The Height Safety Death Trap
COVID-19 has taught us all that we can make unilateral changes to the way we do things as a society and change quickly. Perhaps the notion that to effect cultural change within a business can take as long as 2 years can be reconsidered to improve height safety on all work sites. I suspect we all can adapt quicker than we ever thought we could.
But why can’t we rapidly change the mindset of workers in an effort to finally have a massive reduction in the numbers of Australians who are injured or killed as a result of falls from height? After all, the number of fatalities resulting from unsafe work at height represents 20% of all total workplace deaths since 2003 (close to one death per week).
What counts as a working at height fatality statistic? Simply put, the stats count deaths resulting from a fall from a height whilst working or if you are hit by a falling object whilst working.
We all know that if we have an increased focus on height safety that all of these deaths could be avoided.
The laws are in place to protect workers from such hazards, however too often they are either ignored, misinterpreted, not adhered to or not implemented. In addition we also have to deal with perhaps the biggest working at heights death trap of all, complacency.
Simply put – If the regulations are followed by both employees and employers we could greatly improve height safety and reduce working at heights fatality statistics.
What does the law say? Well, the Occupational Health and Safety Regulations 2017 are very prescriptive with regards to what your choices are to protect workers from working at heights hazards. Read on for a summary of your safety obligations.
Identification of Working at Heights Hazards
The Occupational Health and Safety Regulations 2017 clearly states that all employers must, so far as reasonably practicable, identify any task at a workplace that involves a fall hazard (Section 42). These tasks could include, but not limited to, the following workplace environments:
- Any plant or structure being constructed, demolished, inspected, tested, maintained, repaired or cleaned; or
- on a fragile, slippery or potentially unstable surface; or
- using equipment to gain access to an elevated level or to undertake the task at an elevated level; or
- on a sloping surface on which it is difficult to maintain balance; or
- in close proximity to an unprotected edge; or
- in close proximity to a hole, trench, shaft or pit that is of sufficient dimensions to allow a person to fall into the hole, trench, shaft or pit.
Controlling Working at Height Risks
Once again, the Occupational Health and Safety Regulations 2017 clearly states that all employers must, so far as reasonably practicable, eliminate the risk associated with a fall at the workplace (Section 44).
The regulations continue to set out a hierarchy of control measures that you must work through to ensure the highest possible control is implemented to protect the safety of workers who work at height. If you cannot eliminate the risk you must consider the use of a passive fall prevention system, followed by work positioning systems, fall arrest systems, ladders and administration controls, in that order. The hierarchy and explanation of each step in order is as follows:
Lets not forget that we must first of all try to eliminate the hazard by conducting work on the ground as much as possible and ensure all structures where work is being completed are solid and fit for the work being conducted. Ways of eliminating the hazard could include:
- Prefabricated roofs at ground level
- Using precast panels rather than formwork
- Using paint rollers with extendable handles
A solid construction is a permanent area at height that has been designed in a way that persons accessing the area cannot fall. It must meet the following requirements at all times:
- Structural strength
- Capable of supporting all forces applied to it
- Surface and gradient
- Free from trip hazards
- Smooth areas no greater than 7 degrees
- Cleated areas no greater than 23 degrees
- Edge protection – no live edges
- Void protection – no live voids
- Safe means of access and egress
Passive Fall Protection
A “passive” fall protection system refers to a system that is non-dynamic and stationary. Additionally, after installation it cannot be altered or moved whether or not it is in use or not. They rarely require the use of Personal Protective Equipment or active participation from the worker. Typical passive solutions include:
- Scaffolding systems
- Temporary edge protection
Work Positioning Systems
Work position systems involve harness-based work, where the harness is used to prevent the worker from reaching a position from which they could fall. Examples include:
- Pole straps
- Rope access equipment
- Restraint technique
Fall arrest systems
A fall arrest system is designed to arrest the fall of a person and is suitable for use in situations where the worker could freefall. In this instance, where fall arrest systems are to be used, workers must ensure that systems are in place to rescue the fallen worker.
Ladders and Administrative Controls when Working at Heights
Ladders are only to be used when other options are not reasonably practicable. They should be used primarily as a means of access to a work area safely and must be suitable for the task, surroundings and site conditions. They also must be used in accordance with manufacturer instructions and regulation 45 from the Occupational Health and Safety Regulations 2017.
Administrative controls are work procedures that help to reduce the exposure of employees to fall hazards where it is not reasonably practicable to use a higher level of control, such as:
- No go areas
- Permits systems
- Completion of a Safe Work method Statement is also required
Use of Plant to Control Risks when Working at Heights
Section 47 of the Occupational Health and Safety Regulations 2017 requires the employer to ensure that any plant used to control a risk associated with working at heights is:
- designed and constructed for the task or range of tasks to be undertaken
- designed and constructed in such a way as to enable its safe use in the physical surroundings in which it is to be used and the conditions during which it is to be used
- installed, erected or dismantled in such a manner as to reduce so, far as is reasonably practicable, any risk while that installation, erection or dismantling is being carried out
Review of Working at Heights Control Measures
Your requirement to review and, if necessary, revise any measures implemented to control risks associated with falls is outlined in Section 48 of the Occupational Health and Safety Regulations 2017. This requirement is applicable:
- before any alteration is made to plant or systems of work that is likely to result in a fall; or
- after any incident occurs to which Part 5 of the Act applies that involves a fall or a risk associated with a fall; or
- if, for any other reason, the risk control measures do not adequately control the risks;
- after receiving a request from a health and safety representative.
Emergency Procedures for Working at Heights
The need for provision of emergency procedures for working at heights is covered by Section 49, which states that employers who cannot eliminate the working at heights risk and elect to use a lower control measure, must ensure that emergency procedures are established.
Additional technical information required to support the framework of the Occupational Health and Safety Regulations 2017 is best found in the relevant Australian Standard.
Australian Standards are documents produced by governmental and non-governmental organisations. They are technically specific documents that give rise to the design, testing and application of devices. Examples include:
- AS 1891 Industrial fall arrest systems and devices
- AS 1892 Portable Ladders
Australian Standards are not legislation. However in some cases, legislation refers directly to an Australian Standard, making complying with the Australian Standard a legal requirement.
Australian Standards can also be used as evidence of minimum safety standards and industry expectations in maintaining a safe workplace.
If employers truly believe in the right of all workers to return home safely after each workday, then without hesitation they would comply with what the law states and adhere to Australian Standards. In doing so the moral expectations of society would also be upheld.
Now, I might be a little biased, but the regulations do require that sufficient training is provided to those exposed to fall hazards. Furthermore, Australian Standard 1891 Industrial fall-arrest systems and devices requires that anyone performing harness-based work undertakes training to a Nationally Accredited level. To find out more about our Nationally Accredited Height Safety Course, click here.
The laws are in place to protect workers from such height safety hazards, however too often they are either ignored, misinterpreted, not adhered to, not implemented or perhaps the biggest working at heights death trap of all, complacency.
Without the cooperation of the workers the height safety message always has the potential to be Ignored, misinterpreted or overlooked. So it is critical that all OHS initiatives encourage and engage the workers. They then sell that message to other workers and pretty soon your new higher safety standards are implemented.
If you have all of your workers selling the same height safety messages you best enable your business to eradicate the biggest working at heights death trap of all, complacency.
So if Employers keep up their end of the bargain and abide by our OH&S laws, and employees understand why and what they need to do and comply with employers’ directions, we can then focus on removing complacency as it is replaced with a new normal.
But most importantly of all, “We would save lives”.
If you require further information or assistance, please call our office on 1800 143 343.
All the best,
Business Development Leader
WAM Training (RTO 22054)