Close to the edge
Louise Hosking explains why flat roofs can sometimes be more hazardous than their pitched counterparts.
Article first appeared in December 2015 issue of IIRSM Newsletter. Reproduced with the permission of IIRSM. Click here to Read Full Article)
As specialists in managing safety in the property and schools sectors, we regularly find that clients struggle with managing risks associated with access to their flat roofs.
Many schools, in particular, have vast expanses of flat roofing and in the majority of cases there is likely to be little or no edge protection. Skylights may have been installed, and additional plant or equipment added over the years, which complicates access to equipment requiring regular maintenance such as condenser units, air handling equipment or water storage tanks.
Site agents working for schools will regularly access roofs to deal with an array of objects which mysteriously find their way onto flat roofs such as gym kit, or tennis balls which fit neatly into down pipes – blocking drains which then require emergency attention.
Access arrangements can involve the use of a dubious ladder over a stairwell. Or, where access has been considered, ladders and hatches are positioned close to an unprotected drop.
As long serving members of staff, site agents do not consider the risk to themselves – even when external contractors have refused to undertake work close to unprotected edges. Combined with typical trip hazards such as cables to aerials, vents and uneven roof surfaces, the flat roof becomes a hazardous place to be particularly when surfaces are wet or flooded.
Falls from height remain the most common cause of fatal injuries in the UK, accounting for nearly a third of all fatal injuries to workers. [i] There have been a number of cases where schools or local councils have been prosecuted following falls from flat roofs.
In 2008, Head Teacher John Summerfield famously took a group of students onto the flat roof of their school in Liverpool. One of the students fell through a skylight suffering major injuries. Mr Summerfield was personally fined £20,000 + £15,000 costs.[ii] More recently, a site agent suffered broken bones after falling 1.9m whilst undertaking high level repairs, and his Essex school was fined £6,500 + almost £2,500 in costs. [iii] In other industries, roof repairs have resulted in life changing injuries, fatalities, and significant fines.
It is simply not practical or necessary to provide edge protection around some of the vast expanses of flat roof that many schools and businesses have. Conversely, schools cannot rely purely on safety lines and the use of harness systems (which should be considered a last resort solution.)
In the first instance, schools should consider their flat roof and examine why, when, and how often access is required. As schools have a duty to also protect non-employees, the work undertaken by maintenance contractors (as well as school staff) should also be considered. Risk assessments should then be undertaken to determine how best to manage risks.
In deciding whether a control is reasonably practicable, frequency of access and duration of work must be considered. For example, an engineer undertaking maintenance work on roof top plant, close to the edge, is likely to be in this location for much longer than a few minutes. Edge protection should therefore be provided in this work area.
Conversely, if access only is required more than 2m from the edge, a simple demarcation barrier indicating the safe walk way will be all that is required.
The Hierarchy of Risk Control should always be considered [iv]
- Eliminate the Hazard – Look for alternative ways to undertake work without having to physically step onto the roof. For example, fit guards over down pipes to prevent them being blocked, and manage trees nearby which could block drainage channels. Generally, access to the flat roof should be restricted with strict key control systems in place to ensure only individuals with the competency to do so are allowed to access these locations. Access in inclement weather should also be avoided.
- Substitution – Look for an alternative way to undertake the work which will be safer. For example, the use of mobile access equipment operated by a trained, well supervised person will be a safer way to clear a roof edge gutter than sweeping it clear from the edge of an unprotected roof.
- Engineering Controls – Isolation of the worker from harm via the use of barriers. In some instances, physical barriers will be required. Where access hatches or regularly used walkways are adjacent to the edge, there is a greater risk of a trip leading to a fall in this location. All skylights should be considered as fragile unless a competent person has confirmed otherwise (e.g. manuafacturer, installer, designer.) Skylights should almost always be protected by a grill, or separated from work locations by edge protection. In themselves, they can be a trip hazard. The perception is they are not necessarily a fragile surface, and nothing further is required. Signage warning of the hazard will not be sufficient in isolation.
- Good Housekeeping – Many falls from height occur due to slips, trips and falls whilst working. Uneven, slippery surfaces and low level obstacles such as cables, wires or work tools all increase the risk of falling. Risks associated with a simple trip on a flat roof is potentially far more serious. A tidy work ethic, and non-slip walkways, will therefore be required.
- Safe Systems of Work – These are arrangements, procedures or instructions in place to agree how work will be undertaken safely. Safe Systems will normally be determined via the risk assessment process, and from this a method statement is created which will determine the safe sequence of work and exactly how it will be undertaken. If work is being undertaken by a contractor, there is a joint obligation on both the client and the contractor to ensure the work can be undertaken safely. Risk & Method Statements (RAMs) should therefore be exchanged and agreed
- Information, Instruction and Training – Long serving site agents may have been undertaking their duties in a similar manner for a number of years. They will not necessarily perceive the risks associated with their work, so practical on-the-job training (delivered in a manner which they can relate to) is imperative both in relation to how they undertake their work safely, and also in regard to safe systems which have been created for them. Anyone involved in managing work, such as the school premises manager or business manager, should similarly understand how to assess risks and evaluate RAMs which may have been issued by contractors.
- PPE – The use of personal protective equipment should be considered as a last resort control. Fall restriction devices prevent the user reaching a fall hazard (e.g. edge) as opposed to a personal fall arrest system which will prevent the user from reaching the ground in the event of a fall. In respect of the latter, arrangements must also be in place to rescue if required. It only takes 20 minutes for a worker hanging from such a line to suffer from suspension trauma[v] which can lead to death. Subsequently, the installation and use of such systems should only be considered as a last resort where access to a specific location is infrequent and tasks required are short duration measured in minutes. Or, where other measures cannot be taken.
- Monitoring & Supervision – Once arrangements are agreed and in place, managers and supervisors must ensure safe systems of work are being followed. Working practices should be spot checked and steps taken if safe systems are not being followed.
- Review – A higher level management review of all roof safety arrangements should be undertaken at least annually, or when circumstances change, whichever is sooner.
Designers have duties under Construction (Design & Management) Regulations 2007 to consider work on roofs when they are developing new buildings, or installing new equipment. However, clients are ultimately responsible for this, and should question how decisions are being made on their behalf to avoid expensive alterations later on when it is realized certain activities can not be undertaken safely.
*Louise Hosking MCIEH CMIOSH RMaPS AIEMA SIIRSM is a Chartered Safety & Health Practitioner and Director at Hosking Associates Ltd.
Article first appeared in December 2015 issue of IIRSM Newsletter. Reproduced with the permission of IIRSM.