Despite regulatory trigger height requirements for personal fall protection systems (PFPS), falls from height still constitute a significant portion of workplace fatalities and major injuries. In July, the HSE reported that in the UK during 2022/23, 40 out of 135 work-related fatalities (almost 30%) resulted from falls from height.
‘Work at height’ refers to tasks performed in locations where, without precautions, a person could fall and sustain injury. This includes common scenarios like falling from ladders or through fragile surfaces.
‘The Work at Height Regulations 2005’ pertain to employers and individuals overseeing work at height, such as contractors, facility managers, and building owners. Any work at height must be well-planned, supervised, and executed by competent individuals, using appropriate equipment. Less complex tasks like changing light bulbs or hanging blinds require less planning compared to higher-risk activities like gutter cleaning and HVAC equipment maintenance.
Employees have a general legal duty to exercise reasonable care for their own and others’ safety and cooperate with their employer’s efforts to meet health and safety requirements. However, employers and those in control must first assess risks and implement practical measures to minimize the risks for workers operating at height.
“Roof safety has always been about the ‘hierarchy of controls’,” explains Graham Wilmott, group risk management & standards director at Kee Safety Group. “The ‘six pack regulations’ (the workplace health, safety and welfare regulations 1992) came into full effect in 1994; that was the starting point.”
Raymond Mann, global senior specialist application engineer, 3M Personal Safety Division agrees. He says: “It is always a best practice to resort to PPE as the final effort of control.”
Eliminating or replacing a hazard can be as simple as using a telescopic pole to change a light bulb instead of climbing a ladder, reducing the risk of falling.
According to Wilmott, the primary risk to evaluate before working at height is the frequency of roof access and its potential impact on roof access points. He says: “The HSE suggests that going on a roof two to four times a year is deemed as frequent. Whereas the normal everyday person might say once or twice a month is frequent.”
A single access and egress point is typically used for various tasks on a roof. Since different workers perform these tasks, the access point becomes the most likely location for potential injuries or fatalities.
Willmott says the likelihood and severity of an incident is considered on a scale of one to five: “You know for a fact that, if you fall off of a roof, the potential severity is a fatality, which is a five. But people struggle with the likelihood because ‘I’ve been doing this for 20 years and I’ve never fallen off a rooftop’. The access point is where you potentially have 20 points of contact each year, which is a high frequency. So, the likelihood of an incident occurring at that point is quite high.” He compares the risk to that of having an accident in a car, which is, statistically speaking, most likely within two miles of one’s home, because that is where all journeys start and end.
Control over individuals accessing the roof is of utmost importance, including the requirement for the correct permits. Employers or those in control have a responsibility to ensure the safety of individuals on the roof. However, the choice of equipment while on the roof is the worker’s prerogative.
RISK ASSESSMENT
Before conducting work for a client, a design risk assessment is performed, outlining potential risks and protocols for roof work. When using edge protection, worker participation is minimal. However, if they need to connect to a horizontal lifeline system, workers’ competence must be verified. Also, the length of their fall restraint lanyard should be checked. In cases where a fall arrest system is to be used, a rescue policy, plan, and procedure must also be in place.
For the duty holder, a PFPS is lower in the hierarchy because it involves the individual participating in the safety procedure. The duty holder is responsible for ensuring the individual’s safety and competence in executing their procedures.
However, there are occasions – namely new roof construction or replacement – where installing a PFPS is inadequate or impossible.
Mann adds: “It is not until the roof trusses have been raised and sheathing work begins that there are adequate measures available to provide workers at height the needed and required protection from falls. Even then, swing falls and contact with objects other than the ground can often present hazards.
“Prior to this level of protection becoming available, workers must often perform their work tasks from A-frame ladders, extension ladders, or scaffolding. Use of these elements in general will often not require a PFPS.
“One should also keep in mind that these systems may require additional layers of personal protection with scaffolding, depending on height and installation methods.”
EYES IN THE SKY
Recent technological advances, like Google Earth and drones, have made assessments easier and less risky. However, Willmott emphasizes that these tools cannot reveal critical conditions like the extent of moss and lichen growth on the roof (heightened by global warming), creating slippery surfaces. They may also fail to detect birds’ nests, rat infestations or other potential risks.
Non-biological concerns include the presence of asbestos in the roof construction, fluids or machinery in plant rooms, and the audibility of the building’s fire alarm system on the roof. Each building type introduces its unique risks.
Mann says that workers are easily tempted not to follow the hierarchy of controls. He warns: “People tend to migrate towards whatever is the simplest. They want to take shortcuts and do what takes them the least amount of time to do the job. There’s a trend in the statistics of higher incident rates on Monday mornings and Friday afternoons. That really comes down to people’s minds not being as fresh after two days off, or when they are looking forward to the weekend. If they are presented with a task at the end of their shift, they’re probably more likely to skirt around doing it the way they know they should. I’ve seen every level of employee involved, from general labourers to site superintendents.”
After 35 years of industry experience, Mann says that he isn’t aware of any fatalities resulting from a complete catastrophic failure of a personal fall arrest system. Instead, most incidents he’s encountered or investigated stem from either the incorrect use of the system or, more commonly, the complete absence of its use.