WORKING at HEIGHT

SAFETY RULE #3

“All work at height activities utilise

suitable equipment and controls to
prevent falls”

Implementation Guidance

1 15-Jan-2019
3 – WORKING AT HEIGHT

All work at height activities utilise suitable equipment

and controls to prevent falls

• All work at height requires a permit-to-work process

Management • If work at height cannot be avoided, an assessment
process identifies the best fall protection controls
• Regular access to equipment at height utilizes
permanent engineered solution

• I always review and approve permits for work at

Supervisors height in my area
• I always ensure employees know, and follow safe
methods for all work at height

Employees • I always use a permit-to-work for all work at height

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CONTENTS
3 – WORKING AT HEIGHT ........................................................................................................................ 2
CONTENTS ............................................................................................................................................... 3
BACKGROUND ......................................................................................................................................... 4
MANAGEMENT REQUIREMENTS ............................................................................................................ 5
3.1 All work at height requires a permit-to-work process............................................................... 5
3.2 If work at height cannot be avoided, an assessment process identifies the best fall protection
controls ...................................................................................................................................... 7
3.3 Regular access to equipment at height utilises permanent engineered solutions ................. 10
SUPERVISORS REQUIREMENTS ............................................................................................................. 13
3.4 I always review and approve permits for work at height in my area ...................................... 13
3.5 I always ensure employees know, and follow safe methods for all work at height ................ 14
EMPLOYEES REQUIREMENT .................................................................................................................. 15
3.6 I always use a permit-to-work for all work at height ............................................................... 15

3 15-Jan-2019
BACKGROUND
RULE All work at height activities utilise suitable equipment
and controls to prevent falls.
INTENT Where work at height cannot be avoided, or performed from fixed platforms
with standard railings, other fall protection controls must be implemented to
avoid falls from height
HISTORY
Incidents have occurred internally resulting in significant injuries or fatality.

Incorrect equipment for Working at Height

Fall through ‘sandwich panel’ internal

Contractor fall through skylight freezer ceiling

Industry Statistics – Fatal Falls Data UK (8-year period)

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MANAGEMENT REQUIREMENTS
3.1 All work at height requires a permit-to-work
process
Safety Rules Audit
An external auditor will look for:
• A permit system that covers the activities defined in the guidance.
• A process for approval and authorisation for those issuing permits.
• Evidence of completed permits and inspection of any work at height in progress at the
time of audit.
Scoring Guide (3.3.1)
1 - No - Nothing has been done. The permit to work process does not cover any of the required
activities.
3 - Implementation is at an early stage or there is a substantive lapse. Less than 5 of the 7 required
activities are covered by permits.
5 - Partially implemented. 5 of the7 required activities are covered by permits, with some evidence
available.
8 - Substantially implemented. All 7 activities are covered by permits, with some evidence available
and there is a process for ensuring competency for the people issuing permits.
10 - Yes - Substantially implemented and effective. Evidence that all 7 activities are consistently cov-
ered by the permit system. People issuing permits are trained and assessed as competent.
Expectation
In addition to any local regulatory requirements, the site should have a permit to work
system in place for:
• all roof work,
• use of mobile scaffolds,
• fixed scaffolds,
• work from a suspended cage or bucket,
• work from a cherry picker or mobile elevated work platform,
• work in a roof void,
• work on a suspended ceiling or poly panel ceiling or roof.
A process must be in place to approve and authorise those persons who issue such permits
as competent.

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Examples

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3.2 If work at height cannot be avoided, an
assessment process identifies the best fall
protection controls
Safety Rules Audit
An external auditor will check the site:
• Has an assessment process for Working at Height activities.
• Has assessed Working at Height activities.
• Can demonstrate suitable controls are in place or are available.
Scoring Guide (3.3.2)
1 - No - Nothing has been done. Employees and contractors work at height with little or no
planning.
3 - Implementation is at an early stage or there is a substantive lapse. Routine working at height
activities are in the process of being evaluated.
5 - Partially implemented. Routine working at height activities have been evaluated and utilise the
hierarchy but regularly rely on ‘individual’ protection systems.
8 - Substantially implemented. Routine and planned working at height activities have a clear
assessment process to select the most appropriate fall protection.
10 - Yes - Substantially implemented and effective. The assessment process is used consistently with
evidence that appropriate ‘collective’ protective systems are routinely implemented.
Expectation
Sites have assessed routine Working at Height
activities and have an assessment process in
place when planning Working at Height for
non-routine activities.
To control falls from height the actions from
assessment should consider a hierarchy of
controls in the following order:
Avoiding Work at Height
Prevent falls from height
Minimise consequences
Sites need to demonstrate suitable controls are
in place, based on collective (group) protection
systems (Barriers, scaffolds) before individual
protection systems (Harnesses).
Routine Work at height would include any tasks
that are repeated more than once per year. If
such tasks do not have permanent engineered
solutions implemented that effectively remove
the work at height classification, then a permit must be used each time the task is
performed.
Non-routine includes any task performed once a year or less. Such tasks must be planned
and assed before work begins. Emergency work at height that is not planned must be as-
sessed and controls implemented before work begins.

7 15-Jan-2019
Examples
Collective controls - Permanent (photo 1) and Temporary (photo 2)

Scaffolding used as barrier rails to guide

employees to the work area. Temporary
for 3 months while work is undertaken

Example flow chart for hierarchy of controls

8 15-Jan-2019
Examples of Avoiding, Preventing and Minimising falls from height.

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3.3 Regular access to equipment at height utilises
permanent engineered solutions
Safety Rules Audit
An external auditor will check the site has:
• Identified all fragile roof and potential fragile roof locations.
• Prevented entry to these locations by suitable means.
• Load bearing capacities have been determined by a competent person.
• If access is required, suitable controls for the activity are in place.
• The site has identified where regular access to equipment on the roof is required.
• Access is suitable for the nature and frequency of work, and the type of roofing.
• Platforms and walkways are used for regular access to equipment on the roof.
Scoring Guide (3.3.3)
1 - No - Nothing has been done. No assessments of fragile roofs or regular access to work at height
locations.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. All fragile roofs and regular access roof locations assessed.
8 - Substantially implemented. All fragile roof access assessed, protected and controlled. Collective
group protection used for regular access.
10 - Yes - Substantially implemented and effective. All fragile roofs and regular height access con-
trolled with permanent engineered solutions, including changes and new installations.
Expectation
Fragile Roofs
The site has identified all fragile roof locations, including roof voids, such as those above
freezer rooms, clean rooms or other internal structures. Suitable access controls should be
in place to prevent entry.
Where the load bearing capacity is not known, for example above freezer rooms, and access
is required, structural engineers should be consulted to determine the load bearing
capacity. Suitable walkways should be constructed based on the required activity and load
bearing capacity of the structure.
This information should be included in any permit process to control access and activities.
Examples
Below is an attic space with a ‘floor’ made of ‘sandwich panels’ where access is required for
maintenance of utilities and ventilation systems. The predicted activities highlighted the
ventilation motors (55kg) would need to be replaced at some time. The structure was
checked and found the sandwich panel would not support, 2 employees + 55kg Motor +
tools. Suitable walkways were installed anchored to the structural framework of the
building.

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 3D of a section of the proposed walkways Valves require access and maintenance.
in the roof space. Dedicated walkways installed to prevent
overloading the ‘sandwich panel’ floor of
the roof space.
Access to a roof space was required for activities involving replacement of heavy valves. As a
temporary solution the area was fitted with scaffolding to prevent overloading the
‘sandwich panel’ floor.

Alternatives also include supporting the work area and the access routes from underneath,
as some sites have done previously.

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Regular Access
Sites need to identify where regular access is required to equipment located on the roof. A
priority list for investment should be developed based on access frequency, activities on the
equipment and proximity to the edge. The use of vertical ladders, to frequently access
equipment on the roof is not the preferred means of access.
Examples

Regular access to the roof was

required during a 3 month project.
A scaffold tower with steps, walkways
and platforms was erected.

For a non-fragile roof, single sided

edge protection may be appropriate.

For fragile roofing, where there is a risk

of falling through, an engineered
solution with standard platform railing
on both sides would be required.

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SUPERVISORS REQUIREMENTS
3.4 I always review and approve permits for work at
height in my area
Safety Rules Audit
An external auditor will:
• Check documented procedures.
• Check documentation of training and communications.
• Look for physical evidence of completed permits and approval signatures.
• Interview supervisors through a conversation to understand their current level of
involvement in permit approvals.
• Observe behaviour.
Scoring Guide (3.3.4)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all the verification steps align, and substantial improvement is
required.
8 - Substantially implemented. Evidence from all the verification steps is aligned, and only minor
improvements are recommended.
10 - Yes - Substantially implemented and effective. Evidence from all the verification steps is aligned
and consistently maintained. No further improvements identified.
Expectation
The documented procedures for the work at height permit process should clearly identify
who is responsible for giving approval. In the case of employees, for example production
and maintenance, it should be the person directly responsible for supervising the employees
work. For contractors, it could be the work supervisor, such as a project manager or
foreman, or the person responsible for the area, such as a department manager or
supervisor.
In addition to the approval process, the supervisor responsible for the area where the work
is performed must be involved, so they can understand any impact on their normal
operations, or impact their operations may have on the planned work. They also need to
inform their employees of any new hazards or other changes to their usual working
environment.
The person giving the approval must be adequately trained and competent to assess that
the risks have been identified and that the controls are adequate. If the supervisor, as
described above, does not have this competency, then a two-tier approval can be used,
where a competent expert must also approve the permit.

13 15-Jan-2019
3.5 I always ensure employees know, and follow safe
methods for all work at height
Safety Rules Audit
An external auditor will:
• Check documented procedures.
• Check documentation of training and communications.
• Review use of the OSCAR board, and follow-up actions.
• Look for physical evidence of suitable work at height equipment.
• Interview supervisors through a conversation to understand their current level of
awareness regarding safe work at height methods.
• Observe behaviour.
Scoring Guide (3.3.5)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all the verification steps align, and substantial improvement is
required.
8 - Substantially implemented. Evidence from all the verification steps is aligned, and only minor
improvements are recommended.
10 - Yes - Substantially implemented and effective. Evidence from all the verification steps is aligned
and consistently maintained. No further improvements identified.
Expectation
In addition to approving work at height permits, supervisors have a responsibility to ensure
that employees under their supervision have the necessary training and competency to
perform the work requested of them. Most work at height activities require the use of
specialist equipment that may require specific training or qualifications. Examples include
the use of MEWPS (Mobile Elevating Work Platforms), harnesses and fall arrest equipment,
scaffolding etc.
Supervisors are also expected to intervene and confront any person they believe is not
performing work at height correctly. On a production line, such a confrontation would
require a red Safety Check on the OSCAR board with notes of the follow-up action taken.

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EMPLOYEES REQUIREMENT
3.6 I always use a permit-to-work for all work at
height
Safety Rules Audit
An external auditor will:
• Check documented procedures.
• Check documentation of training and communications.
• Review use of the OSCAR board, and follow-up actions.
• Look for physical evidence of completed work at height permits.
• Interview employees through a conversation to understand their current level of
involvement in work at height activities.
• Observe behaviour.
Scoring Guide (3.3.6)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all the verification steps align, and substantial improvement is
required.
8 - Substantially implemented. Evidence from all the verification steps is aligned, and only minor
improvements are recommended.
10 - Yes - Substantially implemented and effective. Evidence from all the verification steps is aligned
and consistently maintained. No further improvements identified.
Expectation
It should be made clear to employees that they are expected to stop work and seek
assistance if they believe it is unsafe to proceed.
All employees that are expected to carry out work at height must be trained in the permit
process, and any other requirements to perform the work safely.
Any work at height in a production area should be noted on the relevant OSCAR board.

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