In 2007/08, falls from height accounted for one in five recorded fatalities among employees and nearly half of deaths among the self-employed. Peter Bennett looks at two key issues in relation to working at height — training and competence — and unravels what they mean in practice for workers, supervisors and managers.
Regulation 5 of the Work at Height Regulations (WAHR) 2005 states: “Every employer shall ensure that no person engages in any activity, including organisation, planning and supervision, in relation to work at height, or work equipment for use in such work, unless he is competent to do so or, if being trained, is being supervised by a competent person.”
But, confusingly, there are various definitions of competence. Capability, ability, skill, fitness, aptitude, proficiency, and know-how: all of these descriptions fit most people’s understanding of the term in a work environment. In the context of this article, training could be best defined as the process of bringing a person to an agreed standard of competence by instruction and practice.
It would be reasonable to assume that competence and, by extension, the training to achieve competence, particularly in the field of working at height, would be universally acceptable and welcomed in the workplace, but, in reality, it depends on to whom you are speaking.
There is a suspicion among some sections of the workforce that this enthusiastic drive for competence is, at best, a posterior-covering exercise on the part of management, or, at worst, an effort to deflect responsibility, allowing blame to be attributed to the lowest echelon of the organisation.
In truth, it matters little what motivates organisations to aspire to achieve competence in their workforce, at any level, because the very existence of competence is empowering, if it is used and harnessed correctly. We may not always be in a position to significantly alter behaviour but, at the very least, we can be confident that a competent and therefore empowered workforce is, at least in theory, making an informed choice to make the right — or indeed, wrong — decision, with the benefit of knowledge of best practice.
Role-defining
Let’s just clarify who we’re talking about: anyone who actually assembles, operates, or installs work-at-height equipment would be an obvious candidate, and there are internationally recognised training schemes run by the various work-at-height industry bodies, relative to their particular specialisms, which most employers would demand as proof of competence.
While they need not necessarily be trained and competent to actually assemble, operate, or install the work-at-height equipment from which they work, operatives must nevertheless be competent to work at height. That is to say, they must be able to recognise good and bad practice and, when something is wrong, they must understand how serious it could be. They must know whether the fault can be corrected, and be able to make that correction or, alternatively, be sufficiently competent to recognise when work at height simply cannot continue in a safe fashion.
The other main protagonists in this chain of responsibility are, of course, management — those who plan, organise and supervise the work at height. They, too, are required to be competent and to demonstrate competence. Sadly, however, this is an area that is all-too often overlooked. Sure, the message has definitely hit home that those at the sharp end need to know exactly what they are doing when it comes to working at height, but it is taking rather longer for the message to get through to those who control such activities. Not only do managers need to be right up to speed on the latest best practice methods but, more importantly, they need to set high standards of good practice and, in the course of their supervisory role, recognise and put a swift stop to any bad practice they encounter. This is, of course, quite difficult if they themselves are not trained and competent to be able to tell the difference.
Trainees
Another question is whether there is ever a justification for anyone to work at height who is not competent. I believe there is, but only if they are being trained, and only then if they are under the supervision of a competent person.
Despite what some may believe, this does not give you ‘carte blanche’ to simply train one member of your team to establish their competence, and for that person to then take on the role of supervising others who are undergoing training. In this sense, the competence refers to the dual requirement of competence to work at height and competence to train others.
Referring to my previous definitions, this requires that the person is capable of “bringing the trainee through the process to an agreed standard of competence”, ensuring that no important points are omitted, that the trainee is not exposed to unnecessary risk, and that the achievement of the agreed standard can be demonstrated objectively.
Achieving competence
Many organisations will agree with the principles outlined as perfectly sensible but, nonetheless, will still be confused as to what this all means in the real world, and how they will be able to satisfy this elusive requirement for competence.
In the construction industry, to a large extent, this has been addressed by the Construction (Design & Management) Regulations 2007 and their supporting Approved Code of Practice, ‘Managing health and safety in construction’ (L144). The latter sets out how to assess and determine competence against agreed core criteria and, reassuringly, further states: “If your judgement is reasonable, and clearly based on the evidence you have asked for and been provided with, you will not be criticised if the company [or person] you appoint subsequently proves not to be competent when carrying out the work.”
To expand on this idea, let’s consider the Work at Height Awareness Syllabus, which was issued in April 2006 by the Advisory Committee for Work at Height Training. The ACWAHT was established by the HSE and comprises the principal organisations and industry bodies involved in work-at-height activity. The syllabus gives us the following definition in respect of a competent person: “A competent person is a person who can demonstrate that they have sufficient professional or technical training, knowledge, actual experience and authority [i.e. authority delegated to the individual by his employer to carry out a certain function or duty] to enable them to:
Summary
So, what does this actually mean to those involved in working at height? If we are to achieve widespread competence — and bear in mind, we’re only talking about competence, not excellence — we need to recognise that need for training at all levels of the organisation, not just at the sharp end.
For employers, that also means recognising that in order for employees to exercise their competence, they must have the authority to delay, or even stop, work at height, if they have genuine and well-founded concerns.
For employees, that also means recognising that theirs is to reason why — they have a responsibility not to work at height if they believe that the work method or equipment is unsafe.
For the self-employed, they have the special duty to manage and control themselves, ensuring that they balance the unfettered authority they have to decide what they are going to do against the need to always be vigilant and circumspect, particularly where working at height is concerned.
There is no doubt that training is an essential element of establishing competence to work at height, but it is only one element. Unless it is combined with actual experience, underpinning knowledge, and the delegated authority to make a difference, it’s not worth the certificate on which it is written.
Reference
1 HSC (2008): Statistics of workplace fatalities and injuries, falls from height, 2007-08
Peter Bennett is managing director of PASMA.
The Safety Conversation with SHP (previously the Safety and Health Podcast) aims to bring you the latest news, insights and legislation updates in the form of interviews, discussions and panel debates from leading figures within the profession.
Find us on Apple Podcasts, Spotify and Google Podcasts, subscribe and join the conversation today!
The attached document is worth reading and may offer a bit of insight before tomorrows call. From what I gather from reading, the UK is the same as the US in that we need to have Competent people and who identifies their competency is up to the employer.