Access Testing FAQ

Under the Health and Safety at Work Act 1974 there is a responsibility to ensure we provide a safe place of work for our employees, those under our control and any others who could be affected by our actions.

Under PUWER (Provision and Use of Work Equipment Regulations 1998) in general terms requires that equipment provided for use at work is:

• Suitable for the intended use
• Safe for use, maintained in a safe condition and, in certain circumstances, inspected to ensure this remains the case

PUWER Regulation 6: Inspection states equipment should be inspected:

• That work equipment exposed to conditions causing deterioration which is liable to result in dangerous situations is inspected at suitable intervals
• Any deterioration can be detected and remedied in good time
• That every employer shall ensure that the result of the inspection is recorded and kept until the next inspection.

Under the Workplace (health, safety and welfare) Regulations 1992 Regulation 5: Maintenance of workplace, and of equipment, devices and systems, ACOP 5:42 states:

“Equipment that could fail and put workers at serious risk should be properly maintained and checked at regular intervals, as appropriate, by inspection, testing, adjustment, lubrication, repair and cleaning” section 5:43 states “any faults should be properly rectified as soon as possible. Action should be taken immediately to isolate and rectify the fault where there is a risk of serious or imminent harm.”

When cable-based systems are tested by the manufacturer, they are tested using the traveller device. Therefore, if you use a system without the correct traveller, the system is not working within its tested parameters and could fail to work correctly if used to arrest a fall. Obviously, this could prove catastrophic; therefore, the correct system-specific traveller should always be used.

It is determined by the positioning and strength of the fall protection anchorage device.

Further information

A fall arrest system is a safety system or anchorage which enables an operative attached to it to be in a fall risk position, e.g. a safety eyebolt fixed internally adjacent to a window. The operative (using a standard two-metre lanyard) could fall out of the window while leaning out, but the fall would be arrested by the eyebolt and PPE.

A fall restraint system is a safety system positioned in such a way as to not allow an operative to physically be in a fall risk position. An example is a cable-based system set 3m away from a leading edge. An operative attached to the system with a 2m lanyard would be able to get close enough to an edge to clean a gutter, for example, but would not physically be able to step off the roof.

In line with the requirements of Regulation 15 of the work at height regulations, fall protection systems should be designed to be as safe as possible; therefore, fall restraint systems will always be selected over fall arrest as far as is practicably possible.

However, having made the above point, it is rarely possible to ensure that all areas of a fall protection system are restraint. This being the case, ALL cable-based systems should be capable of taking fall arrest forces, as detailed in EN795:2012 Personal fall protection equipment and Advisory Committee for Roof work (ACR) guidance note {CP} 007:2008 Best practice for use of safety lines in roof work.

Note – If a building contains a fall arrest system, a suitable rescue plan must be put in place.

– The Health & Safety at Work Act 1974 states that an employer must supply suitable and sufficient information, instruction, training and supervision necessary for their health and safety at work. This includes the type of high-risk plant we are working with. This is an Act of Parliament and therefore it is a legal requirement to comply with it.

• The Work at Height Regulations 2005 state those involved in work at height are trained and competent.

Regulations 5 and 6(5)(b) 19: You must ensure that everyone involved in the work is competent (or, if being trained, is supervised by a competent person). This includes involvement in organisation, planning, supervision, and the supply and maintenance of equipment.

• The Management of Health & Safety at Work Regulations 1999 require employers to ensure that their employees are provided with adequate health & safety training. In the context of fall protection and suspended access equipment, this particularly applies to working at height and operation and maintenance of work equipment provided.
• PUWER — The Provision and Use of Work Equipment Regulations 1998 — further require training for users, supervisors and managers. In the context of fall protection and suspended access equipment, the duty holder should therefore ensure that only trained operators use this access equipment.

Risk cannot be contracted out and therefore the duty holder is better to control their own risk and supply the required PPE.Further informationIf a duty holder supplies the PPE to be used on their fall protection systems, they can control in conjunction with the system testing contractor (fall protection professional and competent person). They will thereby reduce their liabilities under the Work at Height regulations 2005 and the Health & Safety at Work Act). They can be confident that:

1. The PPE is suitable and sufficient for the system.
2. The PPE is tested, inspected and certified.

Should a duty holder choose not to supply the PPE they need for their fall protection systems, they should assume the responsibilities as below:

1. The duty holder needs someone on site sufficiently competent to inspect the contractor’s PPE and assess whether it is the correct equipment to use on the fall protection systems provided.
2. The duty holder needs someone on site sufficiently competent to inspect the contractor’s PPE and assess whether it is of the correct BS/EN standard, in test and in a suitable condition to use on the provided fall protection systems.

Work at Height Regulations 2005

Apply to all work at height where there is a risk of a fall liable to cause personal injury. They place duties on employers, the self-employed and any person who controls the work of others (e.g. facilities managers or building owners who may contract others to work at height) to the extent they control the work.

Duty holders’ responsibilities (duty holders are all of the above persons)

The regulations require duty holders to ensure:

– all work at height is properly planned and organised;

–  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.

The Health & Safety at work act

Regulation (1) – It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees. Employees include subcontractors, contractors and those under their control or who may be affected by their actions.

Regulation (2)

(c) the provision of such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of his employees;

(d) so far as is reasonably practicable regarding any place of work under their employer control, the maintenance of it in a condition that is safe and without risks to health and the provision and maintenance of means of access to and egress from it that are safe and without such risks; and

(e) the provision and maintenance of a working environment for his employees that is, so far as is reasonably practicable, safe, without risks to health, and adequate as regards facilities and arrangements for their welfare at work.

The Work at Height Regulations 2005 apply to all work at height where there is a risk of a fall liable to cause personal injury. They place duties on employers, the self-employed, and any person who controls the work of others (e.g. facilities managers or building owners who may contract others to work at height) (Duty Holders) to the extent they control the work.

Note – This could be the individual booking out keys for roof access on behalf of a facilities manager or building owner.

Duty holders must, where the equipment they control cannot eliminate the risk of a fall, use work equipment or other measures to minimise the distance and consequences of a fall should one occur.

The duty holder must ensure that:

–      All work at height is properly planned and organised

–      Those involved in work at height are trained and competent

–      Equipment for work at height is appropriately inspected

–      Ensure that the work is properly planned, appropriately supervised, and carried out in as safe a way as is reasonably practicable.

Note: In order for the duty holder to be competent to complete the above assessments and check´s they must be a competent trained individual in the area of working at height.

Further information

– The Health & Safety at Work Act 1974, which states that an employer must supply suitable and sufficient, information. Instruction, training and supervision necessary for their health & safety at work. This would clearly include the type of high-risk plant we are working with. This is an Act of Parliament and therefore it is a legal requirement to comply with it.

• The Work at Height Regulations 2005 state those involved in work at height are trained and competent.

Regulations 5 and 6(5)(b) 19: You must ensure that everyone involved in the work is competent (or, if being trained, is supervised by a competent person). This includes individuals involved in organising, planning, supervising, the supply and use of height access equipment.

· PUWER — The Provision and Use of Work Equipment Regulations 1998 — further require training for users, supervisors and managers. In the context of fall protection and suspended access equipment, the duty holder should therefore ensure that only trained operators use this access equipment.