02 March 2007
Paul Reeve

The myth that the Work at Height Regulations 2005 (WAHR) ban the use of ladders or steps just refuses to go away. Six months after the WAHR were introduced in April 2005, an HSE spokesperson appeared on the BBC's Newsnight to try to dispel the notion that window cleaners could not use ladders because of the new regulations.

But the idea that anything with rungs and stiles on it is banned persisted. Guardian columnist Simon Jenkins wrote on 17 November 2006 that "the HSE's ... ban on ladders, used since the Middle Ages to repair roofs and steeples, must have quintupled the cost of maintenance."

The cost of many maintenance jobs has indeed risen since the WAHR came in and, as we will see, in many situations ladders are restricted, but this is not down to the HSE. As late as last month, the executive was answering claims in The Times and Daily Mail that firefighters were banned from using stepladders after an inspector halted one service using them to fit smoke alarms.

"The Regulations do not ban ladders but say they should be used only when all other safer alternatives for work at height have been ruled out," says Ian Greenwood, head of the HSE's Falls from Height Programme. "A risk assessment must show that the task is low risk and of short duration, or that there are site features that mean other equipment is not appropriate. If so, then ladders can be used."

Greenwood is expanding on senior inspector Richard Lockwood's reassurance published last year on the executive's website: "The Work at Height Regulations do not ban the use of stepladders. However, employers need to undertake a risk assessment before the work starts and only choose steps as the means of access if there are no other reasonable alternatives. Steps will remain an option for certain jobs."

In practice, many contractors who work at height see the enforcement situation as far less important than what clients and major contractors want to see on site. Irrespective of the message from the HSE, numerous clients and main contractors have banned the use of ladders and steps, often dismissing risk assessments that might justify their use.

What's the problem?

Part of the reason the use of ladders and steps is severely tested under the WAHR is that, where reasonably practicable, equipment for work at height must provide a flat, suitably sized working platform; barriers or rails; and good stability.

This "working platform" should:

• be big enough to allow room to work, safe passage (if needed) and the safe use of equipment and materials
• prevent feet from passing through the flooring, or feet and objects passing over the edge (using toe boards, for example)
• be clean and tidy (free from dust or rubbish)
• provide the same security as working from the ground
• allow safe working with both hands.

A quick look at most ladders and many steps will show that they fail to meet these criteria. Falls from ladders and steps, particularly if the person rotates around their centre of gravity, can lead to tragic injuries. The early signs are that the WAHR have reduced the number of injuries linked to ladder and stepladder use, partly by prompting a significant move away from ladders to alternatives such as towers and podium steps, and partly by encouraging task design that avoids the need for work at height.

What else?

All this means that ladders are no longer the first port of call for many types of work at height. The WAHR have given rise to platform steps, access equipment that looks like a robust stepladder but which complies with the WAHR because it offers a good working platform and handrails. Some of these come with outriggers for extra stability.

Podiums, on the other hand, cannot be confused with stepladders (they are more like work cages than steps) but, like platform steps, their use has increased dramatically since the WAHR came into effect. Podiums give a raised working platform of between 1.5 and two metres. They are popular because they offer a stable working platform with barriers to prevent falls, and they allow two-handed work in any direction (360 degrees).

When conducting a risk assessment to see which type of access equipment to use, contractors need to consider factors such as:

• the job/task
• its duration
• the degree of hazard (notably the height)
• the number of people needed
• how frequently the job needs to be done
• the equipment to be used (including stability and barriers)
• the conditions on site (for example, ground conditions need to be clear enough to allow access equipment)
• the location - is it near site traffic, under live power lines or near edges?
• the environment - including temperature and lighting
• the risks linked to transporting, installing and dismantling access equipment
• the competence of workers and the level of training and supervision required
• the physical condition of the operative (age, fitness, head for heights).

A risk assessment should also consider those who work "on the tools" and any passers-by.

You should only specify ladders or steps where a risk assessment shows the task is low risk and of short duration, or where there are features on site that can't be altered and using other equipment isn't practical. These features could involve restricted space that prevents you placing other equipment correctly or ground conditions that mean there is no room to set up alternative equipment.

Though clients don't want contractors' ladders or steps on site, banning this equipment seldom removes the need to work at height. Where ladders are restricted or banned, the client and contractor should negotiate suitable alternatives. At the very least, contractors should try to agree the method of access to work at height before starting work - it's very expensive to find out in the middle of a job that the chosen access method isn't allowed.

Tread carefully

The key factors that contribute to the safety of ladders or steps are:

• practical risk assessment to establish the most suitable work equipment when people have to work at height, taking into account the conditions and type of work
• knowing the limitations of the ladder; employers should contact suppliers or manufacturers if they need more information
• ensuring users are competent in the safe use of ladders, including any accessories
• ensuring ladders are maintained in safe working order; pre-use checks are critical - in particular, missing ladder feet will increase the risk of a ladder slipping or "stepladder wobble".

The HSE says operatives should only work on stepladders for a maximum of 15 to 30 minutes at a time, and only carry light materials and tools (up to 10kg).

It is too dangerous to work from the top rungs of ordinary steps; they are likely to tip over. Steps must be stable and made to industrial, not domestic, standards.

The HSE says that, before deploying steps, users should consider their "condition and position". For example, a stepladder in good condition should include firmly attached feet and secure fastenings when extended. 

For steps to be safe they need to be fully open, locked in place and standing on a firm, level, clear and dry surface. The HSE's latest guidance (www.hse.gov.uk/falls/usingladders/stepladderthreepoints.htm) says that steps, unlike ladders, can be used with both hands free to work, since leaning against the steps' top "D-ring" maintains three points of contact.

Whatever access equipment is used, operatives must know its limitations. If they are required to set up or adjust the equipment, they should be properly trained. Defective access equipment must be reported to the supervisor, clearly identified, and not used.

And if you are looking to move away from ladders, talk to your employees about the options first.

The HSE is planning "Ladders Week 2007" this summer. As well as awareness-raising events and increased inspection activity, the initiative is likely to feature a "ladder trade-in" to take around 4000 defective ladders out of the workplace and offer access to discounted replacements.

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Next steps

The WAHR led to a torrent of ladder safety advice from the HSE and others. There is a remarkable contrast between the range of advice currently on the HSE website and the almost total absence of information on ladder safety only a few years ago. As recently as 2003, the most accessible information on safe working with ladders was a DTI leaflet. Today, no one can reasonably say they are short of practical advice on how to choose whether to use ladders or how to use them safely.

• The HSE's basic ladder safety leaflet is at www.hse.gov.uk/falls/usingladders/index.htm. The longer guide for employers is Safe Use of Ladders and Stepladders, available at www.hse.gov.uk/pubns/indg402.pdf
• A pocket card, Top Tips for Ladder and Stepladder Safety, is available to print at www.hse.gov.uk/pubns/indg405.pdf
• There is an impressive HSE Microsoft PowerPoint presentation covering the whole subject of falls and ladders at www.hse.gov.uk/falls/downloads/6.pdf
• The HSE's brief guide to the Work at Height Regulations 2005 is available at www.hse.gov.uk/pubns/indg401.pdf
• The Glass and Glazing Federation has produced a helpful code of practice for work at height in the domestic replacement window industry, available at www.hse.gov.uk/falls/downloads/gfgcodeofpractice.pdf

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Paul Reeve CFIOSH is health, safety and environment manager at the Electrical Contractors' Association (ECA)

Categories:
Construction, Work at height, Article, Work equipment