Working at Height and the Latest Legislation - Latchways plc - an MSA Brand
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Welcome to MSA's work at height CPD.
This seminar covers full protection systems for working at height from a legislative viewpoint. We will ensure you understand specification and installation obligations and liabilities. Plus how to avoid some common misunderstandings which could impact safety. The primary focus is rooftop horizontal fall protection.
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About MSA Safety and Fall Protection
In this first section we will tell you a little bit about MSA safety and introduce you to our team.
MSA safety is a global leader in the development manufacture and supply of safety products that protect people and facility infrastructures, with over 100 years of proven heritage. Our global HQ is based in cranberry Township near Pittsburgh with annual sales of approximately 1.2 billion dollars and manufacturing operations in the United States, Europe, Asia and Latin America. We are backed by R&D facilities in three continents. Our goal is to provide safety solutions that mean workers can go home safely to their families at the end of each day. Our comprehensive line of products is used by workers around the world in a broad range of industries, including the fire service the oil gas and petrochemical industry, construction, mining and utilities. Specialists in fall protection.
MSA's Latchways Systems
MSA acquired the Latchways brand in 2015 establishing its fall protection centre of excellence in the UK. The Latchways brand has always been a recognised leader in full protection and the origins of the product range go back to 1974, where the Latchways founder Commander Tupper developed the trans fastener, a product that allowed yacht cruise to walk around the boat whilst permanently attached to a fixed cable. The system was quickly adapted for use in the industrial sector as a complete hands free fall protection solution. It was designed to work on buildings, inclines, vertically around bends and corners.
In 2001 the Latchways constant force post was launched, revolutionising the installation of roof mounted systems. The unique constant force technology was also incorporated into horizontal, vertical, inclined and overhead cable lifelines. This is still virtually the only roof anchor system that support the warranty across multiple leading roofing manufacturers. Hence why MSA and Latchways fall protection solutions are specified and installed across the world.
MSA Specialist Fall Protection Team - UK
With MSA you get a team of people dedicated to understanding your fall protection needs we know the legislation you should adhere to. We understand full protection systems and we are a team of true engineers. We can provide the full spectrum of support you need from specification to installation.
Legislation - Working at Height Regulations
Here we will look at legislative considerations for specifiers and what liabilities you may face if different products are used for a specification that haven't been tested to the same standard. Legislation is there to save lives. The importance of working at height legislation cannot be underestimated with falls from height still one of the largest causes of workplace deaths and life limited injury. You play a vital role in helping eliminate that through better design safety measures and implementing to specification, both on new projects and retrofits.
First published in April 2005 and updated in 2007 the work at height regulations bring together the current legislation surrounding working at height, i.e. construction regulations, workplace regulations and CDM regulations. They form a group of goalsetting regulations which are flexible enough to apply to all industries. They also implement the European community temporary work at height directive. As professionals you must understand the work at height regulations. It is important that as designers you ensure that you take up your responsibilities during the project design stage, and to facilitate continued safe access on buildings throughout their lifetimes. This also includes providing method statements detailing how the provision of safe access will be achieved.
CDM 2015 and Fall Protection
Obviously, we are all aware that the CDM construction design and management regulations, were updated in 2015 in a way that made roles and responsibilities little clearer for fall protection.
Key points for working at height are:
- You must document in the health and safety plan your fall protection strategy for managing all hazards and risks throughout the whole design phase, through to occupation of the building, and then supporting any ongoing work such as building maintenance and cleaning.
- Clarity on who is responsible for life the principle designer is responsible not the CDM coordinator, and if there are multiple contractors one principle designer and one principle contractor must be nominated.
Beware of assumptions that can put live at risk
There are some additional CDM considerations for fall protection which principle designers must consider to be confident. Currently standards only require fall protection anchors to be tested on concrete roofs but there are so many different roofing structures and materials, take secret fix, roofs standing seam roofs, and warm flat roofs for example, the anchor will perform differently on different materials when forces are exerted.
Check that the system you use has been tested in the way you need.
Many contractors substitute like for like but need to recheck the suitability for use on a specific roofing system. This is one of the main reasons it is important that a manufacturer tests, on every type of roof type in their system will be fitted to. If the equipment you have specified is changed without your knowledge you could be held legally liable in the unfortunate event of an accident.
Energy absorption technology
Energy absorption technology means that in the event of a fall systems deploy in a controlled manner to absorb the force generated, in doing so it ensures that the load exerted on the point of attachment will not exceed 10K newtons and so allows the post to be fixed to a relatively delicate structure, without the additional requirement to attach to structural steel or purlins. This ensures the roof or structure remains intact and workers are kept safe even in the event of a fall.
System Choice and Design
Next let's have a look at system choice and design. What are the options available to you?
The Hierarchy of Fall Protection
The hierarchy of fall protection helps you structure your planning from the outset. The hierarchy is wherever possible firstly eliminate the risk. Next when you cannot eliminate then guard the hazard, and finally protect the worker.
The fall protection solution specified should be based upon the area requiring access, the frequency of access required, the number of people needing access to the area, and the level of training that these people will undertake. For instance we can choose both collective and personal safety measures to prevent a fall. Similarly we can implement personal safety measures that can reduce the consequence of a fall.
Let's look at system choices collective protection is any system that allows numerous untrained users to access an area, whilst being protected from all fall hazards, without the need for personal protective equipment such as harnesses and lanyards.
Once properly installed or erected collective protection does not require any action by workers or specialist training to keep workers safe. There are a number of detailed criteria to be taken into account for collective protection and it's important to ensure requirements have been fully considered and thought through.
Personal Protection Systems
Personal protection systems safeguard individual users from risks associated with working at height, and are often specified when a collective system is not necessary or possible. There are two categories of personal protection systems, fall arrest and fall restraint. Often the generic term fall arrest system is used for both types but there are critical differences to understand between them.
Fall restraint system
The safest version of a personal protection system is a fall restraint system where each worker was a full body harness and lanyard connecting them to a lifeline system, which is anchored to the building or structure. The lanyard length is fixed so that the worker cannot reach any fall hazard with no need for lanyard adjustment only basic training is required. A fall restraint system should always be designed to be used with a fixed 1.8 metre long lanyard keeping users from accessing any fall hazards and should always accommodate two people as a minimum to ensure safe working practices are adhered to.
Fall Arrest System
In some instances it is impractical or impossible to design a fall restraint system and there are fall hazards which cannot be illuminated or avoided, such as roof lights. These cannot always be guaranteed to be safe to walk on.
In situations like this a fall arrest system is required. This means that fall hazards can be reached by a worker on a fixed or variable length lanyard when they are secured to a lifeline system. A fall arrest system must have restricted access and personnel using these systems, must have undergone specialist training to safely secure and adjust their personal protective equipment PPE. For example some routes may require the use of two lanyards to safely navigate into areas requiring access. Like the fall restraint systems of fall arrest system must be designed to accommodate a minimum of two workers as there is an additional requirement for a rescue plan to be in place should have fall occur, and a user be suspended in their harness.
Let's look at the differences in system designs.
In rooftop applications generally a designer must select a perimeter or Ridge system. The first system shown here is a perimeter system with which the user connects immediately to the roof access location and has full movement around the roof perimeter, whilst remaining in fall restraint at all times.
The second option shown is a Ridge system which also uses additional single point anchor posts to allow access to the roof corners. This type of system requires a comprehensive level of user training to ensure that adjustable personal protective equipment is used in the correct way. In both instances but particularly with the Ridge system, the designer must check that the system specified has been tested and approved to be a fall arrest system.
System Teting and Standards
Let's now go on to understand more about the test standards for fall protection systems. We’ll explain what testing is covered and where specifiers need to be cautious in terms of testing so that they can make the right system choice.
EN 795 is the standard which specifies testing for anchor devices single point anchors within personal fall protection systems. The EN 795:997 standard was replaced in 2012 but why? The standard remained the same in terms of covering single point anchors and there are five different types of anchors which you can get, types A, B, C, D & E.
For example an anchor resin bonded into concrete is a type A anchor. When we talk about a cable lifeline, we're referring to a type C anchor. The type of anchor being used will depend on the type of application.
CEN TS 16415:2013
The test mass in both the 1997 and 2012 standard was 100 kilograms, representing one person working with tools. However remember that it is best practice to always have more than one user on a personal fall protection system, to avoid lone working and for additional safety and rescue potential. So under EN 795:2012 you must adhere to CEN TS 16415:2013 which provides you the architect with knowledge that a manufacturer has tested their system for multiple users to be connected at one time and on a specific base material, i.e. roofing structure. For example if you are designing a system for two people on a standing seam roof then the test mass would be 200 kilograms.
System tsting and Standards - EN 795:2012
As a specifier you cannot assume that a 1997 tested system, will be capable of withstanding two people falling on it. If it isn't then it will fall short of today's standards. The 1997 standard didn't adequately cover restraint systems, the 2012 standard specifically covers restraint systems and possible misuse. For example, if the incorrect lanyard length is used and so a fall hazard then becomes accessible.
Consequently a 2012 tested system must suit fall arrest load two. When you read that a product is tested to the current standard do not assume that it means the 2012 standard and that it has passed the test for multiple users for the specific type of anchor, type C for a cable system and also the type of roof structure that you are specifying.
Leave nothing to chance.
There will be a huge difference in the ability for a type A anchor fixed onto a concrete base material to withstand a load compared to a type C system installed on a metal profiled roof. Remember it is your responsibility through the work at height regulations, that what you specify is fit for purpose. Look for evidence and proof the system is undergone and passed EN 795:2012 testing. That the system has undergone multiuser testing for cable based systems. And that there is evidence of an independent test report called a declaration of conformity, stating the product has successfully undergone testing on that particular base material.
Always question whether you would knowingly specify a life safety product such as fall protection which had not undergone and passed appropriate testing according to the latest standard. Different manufacturers test to different levels look for one which goes above and beyond the standards 1 terms of testing.
System Guarantees and Assurances
So how can you be sure the fall protection system is guaranteed for the application structure? When it comes to particular manufacturers roof systems an non-approved for protection solution installed on the roof, could invalidate the roof warranty, ensure that when a certain roof system is specified check with that roof manufacturer if there is a particular fall protection system that they have forming part of their guarantee. It's worth remembering this when considering any future roof issues. If a non-approved fall protection system had been installed it may well invalidate the roof warranty or guarantee.
System Testing and Standards - EN 13374 and EN 14122-3
You should also be aware of these additional test standards EN13374:2004 and EN14122.3 which are particularly relevant when specifying collective protection such as guard rail. Again you need to go through the same due diligence process when looking at temporary edge protection during construction as you would for permanent edge protection for ongoing building access.
A collective protection system must have successfully undergone the relevant testing depending on the application which you intended to be used. It must also have a valid declaration of conformity available.
Considerations for System Choice
EN795:2012 is the current test standard for personal fall protection systems. You have to be aware of the huge amount of energy that is created when a fall is halted or arrested by a fall protection system. Generally a new roof construction may only be capable of withstanding somewhere around 25K newtons or approximately 2 1/2 tons of force and so a fall protection manufacturer must look to reduce the loads going back to the roof structure to way below these figures.
Load Absorption Strategy
Energy absorption technology, within a fall protection roofing anchor, reduces the possible load back to the roof to 10K newtons and even with a factor of safety of 2 resulting in 20 kilo newtons, this is still easily below the failure point of a new roof construction. If a fall protection product is not tested for its load absorption capacity, huge forces can be applied to a roof construction in the event of a fall, this may result in the roof failing or coming apart in some way.
We've already gone through representative roof testing as part of CEN TS 16415 and also the importance of checking for roofing manufacturer approval. Also ensure that the product you are specifying works in any direction as realistically there is no way of foreseeing which way a fall might occur on a system.
Remember to check that the system will work for the intended number of users, for its anticipated use and also as good practice for avoiding lone working.
All EN 795:2012 tested products should carry clear product markings according to EN365. This ensures that the post clearly displays the manufacturer details and what standard the product has been tested to. It's good practice for a safety product to be made from quality materials to ensure durability.
This video shows you how forces are absorbed by energy absorption technology versus rigid anchors.
Other Considerations - Materials, Walkways, Ladders and Window Maintenance
This final section will run through a series of other working at height considerations from material and walkways to ladders and window maintenance. Roofing systems must often provide maintenance access to a wide variety of equipment. This image represents just some of the scenarios in which fall protection is required, window cleaning, plant maintenance and solar PV maintenance are just some of the working at height challenges that leading fall protection manufacturers can safely overcome.
Walkways provide a level anti slip surface and a demarcation route to guide a worker’s safe movement in areas where there are potential fall hazards. Any walkway product you specify should have BBA certification comply with the roofing manufacturer recommendations, be fire resistant and self-extinguishing, be tested for UV exposure, have undergone impact and fragility testing and be corrosion and moisture resistant.
Fall Proof Covers
A fragile roof needs protection if access is required fall proof covers or roof light covers will help ensure that fall hazards are guarded. Both fall proof covers and roof light covers can be used adjacent to walkways on flat or pitched fragile roofs and could work independently of or in conjunction with cable based fall protection solutions.
Many rooftops are accessed using a fixed ladder this can create further fall risks. The health and safety executive confirms that ladder hoops offer no positive means of fall protection in fact they can be harmful should someone fall and strike the hoops. The preferred industry option is central rung mounted cable lifeline system, whether installed onto an internal or external ladder, workers have the flexibility to use both hands to climb, whilst remaining safely attached. Unlike hoop systems cable lifeline systems present no obstructions that could cause serious injury, while arresting fall.
Self-Retracting Lifelines (SRL)
For fall protection in larger interior spaces such as factories and railcar loading bays, self-retracting lifelines SRLs can connect to an overhead lifeline cable, automatically extending and retracting they offer non-intrusive protection SRLs remained tort don't impede movement and keep hands free to work.
In certain building designs access from inside is needed to carry out external work. For instance external window cleaning and maintenance, legislation for this sits within the CDM regulations 2015 I bolts are commonly used both bolts and fixings need to be able to withstand the loads generated when a fall is arrested. For correct performance installation must comply with BS7883:2005.
Regulation 4 of the work at height regulations states, that every employer must ensure that work at height is properly planned and that planning of work includes planning for emergencies and rescue. Employers must have a specific and planned rescue method. The use of emergency services is not an option there is a legal obligation to ensure any casualty is attended to and recovered quickly. An award winning product the MSA Latchways personal rescue device PRD, incorporates a personal dissent device. In the event of a fall the harness will not only arrest a fall but allows a worker to initiate their own rescue.
Pulling a parachute style release cored lowers them up to 20 metres to the ground gently in less than 30 seconds, even if suspended and unconscious a colleague can safely activate the release with a specially designed poll using the secondary dissent mechanism.
MSAs Latchways PRD is simple, there are no complex costly training courses needed. Efficient no supervision or rescue team needs to be on standby. Productive an instant self-rescue minimises disruption and downtime. And safer as no rescuer is needed, It means there is no risk to anyone else.
Thank you for your time. Having gone through this seminar:
- You should now be able to appreciate how legislation attributes responsibilities for the provision of safe access.
- You should be aware of elements you need to consider when choosing and specifying a fall protection system and the ways it can be integrated within the building design to be compliant.
- You will be able to identify the difference between collective and individual protection between fall arrest and fall restraint.
- You will be able to specify the correct system based on the varying competency levels of individuals using the different systems and be able to demonstrate that a system is fit for purpose.
- You're now aware of the major changes to testing standards for fall protection equipment and their impact on choosing products.
- You've seen how solutions can help with challenges like maintenance and rescue.
If you have any queries leading fall protection manufacturers can help you with the design of your full protection system.
We hope we have given you a useful and practical insight into the main considerations when it comes to working at height. From choosing the right equipment to ensuring it meets regulations, the message is simple we all have a responsibility to do our best in enabling people to go home safely to their families at the end of each working day.