Work at Height Procedure Rooftop, Climbing & Equipment Purpose The information within this procedure demonstrates how Cornerstone Telecommunications Infrastructure Ltd (CTIL) fulfill statutory obligations. Under current legislation, employers are under obligation to control any work at height that may be undertaken. Statistics show that falls from heights are a regular cause of fatal and serious injuries, with the main hazards being falls, falling objects and falls from collapsing structures. CTIL recognises its legal responsibilities in relation to work at height and as such have produced this procedure. Scope This procedure is applicable to all CTIL personnel (permanent or temporary), all contracted employees, suppliers and those visiting our sites. Where persons are required to use other operator s or landlord s equipment, it must be covered by their own work at height procedures. These procedures should apply providing they do not lessen CTIL safety standards ensuring all equipment in place is inspected, tagged and tested to a recognised standard as appropriate. Definitions Working at Height Work in any place where, if there were no precautions in place, a person or object could fall a distance liable to cause personal injury. Mobile Elevating Work Platform Equipment such as powered platforms, vehicle-mounted elevated and rotating work platforms, extendable boom platforms, aerial ladders, articulating boom platforms, scissor lift. Anchor point A secure point of attachment for lifelines, lanyards or deceleration (grabbing) devices. GREEN DATA 1 of 11
Harness (also referred as full-body harness and fall protection equipment) An interconnected set of straps that may be secured about a person in a manner that distributes the fall arrest forces over at least the thighs, pelvis, waist, chest, and shoulders with a means for attaching the harness to other components of a personal fall arrest system. Fall protection and Fall Protection Equipment (FPE) Any one or combination of a guardrail, personal fall arrest, or personal fall prevention methods. Lanyard A flexible line of rope or strap that generally has a connector at each end for connecting the body harness to a deceleration device, lifeline or anchor point. Personal fall arrest system Is a system used to stop a worker in a fall from a working level. It consists of an anchor point, connectors, and a body harness and may include a lanyard, deceleration device, lifeline, or suitable combinations of these. Personal fall restraint system A system used to prevent a worker from falling. The components are similar to a fall arrest system but include a shortened lanyard that prevents the worker from physically reaching an unprotected edge. Excavation Working next to an excavation is seen as working at height as a risk or falling into the excavated area is foreseeable and requires controls. What is required What you need to know! The aim is to provide procedures, controls and knowledge for those working at height and ensure company responsibilities are understood. The procedure also states requirements for third parties and general on site requirements. Within the telecoms industry there are a number of variations of working at height each differing in levels of control. CTIL do not conduct all types of working at height, however this procedure includes the governance for CTIL activities and areas of CTIL control. CTIL provide fall protection equipment (CTIL internal only) that is required for tasks identified by risk assessment or legislation. This equipment is selected and authorised through the HSQE Department. Equipment cannot be sourced without the HSQE Departments authorisation. Planning and acquiring of sites must consider the access and potential work at height controls necessary for safe maintaining and working onsite. All works must have an adequate risk assessment in place. Design must eliminate work at height risks at the source or control in conjunction with the planning of sites. GREEN DATA 2 of 11
CTIL will ensure: Information is available for employees to complete a suitable and sufficient risk assessment for all CTIL work at height activities A work at height procedure is in place and communicated Equipment is in place and tested in line with work at height regulations and replaced if required Internal training and general procedures exist to aid all in working at height. Those working for CTIL will: Comply with CTIL company health and safety documents Use all appropriate equipment supplied and ensure its replacement if required Complete and understand required training and all information provided before working at height commences Complete a risk assessment before accessing a site and before working at height. Work at Height Requirements A risk assessment must be carried out to ascertain the safest method of working at heights. Advanced Climbing Defined by climbing towers or steel structures on a regular basis as a routine element of an employee s job role. (Specifics defined in Responsibility What you must do! section). Advanced climbing competence will be required if access equipment is 5 metres or over in height. Rooftop Worker Defined by those who access flat rooftop areas that involves no climbing other than the possibility of an access ladder which must not be 5 metres or over in height. Working involving ladders and fixed/mobile scaffolds Scaffolds (including Mobile) Fixed scaffolds must only be installed by approved and competent contractors. All fixed scaffold must be inspected and a Scaff-tag attached indicating inspections and period. Where accessing a scaffold, the following inspection guidance must be completed and recorded on the structure by a competent person: Inspect before first use Inspect at intervals of no more than every 7 days and thereafter Inspect following any circumstances liable to jeopardise the safety of the installation e.g. high winds. Mobile Scaffolds Mobile scaffolds must have appropriate guard rails and must be inspected before use. All works should be assessed and completed in compliance with the Work at Height Regulations by competent persons. GREEN DATA 3 of 11
Fixed and Portable Ladders Fixed ladders must be reviewed, checked for inspections and risk assessed before access is attempted. The following points must be observed if using a fixed ladder: Fixed Ladders can be climbed to a height of 3 metres on completion of an onsite risk assessment to determine controls and level of fall protection, personal protective equipment is required regardless (see Equipment and Inspection Requirements section) Any access ladder over 3 metres (but below 5m) in height requires fall protection equipment to be used (Specifics defined in equipment and inspection requirements and roles and responsibilities) Any access ladder at 5 metres in height and above requires full fall protection equipment, RF NARDA alert, two persons and a rescue procedure/equipment to be at the vicinity Fixed and portable ladders must be inspected and tested by a competent person. A risk assessment and method statement is required for each element of work and equipment erection. Portable ladders are only to be used if it is not reasonably practicable to use a safer method of access. Working from a ladder can only take place for short durations, if this is not achievable podium steps are to be used. Ladders should be footed for stability. Mobile Elevated Work Platforms (MEWP) When working with MEWP s appropriate fall restraint and personal protective equipment is to be worn. Operatives and workers using the equipment must wear a certified fall arrest harness and attach within the basket itself to the appropriate attachment point. The equipment itself must be deemed fit for work through a 6 monthly inspection. All operators must be competent to use the equipment. All overhead work taking place must have appropriate signage and guarded demarcated drop zone below the work area, which can be achieved with physical barriers and appropriate signage. In some cases a banksman/spotter may be required. Assessment of overhead hazards must be made before any lift is to take place and must be considered at planning stages of site works. Fixed Safety Equipment Any fixed safety line, eye bolt or fall restraint or arrest equipment found on site must have an inspection record no longer than 6 monthly, this could be in the form of a tag. Systems that are not inspected or the inspection has expired, must not be used. In the case of non-usable fixed safety equipment, other climbing techniques can be used after completing a risk assessment. Guard railing should conform to building regulations. Guard rail should be in place up to 950mm (1100mm on new building) in height (with mid rail and toe board or parapet to leave no bigger gap than 450mm) to protect the building edges or parapets where a fall could occur which could cause significant harm. Working Adjacent to Excavations Any work taking place next to an excavation at ground level with the potential to fall into the excavation must be controlled under Work at Height Regulations; this may include exclusion distances from the excavation for removed soil and signing/guarding to protect open excavations. All controls to be risk assessed specifically for the work to be undertaken. Excavations are not to be entered. GREEN DATA 4 of 11
Rescue Planning Any activity at height that can potentially leave a person suspended must have a rescue plan in place. Any person that completes climbing activities must be accompanied by a trained rescuer and a plan of how the rescue will take place which must be communicated before climbing begins. The rescue plan must always be considered in the planning of work and assessed for adequacy. Training must be appropriate to the rescue equipment in use. Medicals and Health Due to the physical nature of climbing it is necessary to ensure climbers have completed an occupational health medical assessment. The below table indicates durations for climbers to complete health medicals. Age Climber Medicals < 40 Health Assessment every 3 years 41 49 Health Assessment every 2 years > 50 Health Assessment every year Employees who are absent from work through illness or injury, temporarily unfit to work at height for longer than the self-certification period is required to provide their line manager with a medical certificate signed by their GP. The GP should provide on the medical certificate a recommended date for return to work. Radio Frequency (RF) and Chimney Emissions RF radiation is present on most rooftops due to operator antennas and other sources of RF. Training must be received in regards to basic RF safety awareness and exclusion zones for any person climbing or entering a roof space. It is also important that operator shut down procedure is used when completing work activities where RF contact is foreseeable. It is essential to understand what chimneys and flues are emitting on the roofs to be accessed, this is especially vital if working on a hospital, academic research centre, residential property or any laboratory. This risk is to be captured as part of the planning of a site for acquisition and design. Equipment and Inspection Requirements All who work at height must have equipment to do so safely. The equipment levels vary for the type of work taking place. GREEN DATA 5 of 11
Rooftop and Minimum Site PPE Requirements If entering a rooftop with no risk presented from climbing or unprotected edges the basic personal protective equipment (PPE) is required: High Visibility Jacket/ Waist Coat/Weather Proofs It is recommended that any clothing used is of adequate strength and warmth as well as being waterproof for use in poor weather. The style and design of the clothing should meet the following criteria: It should not impede movement when worn; It should not be so loose as to act as a sail in windy conditions; It should not have any loose toggles, straps, buckles, or other parts that could become caught up; It should not compromise any other item of PPE worn with it. Safety Boots Any boot used for climbing should be well fitting with ankle protection, have a strengthened sole and a distinct heel. Reinforced toe protection boots should be to BS EN 344:92 standard. Hard Hat/Bump Cap (dynamic risk assess as needed) Head protection shall be either safety helmets to BS5240, with chinstrap, or climbers helmets to BS4423 or UIAA, and should be selected depending upon the environment where worn (i.e. protection against falling objects or against close impact on the structure). The following Personal Protective Equipment and Fall Protective Equipment requirements are an addition to the above: Access Ladders (over 3 metres but below 5m) and via elevating equipment and scaffold Full body harness Twin Tail Lanyards (1.75m) Climbing helmet (Chin Strap Required) Access Ladders (5 metres and Over) Two person site only Full body harness Twin Tail Lanyards (1.75m) Climbing helmet (Chin Strap Required) Rescue kit Purchasing of this equipment for CTIL internal persons is done through each department but only in conjunction with the HSQE department. No equipment is to be ordered without HSQE involvement. Fall Protection Inspection requirements GREEN DATA 6 of 11
Formal inspections are to be completed and records held. (For CTIL inspection, records are held by Specialist Company). Copies of the Summary of Examination Certificates are to be held by the employee who has been issued with the equipment. Inspection regimes are: Every time by user On first use of equipment Every six months (includes rescue kit) Items requiring inspection are: Harness Lanyards Helmets Rescue Kit Any further fall protection equipment e.g. Latchway device Any site requiring climbing must have a NARDA RF alert onsite. Rooftops must be assessed for dedicated safe walkways and risk information and a risk needs assessment must be completed for the use of an RF NARDA alert. This item must be calibrated within the past two years and switched on. CTIL personnel using the above equipment should be aware of inspection dates and report any lapses or issues to the CTIL HSQE Department. Training and Competence As a minimum work at height activities for rooftops requires the following training: Rooftop Access Course must be completed (every 3 years) RF Awareness Course must be completed (every 3 years) First Aid Emergency Course must be completed (every 3 years) This training is for CTIL lead activities Training for CTIL persons is supplied via Total Access Tel: 01785 850 333. Each department is to arrange the training themselves through their own budget. The CTIL HSQE Department will support if required. Any structure over 5 metres requires additional training: Advanced Climber course to be completed (Every 3 Years) Rescue Training course to be completed (Every 12 months) First Aid at Height course (Every 3 Years) Structures over 5 metres require additional training as mentioned above and additional safe systems of work e.g. rescue planning GREEN DATA 7 of 11
Responsibility What you must do! Managers/Supervisors Managers are responsible for employees and others (contractors etc.) working under their control. Whilst managers may delegate elements of this control activity, they retain the responsibility for managing the health and safety aspects of tasks under their control. Managers will: Provide adequate training to employees with designated roles Ensure all employed people are competent to complete activities Hold a competency list of trained staff and ensure certificates are on HR Octopus Consult with CTIL HSQE department if fall protection equipment is to be purchased in line with this procedure Ensure an adequate risk assessment and dynamic risk assessment is undertaken of the activities under their control and document the findings including rescue planning if required Ensure activities are risk assessed that are under their control and control measures implemented Ensure that all working at height equipment and PPE provided is suitable for the activity, the individual and the risks, and is fit for purpose for the work you manage Only authorise employees under their control to climb after they have successfully completed a medical health assessment (Climbers Only) and all appropriate training Ensure that people employed by CTIL complete any necessary refresher training and assessments Check that employees and contractors use the appropriate operator booking on system prior to accessing any cell sites Check that employees and contractors understand the RF exclusion zones when working or accessing close to antennas Ensure that employees undertaking working at height activities under their control are monitored to check working at height activities are carried out in a safe, professional manner and in accordance with this and other relevant procedures and best practice Ensure that employees have the knowledge to not pass across or work near fragile materials unless suitable precautions have been made to make them safe. Ensure that all Contractors used to carry out work at height are given a copy of relevant Standards/procedures and CTIL receive risk assessments and method statements CTIL HSQE Department The HSQE department will provide support and governance to achieve this procedure. HSQE Department will: Ensure that all managers have an understanding of the requirements of Law, Approved Codes of Practice and Guidance Notes. Ensure climbing equipment and Personal Protective Equipment (PPE) inspection methods are in place Supply assistance with departments purchasing PPE/Fall Protection Equipment Internal teams, suppliers and process are audited and inspected Review risk assessments and method statements as requested Review a climbers status, ensure the quarantine of climbing kit, and inform HR Department in the case of any failed medical or exam GREEN DATA 8 of 11
Investigate issues and incidents regarding work at height Ensure records are kept on HR Octopus. Human Resources (HR) HR are responsible for employees and others (contractors etc.) entering the business to ensure the correct selection process is completed in line with the job description. HR will: Ensure pre medical history questionnaire is requested when recruiting new climbers Ensure medicals are completed and records held whilst a climber is employed by CTIL Ensure the ability to work at heights during recruitment Hold competencies on HR Octopus system Validate that suitably competent employees are appointed. CTIL Employees/Contracted Personnel (Rooftop and Climbing) Employees and contracted persons have a duty to ensure they act responsibly for their own safety and that of others. Employees and Contracted staff Rooftop Workers Will: Complete Rooftop and RF awareness and other required training Obtain all rooftop safety information before accessing sites Complete a dynamic risk assessment before accessing the rooftop and share controls Carry out any necessary equipment checks and inspections within their capabilities, and record them as necessary; Carry out climbing and working at height activities in a safe, professional manner and in accordance with the standards detailed in this document and any other relevant procedures and legislation Not pass across or work near fragile materials unless suitable precautions have been made to make them safe Ensure fall protection equipment is tested within 12 months Undertake a visual check of any parapet, permanent guardrail or other fall protection measure prior to using them Not pass across or work near fragile materials and skylights unless suitable precautions have been made to make them safe Report all accidents and incidents, including possible exposures to RF to the CTIL HSQE Manager within 24hrs Ensure sufficient controls are in place for rooftops with un-protected edges Register and use operators access booking on system prior to accessing any cell Understand RF exclusion zones when working or accessing close to antennas Ensure sufficient controls are in place for rooftops with un-protected edges Assess risks from the emissions from flue s and chimneys Use calibrated NARDA RF Alert when climbing or based on risk basis GREEN DATA 9 of 11
Climbers and those accessing ladders over 5 metres will; Not endanger themselves or others Complete full climber training and refresher Complete tower rescue training (12 monthly) Not climb alone Check weather conditions Ensure they inspect climber equipment before usage Ensure that the rescue plan has been assessed before start of work Ensure the tower/ladder has a safe to climb certificate Ensure fall protection equipment is tested within 12 months Have a valid medical certificate Complete dynamic risk assessment Wear PPE/FPE as indicated by the risk assessment Sign and guard drop zones Use Narda alert for RF warning when close to antennas Suppliers and Facilities Management (Office-FM) All Suppliers carrying out work, or sub-contracting others to work on behalf of CTIL including those under FM within the office will: Ensure all work at height by contracted firms or under FM control is managed and carried out in accordance with the requirements of Law, Approved Codes of Practice (ACOP) and Guidance Notes Provide adequate safety documentation to ensure safe climbing practices which may be assessed against minimum standards in this document. Complete training and medicals and ensure all workers are competent Meet or exceed the requirements of this procedures and related procedures as well as your own Provide adequate safety documentation to ensure safe climbing practices which may be assessed against minimum standards in this document Report all accidents and incidents, including possible exposures to RF to the CTIL HSQE Manager within 24hrs Register and use the site booking on system prior to accessing any cell site Understand RF exclusion zones when working or accessing close to antennas Provide information to those under their direct control and ensure governance of suppliers you use Design effective arrangements to meet current legislation Ensure any works taking place within CTIL premises is controlled and all work at height risks are controlled and reduced to low levels Legal and Other Requirements (WAHR) Work at Height Regulations (HSG47) Excavating Guidance GREEN DATA 10 of 11
(INDG455) Safe Use of Ladders and Step Ladders (HSG150) Managing Construction (CDMR) Construction Design Management Regulations (RIDDOR) Reporting Injuries Diseases and Dangerous Regulation (CTIL HSQE FM37) Climbing Medical Questionnaire Document History Revision Date Revision Changes Made by Summary of Changes 12/08/14 0.1 Andrew Alexander Initial draft 18/08/14 1 Andrew Alexander Initial issue 15/09/14 2 Andrew Alexander Updated regulations 04/11/14 3 Andrew Alexander New CTIL format GREEN DATA 11 of 11