The Work at Height Regulations 2005
Background
In October 2005 there were misleading reports in the press suggesting that the Work at Height regulations forbade the use of ladders for changing light bulbs in a church. Ideally, alternative means of access such as tower scaffolds or mobile elevated platforms should be used. However, the regulations do allow for the use of ladders under certain circumstances.
The Health and Safety Executive took the opportunity of presentations held throughout the country during National Ladders week in November 2005 to make it clear that ladders may still be used provided risk assessments are carried out and the necessary safety precautions are followed.
The Work at Height Regulations 2005 came into force on 6 April 2005 and apply in England, Wales and Scotland. They apply to employers, persons under their control and to the self-employed.
VOLUNTEERS
In the light of guidance form the Health and Safety Executive we would advise that all churches follow the regulations.
The HSE make the following statement in their publication HSG 192 - Charity and Voluntary Workers: a guide to health and safety at work:
"While most Health and Safety law specifically refers to "employees" and the duties owed to them, it is good practice, and very strongly recommended, that people working as volunteers are given the same level of protection as employees. "
Definition
The Regulations define work at height as work in any place, including a place at or below ground level or obtaining access to or egress from such place while at work, except by a staircase in a permanent workplace where, if measures required by the Regulations were not taken, a person could fall a distance liable to cause personal injury.
Planning and Supervision
Work at height must be properly planned and appropriately supervised and must not be carried out at height where it is reasonably practicable to carry out the work in a safer way. For example, light fittings, candelabra, sanctuary lamps, roods and other items at high level could be taken down for cleaning, restoration and repair rather than being worked on in situ.
Where work is carried out at height, reasonable measures must be taken to prevent any person falling a distance liable to cause personal injury. Where access is routinely required at high level such as for the clearance of leaves and debris from gutters or the routine maintenance of parapets and roofs the installation of barriers or fall arrest systems may be necessary.
Schedule 6
Schedule 6 of the regulations deals with the use of ladders and states that ladders may only be used for work at height if a risk assessment under regulation 3 of the Management of Health and Safety at Work Regulations has demonstrated that the use of more suitable work equipment is not justified because of the low risk and the short duration of use, or existing features on site which cannot be altered. The Health and Safety Executive have indicated that "short duration of use" is anything up to thirty minutes. Fixed pews and pew platforms would be a good example of "existing features on site which cannot be altered".
Ladders must be placed on firm surfaces to provide support so that the rungs remain horizontal, and be so positioned to ensure stability during use.
Portable ladders must be prevented from slipping by securing the stiles at or near their upper or lower ends, by using an effective anti-slip or other effective stability device or any other arrangement of equivalent effectiveness. The practice of "footing" a ladder whereby a second person places a foot on the bottom rung of the ladder is no longer accepted as good practice.
Ladders used for access must be long enough to protrude sufficiently above the place of landing to which they provides access, unless other measures have been taken to ensure a firm handhold.
This is only a very brief summary of the regulations and is based on our understanding of current law and practice. Parishes must obtain legal advice if they are unsure of any of their responsibilities.
Chris Hawkings - Ecclesiastical Insurance
(This article first appeared in the Ecclesiastical Architects' and Surveyors' Association Journal of Winter 2005, and is printed by kind permission of EASA and Ecclesiastical.)
See also Health and Safety
January 2006
Further Information
There is no Approved Code of Practice (ACOP) but the Health and Safety Executive (HSE) have issued a Brief Guide, Ref: INDG401 which can be downloaded free from http://www.hse.gov.uk/
Guidance on how to carry out a risk assessment may be found in the Guidance Notes to Ecclesiastical's Church Health & Safety Policy.
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