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AMSASHE00018
Nico Grobler
Revised and ArcelorMittal South Africa
15 May 2014
recommended: Champion for working at
heights
Francois Bezuidenhout
Approved by: Safety, Health and Wellness 28 May 2014
Group Manager
QUALITY.
• Not applicable.
SAFETY.
• This document contains specific safety instructions regarding the management and control of work
performed in elevated positions (i.e. work at heights) that are in line with the ArcelorMittal global
standards document that must be applied and adhered to at all times.
HEALTH.
• People who perform work in elevated positions must be both physically and psychologically fit for this type
of work to avoid complications in the execution of the task. This is described further in the document.
ENVIRONMENT.
• Not applicable.
1.3. PURPOSE.
The purpose of this procedure is to set standards that must be applied to manage and perform work in
elevated positions (work at heights) in a manner that minimizes the risk to those performing the work. Falls
from elevated positions (heights) have contributed to a significant proportion of the fatal incidents in the
ArcelorMittal Group. The causes and contributing factors to these incidents have been:
o Failing to wear a harness
o Lack of job planning and job assessment
o Wearing the wrong sort of harness
o Unstable set up of elevated work platforms
o Wearing the harness incorrectly
o Unguarded or un-barricaded hole, edges, voids excavations or walkways.
“Copyright ArcelorMittal Steel South Africa Limited. This manual is the property of ArcelorMittal Steel
South Africa and may not, as a whole or in part, be reproduced or alienated without the prior written
permission of the copyright holder.”
3.2 Competent person: In relation to the design of lifeline and anchor systems is one who:
a) has obtained an engineering diploma in a mechanical discipline with an academic qualification of
at least T3 or N5, or
b) is a graduate engineer in the mechanical discipline.
3.3 Competent person: In relation to the operation and control of man elevation devices such as mobile
work platforms, scissor lifts, man lifts etc. is one who has been trained both theoretically and
practically and subsequently subjected to practical assessment to confirm the capability to safely
operate the equipment.
3.4 Competent person: In relation to the preparation of a fall protection plan is one who has been
designated to prepare fall protection plans on the strength of having received training in this
procedure document AMSASHE00018.
3.5 Demarcation: Is defined as any method that indicates that an area is used for a specific purpose, or
that access is restricted. Examples are barrier tape, painted lines on floor surfaces, portable signs
denoting drop zones or no unauthorized access beyond a specific point.
3.6 Fall prevention: The design and use of securing devices and systems such that no exposure to a fall
hazard occurs. This may require more than one fall prevention system or a combination of prevention
measures. As these measures (such as work platforms or scaffolds) prevent the worker from falling
from an elevated position they must, wherever practical, be provided to safeguard the work position. It
includes, but is not limited to:
• fixed work platforms
• scaffolds
• man elevation devices such as scissor lifts / Skyjacks and man lifts / cherry-pickers
• manhole covers, floor plates
• handrails, toe-boards
• a short restraining lanyard preventing a person from reaching the exposed work position (such
as an unprotected edge
• Low ground clearance kit is fall prevention/protection system that is designed for large
transformers and will work on low roofs and similar equipment.
Low ground clearance kit: Most fall accidents occur from 1 to 3 meters from the ground. Conventional fall
protection equipment is therefore ineffective considering that often anchors are located at foot level and
deceleration devices such as fall arrest blocks and shock absorbing lanyards may not have the distance
required to deploy to prevent the user from colliding with the ground. The Low Ground Clearance Fall
Arrest-Restraint System is designed to make use of anchors at ground level to be rigged up on the ground
which will give the user full vertical fall protection from the ground & back and restraint when working on the
structure. Integral belay devices are used to perform rescues if required. This fall protection kit is simple to
rig up, simple to use and offers high levels of fall protection & restraint. Typical areas for use are:
AMSASHE00018 (AMSA working at heights procedure)(rev 01).doc
Implementation date: 1 December 2013
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Transformers, low roofs, tankers, machinery and shipping containers. For more information, contact the
AMSA working at heights champion.
3.7 Fall protection: All securing devices used to arrest a person in a fall and to prevent further injury
when the person falls from an elevated position (height). These devices are intended to protect the
worker when falling from an elevated position; fall prevention must always be seen as the preferred
safeguarding before fall protection is considered.
Excludes:
• Safety belts - these do not provide adequate fall protection as they may lead to serious injury
(to for e.g. the back) in the event of a fall arrest. Consequently, their use as fall protection is
prohibited.
3.8 Fall protection system: Means the use of multiple, approved safety components such as body
harness, lanyards, deceleration devices, drop lines, horizontal and/or vertical lifelines and
anchorages, interconnected and rigged so as to arrest a free fall.
3.9 Fall protection equipment: Equipment used to prevent persons from falling from elevated positions
including personal equipment, safety harness, lanyards, deceleration devices, lifelines or similar
equipment.
3.10 Inertia reel: Also known as a self-retracting lanyard or fall-arrest block is a mechanical device that
allows freedom of movement to the person attached to it, yet it arrests a fall by locking in the event of
a fall.
3.11 Ladders: Are one of the means of providing fall protection and are categorized into fixed and portable
ladders
• fixed ladders are mounted to structures, e.g. cat ladders, rope ladders;
• portable ladders are extension ladders, step ladders, etc.
A note on ladders as fall protection: While working from a ladder 1.8m or more above the ground is
classified as working at heights, the use of a ladder may have been identified as the most appropriate
method of protecting a person from falling. Used correctly (as described in training material available), with
or without using a harness as an additional means of protection measure, a ladder provides a safer way to
access an elevated position than by climbing up equipment or standing on oil drums or similar items to gain
access. However, during the HIRA process always consider a scaffold, but this may not be a practical
alternative when the task at hand is considered. All people that use a ladder must be trained in their safe
use.
3.12 Mobile Elevation Devices: Mobile equipment from which people are able to work in an elevated
position. These include but are not limited to portable ladders, rope ladders, man lifts (cherry pickers),
scissor lifts (sky-jacks, JLG platforms) man baskets on cranes (boatswains chair), scaffolds,
suspended scaffold, etc.
3.13 People: Include ArcelorMittal employees, Hired Labour, Contractors and Visitors to the plant.
3.14 Restricted work area: An area above which work is being performed (e.g. the area below a crane on
which maintenance repairs are being done). There is a danger that objects such as tools, equipment
or even people may accidentally fall from the overhead work area causing injury or equipment
damage below. These areas must be cordoned off to control access to prevent avoidable exposure to
this risk.
3.16 Working at heights: Working or walking in an elevated position with a minimum height of 1.8 meters
above floor or normal working surface. This will constitute work conducted above the ground (e.g.
scaffolds, ladders, platforms, roof work, scissor lifts and man lifts, baskets on crane, beams, cat
ladders, potable ladders, on top of equipment or machinery, ropes etc) and work conducted below
ground (e.g. excavations, confined spaces etc). Elevated equipment where the risk of falling is below
1.8 meters is not included in working at heights definitions.
3.17 Pre-use inspection: Pre-use inspection refers to a visual, non-documented inspection to ensure that
a mentioned item is safe for use and free from defects.
3.18 Inclement weather: There is no official FPS definition but a term used to describe any sign or
presence of rough weather conditions such as rain, wind, thunder, hail, snow, extreme heat or cold,
etc. that could endanger the health and safety of workers and/or have a negative influence on
equipment, buildings or structures. Some other variations and explanation are as follow:
• Inclement weather can include any kind of extreme weather, usually snow or ice making
driving hazardous.
• Inclement weather can include severe thunderstorm activity, tornadoes, flooding or other
natural perils causing evacuation of areas, or closing schools and universities, etc.
• Inclement weather may also refer to unpleasant weather which is stormy, rainy or snowy that
actually refer to “inclimate weather” when the weather is supposed to be pleasant!
• Inclement weather may also refer to weather that is going to/or has done something bad, for
example lots of snow, very cold, floods, too much heat, etc.
• Looking at dictionaries, inclement weather means rough, harsh or stormy weather.
3.19 Hazardous weather: Wind of speed greater than 40 km/h or electric storms or rainfall in excess of 40
mm/h.
Environmental Regulations for Regulation 6(3) : Disposal of articles from a high place
Workplaces (Appendix A)
Regulation 6: Work in elevated positions
General Safety Regulations: Regulation 13A: Ladders.
(Appendix A)
Regulation 8: Fall Protection
Regulation 8 par. 5: Roof work
Construction Regulations:
Regulation 14: Scaffolding
(Appendix A)
6. Housekeeping
(3) No employer shall require or permit any person to, and no person shall, dispose of any article from a
high place except by hoist or chute unless arrangements have been made to secure the safety of
persons who may be struck by falling objects.
No employer shall require or permit any person to work in an elevated position, and no person shall work in
an elevated position, unless such work is performed safely from a ladder or scaffolding, or from a position
where such person has been made as safe as if he were working from scaffolding.
13A. Ladders
(1) An employer shall ensure that every ladder is constructed of sound material and is suitable for the
purpose for which it is used, and -
(a) is fitted with non-skid devices at the bottom ends and hooks or similar devices at the upper ends of
the stiles which shall ensure the stability of the ladder during normal use; or
(b) is so lashed, held or secured whilst being used as to ensure the stability of the ladder under all
conditions and at all times.
(a) (i) has rungs fastened to the stiles only by means of nails, screws, spikes or in like manner; or
(ii) has rungs which have not been properly let into the stiles: Provided that in the case of welded
ladders or ladders of which the rungs are bolted or riveted to the stiles, the rungs need not be let
into the stiles; or
(b) has damaged stiles, or damaged or missing rungs.
(a) a ladder which is required to be leaned against an object for support be used which is longer than 9
m; and
(b) except with the approval of an inspector, the reach of a ladder be extended by fastening together
two or more ladders:
Provided that the provisions of this sub regulation shall not apply to extension or free-standing ladders.
(4) In the case of wooden ladders the employer shall ensure that -
(a) the ladders are constructed of straight grained wood, free from defects, and with the grain running in
the length of the stiles and rungs; and
(b) the ladders are not painted or covered in any manner, unless it has been established that there are
no cracks or other inherent weaknesses: Provided that ladders may be treated with oil or covered with
clear varnish or wood preservative.
(a) take special precautionary measures to prevent articles from falling off; and
(b) provide suitable sheaths or receptacles in which handtools shall be kept when not being used.
AMSASHE00018 (AMSA working at heights procedure)(rev 01).doc
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(6) An employer shall ensure that a fixed ladder which exceeds 5 m in length and is attached to a vertical
structure with an inclination to the horizontal level of 75 degrees, or more -
(a) has its rungs at least 150 mm away from the structure to which the ladder is attached; and
(i) extends from a point not exceeding 2,5 m from the lower level to a height of at least 900 mm
above the top level served by the ladder; and
(ii) shall afford firm support along its whole length for the back of the person climbing the ladder,
and for which purpose no part of the cage shall be more than 700 mm away from the level of the
rungs:
Provided that the foregoing provisions of paragraph (b) shall not apply if platforms, which are spaced not
more than 8 m apart and suitable for persons to rest on, are provided. [Reg. 13A inserted by GN
R1791/88]
8. Fall protection
(a) the designation of a competent person, responsible for the preparation of a fall protection plan;
(b) the fall protection plan contemplated in (a) to be implemented, amended where and when
necessary and maintained as required;
(c) steps to be taken in order to ensure the continued adherence to the fall protection plan.
(2) The fall protection plan contemplated in sub regulation (1), shall include-
(a) a risk assessment of all work carried out from an elevated position which shall include the
procedures and methods used to address all the risks identified per location;
(b) the processes for evaluation of the employees’ physical and psychological fitness necessary to
work at elevated positions and the records thereof;
(c) the programme for the training of employees working from elevated positions and records thereof;
and
(d) the procedure addressing the inspection, testing and maintenance of all fall protection equipment.
(3) A contractor shall ensure that the construction supervisor appointed in terms of regulation 6(1), is in
possession of the most recently updated version of the fall protection plan.
(4) Notwithstanding the provisions of sub regulations (1) and (2), the contractor shall ensure that-
(a) all unprotected openings in floors, edges, slabs, hatchways and stairways are adequately guarded,
fenced or barricaded or that similar means are used to safeguard any person from falling through
such openings;
(b) no person works in an elevated position, unless such work is performed safely as if working from a
scaffold or ladder;
(c) notices are conspicuously placed at all openings where the possibility exists that a person might fall
through such openings;
(ii) securely attached to a structure or plant and the structure or plant and the means of attachment
thereto is suitable and of sufficient strength and stability for the purpose of safely supporting
the equipment and any person who is liable to fall;
(e) fall arrest equipment shall only be used where it is not reasonably practicable to use fall prevention
equipment; and
(f) suitable and sufficient steps shall be taken to ensure, as far as is reasonably practicable, that in the
event of a fall by any person, the fall arrest equipment or the surrounding environment does not
cause injury to the person.
(5) Where roof work is being performed on a construction site, the contractor shall ensure that in
addition to the requirements set out in sub regulations (2) and (4), it is furthermore indicated in the
fall protection plan-
(b) that the roof erectors are competent to carry out the work;
(c) that no employees are permitted to work on roofs during inclement weather conditions or if weather
conditions are a hazard to the health and safety of the employees;
(d) that prominent warning notices are to be placed where all covers to openings are not of sufficient
strength to withstand any imposed loads and where fragile material exists;
(e) that the areas mentioned in paragraph (d) are to be barricaded off to prevent persons from entering;
(f) that suitable and sufficient platforms, coverings or other similar means of support have been
provided to be used in such a way that the weight of any person passing across or working on or
from fragile material is supported; and
(g) that there is suitable and sufficient guard-rails or barriers and toe-boards or other similar means of
protection to prevent, so far as is reasonably practicable, the fall of any person, material or
equipment.
14. Scaffolding
(1) Every contractor using access scaffolding, shall ensure that such scaffolding, when used, complies
with the safety standards incorporated for this purpose into these Regulations under section 44 of the
Act.
(2) A contractor shall ensure that all scaffolding work operations are carried out under the supervision of a
competent person who has been appointed in writing and that all scaffold erectors, team leaders and
inspectors are competent to carry out their work.
SANS 10085-1:2004 - The design, erection, use and inspection of access scaffolding.
Section 8 of the Construction Regulations (see Appendix A) calls for the development of fall protection plans
where people are to work in elevated positions. Section 8(2) goes on to prescribe that these plans must
include:
(a) a risk assessment of all work carried out from an elevated position which shall include the
procedures and methods used to address all the risks identified per location;
(c) the programme for the training of employees working from elevated positions and records thereof;
and
(d) the procedure addressing the inspection, testing and maintenance of all fall protection equipment.
This document describes the process that has been identified by ArcelorMittal South Africa to ensure that we
adhere not only to these legal requirements, but also to other best practices that have been identified to limit
the exposure of people to the risk of serious injury or even death whilst working in elevated positions.
7. PROCESS OVERVIEW:
The process may be summarized as follows:
1) Identifying and listing the elevated work positions (including those in devices such as cherry pickers and
skyjacks) where people will be at risk of falling (i.e. the hazards). Refer to Section 8 of this Procedure.
3) Identifying appropriate methods/measures of reducing (if not eliminating) the risk by firstly considering
fall prevention measures, and then secondly, fall protection measures. By using the term “appropriate
methods/measures of reducing (if not eliminating) the risk” it implies that there are various ways in which
to safeguard a person from falling besides using a safety harness or scaffolding.
4) Assessing the residual risk that remains after the fall prevention and/or fall protection measures have
been implemented.
5) Communicating and ensuring an understanding of these identified methods of reducing the risk to those
people who will be working in these positions. This is done by prescribing use of these methods in safe
work procedures captured in either SAP PM work orders (i.e. jobcards), SOM’s, SEM’s or on a working
at heights HIRA.
6) Ensuring that the people who have to use the prescribed methods have been trained how to use the
prescribed fall prevention and fall protection equipment.
7) Ensuring that the fall prevention and fall protection equipment is of sound design and construction and
that any deterioration is detected by means of regular inspections and where permissible, repaired
before it is used again, or else discarded and replaced.
8) Ensuring compliance to the prescribed safe work procedures, inspections, maintenance etc by means of
audits and ensuring that deficiencies and improvement ideas that may be identified are corrected and/or
followed through ensuring continuous improvement. Defective equipment that is not fit for used must be
locked out until repaired and declared safe.
• Where multiple tasks are performed in a work area or on a piece of equipment, it is only necessary
to list a specific task on its own if the risks associated with that task are significantly different and
higher than the those of the other tasks.
• Must also be aimed at identifying elevated work positions taken up by all categories or disciplines of
people working in the respective area or plant. In other words, consider maintenance, production,
roll and tackle, refractory services, service providers (for e.g. air conditioning, IT or garden services),
tarping of trucks and rail wagons, etc.
• Must include areas where roof work (repairing, cleaning or of any other description) is performed.
• The results of the assessment must be recorded in the form of an Elevated Work Position and Task
Inventory. The template for this is available on the SA portal.
Step 1: The Potential Risk Rating (Unmitigated for Normal Conditions) is determined. In this case, the
potential risk must be considered as if no precautions (mitigating actions) have been taken to protect
employees from the risk.
Step 2: Determine the most appropriate means to reduce (mitigate) the risk. Consider the following in this
order:
ELIMINATION - Any means of eliminating the task or the need to work in the elevated position
PREVENTION - Any means of preventing a fall while working in the elevated position
PROTECTION - Any means of arresting a fall and reducing the extent of injury resulting from the fall.
Also consider:
SAFE ACCESS and EGRESS – ensure that the person is able to reach the elevated work position safely.
The risk of falling does not necessarily only begin once in the elevated work position!
Some of the available means of protection are described on sheet 4 “Mitigation tools” and “Guarding” of the
template. This is provided to provide ideas and to stimulate thoughts; there may be many other, even
unique solutions available!
Wherever practical, a safe working area must be provided by means of work platforms or scaffolds. Also,
all walking and/or working elevated situations should wherever practical be secured by means of complete
floors, guard rails, toe boards, hand rails, manhole covers, etc. Mark the guarding provided in the
appropriate column provided on the template.
AMSASHE00018 (AMSA working at heights procedure)(rev 01).doc
Implementation date: 1 December 2013
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