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Adequate and appropriate supervision?

ImageIt has now become the most common complaint that I get from operatives on training courses;  poor supervision being conducted by a person that simply does not know about the equipment being used and is quite literally incompetent. These operators and users are resigned to never pointing out that the policy is wrong and even putting them at risk for fear of being ‘Carded’ by the person in control of their work activities.

Frequently this is a Health and Safety professional that believes that they know all that they need to because they passed a general Health and Safety course. Put directly, there are some people in a position of supervisory power that are making poor decisions and using their power to implement these decisions beyond and often in opposition to the competent decisions of trained contractors.

Why does this happen so frequently? Why would managers allow these decisions to slow the business down and make it more dangerous? The answer is usually fear and ignorance. The manager is not a health and safety professional and therefore will defer to the qualified expert through fear of being held accountable. The qualified expert will on many occasions make decisions based on their judgment and perception and will tend to err on the side of caution believing that this is the safest way. This leads to potential conflict

Image

but of course the Health and Safety professional can always site regulations to back up his case. Let’s just see what some regulations say about supervision (Control of others work activity).

PUWER 98 Regulation 9 paragraph 2 states-

(2) Every employer shall ensure that any of his employees who supervises or manages the use of work equipment has received adequate training for purposes of health and safety, including training in the methods which may be adopted when using the work equipment, any risks which such use may entail and precautions to be taken.

 

 

LOLER 98 Regulation 8 Organisation of lifting operations-

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 (1) Every employer shall ensure that every lifting operation involving lifting equipment is –

(a) properly planned by a competent person;

(b) appropriately supervised; and

(c) carried out in a safe manner.

 

A MEWP (Scissor lift or Cherry Picker) is a piece of Lifting equipment.

Work at Height Regulations 05-

Organisation and planning

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Regulation 4. – (1) Every employer shall ensure that work at

height is –

(b) appropriately supervised; and(a) properly planned;

(c) carried out in a manner which is so far as is

reasonably practicable safe,

and that its planning includes the selection of work

equipment in accordance with regulation 7.

Further the Work at Height Regulations 05 state-

Competence

5. Every employer shall ensure that no person

engages in any activity, including organisation, planning

and supervision, in relation to work at height or work

equipment for use in such work unless he is competent to

do so or, if being trained, is being supervised by a

competent person.

Regulation 5 of the Work at Height Regulations 2005 refers to competence and states that employers should ensure that people engaged in any work at height activity, or using work equipment for that purpose, are competent to do so.

Although ‘competence’ is not defined in the Regulations, HSE has worked with industry to clarify what this means and recommends the definition in Appendix 8 of the Regulations, which state:

‘A competent person is a person who can demonstrate that they have sufficient professional or technical training, knowledge, actual experience, and authority to enable them to: (1) carry out their assigned duties at the level of responsibility allocated to them (2) understand any potential hazards related to the work (or equipment) under consideration (3) detect any technical defects or omissions in that work (or equipment), recognise any implications for health and safety caused by those defects or omissions, and be able to specify a remedial action to mitigate those implications’.

PASMA Training

PASMA Training

I think I can safely stop there. If you are in charge of people that are building Scaffold Towers get PASMA trained to recognise any dangerous acts, bracing patterns and be competent to inspect the towers. If you are supervising MEWP operators get IPAF Trained (Operator of Manager training will do). Insist on pre use and workplace inspections, provide plates for any potentially soft ground and understand when a harness is a hazard and when it is providing protection. Lastly for this blog Ladders. Don’t ban them, they are inanimate objects. Get Ladder Association training to know when they are appropriate and supervise the competent users to ensure they are used safely.

Very lastly I apologise to the huge numbers of real Safety professionals and Supervisors that have actually had this training and run an effective, efficient, safe site. I am not moaning about you and in fact I applaud you and your good work. I just wish that you were not such a small minority. Vast numbers of incidents would be avoided by decent supervision by competent people so lets encourage people to get competent before they get caught out.

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Why Ladder Association training is the only worthwhile ladder training.

ImageThe work at height regulations require that all persons that manage, supervise or actually undertake work at height must be competent. The preferred definition used by the HSE for competency is-

‘A competent person is a person who can demonstrate that they have sufficient professional or technical training, knowledge, actual experience, and authority to enable them to: (1) carry out their assigned duties at the level of responsibility allocated to them (2) understand any potential hazards related to the work (or equipment) under consideration (3) detect any technical defects or omissions in that work (or equipment), recognise any implications for health and safety caused by those defects or omissions, and be able to specify a remedial action to mitigate those implications’.

So clearly use of ladders and stepladders requires sufficient professional or technical training but which training course? There are many courses out there some better than others. Some companies simply expect their Health and Safety manager to create a training course because the equipment is so simple. Some think a tool box talk is sufficient but most don’t bother with anything at all. These approaches hold varying degrees of risk to both the user and the organisation and it is from the point of view of the organisation that I will initially address the question of “why ladder Association Training?”

We know that we must adequately train our employees but how do you measure adequate? It’s tricky and is a balance between risk and cost.

  1. We can do no training, this is free and there is a massive risk of injury, prosecution and a civil suit which we will lose. That clearly works out to be rather expensive.
  2. We can conduct in-house training undertaken by a qualified Health and Safety professional. This training course has not been independently measured, the Health and Safety manager is not a qualified Ladder and Stepladder instructor, no manufacturers were involved and therefore the trained would not be aware of the direction that the industry is moving, new innovations, changes to standards etc. Frequently with this sort of training it is just a case of following the HSE guidance. If there were an incident how would we prove that the training was adequate? That the course corresponded with the very latest industry best practice? We couldn’t, so again we are in danger from prosecution and a civil suit. At least we would have an argument but it would be better to have proof.
  3. We could use a training company that has created their own Ladder course. This is basically the same as the above because without involvement from the manufacturers we do not know if what we are saying is technically correct and the course has not been approved.
  4. We can use The Ladder Association’s network of training centres to conduct the training for us. A Ladder and Stepladder User course for 8 people takes just 4 hours though it is an intensive session. It is possible to train 16 people in a single day. This makes it inexpensive and efficient. This is the correct choice but why?

The Ladder Association began as the British Ladder Manufacturers Association which tells you who the founding members were, yes, manufactures. This provides the proof that it is adequate. This is what we need and it is brilliant value for money.

The ladder association has grown since 1947 when it began, actively welcomes members from all sectors and is made up of expert committees. This means that when something gets into the training course material it has been approved by both professional training organisations and the manufacturers themselves via the training committee and approved again by the executive council. The Ladder Association works directly with the HSE to ensure that the HSE are fully informed of any innovations, developments and guidance. The HSE have in fact given their full support to the work of the ladder association. The Ladder Association code of practice contains a forward from the HSE stating this fact and that is why it is PROOF. Ultimately if you want to get it right, protect your people and your business that the only reliable choice is Ladder Association training. Manufacturer members of the Ladder Association include-

Clearly these guys know what they are talking about.

Training members include-

Along with many others and again we know what we are talking about so you get the very best of both worlds.

Ladder Association training centres have to meet very specific criteria and are audited to ensure ongoing compliance. Instructors are trained over the course of a week having had to meet stringent entry criteria to even get onto the instructor course. If they pass that they also have to undertake 2 sessions with a senior instructor mentor and successfully prove themselves before being deemed competent to train the Ladder Association training course. Trainers are also audited and are subject to unannounced visits again to ensure standards are kept up.

Ultimately, if you want the right training, training that is measured, tested and approved by both manufacturers and the HSE, then it has to be from the Ladder Association. Everything else is just a waste of money.

OTJ Training conduct Ladder Association Training all over the country at your premises or at our training centre in Gloucestershire. We are exceptional value for money and everyone goes away surprised at how useful and interesting the training was so give us a call on 01531 821 779 or visit us at www.otjtraining.com and we will make sure that you have everything that your guys get the training that they need keeping both them and you safe.

Record take up for Ladder Association Training

Excellent News?

I personally think this is good news but not excellent. I still find it hard to believe how few people are being trained on Ladders and Stepladders. I have put the story of the growth in take up below these comments and it is well worth a read.

If we consider the legalities of Ladder Training, ladders are work equipment and therefore adequate training was required by the PUWER back in 1998. No take up generally and falls from height continued to account for a grossly unacceptable number of deaths and major injuries. By using the statistics compiled from RIDDOR it also became clear that 60% of the major injuries were from ‘Low falls’ (falls from below head height). This indicated a need for a change to current legislation (Construction Health and Safety regulations 1996) to take this into account.

Martin Holden, HM principal specialist inspector for the HSE Construction Corporate topic group than created a committee of experts to discuss what had to be done. This committee became known as ACWAHT (Advisory committee on Work at Height Training). The reason that it ended up being all about training is due to the very simple fact that people are required to create an unsafe situation. Equipment is inanimate and therefore benign but with human intervention it can become dangerous. The team then decided that all persons involved with Work at Height must be Competent and in order to measure competency they had to redefine it. This is what they came up with and this is how the HSE are measuring Competency for work at height in a court of law.

Click on the picture and scroll down to be able to click on “what do the regulations say about competence”

HSE Competency link

HSE/ ACWAHT competency Definition

With this definition so crystal clear why then such a slow and low take up? There are a number of factors to take into account but perception of hazard is key.

Certain equipment is safer by it’s nature than other equipment. MEWP’s  and Mobile Towers utilise collective Fall Prevention and are first choice for a lot of work at height. At OTJ Training we provide training to the highest standard via IPAF and PASMA. There is general acceptance that training on this sort of equipment is necessary and beneficial though the equipment is statistically safer than a ladder. We train people on the use of Harnesses and how to always attempt to create a restraint situation if possible to prevent a fall. Clearly training is vital and a lot of people realise this. All of this to prevent a fall and in fact we MUST to do all that it reasonably practicable to prevent a fall.

Falling however is not the problem. Felix Baumgartne fell from the edge of space, 38894 m from the ground and he is fine.

The reason that he is fine is simple. He decelerated prior to impact. With the use of ladders and Stepladders there is only acceleration and impact. We know from one of my previous blog posts that the impact force of an 80Kg load falling 2m is around 15600 n so with that in mind it is absolutely vital that people do not fall off. Sadly the only thing that prevents people falling off is the way that the equipment is used and the quality and suitability of the equipment.

Unlike MEWPs etc there are no control measures to prevent falls or mitigate the consequences of landing at speed so the only sensible option is training and supervision. The Ladder Association Training programme is quite simply the best that there is and last year we trained over 5000 people. Sites that had banned Stepladders have realised that its people that need to be controlled and are now asking for a Ladder Card to prove competency instead of an outright ban. As long as those supervising are also trained and competent we can all work effectively, efficiently and above all safely. I am proud to be one of the Ladder Association’s Lead instructors and to sit on the Training Committee helping with the development of the training course to make sure we meet the needs and challenges of industry. OTJ Training offer the full range of Ladder Association training courses  so please take a look at http://www.otjtraining.com and join the thousands of Competent Ladder Users.

The number of people trained by the Ladder Association in the safe use of ladders reached an all-time high in 2012, passing 5,000 for the first time.

The 5,052 people trained in 2012 marks a 47% increase on 2011’s figure of less than 3,500. In training almost 1,000 people during November, the association also reached its highest ever number trained in one month.

Technical director Don Aers said: “It is great to see that more people and organisations than ever are taking the safety message on-board and understanding that there is a vital need for people who use ladders for their work to be trained and competent.

“There are a number of reasons for such an impressive increase, but first and foremost it is evidence of the increasing recognition within industries that ladder training is essential. One of our main goals at the Ladder Association is to make sure that industries where ladders are commonly used understand the dangers of work at height and the need for people using ladders to be competent.”

During the year the Ladder Association took over the Ladder Exchange programme that had previously been run by the Health & Safety Executive. Ladder safety publicity associated with this boosted training numbers.

Mr Aers added: “Our campaigns throughout 2012 played a large part in getting the safety message out, and we have plans to do even more in the coming year. By the end of 2013 we are aiming for another equally sharp jump in the number of people who have the training and understanding they need to be safe at work.”

Harnesses and MEWP’s

Should people wear a harness in a scissor lift?

No, not under normal operating circumstances.

  • If a person absolutely had to lean out of the machine to undertake a task
    IPAF Harness Statement H1

    IPAF Harness Statement H1

    then it would be reasonable to use a restraint system to prevent the person actually over reaching and falling over the guardrails. That’s it, completely  straightforward. You need read no further unless you want to know why it is actually very dangerous to use one under normal circumstances and if you want to understand the reason that we definitely do use short adjustable restraint lanyards in Boom Lifts.

One of my passions is this. 70% of the people that I train as IPAF Operators tell me that they are told to wear a harness in a scissor lift. When I ask them exactly what type of harness or lanyard do they require in these scissors? They usually reply “They don’t actually mind, as long as we wear a harness.” I have heard twice now of separate companies having a policy of wearing a harness in a scissor lift but they did not actually have to attach it to the scissor lift!?

Explanation

  • It’s clear that an explanation is required and that the explanation should be straight forward (insert Preventing falls from Boom Type Mewps) and make sense to absolutely everyone. I would therefore like to start with what we are trying to achieve by wearing a harness in a Boom. We are protecting ourselves from a very real hazard, that of the innocuously
    Boom flick in action

    Boom flick example

    termed, Boom Flick. Doesn’t sound bad but it will easily throw an unattached operator out of a boom and to their death following a mere glancing blow near the slew ring. The reason is incredibly simple. The further away from the base you are the further the basket will travel in the same amount of time. Imagine a fishing rod, a very small movement from the wrist at one end produces a whipping motion at the other.

  • In a boom lift the length of this imaginary fishing rod is commonly over 12m you are at the whippy end and the resulting force is huge. If a person is attached with a lanyard that prevents them coming over the guardrail they would suffer from being thrown about in the cage. Usually these injuries would be relatively minor and survivable. If however the person was not attached they would be
    Impact force calculation

    Impact force calculation

    thrown clear and would then fall accelerating at 9.81 m/s Squared until they hit the ground. If anyone read one of my earlier posts then they will know that an 80Kg load dropped 2m onto a hard surface will generate an impact force of 1.5 tons. (Insert calculation) This will be likely to cause major injury or death.

Could it be even worse?

  • Incredibly yes, It is potentially worse if a person uses, as people commonly do, a standard 2m fall arrest lanyard. Yes the person would be attached but they would not be restrained and would be thrown out of the basket sideways. The fall arrest lanyard would then deploy reducing the force on the person to >6Kn. Thats about 600Kg by the way. The main problem now is that most MEWP’s in common use have a maximun allowable side load rating of around 400n (40Kg). It doesnt take a mathematition to understand that if we put 6000n on a machine capable of dealing with 400n we have a possible, even probable overturn situation. This would increase the overall risk as it would involve anyone else in the basket and anyone that could be hit by the falling MEWP etc. Examples of maximum side load or manual force from a range of equipment are below.
Genie Z45-25J Specification (Side Load)

Genie Z45-25J Specification (Side Load)

jlg-260-mrt Specification (Side Load)

jlg-260-mrt Specification (Side Load)

HA16PX

HA16PX

gs2046

gs2046

1230ES

1230ES

  • Lanyard length and height of anchorage point are therefore critical and therefore a lanyard must be adjustable and must be adjusted short enough to prevent someone being thrown out. I use a 1.5m Adjustable Lanyard that adjusts down to 0.75m and I only ever have problems when thoughtless manufacturers put the specified anchorage point on or close to the top rail.
  • I would certainly wear a harness and lanyard in a scissor lift if I was worried about floating away. I am not concerned about this however as I have a rudimentary understanding of gravity and the direction that gravity takes (down in case you are wondering). I am surrounded by guardrails set at a minimum height of 950mm and I am not away from the point of rotation so cannot be flung out like a boom. I keep my feet on the floor as there is no other acceptable place that I can stand whilst in the machine. I cannot fall out uness I lean out over the guard rail and I would then undertake a job specific risk assessment to take this into account and would then consider this an exceptional circumstance and refer back to the very start of this article.

Harnesses and Scissors.

  1. Some people say- ‘Why not wear one anyway, we are covered for anything then?’
  2. Others may say- ‘By attaching people are prevented from climbing on the guardrails so are easier to police.’
  3. Or the classic- ‘Its company policy to wear a harness over 6 feet so we have to.’
  • This is all rubbish of course and it is clear that the risk assessments are inadequate. For point 1, there is no hazard so what are we being protected from? Worse though, we are creating a hazard. If we select a short restraint lanyard we now cannot see all around the effectively as we are trapped in one place. If we need to manoeuvre the machine we are effectively doing it blind. Clearly a significant hazard with real risk of crushing or overturn. OK then, use a 2m fall arrest lanyard, then the operator has freedom of movement. In this instance I refer back to the Platform side force limit (frequently 400n) and the imposed side load of up to 6000n. Any policy that deems this as acceptable is extremely flawed.
  • On point 2 if people are willing to stand on the mid rail or even above that they will be perfectly happy to either detach themselves to achieve this or wear a lanyard long enough to enable themselves to. Either way, disastrous.
  • On point 3, why the rule? Work at height is based on the person being ‘liable to suffer a personal injury if they fell from that place’ this includes a place at, above or below ground level. Where did the arbitrary height come from and how have they missed the at or below ground level bit? Company policies should take into account industry best practice and advice from the enforcing authority and Industry experts.  The people planning work at height should be Trained and Competent . MEWP’s for Managers training from IPAF (The International Powered Access Federation) would create this competency as required by law and would create understanding of the hazards and risks associated with MEWP’s, just one being the use of harnesses. We run the MEWP’s for Managers training courses from OTJ Training and without exception attendees have rated the course as excellent and have enjoyed the experience.
Work at Height Regulations a brief guide

Work at Height Regulations a brief guide

CIS58

CIS58

Preventing falls from Boom Type platforms

Preventing falls from Boom Type platforms

Training

  • If we accept all of that, and you should because it is correct, what about the users of the harnesses? They need to be trained to don and doff them correctly, to know why they are wearing them and what they are trying to achieve with their use. They should know how to adjust the lanyard to the right length and test that it will be effective prior to using a boom or under the above stated exceptional circumstances in a vertical lift. IPAF have a harness training course specific to use in a MEWP and this is highly recommended for all MEWP operators including those that will only use a vertical machine as they may find themselves in one of those ‘exceptional’ situations.

Frequently asked Questions-

1. Q) Does the hydraulic oil or engine oil in a MEWP cause degradation of polyester harnesses and lanyards and if so, should I put my harness on before or after my MEWP pre-use visual and function checks?

A)     Yes they both cause deterioration and would cause the harness and lanyard to be scrapped. I conduct the pre use checks up to the point of having to enter the platform to check the operating controls without my harness and don it to enter the cage keeping it away from potential contaminants, in it’s box until needed.

2. Q)   Is it o.k. for me to wear my jacket / hi-viz vest over the top of my harness and lanyard?

A)     There is no problem with wearing something over the harness as long as it doesn’t effect the way that it works. A jacket can even protect the harness from the elements and some harnesses are built into jackets for just this reason.

3. Q)  Has it ever been proved that wearing a safety harness has directly saved a MEWP operators life… are there any photos?

A)     Yes, many times and by clicking on this link you can see an example.  http://www.vertikal.net/en/news/story/11343/ The Website holds many instances of harnesses saving lives, just type harness in the search box.

4. Q)  Is it o.k. to buy second hand harness safety equipment… there are some bargains to be had on eBay…some descriptions include ‘opened but never used’… ‘new with defects’… ‘slight wear’… ‘I fell in it once so I know it works!’… all of them less than a £10!

A)     NO! Buy it new from a reputable place ensuring you know what you need. Once you have it, you can record all of the information including date of first use and then you will know exactly what happens to it. If you are unsure exactly what you need, you need training and ask the instructor during the training, or ask me. I will be happy to help.

Are stepladders dangerous?

No, people can use them in a dangerous way but stepladders in themselves cannot be dangerous. In fact when was the last time you heard of a stepladder attacking someone? Leaping out from behind a bush with the aim of inflicting injury to unwary passers-by?  Same as me I guess, never. So why have some companies banned stepladders?

Some companies have blamed the HSE and stated that they banned them. The HSE responded to this ridiculous allegation with this-HSE great health and safety myths (Ladders)

It is clear that the people that write the law and enforce the law have not banned them and in fact encourage their use in the right circumstances.  Inappropriate use and poor or inappropriate equipment is a significant contributory factor in accidents. Statistically lots of people fall from ladders and stepladders so some companies just banned them to reduce the statistics. But it’s not the Ladders that are at fault, it’s inappropriate use or equipment that leads to the accidents.

It is therefore very important to know when Stepladders are appropriate and when they are not. I have been asked frequently what height would be acceptable and how high is too high but it’s not as simple as that. People love numbers and datum’s from which to work and I will admit that I too like to know exactly what I can and can’t do.

The problem is always the same, variables. Variables are things that can change as opposed to constants which stay the same. Constants as far as we are concerned are minimal. We have things like acceleration due to gravity which is constant enough to use directly but in order to have others we have to use estimates. These estimates are inaccurate but at least allow us to move on with what we are trying to do. One of these usable estimations is that the apparent average weight of an adult human male is 80kg. This is widely used in MEWP’s and for the purposes of testing Harness Lanyards.

This leads me to the seemingly simple question of how high is too high and the rather complicated answer of “it depends.” We have to consider impact force if we are to make a reasonable decision. I decided to actually work out the impact force of a 80kg load dropped 2m as a comparison. I was shocked by the result. The results were completely reliant upon the amount the falling body travelled during the impact. If the 80kg landed on concrete and only travelled 1cm then the force would be 15.6Kn which is about 1560Kg which is about 1 ½ Tons! This is clearly a lot so why aren’t people dying from low falls all of the time?

Well actually there are huge numbers of injuries and still far too many deaths from falls from height and that is why training is so important. If a person fell 2m and landed on their feet bent their knees and also rolled, the impact would be dissipated brilliantly and it is unlikely that an injury would occur but if a person fell backwards because they lost their balance, they wouldn’t be able to put their arms out so they would hit the back of their head with a potentially catastrophic force. This is why there are so many injuries. Between those two possibilities are an infinite number of different falls resulting in an infinite number of different outcomes.

What you land on will also have a massive effect on the outcome. If you fell onto something hard and sharp it will cut into you. If you land on something blunt and soft it will cushion you so you could fall further without injury. Frequently, people falling from steps or ladders land, partially inverted (Upside down) on something sticking up from the ground like a chair, table or machine. It’s just a matter of luck then as to whether a person is paralysed or just suffers a ‘but of a bump’.

What I am getting at, all be it slowly, is that there cannot be rules like how high because it depends what a person would land on etc. All we can do is make sure that we address each individual situation at the time, in the place and understand what we are looking for. This is why training is vital. With both ladders and Stepladders it is only making the right decisions and taking the right precautions that accident and injury can be avoided. It’s not the ladders, it’s the user.

I am aware of certain companies issuing a permit to work for stepladders. Again, I have to wonder at this decision as invariably in my limited experience, the most important and mandatory requirement is not even asked for i.e. “is the person that will be selecting and using the equipment trained and competent”?Image

Really this competence should be all we need because a competent user will look at the hazards, assess the risks dynamically and take the necessary precautions. Ladder Association User Training provides all these skills, making a successful trainee provably competent as required by law, in just half a day. Just do it.