Working At Height

Plymouth City Council

Health & Safety Performance Standard 3
(HSPS 03)
April 2006

Working At Height
Contents
Section

Page

Introduction

Responsibilities

Guidance

Risk Assessment

Health Conditions

Monitoring Health & Safety Performance.

G Further Information

Appendix 1: Overview for Working At Height Risk Assessment

12

Appendix 2: Example Ladder Checklist

13

Appendix 3: Worked Example of a Risk Assessment

16

Health, Safety & Wellbeing Team

Human Resources, Chief Executives Department
Plymouth City Council
Email: healthandsafety@plymouth.gov.uk

Guide to Working At Height Plymouth City Council

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Guide To Working At Height

A.

INTRODUCTION

Council health and safety policies, performance standards and guidance notes should be
regarded as the health and safety standard each Department, Service Unit, School and
team is expected to achieve, and against which health and safety performance will be
monitored and audited.
The Working At Height Regulations 2005 came into force in April 2005. The Regulations
encompass previous legislation and guidance from a number of sources and are the
definitive document for working at height. There is no measured height applicable to the
regulations therefore any height above ground level however small, must now be
considered as working at height.
Falls from height are currently the single biggest cause of death in workplaces within the
United Kingdom. The Regulations remove the previous 2-metre rule, which was used as a
guide to establish the definition of working at height. The intention is to collate all existing
legal requirements for working at height into a single set of regulations, which apply, to all
industries. The Regulations are intended to provide legislation which is practical,
does not present unworkable requirements and addresses high-risk environments in a risk
based approach. The Regulations will apply to all workplaces that come under the scope
of the Health & Safety at Work Act etc 1974.
Where the Council is the designated Client, it has a duty to ensure Contractors meet
Council standards and legislation, including those applicable to working at height.
SCOPE
This guidance applies to all Plymouth City Council (PCC) staff and all locations owned,
managed or where work activities are undertaken on behalf of the council. Departments
are to ensure their Departmental Health & Safety Arrangements meet the requirements
identified in this Health & Safety Performance Standard.
DEFINITION OF WORK AT HEIGHT
Work at height is any place, including a place at, above or below ground level, where a
person could be injured if they fell from that place. Access and egress to a place of work
can also be work at height.
N.B the following non-exhaustive lists are provided for guidance;

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Examples of activities that are

classified as working at height
include:

Working off bandstands

Working on a flat roof
Erecting falsework and
formwork
Working at ground level
adjacent to an open
excavation
Working near or adjacent
to fragile materials
Working on formwork
within an excavation
Working from a ladder

Some examples of where the regulations

do not apply:

Walking up and down a

staircase in an office
An Operator sitting in a seat
on an excavator
Working on the upper floors of
an office block or a portacabin
Sitting in a chair

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B.

RESPONSIBILITIES

Chief Executive
The Chief Executive is ultimately responsible for all operations undertaken by Plymouth
City Council including activities where working at height is required. The Chief Executive
will delegate the responsibility for operational work to the Directors of each Department for
the provision of Council services.
Directors
Directors are responsible for all operations within their Departments including those
operations where working at height is necessary, however the operation of services will
normally be delegated to Departmental Line Managers. Directors are responsible to the
Chief Executive for ensuring resources are adequate to ensure, as far as reasonably
practicable the safety of persons working at height on behalf of the Council. This will be
achieved by Directors implementing an effective Health & Safety Management System
within their Departments to meet the requirements of Corporate Policy and Corporate
Health & Safety Performance Standards.
Line Managers
Line Managers are responsible to their Director for implementing the Health & Safety
Management System in operation within their Department.
Operational Staff
Operational staff are responsible for following the operational requirements detailed within
the health & safety management arrangements of their Department.

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C.

Guidance

The Working at Height Regulations 2005 require all work at height to be properly planned,
supervised and carried out in a manner which is, so far as reasonably practicable, safe.
Work may only be carried out when weather conditions will not jeopardise the health and
safety of any person involved in the work. There are further requirements to ensure that
planning includes appropriate selection of work equipment for the job and that emergency
procedures are in place for the duration of work. The hierarchy of control for working at
height should followed and are detailed below:

It may be possible to avoid working at height by changing a work process, e.g. inspection
of a roof may be undertaken by use of binoculars or by inspection from an adjacent
building if appropriate.
Consider using the safest means of working at height as far as reasonably practicable and
determine what control measures can be implemented to reduce the risk of injury. The use
of roof edging, debris netting, mobile or static work platforms and ladders should be
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considered. A non-exhaustive safety equipment selection list, which may be suitable for
undertaking work at height, is produced below;
Work Equipment Safety Selection List

Static Platforms such as Scaffolds and Fixed Towers.

Mobile Platforms such as elevating lifts, (Cherry Pickers).
Cradles.
Mobile Towers.
Trestles
Ladders and Stepladders

DUTY HOLDERS
Persons responsible for operations involving working at height are designated as duty
holders, and must ensure the following requirements are met all work at height is properly planned and organized;
all work at height takes account of weather conditions that could endanger health and
safety;
those involved in work at height are trained and competent;
the place where work at height is done is safe;
equipment for work at height is appropriately inspected;
the risks from fragile surfaces are properly controlled; and
the risks from falling objects are properly controlled.
MINIMISE THE LIKELIHOOD OF AN INCIDENT OCCURRING;
The method for determining the action required is by risk assessment and reference
should be made to the Corporate Health & Safety Performance Standard (HSPS1) for
further information and advice. An overview for undertaking a risk assessment for working
at height is included as Appendix 1.
Good practice and legislation indicate that where working at height is deemed necessary
arrangements must be made to reduce the risk of injury to a minimum, therefore work at
height should only take place if there is no other practical alternative. Where possible staff
should not be asked to work in any area where there is a risk of falling, if this is not
possible suitable edge protection should be supplied and lone working avoided. All
equipment used during the course of working at height must be suitable and sufficient for
the task, and fall arrest/ fall protection equipment must be provided where necessary.
Personal Protective Equipment should only be used when all other safety measures have
been implemented and a residual risk that is un-acceptable remains. Staff working at
height must be adequately trained and any equipment (such as harness/lanyards or fall
arrest equipment) provided must be regularly inspected, visually before use and formal
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inspection made and documented by a competent person at minimum 6 monthly periods.

Inspection periods may be more frequent if determined by the condition and use of the
equipment, manufacturers recommendation or risk assessment.
Work environments are also a consideration and hazards such as fragile roofs, working
over water or other high-risk areas must be taken into account, this also includes below
ground level situations. Arrangements must be in place to allow for access, egress and
rescue in an emergency situation.
Equipment such as scaffolds, ladders, work platforms (whether mobile or static) must be
properly selected, built and maintained, inspected and dismantled as detailed in any
specific legislation and guidance that may be applicable. Equipment for working at height
should be regularly inspected by a competent person, and repaired or disposed of as
necessary, the inspection should be documented and items marked to indicate the date
tested.
A Register of equipment should be compiled for use in managing the inspection regime;
equipment manufacturers indicate the frequency of inspection that is required. Visual
inspections should always be made prior to use and defects reported to supervisory staff,
defective equipment should be withdrawn from use until replaced or repaired as
appropriate.
A further consideration relates to objects falling or being thrown from height, it is the
employers responsibility to prevent this, where it is not practicable to prevent such actions
employers must ensure that persons are protected from injury by appropriate means.
Practically this means the provision of personal protective equipment such as head
protection (Hard Hats) or protective items such as debris netting or covered overhead
walkways, and securing of work areas to prevent unauthorised entry and possible injury.
Ladders & Stepladders
Ladders are a useful means of working at height although they should be considered only
when safer equipment, as far as reasonably practicable is not suitable for the work being
undertaken. Ladders should not be the first consideration for working at height operations.
Unless identified by risk assessment, ladders used should be type Class 1 which are
rated for industrial and not domestic use. Example Ladder Inspection form/checklists are
produced as Appendix 2 and may be used as appropriate to the department. Formal
inspection should be made at 6 monthly periods and be recorded; visual inspections must
be made before use.
Ladders if used must be suitable for the work being undertaken; therefore ladders made of
an appropriate material that is suitable for the task i.e. a ladder being used close to an
electricity source should be constructed of a non-electricity conducting material. All
persons using ladders must be trained and competent to use them.

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Harness & Lanyards

Where operational need and risk assessment identify lanyards and harnesses are required
(such as when working from mobile work platforms) this equipment must be provided as
personal protective equipment. There is great variation regarding harness design
dependent on the manufacturer and the use the equipment is required for, therefore expert
advice from the Councils Health & safety equipment supplier should be sought. All staff
using such equipment must be suitably and sufficiently trained as should any person with
supervisory or maintenance duties involving harness use. Harnesses must be formally
checked at 6 monthly intervals and visual checks made prior to every use, damaged, worn
or ill fitting harnesses must be removed from use. All formal checks must be recorded.
Lanyards must always be anchored to a robust non-movable anchor point when harnesses
are used and Departments must ensure their arrangements meet the requirements of this
performance standard (HSPS03)
Fall Arrest Equipment
Fall Arrest equipment should be provided when risk assessment and operational needs
have identified it as a control measure. This type of equipment should only be used when
all other control measures fail to adequately ensure the safety of operatives, and not as a
stand-alone solution to working at height operations.
Fall Arrest equipment has limitations to its use and should only be used by suitably and
sufficiently trained persons. The need to formally and visually check is paramount as the
consequences of equipment failure may lead to serious or fatal injury. Fall arrest
equipment that is faulty or poorly maintained must be withdrawn from use. There is a need
to anchor fall arrest equipment, separate legislation other than the Working at Height
Regulations are in place and must be complied with, further advice should be sought from
the Health & Safety Team prior to any purchase or use of fall arrest equipment. Any person
supervising staff using fall arrest equipment or who have a responsibility for
checking/maintaining such equipment must be competent and receive suitable training.
Scaffolds & Mobile Towers
Competent persons who have received suitable and sufficient training must only erect
scaffolds. Any person using a scaffold or mobile tower must follow Safe Systems of Work
and these must be formulated and implemented by departments. When contractors erect
scaffolds or towers, they must not be accepted until checked by competent Council staff,
which have recognised qualifications or suitable scaffold training, and a handover
certificate is properly completed.
Legislation and guidance is in place with regard to use of scaffolds and mobile towers
which must be complied with, risk assessment must also be undertaken and further advice
may be provided on request to the Corporate Health, Safety & Wellbeing team. Inspection
regimes apply to scaffolds and mobile towers and records of inspection must be kept.
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Trestles & Static Work Platforms

Various types of trestles and work platforms are used during the course of work, where
possible professional equipment should be supplied and used as those made up of
stepladders and boards are by todays standards considered a safety risk. Risk
Assessment should indicate the need for use of trestles or work platforms and further
advice can be sought from the corporate Health & Safety team.

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D. RISK ASSESSMENT
Risk Assessments should be completed for operations involving working at height and be
appropriate to the task, where necessary they should be specific assessments bespoke to
the work being undertaken and identify significant hazards including working at height.
Corporate guidance for risk assessment is available in Health & Safety Performance
Standard (HSPS1), which should be read in conjunction with this document.
The following hazards should be included in risk assessments involving working at height

The distance and potential for falling.

The frequency and duration of work
The surface that any equipment used is being sited upon.
The environment including weather.
Physical limitations such as adjoining structures.
Access and egress.
Arrangements for emergency attendance of rescue and medical services.
The task and abilities of staff involved.

Risk Assessments should identify hazards and detail Control Measures prior to work
being undertaken. Safe Systems of Work may need to be written and communicated to
staff, contractors and other agents as appropriate. Safe Systems of Work may be verbal
but normally take the form of written codes of practice, Permit to Work controls, written
instructions or be dictated through operational supervision. In most circumstances
apprentices or young persons should not be allowed to work at height unless this is
necessary for them to gain experience that cannot be provided by working at ground level,
under these circumstances a specific risk assessment must be undertaken and suitable
and sufficient supervision must put in place.
A worked example of a risk assessment including working at height operations is included
as Appendix 3. An overview in undertaking a risk assessment for working at height is
produced as appendix 1.

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E.

HEALTH CONDITIONS

Where working at height is identified as increasing the risk of injury due to health concerns
such as epilepsy, diabetes, high/low blood pressure or muscular skeletal conditions
(please note this list is not exhaustive) then referral should be made to the Occupational
Health Team for advice prior to work at height being undertaken.
F.

MONITORING HEALTH & SAFETY PERFORMANCE

Departments are to ensure suitable arrangements are made to monitor the implementation
of this Health & Safety Performance Standard. It is recommended that an asset register of
equipment should be compiled by departments detailing the dates when assets are
formally examined, condition of equipment, actions resulting from the checks, next
examination date and the competent examining officer.
Asset Register Information, Risk Assessment and Safe System of Work documentation
should be retained for a minimum of 3 years after they cease to be current. This is
required, as it may be necessary to provide this information to officers such as Health &
Safety Executive Inspectors, or provided in any case of litigation. Records also provide the
bedrock information for other operation such as audit.
Only competent persons who have the necessary knowledge, experience, practical ability
and training should undertake inspection of equipment. Training is available from many
sources including manufacturers of safety equipment for use in working at height; the
Corporate Health, Safety and Well-being Team can give further advice.
Supervisory visits should be made as appropriate to sites where working at height is
necessary and be recorded. Auditing should also be considered and this will also assist in
maintaining quality assurance standards. Workplace inspections should be undertaken
and recorded, and any necessary action taken as a result.
Where the organisation acts as the Client then suitable arrangements for control of
contractors must be implemented, high-risk tasks such as working at height must be
suitably controlled and evidence documented.

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G.

FURTHER INFORMATION
1. The Health & Safety Executive (HSE) website is useful for further information and
can be accessed at www.hse.gov.uk.
2. INDG 401: Working at Height-A Brief Guide. (HSE Books).
3. INDG 402: Safe Use of Ladders and Stepladders. (HSE Books).
4. INDG 405: Pocket Guide: Ladders-Stepladders. (HSE Books).
5. The Working At Height Regulations 2005.

Further information and guidance is available from the Health, Safety & Well-being Team
(Health, Safety & Wellbeing Team, Human Resources, Chief Executives Department
Plymouth City Council. Email: healthandsafety@plymouth.gov.uk) and in the Document
Library within the Councils Intranet system.

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Appendix 1: Overview of Risk Assessment Process.

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Appendix 2: Examples of a Ladder Checklists (Prompt) & Ladder Inspection Forms

LADDER CHECKLIST (PROMPT) 6 MONTHLY
The appointed person whom carrying out six monthly inspections of ladders must do so
using the following table and using a Ladder Inspection Form, an example is detailed
below:
LADDER PART
Wooden Rungs

Wooden Stiles

Metal Rungs
Metal Stiles

CONDITION
Missing
Split
Damaged
Wire ties broken
Split
Damaged
Warped
Safety feet attached, if
fitted
Missing
Cracked Weld Joint
Buckled
Twisted
Safety feet attached, if
fitted

ACTION
The ladder is to be taken
out of service immediately,
secured and thereafter
destroyed to prevent reuse.

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Paint has been applied.

All Parts of both wooden
Grease or oil deposits
and metal ladders.
present.
All accessories bolts / Missing
pins
Loose
All parts
ladders.

of

This is acceptable as the

wooden A clear preservative or
condition of the timber can
varnish has been applied.
still be assessed.

Appendix 2 cont;
LADDER INSPECTION FORM
SECTION

I.D. No.

MANAGER

The ladder has been inspected and checked with observations listed. The ladders
remain serviceable and fit for continued use.
REF NODATE
CONDITION
SIGNATURE
ACTION

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Appendix 2 cont;

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LADDER CHECK LIST

Equipment Marked to show date checked .Yes/No

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GUIDE TO WORKING AT HEIGHT PLYMOUTH CITY COUNCIL

Appendix 3: Risk Assessment-Worked Example

Assessment Reference No.

Assessment date
Persons who may be
affected by the activity (i.e.
are at risk)

RA0000
30th November 2005
Operative & Members of public

Area or
Activity
assessed:

Emergency guttering repair above

ground level

Total no. of
continuation
sheets used:

SECTION 1: Identify Hazards - Consider the activity or work area and identify if any of the hazards listed below are significant (tick the
boxes that apply).
Fall of person
1. (from work at *
height)
2. Fall of objects *
Slips and
Trips,
3.
housekeepin
g
Manual
4. handling
operations
5. Mechanical
5 Lifting
operations

Hazardous
fumes,
21.
chemicals,
dust
Hazardous
22. biological
agents
Confined
space /
23.
asphyxiation
risk

Display screen
6. equipment
work

Condition of
11. building &
glazing

16. Noise at work

Repetitive
7. movements or
static postures
Layout,
storage,
8.
space,
obstructions
Heating,
9. lighting &
ventilation

Electrical
12. hazards or
Equipment

Vibrating
17. tools or
equipment

Use of
13. portable tools
/ equipment

Fire hazards
18. & flammable
material

Fixed
14. machinery or
equipment
Transport /
15. driving at
work

Pressure
Food
19. vessels or
24.
preparation
stored energy
Outdoor work
Occupational
20. / extreme
* 25.
stress
weather

10.

Welfare
facilities

(S) Severity: Insignificant = 1; Minor = 2; Moderate =3; Major = 4; Fatal = 5

(P) Probability: V. Unlikely = 1; Unlikely = 2; Possible = 3; Likely = 4; Almost Certain = 5
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Lone working /
26. work out of
hours

Violence to
27. staff / verbal
assault

28. *

29. *
30. *

(R) Risk rating = S x P Low = 1-5;

Medium = 6-10; High = 11-15; Very High = 16+

Guide to Working at Height Plymouth City Council

SECTION 2: Risk Controls - For each hazard identified in Section 1, complete Section 2.
spare boxes 28 30.
Hazard
No.

Hazard
Description

Fall from
height

Fall of
objects

HSPS03 April 2006

Existing controls in place to reduce risk you

must check that these controls are
actually working

*List any additional hazards in the

Further action needed to reduce risks

Residual
Risk

Reduced
Ris
k

S P
4 2

R
8

S
4

1.1 Three points of contact to be

maintained whilst working on ladders.
1.2 Ladders secured top and bottom
during work operations.
1.3 Ladders checked visually prior to use
by operative.
1.4 Formal ladder inspection at 6
monthly intervals.
1.5 Code of Practice CP11 followed.
1.6 Ladder training session attended.
1.7 Lanyard & harnesses are used
during elevated work platform
operations.
1.8 Mobile Tower work undertaken from
within the confines of the tower only.
1.9 Roof work undertaken only after
Specific Risk Assessment is
completed.
1.10 No person under 18 years of age
works at height unless Specific Risk
Assessment is completed.
2.1 Area underneath ladder secured from 4
Access to un-authorised persons.
2.2 No fallen object to be left in-situ.

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1.1.1 Specific Risk Assessment to be

undertaken if significant risk is
identified at specific locations and
risk is not adequately controlled.

Nov 2005

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3.1 No external working at height is

3
Inclement
Undertaken during periods of
Weather
Ice, snow, rain or heavy wind.
3.2 Woollen work gloves (Type), thermal
Undergarment, weather resistant
Trousers/jacket (Type) supplied.
3.3 If unexpected inclement weather is
Experienced during the work, work at
Height to be stopped and Supervisor
to be contacted for instructions.
Name of
A.N Other
SIGNED
Assessor(s)

Health and Safety Risk Assessments continuation sheet

Department

Housing

Service Unit

Building Repairs Service

Assessment Reference No

RA0000

Continuation sheet
number:

SECTION 2 continued: Risk Controls

Hazard
No.

Hazard
Description

Lone
working
/Out of
hours

Existing controls in place to reduce risk

you
must check that these controls are
actually working
4.1 Work diary lodged with Supervisor.
4.2 Adequate supervisory visits
undertaken.
4.3 Mobile phone issued to all operatives.
4.4 Operative books on and off of job with
Supervisor.

Residual
Risk

Reduced
Risk

12

4.1.1 Consider providing GPS tracked

mobile phone & remote supervision.

1.1 Customer Alert Register checked by

Supervisor.

12

5.1.1 Operations Manager to consider

applying person warning code to
work tickets.

Violence &
Aggression

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Name of
Assessor(s)

A.N Other

Signed

Department

Housing

Service Unit

Building Repairs Service

SECTION 3
3.1 Best Practice Standards
Are there any relevant best practice
standards or legal requirements
which should be followed for the
hazards being assessed?
e.g. Council Policies, or guidance
(corporate or departmental),
legislation, HSE guidance or
Approved Codes of Practice, British
or European Standards, professional
or trade guidance.

SECTION 4:

List these:
1. Corporate Health &
Safety Performance
standard 3.
2. Departmental Health
& Safety Manual.
3. Working at height
Regulations 2005.
4. Health & Safety at
Work Act 1974.
5. Housing Repairs
Code of Practice 11.

3.2 Vulnerable Staff

List these:

Are there any staff who may be

particularly vulnerable and at risk. If
so, a personal risk assessment
should be carried out.

1. Apprentices.

e.g. young persons (under 18); new

and expectant mothers, staff with
disabilities or health conditions that
might increase risk.

ACTION PLAN list how the further action required, as identified in Section 2, will be undertaken.

Hazard

Action Required

Costs /
resour
ces
require
d

Target
Date

Action by whom?

Completion
Date

1. Fall from height

1.1.1 Specific Risk Assessments to be

Unknown
undertaken where control measures indicated
by this Risk assessment are not acceptable.

As
identified

Line
As required
Manager/Supervisors

4. Lone Working

4.1.1 Consider provision of GPS tracking

mobile phones and remote monitoring

1st
January

Operations Manager

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Unknown
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services.
5. Violence &
Aggression

5.1.1 Consider printing Person warning

Codes on Operatives job tickets.

Unknown

2006
1st
January
2006

I confirm that this risk assessment is an accurate reflection of the risks and controls in place
The further action required, as outlined in the Action Plan above, will be achieved by the target dates

Operations manager

YES / NO
YES / NO see below*

*Managers comments (if further resources are required etc.)..

..
Signed by responsible manager: A Person.. Signature... Date1st December 2006
Review date 30th November 2006
For guidance on completing this form, please refer to Council Health & Safety Performance Standard HSPS1 Health & Safety Risk
Assessment available on the Health, Safety & Wellbeing Document Library, where further copies of this form can also be obtained.

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SECTION 5: ASSESSMENT REVIEW RECORD

This form can be completed each time the risk assessment is reviewed. It is not necessary to re-write the assessment unless
significant changes are made.
Date of
review

Name of Reviewer

Signature

Comments

Next
review
date

For guidance on completing this form, please refer to Council Health & Safety Performance Standard HSPS1 Health & Safety Risk
Assessment available on the Health, Safety & Wellbeing Document Library, where further copies of this form can also be obtained.

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