The Rules for Working at Height Explained (and why competence really matters)
The Act imposes a general duty of care on Facilities Managers, among others, to ensure the safety of workers. It specifies the need for risk management, and the production of appropriate policies, controls and systems (such as permits to work), to govern work at height.
Construction (Design and Management) Regulations (CDM) 2015
CDM 2015 requires Facilities Managers to manage the health and safety risks around a construction project, and to regularly review this management to ensure it is appropriate.
Making sense of it all
While it may appear that Facilities Managers are subject to a dizzying array of regulations, the actual requirements are fairly straightforward to meet. Many of the procedural ones will be addressed by simply following general Health and Safety best practice – likely to be well-established in any organisation of reasonable size.
The more you understand the differences between permanent and temporary access, passive and active systems, and collective and personal protection, the more you will be able to assess the most appropriate option for your premises. When done properly, this will allow you to address your statutory responsibilities, while also improving the accessibility, and therefore maintainability, of the building; a rare win-win.
If you’d like to learn more about your responsibilities and how to mitigate risks, download our free guide to roof risk management.
Competence to work at height should not be treated as a binary decision.
While it is true that an employee or contractor will either be competent to do a job, or not, this blunt approach does facilities managers no favours. This is because it doesn’t take into account the different degrees of competence required depending on the roof type and the means of access. For example, using cherry pickers or rope systems requires very specific skills and qualifications, whereas caged ladders and staircases can be used by a broader range of personnel.
Ultimately, facilities managers are expected to exercise good judgement, and factor in the means of access alongside the required skills when determining competence. A more nuanced view of work at height competence then – understanding how different means of roof access determine what makes a worker competent – can pay dividends. To begin with, by mapping different competence levels against means of access, facilities managers can make more informed choices about the access provision they make on site.
In addition to this, it can lead to a reduction in expensive over-competence – where the most qualified (and usually most expensive) contractors are set tasks that could be completed by other staff or less specialist contractors. It also protects facilities managers from the risk of under-competence – where workers with qualifications and experience to work at height in certain scenarios are inadvertently assigned jobs that they are not competent for, increasing the risk of injury and prosecution for failing to meet one’s duties.
Assessing the Risk of Work at Height
Each employing organisation should decide how to assess workers, based on the job at hand and the access to and around the roof.
Based on our own extensive experience of roof work, we have developed a three tier system for categorising a worker’s competence to work at height. It’s worth noting that there is no zero level – if an individual doesn’t meet any of these standards, they should not be working at height.
Work at Height Competence Explained
A person with Basic competence will have only limited experience in working at height. They have had some training in working at height safely relevant to their typical means of access in the last two years, for which they should have evidence. They occasionally work at height, but not on a regular basis, and their experience is limited to a narrow range of scenarios. Examples of workers who typically meet the Basic competence level are HVAC maintenance contractors and Facilities Technicians.
A contractor or employee with Advanced competence has a far greater breadth and depth of experience. They regularly work at height, and have done so in many different scenarios. They will have had more training in different means of access and protection systems, with multiple qualifications covering a range of topics, and are therefore more aware of the range of hazards that can exist when working at height. They can demonstrate extensive experience of relevant work over a number of years. As examples, roofing contractors and experienced Facilities Managers are likely to meet the Advanced level of competence.
Expert competence is limited to the most experienced height safety specialists, and relies on expertise unlikely to be held in-house. These contractors spend every day working at height, and can make themselves safe in almost any situation. They will have extensive qualifications relating to undertaking and managing work at height, including multiple specialist certifications, and will be able to provide logbooks showing regular updates to their training to maintain their qualifications. They will also usually be a member of a trade association, which will set stringent standards for member competence. IRATA-certified Rope Access Technicians are the most common examples of contractors with Expert competence.
Taking Action on Competence Levels
In a world where Facilities Managers hold more legal duties than ever before, a good grasp of competence is vital. By understanding the work at height competence of workers, Facilities Managers can take action to improve the means of access on their premises and ensure they are appropriate for the full range of work required. For example, by installing permanent fixed access solutions such as caged ladders.
More than that, undertaking this proactive assessment will also provide a useful foundation for future risk assessments and work orders, as well as demonstrating adequate consideration has gone into safe provision, in line with their duties.
Put simply, understanding competence is the route to safer, more cost-effective compliance.
