment:
(a) of a permanent character and accordingly strong enough to be suitable for repeated
use;
(b) specially designed to facilitate the transport of goods, by one or more modes of
transport, without intermediate reloading;
(c) designed to be secured or readily handled or both and having corner fittings for
these purposes; and
(d) of a size such that the area enclosed by the 4 outer bottom corners is either:
i) at least 14 sq. m.; or
ii) at least 7 sq. m. if it is fitted with top corner fittings.

“corner fittings” (夾角接頭) means an arrangement of apertures and faces either at the top
or at the bottom or both at the top and the bottom of a container for the purposes of handling,
stacking and securing of any of these purposes.

References

Factories and Industrial Undertakings (Cargo and Container Handling) Regulations 1978,
Hong Kong, Available at http://www.elegislation.gov.hk/hk/cap59k
(Accessed on 31 December 2019).
International Labour Organization (2005) “ILO Code of Practice: Safety and Health in
Ports”, 1st ed., Geneva.
Labour Department (n.d.) “Safe Handling of Containers”, Container Handling Central
Committee, Hong Kong.
Labour Department (1992) “Safe Practices for Container Handling” Feb. 1992,
Government Printer, Hong Kong.
Labour Department (2001) “Code of Practice on Mechanical Handling Safety in Container
Yards”, Government Printer, Hong Kong SAR.
Labour Department (2006) “A Casebook of Occupational Fatalities in the Container
Handling and Storage Sector”, Government Logistic Department, Hong Kong.
Labour Department (2007) “A Guide to the Factories and Industrial Undertakings (Cargo
and Container Handling) Regulations, December 2007, Hong Kong.
Labour Department (2008) “A Safety Guide for Freight Container Inspection”,
Government Logistic Department, Hong Kong.
Occupational Safety and Health Council (1994) “Safety Guide for Cargo Unloading on
Vessels”, OSHC, Hong Kong.

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Occupational Safety and Health Council (1999) “Safety Guide for Container Loading,
Unloading and Transportation”, OSHC, Hong Kong.
Occupational Safety and Health Council (2015) “Safety Tips for Container Truck Drivers”,
OSHC, Hong Kong.
Occupational Safety and Health Council and Marine Department (n.d.) “Safety Kits for
Cargo Handling on Vessels”, OSHC / Mardep, Hong Kong.

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 Chapter 9
Goods Lift Safety; Quarry Safety; Boiler and Pressure Vessel
Ordinance and Subsidiary Regulations; Shipbuilding and Ship
Repairing; Work Over/Near Water

9.1 Introduction to Goods Lift

Goods lifts, commonly known as a dumbwaiters, are small cargo elevators designed to lift
small goods from floor to floor. In an industrial setting, they are typically found in
restaurants between the kitchen and the service counter, as well as in multi-storey factory
units owned by the same proprietor.

9.2 Factories and Industrial Undertakings (Goods Lifts)

Regulations (Cap. 59O) (R. 2-10)

The owner of a goods lift shall ensure the following safety measures are taken:
 The lift shall be of good mechanical construction, made of sound materials and be
properly maintained.
 The lift shall be thoroughly examined by a competent examiner at least once
annually and a report of the examination entered in a statutorily required register.
 Where an examination shows that the lift cannot be used with safety unless certain
repairs are carried out immediately, or within a specified time, the examiner shall,
not later than 28 days after the completion of the examination, send a copy of the
report of the examination to the Commissioner for Labour.
 The owner of a lift shall keep a register in a prescribed form containing a report of
every examination, with each entry therein signed by the person carrying out the
examination, and on being requested by an OSO, produce the register for inspection.
 The liftway of a lift shall be protected by a substantial enclosure fitted with doors
with an interlocking device, which cannot be casually opened unless in an
emergency or during repairs or examination.
 The enclosure of a liftway shall prevent, when the doors are closed, any person
entering or falling down the liftway or coming into contact with any moving part of
the lift.
 The lift and the enclosure of the liftway shall prevent any goods carried in the car
or platform from being trapped between the car or platform and the moving parts
of the lift or any fixed structure.
 There should be provided and maintained for every lift adequate lighting for the car
or platform and at each landing place, a “stop” switch or ‘stop” push for stopping
the lift; and automatic devices to prevent the lift from overrunning.

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  No operating switch shall be installed in or on the car or platform of the lift.
 There should be displayed conspicuously in or on the car or platform notices in
English and Chinese stating the maximum working load which the lift can safely
carry and that the carriage of persons in the lift is prohibited.
 No load greater than the load stated in the notice shall be carried in a lift.
 No person shall travel or cause or permit any other person to travel in a lift.
 Every person engaged in the operation of a lift shall report to the owner any defect
in the operation mechanism or safety devices fitted to the lift or liftway.

Source (Issued by Labour Department): Guide to Safe Regulations on Goods Lift (1995); A Guide to the
F&IU GL Reg (2007).

9.3 Introduction to Quarrying

Quarrying is a hazardous trade that involves a series of workplace hazards, including

inhalation of dust or fumes, high noise levels, excessive vibration, badly designed places
of work resulting in musculoskeletal disorders, skin contact with chemicals, exposure to
direct sunlight and injury as a result of the use of mechanical plant and heavy earthmoving
equipment. In Hong Kong, quarrying work is mainly regulated by the Mines Division of
the Civil Engineering and Development Department under Mines (Safety) Regulations
(Cap. 285B). Labour Department regulates quarry safety under the Quarries (Safety)
Regulations (Cap. 59F). In recent years, due to the rapid development of the property
market, there are less and less quarries that inherently require a lot of open spaces to operate.
There is only one quarry, Lam Tei Quarry, in Hong Kong where locate at Tuen Mun. It is
still in operation with its operating contract expiry in 2022/23.

9.4 Quarries (Safety) Regulations (Cap. 59 F)

R.1 Citation
R. 2 Interpretation
R. 3 Application for Approval as Supervisor
R. 4 Grounds for Approval of Supervisor
R. 5 Application for Approval as Deputy Supervisor

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R. 6 Grounds for Approval of Deputy Supervisor
R. 7 Commissioner for Labour to Serve Notice of Decision on Applicant
R. 8 Approval to be Withdrawn on Request
R. 9 Proprietor to Give Notice of Termination of Employment of Supervisor or
Deputy Supervisor
R. 10 Grounds on which Approval of Supervisor or Deputy Supervisor may be
Withdrawn
R. 11 Time Limit for Appeal
R. 11A Operation of Decision in Case of Appeal
R. 12 Powers of Chief Executive on Appeal
R. 13 Permission for Supervisor or Deputy Supervisor to Continue to Act Pending
Appeal
R. 14 Registers to be Kept in Quarry
R. 15 Quarry to be Fenced
R. 16 Warning Notices
R. 17 Proprietor to Provide Safety Helmets
R. 18 Proprietor to Provide Safety Rope or Harness
R. 19 Certain Number of Workers to be Trained in First Aid
R. 20 Proprietor to Deliver to Commissioner for Labour Particulars of Persons Trained
in First Aid
R. 21 First Aid Equipment to be Kept in Quarry
R. 22 First Aid Equipment to be Kept in Box or Cupboard
R. 23 Proprietor to Designate a person in Charge of First Aid Box or Cupboard
R. 24 Stretcher to be Kept alongside First Aid Box or Cupboard
R. 25 No Work to be Carried on Except under Sole Supervision of the Supervisor or
Deputy Supervisor
R. 26 Supervisor on Duty to Complete Daily Entry in the Time Register
R. 27 Persons not to Work in Quarry without Sufficient Instruction or Training
R. 28 Supervisor on Duty to Inspect Working Places Periodically
R. 29 Supervisor on Duty to Prohibit Entry to Dangerous Place or Road
R. 30 Inspection Report
R. 31 Offence to Enter Dangerous Place or Road in Contravention of Prohibition
R. 32 Worker to Carry out Periodic Inspections of Working Place
R. 33 Supervisor on Duty to Inspect Working Place Reported to be Unsafe
R. 34 Inspection Report
R. 35 Offence to Enter Unsafe Place in Contravention of Prohibition
R. 36 Safety Helmet to be Worn for Certain Work
R. 37 Safety Rope or Harness to be Worn for Certain Work
R. 38 Supervisor on Duty to Inspect Equipment Periodically
R. 39 Supervisor on Duty to Prohibit Use of Unsafe or Inefficient Equipment
R. 40 Inspection Report
R. 41 Offence to Use Unsafe or Inefficient Equipment in Contravention of Prohibition
R. 42 Offence to Use Mechanical Equipment Without Permission of Supervisor on Duty
R. 43 Inexperienced Person Not to Use Mechanical Equipment
R. 44 Unlicensed Person Not to Use Certain Vehicles in Quarry

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R. 45 Supervisor on Duty Not to Permit Mechanical Equipment to be Used at or near
Edges unless Banksman Present
R. 46 Mechanical Equipment Not to be Used at or near Edges unless Banksman Present
R. 47 Worker to Report Defect in Equipment
R. 48 Supervisor on Duty to Inspect Reported Defect in Equipment
R. 49 Inspection Report
R. 50 Offence to Use Defective Equipment in Contravention of Prohibition
R. 51 Offence to Go under Certain Mechanical Equipment
R. 52 Manner in which Work is to be Executed
R. 53 Overburden to be Cleared back
R. 54 Maximum Height of Face
R. 55 Commissioner for Labour may Permit Work on Face Exceeding Maximum Height
R. 56 Work on Faces Not to be Carried on Simultaneously where Danger of Falling
Objects Exist
R. 57 Accidents and Dangerous Occurrences
R. 58 Penalties
R. 59 Liability of Proprietor

9.5 Boilers and Pressure Vessel Ordinance (Cap. 56) and

Subsidiary Regulations

9.5.1 Introduction

The Boilers and Pressure Vessels Ordinance (Cap. 56), sets out the provisions relating to
the control, use and operation of boilers and pressure vessels and was enacted to provide
acceptable standards in the design, manufacture, installation, maintenance, examination,
testing and operation of boilers and pressure vessels, which include thermal oil heaters, air
receivers, steam receivers, steam containers, and pressurized fuel containers. The law
applies to all such appliances except those used for domestic purposes and those
specifically exempted.

9.5.2 Inspection and Certification by Appointed Examiner

The Boilers and Pressure Vessels Authority, currently the Commissioner for Labour, has
delegated certain powers under the Ordinance to the Principal Surveyor (Boilers and
Pressure Vessels) of the Labour Department. The boilers and pressure vessels (“PVs”)
subject to the Ordinance are required to be inspected by an Appointed Examiner who,
according to paragraph 2.3.2 of the Code of Practice for Owners of Boilers and Pressure
Vessels issued under Section 18A of the Boilers and Pressure Vessels Ordinance, Cap. 56,
is an engineer from the private sector appointed by the Authority as a Boiler Inspector for
inspection and certification of boilers or PVs or an Air Receiver Inspector for inspection
and certification of air receivers before their first use and periodically thereafter.

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9.5.3 Competent Person

The Authority also issues certificates of competency to any person who satisfies him of his
suitability to operate a boiler or steam receiver. The Ordinance requires that every boiler
and steam receiver must be operated under the direct supervision of a Competent Person
holding a suitable Certificate of Competency for that type and class of boiler or steam
receiver. If a large number of such equipment is in operation at the same time, the owner
must ensure that each unit can be directly supervised by a competent person. If they are in
close vicinity to each other and on the same floor, one competent person may be considered
acceptable. However, if they are installed on different floors, or are too far away from one
another on the same floor, such that one competent person cannot reasonably be expected
to take care of all the working equipment simultaneously, then additional competent
persons are required.

9.5.4 Prohibition Order

The Authority may, by notice in writing, prohibit any further use and operation of a boiler
or pressure vessel when it appears to him that:
 the boiler or pressure vessel or its auxiliary equipment is not in safe working order;
 the boiler or pressure vessel or its auxiliary equipment has not been examined in
accordance with the Ordinance;
 the boiler or pressure vessel is operated at a pressure greater than its maximum
permissible working pressure; or
 the seal of the safety valve is broken or the setting of the safety valve has been
tampered with by an unauthorized person.

Upon receipt of a prohibition order, the owner must stop using the boiler or pressure vessel
concerned immediately and rectify the faults for which the prohibition order is issued. The
owner should engage an Appointed Examiner to thoroughly examine the boiler or pressure
vessel and obtain a new Certificate of Fitness which should be submitted to the Authority,
who may permit the use of the boiler or pressure vessel to be resumed.

9.5.5 Examination after Extensive Repairs

When extensive repairs have been carried out on a boiler or pressure vessel, the equipment
and its fittings and attachments must be examined by an Appointed Examiner and issued
with a new Certificate of Fitness before being put back into use.

9.5.6 Accidents and Defects

If an accident occurs involving a boiler, PV or its auxiliary equipment, or if the owner

becomes aware of any such equipment that is likely to endanger life or damage property,
he / she must at once stop using the equipment and notify the Authority of the accident or
defect within 24 hours of the accident or defect together with the latest Certificate of Fitness

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and detailed information about the equipment and the accident or defect. The detailed
information shall include:
 the address or place at which the boiler or pressure vessel is installed;
 a general description of the boiler or pressure vessel;
 the purpose for which the boiler or pressure vessel is or was used;
 where applicable, the name and the address of the Appointed Examiner who issued
the latest Certificate of Fitness in respect of the boiler or pressure vessel;
 in the case of an accident involving a boiler or pressure vessel:
 the number of persons killed or injured, if any;
 details of the part thereof that failed and the extent of failure generally, if
known; and
 the pressure at which the equipment was being operated at the time of the
accident; and
 in the case of a defect in a boiler or pressure vessel, details of the nature of the
defect.

9.5.7 Air Receiver and Cement Tank

A cement tank designed to utilize compressed air to blow out the contents during discharge
or purge is within the meaning of an air receiver and subject to the same provisions that
apply to an air receiver in the BPVO.

Owners of air receivers are advised to observe the following safe practices:
 An air receiver should be protected by paint and kept away from hazardous
environment such as hot furnace, dripping water pipe etc. to prevent it from
potential damage and accelerated deterioration.
 An air receiver should have adequate provisions to allow any condensation of
moisture inside the receiver to be drained away easily. It should also be drained
empty of moisture condensation regularly.
 The inside of an air receiver should be thoroughly cleaned periodically, in particular
for inspection by an Appointed Examiner.

Since a cement tank is opened frequently by the operator for inspection of the contents after
discharging, it should be fitted with:
 a suitable safety locking device, approved by the Authority, at the manhole door to
prevent the door from being opened if the pressure inside the tank has not been
completely released; and
 a warning notice, in English and Chinese, near the manhole doors stating that the
operator must not open the door until the pressure inside the tank has been
completely released.

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9.5.8 Registration

No boiler, pressure vessel or steam container may be used or operated unless:

 it is registered under the Ordinance; and it has been examined and issued with a
Certificate of Fitness (Certificate of Fitness is not required for a steam container);
or
 it has been exempted by the Authority from the relevant provisions of the Ordinance.
The above requirements do not apply to boilers, pressure vessels or steam containers:
 belonging to the State;
 being used solely for domestic purposes;
 being part of the fixed equipment of a vessel or other floating craft;
 being used as part of the equipment for supplying locomotive power to a vehicle;
 being used for operating the ancillary equipment of a vehicle for the carriage of
passengers or goods.

9.5.9 Procedure

 The application form for registration may be obtained free of charge on request
from the Authority.
 The owner of a new boiler or pressure vessel, other than a pressurized fuel container,
must deliver to the Authority, not less than 30 days before the boiler or pressure
vessel is put into use, the completed application form and the following:
 one copy of the maker's certificate and one copy of the certificate of inspection
during construction issued in respect of the boiler or pressure vessel by a
recognized inspection body; or
 documentary evidence, to the satisfaction of the Authority, that the boiler or
PV complies with a recognized engineering standard or code in respect of:
 the welders employed and welding procedures used in the construction,
erection and repairs of the boiler or pressure vessel;
 Heat treatment before and after welding;
 tests and inspections carried out on the boiler or pressure vessel; and
 any other relevant technical details that the Authority may specify, e.g. the
kind and grade of material used in the pressure parts of the boiler or pressure
vessel; or
 if the owner cannot deliver the above documents, he/she must deliver details
of the design and methods of construction, inspection and testing of the boiler
or pressure vessel and its auxiliary equipment.
 The owner of a new steam container must deliver to the Authority, not less than 30
days before the steam container is put into use, the completed application form and
two copies of the maker's certificate or two copies of the plan of the steam container
prepared by a Boiler Inspector.

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  Every copy of the above documents delivered to the Authority must have a
declaration on it by an Appointed Examiner that it relates to the boiler or pressure
vessel in respect of which it is so delivered. The Appointed Examiner shall
determine the maximum permissible working pressure for the boiler or pressure
vessel and state the same in the documents accompanying the application for
registration. Where any document is not written in English or Chinese, it should be
accompanied by an English translation.
 If the documents are not produced or do not give the Authority sufficient
information to enable him to assess the maximum permissible working pressure, he
may require the owner to have the boiler or pressure vessel inspected by an
Appointed Examiner at the owner's expense.
 When the Authority is satisfied with the application he will notify the owner in
writing of the registration number and the maximum permissible working pressure
of the boiler, pressure vessel or steam container. The owner shall engrave, impress
or incise the registration number onto a conspicuous place on the boiler, pressure
vessel or steam container.
 If the Authority is not satisfied that the application meets the requirement for
registration, one copy of the documents with reasons for refusal of registration will
be returned to the owner. The owner may re-apply after rectifying the deficiencies.
The boiler or pressure vessel must be examined and issued with a Certificate of
Fitness by an Appointed Examiner before it is put into use.
 Where an owner is aggrieved by the decision of an Appointed Examiner as to the
maximum permissible working pressure at which his boiler or pressure vessel may
be operated, he may appeal to the Authority in writing not later than 7 days after he
is notified of the decision. The decision on the appeal by the Authority shall be
final.

9.5.10 Maintenance and Periodic Examination of BPV and Steam

Containers

Every boiler, pressure vessel and steam container and its auxiliary equipment shall be
properly maintained and operated in a safe working condition at all times. In particular,
the owner should ensure that:
 the boiler or pressure vessel has been properly examined by an Appointed Examiner
before the current validity of the Certificate of Fitness expires.
 the permanent outlet from any steam container to the atmosphere must be open and
free from obstruction at all times;
 a boiler room must be maintained in a clean condition and be free from defective
joints, oily waste or other inflammable material; and
 the firefighting appliances provided in connection with a boiler or its auxiliary
equipment must be properly maintained and kept in a readily accessible place.

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9.6 Shipbuilding and Ship Repairing

9.6.1 Introduction

In the operations of shipbuilding and ship repairing, there exists lots of hidden hazards.
Any negligence could result in disastrous accidents, which if it occurs, can be difficult to
remedy. General hazards include those hazards involving painting, arc and gas welding,
work in a confined space, and work over water. The safety precautions against the hazards
involved in the above operations have been dealt with in other relevant modules.

9.6.2 Specific Hazards Involved in Shipbuilding and Ship

Repairing

Other than the abovementioned general hazards, there are specific hazards such as carrying
out of abrasive blasting work in a confined space, testing or dismantling of any pipe or
equipment that contains steam, oil or other flammable, toxic or corrosive substances,
ballasting and de-ballasting of a ship, bunkering and transferring of fuel oil, radiography
work, pressure testing, work over water etc. A permit-to-work system should be applied
to all these operations.

Sources (Issued by Labour Department): Safety Guide for Construction Work over / near Water (2015);
(Issued by Occupational Safety & Health Council): Construction Work Over Water Safety (2015); Safety
Kits for Cargo Handling on Vessels (n.d.); Safety Kits for Cargo Handling on Vessels (Handy Version) (n.d.);
Safety Guide for Cargo Loading on Vessels (1994).

9.6.3 Fires and Explosions

9.6.3.1 Smoking and Naked Flame

 Total prohibition of smoking on board the ship being built or under repair is
unrealistic. Smoking may be controlled by designating certain safe areas as
‘smoking spots’.
 The areas selected should be free of flammable vapours and also due account should
be taken of the prevailing wind conditions.
 Metal containers should be made available for extinguishing cigarettes and disposing
matches.

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 Smoking and the use of a naked flame should be prohibited in areas other than
smoking spots. Conspicuous warning notices should be displayed where smoking is
forbidden.
 Particular attention should be paid to such areas as certain machinery spaces, score
rooms, holds, battery rooms, pump rooms, lamp rooms, paint rooms, tanks,
cofferdams etc. and also deck areas near open hatches where hazardous cargo is
being carried.

9.6.3.2 Spontaneous Combustion

 Spontaneous combustion can occur where there are damp or oil soaked rags or cotton
waste.
 Steel receptacles fitted with close fitting covers should be provided for the storage
of oil soaked rags or cotton waste, prior to removal from the ship for disposal.

9.6.3.3 Hot Work including Arc and Gas Welding and Flame Cutting

 No hot work should be commenced until a responsible person has thoroughly

checked the vicinity of the job to ensure that there is no flammable material beneath,
behind or within the object under repair or demolition, e.g. tanks, cabins etc. Steps
should be taken to prevent sparks from dropping down into open hatchways or
ventilators. Where access to interiors is impeded by closed manholes, tank lids,
locked doors, etc., no hot work should be carried out.
 Before commencing burning or welding always check what is on the other side of
the placing and check again on completion of the work.
 Whenever possible, station a watchman on the opposite side.
 Fire patrols should be alerted to the fact that materials may smoulder for a long time
after work has ceased.
 Fire extinguishers should be readily available when welding operations are being
carried out.
 Hot work should not be started before all combustible materials such as dunnage,
sacking, waste paper, paints, oil etc. have been cleared from and around the area.
 Hot work should not be carried out in or near refrigerated spaces before they have
been gas-freed, the insulation stripped, all combustibles removed and the atmosphere
freed of any flammable dust.
 Hot work should not be done on smokeboxes, uptakes, fan trunks, ventilators,
Samson posts, pipes etc. before a thorough examination has been undertaken to
eliminate any risk of fire.
 Hot work should not be done in or near tanks that contained or had contained oil. In
a tank which had previously contained oil, ensure that no oil-impregnated scale is
likely to give off gas remains. There should also be no flammable material which
might catch fire in adjacent spaces by transmission of heat through bulkheads, etc.

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 To prevent the possibility of formation of petroleum vapours when hot work is in
progress in or around a tank which had previously contained oil, a small quantity of
water for quenching should be provided.
 Hot work should not be carried out within or in the vicinity of any oil compartment,
cofferdam or pump room (in oil tankers), rudders or similar confined spaces unless
a gas-free certificate allowing such work has been obtained and verified.
 If the presence of iron sulphide is known, or suspected to be present after the carriage
of sour crudes, any impregnated scale should be first damped down and then scraped
off before hot work is allowed, whether inside or outside the tank.
 No oxygen or acetylene cylinder should be taken below the topmost deck unless it is
installed or placed in a part of the vessel which is adequately ventilated to prevent
any dangerous concentration of gas or fumes.
 No acetylene generating plant should be installed on board a ship under repair.
 The storage of oxygen cylinders and fuel gas cylinders on board a vessel should be
separate from each other and their quantities kept to a minimum.
 Smouldering ropes should not be used to light blow-pipes. Spark lighters, such as
ones employing flint on steel, are suitable.
On the safe use of oxy-acetylene gas welding and flame cutting set, read 3300 Chapter 4.

9.6.3.4 Electrical Installation

 An electrical apparatus should not be connected to the power supply without the
approval and supervision of a responsible person.
 After work ceases, ships undergoing major repairs and others constituting large fire
risk should be made dead electrically to the utmost extent possible. The only electric
circuits retained should be those needed to provide emergency lighting, and for fire
wardens to effect their patrols.
 In hazardous areas, electrical equipment should be flameproof or, in some
applications, intrinsically safe.
 When handling volatile petroleum or engaged in gas-freeing operation, flammable
vapours should be prevented from entering any accommodation and machinery and
boiler rooms, because much of the electrical equipment in these spaces is not
approved for use in the presence of flammable vapours. Air-conditioning or forced
ventilation should be shut down. If the hazard persists, oil handling or gas-freeing
operations should be suspended.
For other electrical safety measures, read 3300 Chapter 3.

9.6.3.5 Aerosols

 An aerosol spray may ignite on contact with a naked flame, heated surface or lighted
cigarette. They should be stored in a cool place out of the sun’s rays.

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9.6.3.6 Stowage

 Close stowage retards fire spreading. Always keep cotton waste, combustible stores,
etc. stowed compactly in securely closed lockers.

9.6.3.7 Compartmentation, Doors, Means of Escape

 The compartmentation of working areas aboard a vessel should be maintained at all

times so that fire is confined to a limited space or compartment. Fire doors and walls
will keep a fire in check. Adequate and safe means of escape from any part of the
vessel including the ship’s holds should be maintained at all times. Ropes and
vertical ladders are not satisfactory where emergency evacuation is required.

9.6.3.8 Lifting Equipment

 In areas likely to contain flammable gas, temporary protection may be provided by

preventing the striking of metal parts and so ensuring against the risk of sparking.

9.6.3.9 Hot Scot

 An incandescent carton from the main or galley funnel, or from the funnels of other
craft alongside may ignite flammable vapours or other combustibles. When it occurs,
tank cleaning or other hazardous operations should cease immediately.

9.6.3.10 Portable Oil Engines

 Unless a vessel is wholly gas-free and frequent gas tests are made, the use of portable
oil engines should be prohibited in the vicinity of spaces likely to contain flammable
gas.

9.6.3.11 Handling of Petroleum, Bunkering etc., Opening and

Closing of Oil Tanks

 Personnel concerned should make themselves familiar with the nature and
characteristics of the petroleum and of the conditions of the tanks, pipelines and
venting systems so as to plan the safe handling of the fuel or cargo.
 During the handling of residual petroleum, all openings should be closed and secured.
 Any opening required to be opened for sounding or sampling should be covered with
sandbags or other suitable device.
 Before opening any oil tank fitting, any pressure in the tanks should be relieved.
 In the event of thunderstorms, gas-freeing, tank cleaning or handling of oil should be
stopped.

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 No unauthorized craft should be allowed to secure alongside a vessel when in the
process of handling residual oil and also when cleaning or gas-freeing oil tanks.
 When tugs are alongside or assisting a tanker, all cargo tank openings must be closed,
unless all tanks are gas-free.

9.6.3.12 Fire Hazards in Machinery Spaces

 If a hot bearing has been observed in a closed crankcase, the crankcase must not be
opened until the bearing has cooled down, otherwise the entry of air could create an
explosion.
 Oil should not be allowed to accumulate in boiler registers, tank cops, bilges and
near hot pipes or other heated surfaces.
 Save-alls and drop trays should be kept free from oil and any leakage should be given
immediate attention.
 Any oil found in bilges should be disposed of and the bilges washed at the earliest
opportunity. The source of leakage to the bilge should be located and repaired.
 When handling residue oil or gas-freeing, vapours should be prevented from entering
machinery spaces, as much of the equipment there is neither explosion proof nor
intrinsically safe. Burners in the boilers are potential sources of ignition.

9.6.3.13 Use of Tools in Hazardous Areas

 Care should be taken to avoid smears or flakes of aluminium adhering to surfaces.

To avoid the risk of ignition of flammable mixtures, tools which have been used on
aluminium structures or fittings should be cleaned after use.
 Only plastic or wooden hand tools should be used for removing paint or scale and
sludge in tanks that have contained flammable liquids.

9.6.3.14 Gas-Freeing (Tank Cleaning)

 Ensure there is no cooking or other naked flame on board, except in areas considered
safe. Ensure no smoking.
 Ensure all ventilators are suitably trimmed and any mechanical ventilation stopped.
 Ensure all tank openings, except those required to be used, are closed.
 The precautions recommended for gas-freeing tanks apply to pump-rooms and
cofferdams.
On other fire safety measures, read 3300 Chapter 1.

9.6.4 Entry into Confined Spaces (Gas-free Tank)

 A gas-free tank may become hazardous:

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 o if there occurs a change in temperature causing vapour to be given off from
scale, sludge or residue;
o upon dismantling or testing of fittings including heating coils which may
contain volatile oil or vapour;
o upon disturbing scale or sludge; and
o upon opening valves or accidentally removing blanks leading to the tank
permitting ingress of volatile oil, vapours, inert gas etc.
For other confined space safety measures, read 3200 Chapter 2.

9.6.5 Safe Means of Access and Places of Work

9.6.5.1 Gangways

 When the upper end of a gangway rests on, or is flush with the top of a bulwark,
suitable and substantial steps, properly secured to the deck and equipped with
substantial upper and mid-handrails, should be provided between the top of the
bulwark or rail and the deck.
 Where practicable, an accommodation ladder should be used instead of a gangway,
if the latter has a dangerous angle.
 Do not rig gangways on ships’ rails unless the rail is specially reinforced.

9.6.5.2 Accommodation Ladders

 When accommodation ladders have fixed steps and the angle is such that personnel
are required to walk on the edges of the steps, suitable cleated duckboards should be
laid over and secured to the ladder.
 The fencing between the accommodation ladder and the walkway should be fitted in
such a way that there are no gaps.

9.6.5.3 Portable Ladders

 Where it is not possible to make use of a gangway or accommodation ladder because

of tides or other reasons, a portable ladder may be used provided that when in use
there is a safe clearance behind the rungs.
 Portable ladders should stand on a firm base and be securely lashed in position. If
fixing is impracticable, a person should be stationed at the base of the ladder when
in use to prevent it from slipping.

9.6.5.4 Rope Ladders

 As far as possible, rope ladders should not be used as a means of access.

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 The ladder should never be secured to rails unless the rails are able to take the weight
of men and the ladder with an ample margin of safety.

9.6.5.5 Safety Nets

 Those parts of a gangway, accommodation ladder or portable ladder that overhang

the water should have a net spread below in such a manner that a person slipping is
prevented from falling into the water.
 Safety nets should also be used when there is a danger of any one dropping from a
height, e.g. a hold or deep tank.

9.6.5.6 Stages and Staging

 All staging including the staging materials should be thoroughly examined by a

competent person for any possible defects and should be of adequate strength,
suitable quality and in good condition.
 Dunnage wood should not be used in the construction of staging.
 Planks should not be supported on the rungs of ladders for use as a working platform.
A proper working platform should be erected.
 All stages other than suspended stages should be secured in position to prevent
movement. Suspended stages should be prevented from twisting and their planks
secured against slipping.
 Workers working on stages which do not comply with the requirements for a working
platform should wear a safety harness attached to a lifeline which should be suitably
anchored.
 To safeguard persons below, personnel working on stages should be provided with
and use suitable tool containers. All articles should be lowered by means of a rope.
 The use of fibre ropes or ropes made with strands consisting of wire cores should not
be allowed. Fibre ropes may be used where the suspension ropes are reeled through
blocks.
 A bosun’s chair should not be used.

9.6.5.7 Work on Hatches and in Holds

 Every space exceeding 2m in depth which is served by hatchways (including access

and trimming hatchways) should be securely fenced.
 No person should be allowed on a hatchway unless it has been ensured that the
hatchway is completely covered.
 A person working on partly covered hatchways should be protected against the
danger of falling by spreading a safety net below or by other suitable means. Safety
nets should not be secured to the hatch covers.
 Rope ladders should not be used for access to holds.

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9.6.6 Machinery Hazards

9.6.6.1 Overhauling Machinery

 When machinery is being overhauled measures should be taken to prevent its turning
or inadvertently starting.
 Steam-operated machinery should have the steam valves and exhaust valves, if any,
securely closed. The lines should be drained and drain valves left over.
 Diesel driven machinery should have the valves in the air starting system securely
closed.
 In the case of electrically operated machinery and electric generators the fuses should
be removed and circuit breakers taken out at the main switchboard. Where
practicable, the circuit breakers should be locked in the isolated position.
 Before any personnel are allowed to enter the main engine crankcase or gear case,
the turning gear should be engaged and a warning notice posted at the starting
position.

9.6.7 Accident Statistics

According to the statistics of the Marine Department, since 2014, there have been less than
10 accidents every year related to shipbuilding and ship repairing as compared to around
30 to over 40 in the preceding years. The causes of accidents are mainly related to manual
handling, stepping on or striking objects or slipping, machinery or mechanical appliances,
persons falling, falling or swinging objects, hand tools, towing or mowing, and defective
equipment.

9.7 Work Over/Near Water

Land-based construction work over or near water is mainly regulated by the F&IUO (Cap.
59) and the OSHO (Cap. 509) and their subsidiary regulations administered by the Labour
Department. Sea-based construction work carried out on vessels is regulated by the
Shipping and Port Control Ordinance (Cap. 313), Merchant Shipping (Local Vessels)
Ordinance (Cap. 548) and their subsidiary regulations administered by the Marine
Department. A safety management system should be implemented to address safety
concerns.

Potentially hazardous or unfavourable site conditions which will likely affect the safety of
the workplace should be considered in the planning and design of a construction project
that involves work over or near water. These may include:
 sites with strong tides, winds or waves;
 sites which are too remote from the city centre or hospitals;

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  sites which have restricted space for manoeuvring, such as those for temporary
storage;
 the activities of other contractors including sub-contractors within the sites;
 adjacent maritime activities; and
 emission of noise, toxic gases, harmful chemicals or dust from processes on or
around the sites.
As an example, the construction of the Hong Kong-Zhuhai-Macao Bridge Project involves
large scale civil work that are many kilometres away from the local coastline, and a serious
injury sustained will be further aggravated as it takes time to deliver the victim to a nearby
hospital. In terms of risk management in reducing the severity of an accident, the need for
effective and efficient immediate rescue, resuscitation, revival and other first aid treatment
becomes of paramount importance.

Before work, a task-specific risk assessment should be conducted and periodically

reviewed by a competent person. All potential hazards involved, such as drowning,
overturning of mobile plant / equipment into the water, and collapse in confined spaces
should be properly identified and dealt with.

A safety plan for work over/near water should be prepared including method statements,
safe working procedures, as well as emergency preparedness. Contingency plans,
rescue/evacuation arrangements should be in place and periodically tested to evaluate their
effectiveness.

Apart from the normal health and safety measures that are implemented on land, the
following specific precautions should be taken:
 Lifting appliances / mobile plant on vessels should be fixed and securely anchored.
 Lifting appliances / mobile plant should be kept away from dangerous edges close
to water.
 The operating zone of the lifting appliances / mobile plant should be clearly
demarcated and properly fenced off.
 Suitable lifejackets / buoyancy aids with whistle and self-activating light (for night
work) should be provided, checked and worn by workers with a risk of falling into
water. They should be serviced by an authorized agent at least once a year and the
maintenance record properly kept.
 A lifebuoy with sufficient lifeline (not less than 30 m) should be provided at less
than 50 m intervals along the edges of places where work is being carried out
overside or in an exposed position on vessels where there is a reasonably
foreseeable risk of falling or being washed overboard. To avoid any delays to
rescue operations, the lifebuoys should not be tightly tied to posts.
 Safety harnesses with a continuous and effective anchorage system should be
provided when it is impracticable to provide a suitable working platform, access
and egress or safe place of work.
 Safe means of access and egress should be provided between a vessel and

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  another vessel;
 the shore;
 a workplace on land / over water.
 Efficient lighting should be provided at all points of access and egress.
 Ramps of adequate strength should be provided for the access of vehicles from land
to vessels, or vice versa, and such ramps should not be used as access gangways for
people unless a suitable separation is provided.
 Rescue/evacuation teams (including first aiders) of suitable capacity should be
organized to deal with emergency situations.
 Sufficient rescue/evacuation boat(s) should be provided and kept ready for
immediate use in case of emergency.
 Emergency procedures should include rescue/evacuation at times of adverse
weather (typhoon, thunderstorm, heavy rainstorm, etc.). Necessary information on
adverse weather should be made available from the Hong Kong Observatory
(including any specific data / forecast to be prescribed with due regard to the
peculiar site location / situation). Evacuation procedures should be timely launched
with due regard to impending adverse weather.
 An effective communication system should be established between front-line
workers and supervisory staff in case of emergencies, including provision of
sufficient communication equipment.
 Workers should undergo Mandatory Basic Safety Training for land-based
construction work and/or Shipboard Cargo Handling Basic Training for marine
construction work at sea.
 Job specific safety training and regular refresher training should be provided to
workers to enhance/maintain their safety awareness of potential hazards associated
with work over water / near water / on vessels, including those during inclement
weather.
 Specific safety training should be provided to workers on the use of lifejackets and
procedures for checks on lifejackets as well as rescue arrangements for persons who
fall into water.
 Essential safety information and contingency arrangements should be provided
(such as by issuing portable safety cards) to workers engaged in work over water /
near water / on vessels.

Taking the Hong Kong-Zhuhai-Macao Bridge Project as an example, it is crucial for a

safety practitioner to write a proper accident investigation report. The Labour Department
has published a Sample Concise Investigation Report for the Fatal Accident in the Hong
Kong-Zhuhai-Macao Bridge Project on 29 March 2017 on its website
https://www.labour.gov.hk/eng/news/pdf/171102_Concise_investigation_report_re_HZM
B_fatal_case_ENG.pdf.

Key points to note in writing this kind of accident report are summarized below:

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  The first section of the Report is an Introduction that gives a very concise yet clear
depiction of the accident. It amply exemplifies the basic 7W’s of an accident report,
including Who (5 workers), Which (TWP beneath the deck of the bridge under
construction), What (Lifting systems … 2 sets of “LG”), hoW (causing… killed …
injured), Where (HK Link Road Section between HKSAR Boundary and Scenic
Hill of the HZMB Project), When (1500 hrs on 29 March 2017) and Why (Collapse).
The last W (Why) is the crux of the investigation and can be further expanded and
presented in the part detailing the Causes of the Accident.
 Where there are technical terms such as TWP, they should be elaborated and, where
practicable, portrayed visually with the aid of Figures and/or photos.
 The second section of the Report are Background Information giving the
relationship amongst the workers involved and the various duty holders. These
should be based on the facts of the accident.
 The third section of the Report are the Circumstances of the accident, i.e. what
happened on the day of the accident.
 The fourth section of the Report is a summary of the Investigations that took place
afterwards, including attendance at the scene of the accident, tests and examinations,
expert opinions and eyewitness interviews.
 The fifth section of the Report are the Findings and Observations resulting from the
investigations, giving both the direct causes and root causes of the accident.
 The sixth section of the Report are Criminal Proceedings that were instituted after
the accident, detailing the relevant legal requirements that had been infringed,
which is exclusive to the Government Report only. For a safety practitioner, the
last section should be Conclusion and Recommendations, or two sections, one
being the Conclusion and the other Recommendations. It is prudent to note that the
suggested Recommendations need not be directly related to possible breaches of
safety laws. They should aim to prevent a further recurrence instead of purely
fulfilling the legal requirements.
The 7W accident investigation technique mentioned above is derived from Ishikawa’s 5M
Ergonomic Model (Man-Machine-Material-Method-Medium / Mother Nature, re-
modelled as Who-Which-What-hoW-Where) by adding the 2 other W’s of When and Why.
3600 Chapter 1 gives more detailed information on Accident Causation, Reporting and
Investigation, including a brief description of the 5M Ergonomic Accident Causation
Model.

Other examples of reports of classical accident cases issued by the Labour Department can
be found in the Green Cross published by the Occupational Safety and Health Council,
(Available at http://www.oshc.org.hk/tchi/main/osh_info/publications/green_cross/index.html).

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9.8 Concept Checklist

This chapter is about goods lift safety, quarry safety, boilers and pressure vessels,
shipbuilding and ship repairing and work over / near water. Key points to note include:
 Introduction to goods lift
 F&IU (Goods Lifts) Regulations
 Introduction to quarrying
 Quarries (Safety) Regulations
 Boilers and Pressure Vessels Ordinance and its subsidiary regulations
 Shipbuilding and ship repairing
 Work over / near water

9.9 Further Thinking

 As a result of the ongoing relocation of local industries to Mainland China and the
scarcity of land in Hong Kong, both shipyards and quarries are beginning to
disappear from the local scene. With the closure of the Anderson Road Quarry, the
only quarry remaining in Hong Kong is the Lam Tei Quarry in Tuen Mun. In a
quarry, huge dumpers similar to the RTGC in container yards are used, and it is
more difficult to delineate the driveway and the pedestrian walkway in a quarry
than in a container yard. What extra safety precautions will be needed?
 For ships and boats, any work activity afloat will be the jurisdiction of the Marine
Department while any work activity on solid ground is the jurisdiction of the Labour
Department. If an operation involves both areas, e.g. if an accident happens while
unloading a pack of goods onto the quay using a lifting boom on a barge, which
jurisdiction do you think will apply: the Merchant Shipping (Local Vessels)
Ordinance or the F&IUO?

References

Boilers and Pressure Vessels Ordinance, 1963, Hong Kong, Available at

http://www.elegislation.gov.hk/hk/cap56 (Accessed on 31 December 2019).
Colaco R. (1975) “A Guide for Boiler Operation”, Government Printer, Labour Department,
Hong Kong.
Factories and Industrial Undertakings (Goods Lifts) Regulations 1976, Hong Kong,
Available at http://www.elegislation.gov.hk/hk/cap59O (Accessed on 31
December 2019).
Higginson K. (1970) “Utilization of Flash Steam to Save Fuel Costs”, Labour Department,
Government Printer, Hong Kong.
International Labour Organization (2019) “ILO Code of Practice: Safety and Health in
Shipbuilding and Ship Repair”, Revised Edition, Geneva.

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Labour Department (1972) “Code of Good Practice for the Operation of Liquid Fuel Fired
Commercial, Industrial and Domestic Appliances”, Government Printer, Hong
Kong.
Labour Department (1978a) “A Guide to the Boiler and Pressure Receiver Ordinance, Cap.
56 and the Boiler and Pressure Receiver Regulations”, Government Printer,
Hong Kong.
Labour Department (1978b) “A Guide to the Boiler and Pressure Receiver Ordinance, Cap.
56 and the Boiler and Pressure Receiver Regulations”, Government Printer,
Hong Kong.
Labour Department (1986) “Code of Safe Practice for Ship Building and Ship Repairing
Industry”, December issue, Hong Kong.
Labour Department (1990) “Guide to Operator of Electric Heater Boilers”, Government
Printer, Hong Kong.
Labour Department (1993) “Fire-Tube Boiler Operation”, Government Printer, Hong Kong.
Labour Department (1994a) “Code of Practice for Pressure Equipment Owners Issued
under Section 18A of the Boilers and Pressure Vessels Ordinance”,
Government Printer, Hong Kong.
Labour Department (1994b) “Code of Practice for Steam Receivers Issued under Section
18A of the Boilers and Pressure Vessels Ordinance”, Government Printer,
Hong Kong.
Labour Department (1994c) “Code of Practice for Thermal Oil Heaters Issued under
Section 18A of the Boilers and Pressure Vessels Ordinance”, Government
Printer, Hong Kong.
Labour Department (2002) “Code of Practice for Fossil-Fuel Boilers Issued under Section
18A of the Boilers and Pressure Vessels Ordinance”, Government Printer,
Hong Kong.
Labour Department (2006) “Electrically Heated Boilers and Their Operation”,
Government Logistics Department, Hong Kong.
Labour Department (2007) “A Guide to the Factories and Industrial Undertakings (Goods
Lifts) Regulations”, Government Logistics Department, Hong Kong.
Labour Department (2008) “Brief Accident Cases of Boilers and Pressure Vessels in Hong
Kong”, Government Logistics Department, Hong Kong.
Labour Department (2013) “Code of Practice for the Safe Operation of Electric Steam
Boilers Issued under Section 18A of the Boilers and Pressure Vessels
Ordinance”, Government Logistics Department, Hong Kong.
Labour Department (2015) “Registration of Steam Boilers”, Government Printer, Hong
Kong.
Labour Department (2016a) “Code of Practice for Owners of Boilers and Pressure Vessels
Issued under Section 18A of the Boilers and Pressure Vessels Ordinance”,
Government Logistics Department, Hong Kong.
Labour Department (2016b) “Guide and Syllabus for4 Examination for Certificate of
Competency Issued Under the Boilers and Pressure Vessels Ordinance Cap.
56”, Government Logistics Department, Hong Kong.
Labour Department (2016c) “Operational Guide for Air Receivers”, Government Logistics
Department, Hong Kong.

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Labour Department (2017a) “Code of Practice for the Safe Operation of Thermal Oil
Heaters Issued under Section 18A of the Boilers and Pressure Vessels
Ordinance”, Government Logistics Department, Hong Kong.
Labour Department (2017b) “Fatal Accident in Hong Kong-Zhuhai-Macao Bridge
Project”, November 2017, Available at
https://www.labour.gov.hk/eng/news/Concise_Investigation_Report_2017.ht
m (Accessed on 31 December 2019).
Labour Department (n.d.a) “Guide to Electrically Heater Boiler Operator”, Government
Printer, Hong Kong.
Labour Department (n.d.b) “Code of Safe Practices in the Shipbuilding and Ship repairing)
Industry”, Hong Kong.
Labour Department and Occupational Safety and Health Council (2006) “Safe Operation
Guideline for Pressurized Fuel Containers”, Government Logistics
Department, Hong Kong.
Labour Department and Marine Department (2015) “Safety Guide for Construction Work
over/near Water”, Government Printer, Hong Kong.
Labour Department and Occupational Safety and Health Council (2012) “Guide to
Operation of Steam Receivers”, Government Logistics Department, Hong
Kong.
Labour Department and Occupational Safety and Health Council (2016) “A Guide to the
Construction, Installation, Operation and Maintenance of Air Receivers”,
Government Logistics Department, Hong Kong.
Marine Department (1973) “Shipbuilding and Ship-Repairing Safety Guide”, Government
Logistics Department, Hong Kong.
Marine Department (1994a) “Shipbuilding and Ship-Repairing Safety Guide
(Supervisors)”, Government Printer, Hong Kong.
Marine Department (1994b) “Shipbuilding and Ship-Repairing Safety Guide (Workers)”,
Government Printer, Hong Kong.
Marine Department (n.d.) “Casualties in Ship Repairing and Ship Breaking Accidents
(1997-2018)”, Available at
https://www.mardep.gov.hk/en/publication/mias_archive.html (Accessed on
31 December 2019).
Quarries (Safety) Regulations 1969, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap59F (Accessed on 31 December 2019).

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 Chapter 10
Dangerous Goods Ordinance (Cap. 295) and Regulations; Gas
Safety Ordinance (Cap. 51) and Regulations

10.1 Introduction to the Dangerous Goods Ordinance (DGO)

(Cap. 295) and its Subsidiary Regulations

The Dangerous Goods Ordinance (Chapter 295) was enacted in 1956. It is a piece of
legislation which provides for the controlling measures of dangerous goods on land and at
sea. Under the Ordinance, there are 5 Subsidiary Regulations, 2 of which are not yet
enforced. They are:
 Dangerous Goods (Application and Exemption) Regulations (Cap. 295A)
 Dangerous Goods (General) Regulations (Cap. 295B)
 Dangerous Goods (Shipping) Regulations (Cap. 295C)
 Dangerous Goods (Government Explosives Depots) Regulations (Cap. 295D)
 Dangerous Goods (Application and Exemption) Regulation 2012 (Cap. 295E) (not
yet enforced)
 Dangerous goods (Shipping) Regulation 2012 (Cap. 295F) (not yet enforced)

The DGO stipulates about 400 types of dangerous goods which are classified into 10
Categories in accordance with their characteristics, e.g. inflammable, toxic, corrosive,
spontaneous combustible, dangerous when wet, etc. In addition to the classification of
such goods, the DGO also provides for the control of such goods in other aspects, including
proper labelling and packaging of such goods, safety precautions during manufacture,
storage, use or conveyance of such goods on land and safety measures in the course of
shipment and transshipment of such goods.

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Sources (Issued by Fire Services Department): Detailed Guidelines on Application for Storage of Cat 2 &
Cat 5 DGs in Construction Sites (2005); Guidance Notes for Using Containers or Cargo Vehicles to Convey
or Stow Vehicle Parts Containing or Stained with Fuel (2003); Proposed Amendments to the Dangerous
Goods Ordinance (1999); Proposed Amendments to the Dangerous Goods (General) Regulations (Cap 295B)
& the Dangerous Goods (Application & Exemption) Regulations 2012 (Cap 295E) Consultation Document
(n.d.); Code of Practice for Interim Measures for Conveyance of Cat 3 and 4 DGs by Vehicles (1998);
Potential Hazards in the Conveyance of Flammable Liquid (Cat 5 DG) (n.d.); Guidance Notes for Using
Containers or Cargo Vehicles to Convey or Stow Vehicle Parts Containing or Stained with Fuel (2003);
Regulations on Gas Cylinder Approval & Examination (n.d.); Safety Guidelines for Storage or Use of Helium
Gas Cylinder in Lunar New Year Fairs (n.d.); Fire Protection Notice No. 4 Dangerous Goods General (n.d.);
Fire Protection Notice No 5 Hints on the Safe Use of Kerosene & Gas Appliances (n.d.); Safety Tips on
Refueling Generators / Internal Combustion Engines (n.d.); There are Many Types of Compressed Gases,
Understand Your Legal Liability (n.d.); Compressed Gas Cylinders_Storage Exceeding the EQ Requires a
Licence (n.d.).

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10.2 Dangerous Goods (Amendment) Ordinance

When the DGO was first enacted, there were no international standards governing the
classification, labelling and packaging of dangerous goods. Over the years, international
codes on the general transportation of dangerous goods and for specific modes of transport
have been developed and published, all based on the system developed by the United
Nations (UN) Economic and Social Council’s Committee of Experts on the Transport of
Dangerous Goods. Presently, the provisions for classification, labelling and packaging are
different in many ways from the United Nations' (UNs') Recommendations and
International Maritime Dangerous Goods (IMDG) Code, on which most overseas countries'
dangerous goods legislation is based. When dangerous goods are imported, exported or
re-exported, they are required to comply with two distinctive sets of requirements
prevailing in Hong Kong and other countries. This has created practical difficulty for local
trades and users. Furthermore, these international standards have stipulated a total of about
2,000 types of dangerous goods and that most of these dangerous goods are often found in
Hong Kong but are not covered by the DGO. In order to bring these provisions in line with
international standards, the controlling authorities under the DGO has carried out a
comprehensive review of the provisions for exempted quantities, classification, labeling,
packaging and conveyance of dangerous goods other than Categories 1, 2 and 5 on road by
vehicles, and the penalties for offences under the Ordinance.

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Sources from www.emsd.gov.hk

10.3 Gas Safety Ordinance (GSO) (Cap. 51)

The Electrical and Mechanical Services Department (EMSD) is responsible for the
enforcement of the Gas Safety Ordinance and acts as Hong Kong’s regulator on gas safety
by establishing gas safety standards and implementing safe working practices in the
importation, manufacture, storage, transport, supply and use of Towngas, Liquefied
Petroleum Gas (LPG), Natural Gas, or any mixture of such gases, whether in the form of a
liquid or vapour.

The enforcement of gas safety practices and its safe utilization are achieved through:
 Maintaining and administering a Register of gas supply companies, gas contractors
and installers, monitoring their performance and enforcing safety measures when
necessary.
 Monitoring, inspecting and approving the construction and operations of both new
and existing LPG installations, bulk storage at LPG terminals and the approval of
LPG road tankers. EMSD has also been involved in the Government’s LPG vehicle
initiative to improve the environment. EMSD also monitors and regulates the
natural gas supply facilities and pipelines, as well as the Towngas production plants,
storage systems and transmission and distribution network throughout Hong Kong.
 Preparing and approving safe codes of practice for gas installations and ensuring
gas safety with random inspections of the approved domestic gas appliances for use
in Hong Kong.
 Running an ongoing public gas safety education programme.

10.4 Subsidiary Regulations of GSO

10.4.1 General

Under the GSO, the following subsidiary regulations have been enacted:
 Gas Safety (Gas Quality) Regulations (Cap. 51A)
 Gas Safety (Gas Supply) Regulations (Cap. 51B)

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  Gas Safety (Installation and Use) Regulations (Cap 51C)
 Gas Safety (Registration of Gas Installers and Gas Contractors) Regulations (Cap.
51D)
 Gas Safety (Registration of Gas Supply Companies) Regulations (Cap. 51E)
 Gas Safety (Miscellaneous) Regulations (Cap. 51F)
 Gas Safety (Gasholders Examination) Regulation (Cap. 51G)

10.4.2 Gas Safety (Gas Supply) Regulation R. 23A

 No person shall carry out, or be permitted to be carried out, any works in the vicinity
of a gas pipe unless he or the person carrying out the works has, before commencing
the works, taken all reasonable steps to ascertain the location and position of the
gas pipe.
 A person who carries out, or who permits to be carried out, any works in the vicinity
of a gas pipe shall ensure that all reasonable measures are taken to protect the gas
pipe from damage arising out of the works that would be likely to prejudice safety.

10.4.3 Code of Practice: Avoidance of Danger to Gas Pipes

All works on roads are covered by the CoP: Avoidance of Danger to Gas Pipes, together
with works in areas other than built-up roads, including works in footways, on slopes, on
government and private land. Shallow works such as road resurfacing are also covered
since there is a need to ensure that surface boxes for valves and pipes which have been
extended to ground level are not damaged. Other matters relating to works near gas pipes,
such as the need to support excavations, are also covered. This CoP should also be
followed, in-so-far as is practicable, for works in the vicinity of submarine gas pipelines
and aboveground gas installations.

Sources (Issued by Electrical & Mechanical Services Department): Code of Practice GPS01 Avoiding Danger
from Gas Pipes (1997); Avoiding Danger from Gas Pipes (n.d.); Avoiding Danger from Gas Pipes - Guide
to Estate Management Companies (2016); Avoiding Danger from Gas Pipes - Information for Worker who
Actually Carries out the Works in the Vicinity of Gas Pipes (n.d.); Avoiding Danger from Underground Gas
Pipes & Electricity Cables (n.d.).

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10.5 Concept Checklist

This chapter is about the Dangerous Goods Ordinance and Regulations as well as the Gas
Safety Ordinance and Regulations. Key points to note include:
 Introduction to the DGO and its subsidiary regulations
 DG (Amendment) Ordinance
 Gas Safety Ordinance (“GSO”)
 Subsidiary regulations of GSO

10.6 Further Thinking

There may exist different requirements in the F&IUO and DGO to control the same type
of dangerous goods. For example, Regulation 9 the F&IU (Fire Precautions in Notifiable
Workplaces) Regulations permits the storage of less than 35 litres or less of thinner inside
properly designed cupboards or bins in the workroom of an industrial undertaking, while
Regulation 99(3) of the Dangerous Goods (General) Regulations only permits the storage
of such a chemical as long as it is not more than 20 litres without a dangerous goods store.
Hence, a proprietor of an IU storing a quantity between 20 and 35 litres of thinner in his /
her workplace will be fine with the law of the Labour Department but will contravene the
law of the Fire Services Department. What should the advice of a safety practitioner be to
this proprietor?

References

Dangerous Goods Ordinance 1956, Hong Kong, Available at

http://www.elegislation.gov.hk/hk/cap295 (Accessed on 31 December 2019)
Dangerous Goods (Application and Exemption) Regulations 1964, Hong Kong, Available
at http://www.elegislation.gov.hk/hk/cap295A (Accessed on 31 December 2019)
Dangerous Goods (General) Regulations 1964, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap295B (Accessed on 31 December 2019)
Dangerous Goods (Shipping) Regulations 1964, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap295C (Accessed on 31 December 2019)
Dangerous Goods (Application and Exemption) Regulation 2012, Hon g Kong, Available
at http://www.elegislation.gov.hk/hk/cap295E (Accessed on 31 December 2019)
Dangerous Goods (Shipping) Regulation 2012, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap295F (Accessed on 31 December 2019)
Electrical and Mechanical Services Department (2016) “Avoiding Danger from Gas
Pipes - Guide to Estate Management Companies”, Government Logistics
Department, Hong Kong.
Electrical and Mechanical Services Department (2018) “Code of Practice: Avoidance of
Damage to Gas Pipes”, Government Logistics Department, Hong Kong.

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Electrical and Mechanical Services Department (n.d.a) “Avoiding Danger from Gas
Pipes”, Government Logistics Department, Hong Kong.
Electrical and Mechanical Services Department (n.d.b) “Avoiding Danger from Gas
Pipes: Information for Worker who Actually Carries out the Works in the
Vicinity of Gas Pipes”, Government Logistics Department, Hong Kong.
Electrical and Mechanical Services Department (n.d.c) “Annual Inspection of LPG
Installations”, Government Logistics Department, Hong Kong.
Gas Safety Ordinance 1991, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap51 (Accessed on 31 December 2019)
Gas Safety (Gas Quality) Regulations 2019, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap51A (Accessed on 31 December 2019)
Gas Safety (Gas Supply) Regulations 1991, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap51B (Accessed on 31 December 2019)
Gas Safety (Installation and Use) Regulations 1991, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap51C (Accessed on 31 December 2019)
Gas Safety (Registration of Gas Installers and Gas Contractors) Regulations 1991, Hong
Kong, Available at http://www.elegislation.gov.hk/hk/cap51D (Accessed on 31
December 2019)
Gas Safety (Registration of Gas Supply Companies) Regulations 1991, Hong Kong,
Available at http://www.elegislation.gov.hk/hk/cap51E (Accessed on 31
December 2019)
Gas Safety (Miscellaneous) Regulations 1991, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap51F (Accessed on 31 December 2019)
Gas Safety (Gasholders Examination) Regulations 1996, Hong Kong, Available at
http://www.elegislation.gov.hk/hk/cap51G (Accessed on 31 December 2019)

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 Chapter 11
Roadwork Safety

11.1 Introduction

Apart from CS(S)R, there are other safety legislation relevant to roadworks including the
Road Traffic Ordinance (Cap. 374) and its subsidiary regulations, and in particular the
Code of Practice for the Lighting, Signing and Guarding of Road Works (“the CoP”) which
is enforced by the Highways Department (“HyD”).

Source (Issued by Highways Department): Code of Practice for the Lighting, Signing & Guarding of Road
Works (2017)

Workers required to work on a roadway/roadside include those engaged in road

construction and maintenance, utilities management (e.g. electricity, communications,
water and gas), service maintenance (e.g. drains, replacing street bulbs/lamps, and tree
cutting) and traffic management (e.g. tunnels, bridges, and expressway operation
establishments). Being struck by moving vehicles is one of the major threats to those
workers.

11.2 Roadwork Safety as Required by the Road Traffic

Ordinance and its Subsidiary Regulations

According to the Road Traffic Ordinance (Cap. 374), the HyD has prescribed the CoP. The
CoP was prescribed with reference to standards of the USA and Europe, etc., and based on
local past experience. When carrying out road maintenance works, contractors should
follow the requirements of the CoP. Furthermore, pursuant to regulation 20 of the Road
Traffic (Traffic Control) Regulations (Cap. 374G), contractors shall, in accordance with
Schedule 5 of the Regulations, erect signs, road markings, barriers and road hazard warning
lanterns with positions in compliance with the CoP, which otherwise would constitute an
offence. Non-compliance with other requirements of the CoP may in any civil or criminal

218
proceedings be relied upon by any party to the proceedings as tending to establish any
liability which is in question in those proceedings.

On the other hand, when conducting maintenance works on expressways, contractors shall
first apply to the HyD for an expressway works permit under the Road Traffic (Expressway)
Regulations (Cap. 374Q), and shall comply with the conditions of the permit, which
otherwise would constitute an offence.

11.3 Road Traffic Ordinance (Cap. 374)

The Road Traffic Ordinance empowers the Director of Highways to prescribe and from
time to time revise the CoP.

11.4 Road Traffic (Traffic Control) Regulations (Cap. 374G)

The person responsible for road works is required under the Road Traffic (Traffic Control)
Regulations to provide the following safety measures:
 R. 20: To erect and maintain prescribed lanterns, traffic signs and road markings to
be located in the manner set down in the CoP. Any non-prescribed equipment will
be treated as illegal obstructions if placed on any part of a road, unless with the
permission of the Commissioner for Transport or the Director of Highway.
 R. 21: To provide prescribed portable light signals or manually operated temporary
signs (“Stop / Go” signs) when the passage of vehicles in two directions is less than
5.5 m in width due to obstruction or excavation, so that vehicles will pass the
obstruction or excavation in either direction without risk of accident and without
unnecessary delay.
 R. 22(1): To provide sufficient fencing around dangerous excavations as will be
adequate and effective to prevent any pedestrian or vehicle from falling into the
excavation or being otherwise endangered, taking into account the nature and
position of the excavation.

11.5 Road Traffic (Expressway) Regulations (Cap. 374Q)

The Regulations require the persons carrying out expressway works, whilst on foot on any
part of an expressway, to wear reflective jackets. If necessary, road works personnel should
wear reflective trousers to enhance conspicuity. The vehicles used in connection therewith
shall be coloured bright yellow and installed with flashing lanterns and warning signs.

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11.6 Code of Practice for the Lighting, Signing and Guarding
of Road Works

Similar to the aforementioned Road Traffic Ordinance and its subsidiary regulations, the
requirements in the CoP are oriented towards ensuring traffic safety. However, it is very
difficult to draw a fine line between public safety and workplace safety in this respect.
Nonetheless, particular attention should be given below to those provisions that specifically
tackle the safety of road works personnel:
s. 3.2 Use the opportunity of lane closures for regular maintenance to carry out other
maintenance works required. Where permanent variable message signs, variable
speed limit signs, lane control signals or traffic information systems are available,
the person responsible should arrange with the Transport Department (“TD”)
and/or tunnel operator(s) to use these signs and systems to provide additional
warning to motorists. Reasons for not using these signs and systems must be
properly recorded.
s. 3.4 The person responsible shall strive to avoid putting the worksite in a vulnerable
situation and to carry out road works in daytime as far as practicable, with a time
window and working space sufficiently wide for setting up, maintaining and
removing lighting, signing and guarding and protection measures before, during
and after works execution, so as to minimize the risk of the road works being hit
by oncoming or passing vehicles.
s. 3.9 The person responsible should prepare layout plans showing the lanterns, traffic
signs and guarding equipment to be used to ensure that the necessary equipment is
available when required, and also ensure that the site staff clearly understand
where and what equipment is to be used. For works which require the lighting,
signing and guarding to be varied in any way during the works, a separate plan
showing each different phase should also be prepared.
s. 4.15 The boundaries of all road works on carriageways must be clearly delineated by
traffic cones. The aim is to guide approaching vehicles gradually into a lane
passing the works by means of an approach taper, and to ensure that a motorist can
readily judge the limits of the carriageway throughout the length of the works. Oil
drums, barrels or concrete blocks must not be used to delineate road works.
s. 4.19 Traffic cones or cylinders when used on one site shall be of the same height. Cones
and cylinders should be constructed in a manner that they will yield or collapse,
and will not present a hazard, when struck by vehicles.
s. 4.20 Cones or cylinders should be placed close enough together to give an impression
of continuity and an appearance of substance. The maximum cone or cylinder
spacings as outlined in the CoP should be followed.
s. 4.21 Obstructions and excavations shall be adequately guarded at all times for the safety
of all road users by means of continuous temporary tubular barriers which clearly
separate pedestrians from the works and trafficked carriageway and warn
pedestrians of their presence. Temporary tubular barriers may also be used for
fencing excavations to warn road users to take special care of the presence of
excavations so as to prevent pedestrians or vehicles from falling into the

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 excavation or being otherwise endangered. They should be placed with sufficient
clearance to excavations, materials or plant to prevent danger to pedestrians.
s. 4.25 Water-filled barriers without the stipulated containment level may be used as an
alternative to temporary tubular barriers and traffic cones to separate the trafficked
carriageway from the adjacent footway or work zone of road works, especially for
long term works. The barriers are proprietary-made water fillable plastic
containers of various sizes and shapes with a device for interlocking adjoining
container units. They are heavier in weight and offer better resistance to
displacement by vehicular collision as compared to temporary tubular barriers and
traffic cones.
s. 4.29 Temporary safety barriers with appropriate containment level are capable of
absorbing the energy of colliding vehicle. It may take the form of a permanent
type safety barrier erected temporarily or a purpose-made temporary safety barrier
of concrete, steel or water-filled type. It can be used as one of the means to
minimize the risk of off-track vehicles penetrating into the work zone and causing
damage or injuries to road works personnel, motorists, passengers and other road
users. If there is a need to provide protection to adjacent footways or hazards,
such as bridge piers and slopes, in association with the road works, the use of such
barriers should be considered.
s. 4.32 During the hours of darkness or at times of poor visibility, all obstructions or road
works must be properly delineated with prescribed road hazard warning lanterns
to indicate to road users the limits of the works.
s. 4.33 The colour of the light shown by a lantern shall be amber and the external surfaces
of the body of the lantern shall be coloured yellow. Each lantern shall be fitted
with a supplementary reflector of at least 50 cm2 in area which must appear under
headlamp illumination to be of a similar colour to the light emitted by the lantern.
s. 4.34 Lanterns may show an intermittent or revolving light. Flashing lanterns shall have
a flashing rate of 90 - 150 times per minute. The following is a list of lantern types
indicating where they shall be used:
 Low intensity battery operated lamps - to delineate temporary edges of
carriageways or footways. On temporary edges of a footway delineated by
temporary tubular barriers, a lantern shall be placed near each corner of the
delineated area, and additional lanterns shall be placed along the edges
exceeding 4 m in length so that the spacing between lanterns is not more than
4 m.
 High intensity battery operated beacons - to draw drivers’ attention to hazards,
e.g. at approach tapers or in conjunction with advance warning signs. They
shall not be used as a means of delineating the works. High intensity battery
operated beacons of the unidirectional type shall be used to supplement signs
indicating the beginning of a temporary diversion on expressways or roads
other than expressways with speed limit over 80 km/h.
 Revolving lanterns - to draw drivers’ attention to works on expressways by
placing them at the entry/exit points of a lane closure and mounting them on
vehicles.

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s. 4.42 A Flashing Arrow Sign (FAS) has a matrix of individual lights that can flash on
and off in a control manner to show arrangements such as “arrow to the right” or
“arrow to the left”. It must be used to warn motorists to take special care of the
presence of stationary or slowly moving works vehicles and lane closure on
expressways, high speed roads and roads with speed limit of 70 km/h or above. It
can be mounted on a vehicle, a trailer or a frame. For indicating lane closure on
these roads, FAS shall be placed on top of the barricade sign. Extending the use
of FAS on roads with a speed limit of 50 km/h or below should duly consider the
site-specific traffic condition and road layout. Any possible blockage of drivers’
sightline near a signalized junction or pedestrian crossing should be avoided.
s. 4.45 Temporary Variable Message Sign (VMS) is a LED matrix sign for displaying
variable messages. It stands out more than conventional sign plates and can better
draw the motorists’ attention to the road works ahead. A temporary VMS shall be
used for road works on expressways with hard shoulders of a width not less than
3m in addition to advance warning signs. Where considered appropriate, it should
also be used on other roads to provide additional warning to motorists.
s. 4.48 Road markings of an approved type may be used at road works where appropriate
to delineate carriageway edges or to divide a carriageway into traffic lanes. Where,
during the course of road works, the road remains in use and dangers are likely to
occur through absence of road markings, temporary markings shall be laid down.
Suitable self-adhesive materials for such temporary markings should be used.
Other materials, such as thermoplastic material complying with the requirements
for road markings, may also be used. The markings must be completely removed
as soon as their purpose has been served.
s. 4.52 For their own safety, it is important that persons working on or near carriageways
are made visible to motorists and they shall always wear highly visible clothing,
incorporating retroreflective stripes or patches. Under the Road Traffic
(Expressway) Regulations (Cap. 374Q), any person carrying out expressway
works must, when on foot on any part of an expressway, wear a reflective jacket
of a type approved by the Director of Highways. If necessary, road works
personnel should wear reflective trousers to enhance conspicuity.
s. 4.53 A Truck Mounted Attenuator (TMA) is designed to absorb the energy of a trailing
vehicle colliding onto the vehicle fleet so as to reduce the severity of damage and
injury. The equipment is mounted at the rear end of a shadow vehicle to protect
road works personnel in the works areas in front or to escort works vehicles when
performing mobile operation activities. The setup of shadow vehicle with a TMA
shall be used for lane closure and mobile operations on expressways, high speed
roads and other roads with a speed limit of 70 km/h or above.
s. 4.55 The General Road Works Signs obtainable from the TD are to be displayed at
locations and heights as indicated in the CoP.

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s. 5.6 The first sign, which should always be a “Road Works Ahead” sign, shall be sited
in advance of the start of the approach taper, and suitably located such that
motorists are provided with the minimum visibility to the sign. If placement of
the first sign is required at a position where it does not meet the minimum visibility
to the sign due to site constraints, an additional sign shall be placed in advance of
the original position to give motorists sufficient warning when approaching the
worksite. For roads of speed limit not exceeding 70 km/h, at least one additional
advance warning sign, describing the hazard, shall be placed midway between the
first sign and the hazard, whilst for higher speed roads, two additional signs are
required, equally spaced, between the first sign and the works.

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s. 5.7 Where the approach conditions are such that the warning signs could be missed,
such as where the approach is on a left hand bend, the approach signs should be
duplicated on the right hand side of the road. For dual-carriageway roads,
duplicated signs both in the verge and the central reservation shall always be
required.
s. 5.8 On roads where the alignment is poor or there is insufficient width for two way
traffic, advance warning to traffic in each direction should be given by a “Road
Works Ahead” sign.
s. 5.9 The “End of Road Works” sign shall be placed beyond the limit of the works. On
dual-carriageway roads, the sign shall be duplicated both in the road verge and the
central reservation.
s. 5.10 The design of approach tapers is an important feature of all road works, to ensure
that motorists are guided to safely pass the works area. The use of traffic cones,
together with road hazard warning lanterns, regulatory “Keep Right/Keep Left”
signs and “Barricade” sign indicating lane closure provides a uniform and
consistent indication to motorists of the obstruction or excavation on the
carriageway. At locations where visibility could be a problem, the barricade sign
should be used with a FAS. Approach tapers shall not be used for entering or
exiting the works site.
s. 5.12 High intensity battery operated beacons of the type showing an intermittent amber
light shall be placed within the line of cones. They shall be mounted on stands or
cones. On roads with a speed limit of 70 km/h or above, mounting on cones is the
only acceptable method.

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s. 5.13 Where traffic control, either by use of portable light signals or “Stop/Go” signs is
used, a much shorter approach taper is required. It shall be formed by cones at 45°
to the line of the road, placed at 1 m spacing. High intensity battery operated
beacons shall be placed between each successive cone at 1 m spacing.
s. 5.14 For exit tapers at the end of the temporary carriageway restrictions, the taper shall
be formed at 45° to the line of the road.
s. 5.15 Throughout the length of the restricted carriageway, cones shall be used to
delineate the edge of the carriageway. They shall be placed at appropriate spacing.
s. 5.21 Obstructions or excavations shall be guarded on all sides. Unless there are
continuous barriers or railings which prevent pedestrians from approaching the
obstructions or excavations, the obstructions or excavations shall be guarded by
temporary tubular barriers.
s. 5.22 For works on expressways, high speed roads and roads with a speed limit of 70
km/h or above, a guarding arrangement using a TMA mounted on a shadow
vehicle shall be placed in front of a longitudinal safety clearance zone before the
works area, unless temporary safety barriers are provided at the approach taper.
s. 5.23 For excavation works on carriageways with an excavation depth not exceeding
150mm, such as cold milling and resurfacing works, the maximum spacing of
traffic cones and lanterns placed alongside the works area and the longitudinal
safety clearance zone shall be 3 m and 6 m respectively. With such an
arrangement, the provision of temporary tubular barriers is not required.
s. 5.24 For works on carriageways with:
 excavation depth greater than 150 mm;
 works involving temporary removal of existing roadside barriers;
 the need to provide protection to temporary or permanent bridge supports; or
 any other situations where the person responsible considers there is risk of off-
track vehicles penetrating into the work zone taking into account the site
conditions including available lanes / working width, road curvature, speed
limit of the roads, access arrangement for works / emergency vehicles, frontage
access, duration of works, and extent of works area, etc.,
the person responsible shall use temporary safety barriers whenever possible to
provide sufficient fencing for the approach taper and around the work site to
minimize the risk of causing damage or injuries to road works personnel, motorists,
passengers and other road users in case the road works are hit by a vehicle. If
temporary safety barriers are provided at the approach taper, it can be used as an
alternative to the TMA mounted on a shadow vehicle for guarding.

s. 7.3 For expressways and roads with a speed limit of 80 km/h or above, the lateral
safety clearance between the works area and any part of the trafficked carriageway
shall not be less than 1.2 m. Where it is impractical to provide such safety
clearance, the lateral safety clearance shall be as wide as practicable with an
absolute minimum of 0.5 m. Also, measures to temporarily reduce the speed of
traffic passing the site to 70 km/h shall be put in place. For roads other than

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 expressways with a speed limit of 70 km/h or below, the lateral safety clearance
shall not be less than 0.5m. The above are the minimum lateral clearance
requirements. Where it is reasonably practicable to provide additional clearance
by closing the traffic lane adjacent to the road works, this should be done.
s. 7.4 To provide the required minimum lateral safety clearance, it may be necessary to
occupy part or whole of the adjacent traffic lane if it is agreeable to relevant
authorities. In situations where the required closure of part or whole of the
adjacent lane to provide the lateral clearance is restrained by site conditions, the
available options could include:
 closing the road for the road works and diverting its traffic to another route, if
practicable;
 setting up a guide island, imposing a speed limit reduction temporarily or by
other means, reducing the speed of the oncoming and passing traffic to a safe
limit such that the traffic will not pose any hazard to the road works personnel.
The alternative must be fully justified and properly recorded with the
consideration to address workers’ safety, and agreed by the TD, Police Force and
the HyD.
s. 7.5 Longitudinal safety clearance zone is an unoccupied space between the end of the
approach taper and the works area which provides a margin of safety for both the
traffic and road works personnel and should not be used as a working space. The
interface of the longitudinal safety clearance zone and the works area shall be
delineated by traffic cones at 1 m spacing unless a continuous barrier is provided
along the interface. The purpose of marking the interface is to prevent road works
personnel inadvertently entering this safety clearance zone. For expressways,
high speed roads and other roads with a speed limit of 70 km/h or above, a
longitudinal safety clearance zone of 50 m in length together with the guarding
arrangement shall be provided. For roads with a speed limit below 70 km/h, a
longitudinal safety clearance zone of 10 m in length shall be provided. Should
there be situations where site constraints restrain the implementation of the
longitudinal safety clearance zone and the guarding arrangement, the agreement
of the directorate officer in the government department or the equivalent in
another department responsible for the road works, for not adopting the specified
guarding arrangement must be sought.
s. 7.6 Setting up the works area should commence with the placing of traffic signs, cones
and barriers. The operation should be performed facing oncoming traffic,
beginning with the “Road Works Ahead” sign, and progressing in sequence
towards the obstruction or site of works. Removal of the set-up is the reverse of
this procedure.
s. 7.7 All signs made temporarily redundant by the road works shall be covered, and any
road markings made temporarily redundant shall be masked. Temporary road
works signs must not obscure any permanent sign. When the signing layout has
been established, it is advisable to drive through the site to check the signing from
the driver’s point of view.

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s. 7.8 Once a works area is established, tools and materials must not be left outside the
area. Site traffic and equipment must be parked within the works area, and
movement of plant and materials to or from the site should, if possible, be
restricted to “off peak” traffic periods. The site must be kept tidy, and the adjacent
carriageways and footways kept free of loose stones, materials and debris.
Temporary footways must be maintained in a satisfactory condition such that the
movement of pedestrians is not impeded in any way.
s. 7.10 Minor works (which are those planned to start and be completed on the same day
outside the hours of darkness and not during times of poor visibility) on minor
roads may dispense with the need for a “Barricade” sign, provided a
conspicuously coloured works vehicle is permanently in attendance, with an
amber flashing roof beacon and rear markings, parked at the start of the works
area.
s. 7.11 For minor works on minor roads, the advance warning signs may be dispensed
with provided a vehicle fitted with an amber flashing roof beacon is permanently
in attendance throughout the works or the works are confined between parked
vehicles.
s. 7.12 A road may be considered a minor road if it satisfies the following:
 a single carriageway access or local distributor road in an urban area;
 subject to a speed limit of 50 km/h; and
 characterised by infrequent bus services and low pedestrian flows.

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s. 7.16 High speed roads are designed to carry a large volume of free flowing traffic. They
are the trunk roads connecting to expressways and have the following typical
characteristics:
 speed limit of 70 km/h or above;
 no adjacent pedestrian facilities; and
 directly connecting to expressways with no traffic lights.
s. 7.18 Basically, the procedures and requirements of lighting, signing and guarding for
road works on high speed roads should follow those prescribed above. To enhance
traffic safety and where considered appropriate, consideration should be given to
adopting the practices for expressways.
s. 8.2 Summary of Safety Requirements applicable to Expressway Works:
 size of warning sign to be 1200 mm;
 first advance warning sign to be placed 600 m ahead;
 1,000 mm high cones to be used;
 cone spacing to be 9 m parallel to traffic lane (18 m for short duration day time
works not at tight bends nor near slip roads);
 approach and end taper cone spacing to be 2 m and 1 m respectively;
 temporary tubular barriers not to be used;
 high intensity battery operated beacons to be used along tapers and in
conjunction with advance warning signs;
 road hazard warning lanterns to be mounted on cones 1.2 m above the road
surface;
 flashing arrow signs (FAS) to be used with barricade signs to indicate the
beginning of a temporary diversion;
 slow moving works vehicles to be mounted with FAS;
 high visibility clothing to be worn by workers;
 1.2 m lateral safety clearance to be maintained;
 50m longitudinal safety clearance zone to be maintained; and
 shadow vehicle with a TMA in front of the 50m long longitudinal safety
clearance zone to be placed before the works area as a guarding provision;
 any permanent variable message signs, lane control signals, variable speed
limit signs and/or traffic information system in the vicinity of the lane closure
shall be displayed with a suitable message to provide additional warning to
motorists. The Transport Department and/or tunnel operator(s) shall be
contacted in advance and during the works for this purpose.
s. 8.6 Due to the free flow condition and the generally higher speed on expressways, the
following requirements must be carefully observed:
 Traffic must always be presented with a full lane to travel in. This means that
when closing a lane, a full lane width must always be closed, never part of a
lane.

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  A lateral safety clearance shall be maintained between any activity and the
trafficked carriageway. Since partial lane closure on expressways is not
permitted, the lateral safety clearance required will necessitate the closure of
an additional traffic lane if the total width of the works area and lateral safety
clearance is wider than one traffic lane.
 A longitudinal safety clearance zone together with a guarding arrangement
shall be maintained between the end of the approach taper and the works area.
s. 8.7 Layouts shall be designed so that traffic merges to the left if more than one lane
on the left side of a carriageway is to be closed. This may necessitate the forming
of a guide island before the actual work zone to merge traffic to the left before
shifting traffic back to the right side of the work zone. Traffic could be merged
directly to the right at the lane closure if only the leftmost lane is closed. Left
merging must be followed if it is necessary to close, using a single approach taper,
more than one lane leaving only the right most lane for traffic.
s. 8.9 The Police must always be informed before a lane closure is implemented.
s. 8.10 Depending on the traffic density and the road conditions, it may be necessary to
have the assistance of the Police when setting up or subsequently removing a lane
closure on an expressway. This applies particularly to the placement of advanced
warning signs in the central reservation and to the establishment of the approach
taper.
s. 8.12 When it is necessary to set up a guide island to force left merging, the whole guide
island shall be in place before setting up cones and other signs to delineate the
main work zone.
s. 8.13 When it is necessary to set up lane closures during the hours of darkness, extreme
caution must be exercised during the whole operation. The procedure for setting
up the lane closure will be the same as that for day time closures, except that the
appropriate road hazard warning lanterns must be set out at the same time as the
signs and cones, so that approaching traffic is always presented with lanterns and
signing.
s. 8.15 All vehicles shall enter or leave the lane closure only at the designated entry or
exit points.
s. 8.17 When planning road pavement repairs or resurfacing works, the lateral safety zone
shall be taken into account. It shall be necessary to close the middle lane to create
a safety zone if the whole width of the slow lane is to be occupied for the
resurfacing work. An alternative is to carry out the works when the whole
carriageway can be closed.
S. 9 Some key points to note:
 If the road traffic is obstructed, signs must be erected.
 If the road width is restricted to less than 5.5 m, traffic control must be operated.
 Traffic must always be provided with a full lane on expressways.
 An escort must be provided in carrying out mobile operations on expressways,
high speed roads and other roads with a speed limit of 70 km/h or above.

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A-1.1 In mobile operations, works vehicle(s) (“WVs”) may move along the road
intermittently or continuously, but planned stops shall not be more than 15
minutes each. Operation vehicles should progress with the flow of traffic at a
speed not exceeding 25 km/h or the speed specified by the manufacturer of the
truck mounted attenuator (TMA), whichever is the less. Mobile operations mainly
include the following activities:
 setting up lane closure;
 removing lane closure;
 road lighting maintenance;
 picking up litter;
 landscaping work, e.g. pruning, weeding and watering;
 gully emptying;
 road sweeping and cleansing; and
 patching pot-holes.
A-1.2 Mobile operation procedures shall be adopted on expressways, high speed roads
and all other roads with a speed limit of 70km/h or above. The principles of these
procedures are applicable to mobile operations on high speed roads and roads with
a speed limit of 70 km/h or above.
A-2.1 Depending on the traffic conditions, call the Police for assistance when necessary
especially during the hours of darkness before the mobile operation.
A-2.2 Under the following circumstances, mobile operation procedures shall not be
carried out, except in emergencies:
 Work requiring WVs to stop for more than 15 minutes.
 Inclement weather and poor visibility.
 Traffic flow is significantly affected.

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A-2.3 During the mobile operation,
 the WVs must be escorted by a shadow vehicle (SV) equipped with a TMA.
The TMA shall be unfolded during mobile operations. All the WV(s) and SVs
shall be equipped with a flashing arrow sign (FAS). The FAS installed on the
SV should be positioned near the vehicle end as close as possible, but without
affecting the folding and unfolding operations of the TMA.
 the TMA shall be folded up or unfolded at a suitable place. A suitable place
refers to an area where the folding or unfolding of the TMA shall not cause any
disturbance to any oncoming or nearby vehicles. Hard shoulders or laybys of
widths not less than 3m and with sufficient visibility for oncoming vehicles are
considered as a suitable place where the TMA can be folded up or unfolded;
 the distance between the WVs and the SV shall follow the buffer distances.
For moving works, such as road lighting maintenance, picking up litter,
landscaping works, gully emptying, road sweeping and cleansing, and patching
pot-holes, at a bend or location with inadequate sightline distance, when the
geometry of the road section of inadequate sightline distance is in such a
manner that the driver of a vehicle immediately bypassing the SV cannot see
the WV ahead, an additional SV equipped with a TMA shall be provided
between the SV and the first WV to prevent any vehicle bypassing the SV from
wedging-in the relevant road section inadvertently. The last SV of the convoy
shall stay before the start of the bend or before the crest of a slope. The SV
shall also keep a distance of at most 100m from the WVs;
 all the WVs and SVs shall be equipped with communication facilities in order
to maintain effective communication; and
 all the WVs and SVs must switch on their hazard warning lights, strobe lights
and the FAS to alert oncoming vehicles to use other traffic lanes. In addition,
drivers of the WVs and SVs should pay attention to the road traffic at the back.
A-3.1 The following work procedures shall be observed in setting up a lane closure:
 Informing the TD and/or tunnel operator(s) to suitably display a road works or
lane closure related message if there is any permanent variable message signs,
lane control signals, variable speed limit signs and/or traffic information
system in the vicinity of lane closure;
 Erecting temporary VMS (where appropriate) and advance warning signs;
 Setting up the approach taper; and
 Completing the lane closure set-up.
A-4.1 In removing the lane closure set-up, the procedures shall be carried out in the
reverse order to those of setting up the lane closure:
 Removing the lane closure set-up;
 Collecting all advance warning signs; and
 Informing the TD and/or tunnel operator(s) to suitably cancel the display of
road works or lane closure related messages if there is any permanent variable

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 message signs, lane closure signals, variable speed limit signs and/or traffic
information system in the vicinity of lane closure.
A-5.1 The following working procedures shall be followed when carrying out mobile
operations including road lighting maintenance, picking up litter, landscaping
work, gully emptying, road sweeping and cleansing, and patching pot-holes
(except for road bends and special road sections with inadequate sightline):
 The WVs and the SV shall move slowly along the slow lane or fast lane with
their strobe lights, FAS and hazard warning lights switched on and the TMA
unfolded at a suitable place beforehand, and with a speed not more than 25
km/h or at the speed specified by the manufacturer of the TMA, whichever is
lesser.
 The buffer distances between the WVs and the SV shall be maintained.
 When the work location is identified, the WVs and the SV shall communicate
with each other by telecommunication so as to ensure they stop at a safe spot
before letting workers come down to the road or commence work on the WVs.
 Workers shall work within 3 m on the side or in front of or on the WVs, and
shall stay within the traffic lane on which the WVs and the SV has stopped.
A-5.2 The following procedures shall be followed when carrying out mobile operations
including road lighting maintenance, gully emptying, picking up litter,
landscaping works, road sweeping and cleansing, and patching pot-holes on a road
bend or road section with inadequate sightline (e.g. after a crest):
 Same as para. A-5.1(a).
 Same as para. A-5.1(b).
 When the work location is on a road bend or on a road section with inadequate
sightline (e.g. after a crest), the provisions under para. A-2.3(c) shall be
followed.
 Same as para. A-5.1 (d).
 After the work is completed, the SV shall move forward once the WVs has left
the road bend or the road section with inadequate sightline. After the SV
catches up the WVs, it shall then maintain a proper buffer distance and proceed
to the next work location.
A-5.3 The following procedures shall be followed when carrying out mobile operations
including road lighting maintenance, picking up litter, landscaping works, gully
emptying, road sweeping and cleansing, and patching pot-holes on an expressway,
the work locations of which are on the hard shoulder (except for road bends and
special road sections with inadequate sightline). A-5.3.1 Hard Shoulder Width not
less than 3.3m (a) The procedures as described in para. A-5.1(a) to (d) above shall
be followed, except that the WVs and the SV shall move slowly along the hard
shoulder and workers shall stay within the hard shoulder on which the WVs and
the SV has stopped. A-5.3.2 Hard Shoulder Width less than 3.3m (a) The WVs
shall move slowly along the hard shoulder occupying part of the slow lane if
necessary and the SV shall move slowly along the slow lane, with their strobe
lights, FAS and vehicle’s hazard warning lights switched on and the TMA

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 unfolded at a suitable place beforehand, and with a speed not more than 25km/h
or the speed specified by the manufacturer of the TMA, whichever is the less. (b)
Same as para. A-5.1(b). (c) Same as para. A-5.1(c). (d) Workers shall work within
3m on the side or in front of or on the WVs, and shall stay within the hard shoulder
on which the WVs has stopped. A-5.4 The following procedures shall be followed
when carrying out mobile operations including road lighting maintenance, picking
up litter, landscaping works, gully emptying, road sweeping and cleansing, and
patching pot-holes, the work locations of which are on the hard shoulder and on a
road bend or special road section with inadequate sightline. A-5.4.1 Hard Shoulder
Width not less than 3.3m (a) The procedures as described in para. A-5.2 above
shall be followed, except that the WVs and the SV shall move slowly along the
hard shoulder, the FAS shall be switched off and workers shall stay within the
hard shoulder on which the WVs and the SV has stopped. A-5.4.2 Hard Shoulder
Width less than 3.3m (a) Same as para. A-5.3.2(a). (b) Same as para. A-5.1(b). (c)
Same as para. A-5.2(c). (d) Same as para. A-5.3.2(d). (e) Same as para. A-5.2(e).
A-6 The following safety precautions shall be observed in carrying out mobile
operations:
 The driver of the SV with TMA must have received proper training on driving
the vehicle provided by recognized institutions of motoring. Upon satisfactory
completion of the training, a completion certificate valid for not more than 3
years will be issued to the driver. Only drivers with valid certificates are
allowed to operate vehicles mounted with TMAs.
 Check the WVs, the SV, the strobe lights, the TMA, the FAS, the high intensity
battery operated beacons, the low intensity battery operated lamps and the
telecommunication equipment to ensure that they can function properly.
 Maintain the buffer distances and stop at pre-determined locations.
 Workers in the WVs must pay attention to the traffic conditions and ensure that
the SV has stopped at a suitable location and it is safe before they get off the
WVs.
 Workers should always face the direction of the oncoming traffic and pay
attention to the traffic conditions when erecting warning signs, road hazard
warning lanterns and traffic cones.
 Workers must wear proper personal protection equipment such as safety
helmets and reflective jackets.

11.7 Safe System of Work

Most accidents involving deaths or serious injuries occur on expressways. The vehicles
involved were traveling near road sections where maintenance works were being
undertaken late at night or during the small hours of morning and crashed into the works
vehicles which were either parked at the maintenance works area or moving slowly. As the
speed of vehicles on expressways is relatively high, any accident may cause serious
consequences.

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Major safety problems of roadway/roadside work include:
 failure to devise and implement a safe system of work by conducting task-specific
risk assessments and formulating safe working procedures and measures to safeguard
the workers at work;
 poor temporary traffic management control such as unclear and insufficient traffic
signs, insufficient buffer space, and detours / temporary routes causing driver
confusion;
 insufficient clearance provided between the work zone and live traffic;
 inadequate arrangements to warn drivers or control their movement close to workers
at work;
 insufficient lighting, signing and guarding in place to protect the workers engaged in
roadway or roadside work;
 the procedure for installing and removing traffic cones, signs and traffic control
measures were not well planned; and
 inadequate training and supervision provided to the workers involved, particularly
lookout men at the ingress/egress of construction sites.

Safety practitioners should advise their clients/contractors to adopt a safe system of work
including, but not limited to, the following preventive measures:
 Task-specific risk assessments should be conducted by a competent person, taking
into account the specific nature of work (e.g. handling of vehicle breakdown,
handling of traffic incident/accident, diversion of traffic, cordoning off of incident/
accident scene, lane closure, stopping of vehicle, vehicle recovery and various types
of roadworks), work location (e.g. toll booth, toll plaza, trunk road, carriageway,
footway, junction of expressway, tunnel and bridge) and all major risk factors namely,
estimated approach speed of vehicles, weather condition, visibility, layout of the road,
road condition, flow of traffic and traffic volume. Where lane closure is involved, a
permit from the Police must be sought in the first instance;
 Safe working procedures and measures should be formulated and implemented to
safeguard the workers, having due regard to the result of the risk assessments, and in
line with relevant codes of practice / guidelines. The safe working procedures and
measures should enable safe conduct of the road works as a whole, including the
setting up and removal of lighting, signalling and guarding of the works, which not
only should take care of the safety of the workers involved but that of other road
users as well;
 Provision of training workshops on safe working procedures, e.g. warning sign, PPE,
seeking information from Police;
 The control measures to tackle the hazard of being struck by moving vehicles in toll
areas should include, but are not limited to the following:
o as far as practicable, provide direct access to toll booths, such as tunnels or
bridges without requiring workers to cross active traffic lanes;

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o install a suitable metal railing along the pathway within a toll area to safeguard
the workers while they are walking along the pathway;
o display suitable and adequate warning signs in respect of road-crossing safety
within a toll area;
o demarcate and isolate the work areas on carriageways by suitable and adequate
warning lights, traffic cones, traffic signs and barriers in accordance with the
established safety procedures / relevant codes of practice;
o ensure that the setting-up and removal procedures and requirements for
warning lights, traffic signs, traffic cones and barriers are in accordance with
the established safety procedures / relevant codes of practice;
o consider using work zone protection barriers designed to an appropriate
standard for absorbing the energy of colliding vehicle(s) in order to minimize
damage and injuries to workers concerned;
o as far as practicable, give advance warning to alert road users about any
emergency situations, such as road accidents ahead through the display/
broadcasting/radio systems of the highways/tunnels;
o as far as practicable, use suitable flashing arrow signs with barricade signs to
indicate the beginning of a temporary traffic diversion;
o ensure that shadow vehicles equipped with a suitable truck-mounted attenuator,
high mount strobe light bar, flashing arrow signs and rear marking are used
when conducting road works on roads with a speed limit of 70 km/h or above
(including expressways);
o where appropriate, impose temporary speed limits on traffic routes through
erecting speed limit signs;
o place plant, equipment and tools as far away as practicable from moving
vehicles;
o maintain an adequate buffer distance from the barriers to the work areas;
o arrange the operation to be performed with the workers concerned facing the
oncoming traffic as far as possible;
o arrange the workers who guide vehicles to carry out their duties at safe
positions as far as possible and provide them with suitable personal protective
equipment as necessary, such as high visibility reflective clothing and traffic
control batons, and ensure their proper use of the equipment;
o without prejudice to the safety of other road users, consider upkeeping the
lighting, signing and guarding requirements for carrying out road works and
adopting new innovations to enhance road works safety, by making reference
to the latest relevant technologies and overseas standards/practices and taking
into account their technical capability, implementation procedures and
constraints.
o An effective coordination/communication system among the contractors,
different levels of management/supervisory personnel and workers should be
established and maintained to ensure full appreciation of potential traffic

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 hazards and clear understanding of the associated hazard control program and
delineation of safety responsibilities;
o The workers and management/supervisory personnel should be provided with
the necessary safety information, instruction and training to ensure that all
workers involved are familiar with the safe working procedures and safety
measures in the traffic hazard control system; and
o An effective monitoring and control system should be established and
maintained to ensure that the safe working procedures and safety measures for
potential traffic hazards are strictly followed. The works vehicle(s), the
shadow vehicle, the truck mounted attenuator, the flashing arrow signs and the
telecommunication equipment, etc. should be maintained and checked
periodically to ensure that they function properly.

When conducting mobile operations on expressways, it is necessary to use shadow vehicles.

Shadow vehicles must be equipped with a truck mounted attenuator, amber flashing beacon,
flashing arrow sign and barricade sign. According to the speed limit of the road and mode
of operation, the works vehicle and shadow vehicle need to maintain a proper buffer
distance. The relevant requirement on buffer distance can be found in the CoP.

In 2007, the HyD included the requirement of using shadow vehicles when conducting
mobile operations (such as setting up a lane closure, removing lane a closure, gully
emptying, sweeping/watering, or emergency road surface repairs, etc.) on expressways in
the CoP in order to strengthen protection within the works area. The works vehicle and the
shadow vehicle shall be equipped with warning lanterns and signing to provide early
warning to other motorists. The CoP also stipulates that, when carrying out maintenance
works on expressways with lane closure, advance warning signs shall be displayed at least
600m in advance of the works area. Flashing arrow signs shall also be displayed where
temporary diversion begins.

Under its road maintenance contracts, the HyD has required the contractors to formulate
safety plans and implement safety management systems to strictly ensure that works
procedures are conducted safely. The foremen and safety officers / safety supervisors of
contractors shall conduct site inspections to monitor safety at operations. The HyD will
also conduct regular random and surprise inspections. If any irregularities are found, the
HyD will deduct payment according to the contract mechanism. Serious non-compliance
cases will be reflected in the contractor’s performance reports. The past performance of
contractors is one of the factors in considering their future tenders for public works
contracts.

In addition, contractors are required to conduct road maintenance works late at night or
during the small hours of morning to alert the TD in advance, such that the TD can better
disseminate information about the areas of road maintenance works and traffic
arrangements to motorists through various channels. Where work has to be done during the
period 7pm to 7am or during holidays, a construction noise permit must be sought from the
Environmental Protection Department.

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Source from https://www.legco.gov.hk/yr16-17

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11.8 Concept Checklist

This chapter is on roadwork safety. Key points to note include:

 Introduction
 Roadwork safety as required by the Road Traffic Ordinance and its subsidiary
regulations
 Road Traffic Ordinance
 Road Traffic (Traffic Control) Regulations
 Road Traffic (Expressway) Regulations
 CoP for the Lighting, Signing and Guarding of Road Works
 Safe system of work

11.9 Further Thinking

Apart from the Transport Department, Police and Environmental Protection Department,
permission from other Government Departments may be required for certain road work,
e.g. Highways Department if it involves an expressway, Water Supplies Department if it
involves water works on roads, Drainage Services Department if it involves sewage works
on roads, Civil Engineering and Development Department if it involves slopes, Leisure and
Cultural Services Department if it involves branch trimming or fallen tree removal,
Agricultural, Fisheries and Conservation Department if it involves roadwork in country
parks and special areas etc. Each Government department may have their own specific
health and safety requirements stated in different guidelines as stipulated in laws, codes of
practice, technical circulars or practice notes. Try to identify some of these laws and
guidelines.

References

Highways Department (2017) “Code of Practice for the Lighting, Signing and Guarding of
Road Works”, Government Logistics Department, Hong Kong.
Labour Department (2016) “Systemic Safety Alert - Road/Roadside Work Safety”, SSA-
05-2016, Labour Department.

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