I stand corrected, Welcome to the forum UBA1
The consultation on the Temporary Work at Height Directive ended in April of this year, but you can read the proposed regualtions at the HSE's website here:
http://www.hse.gov.uk/consult/condocs/cd192.pdf It is a large file, 166 pages long so it takes time to load.
"Work at height" involves so many different situations within dozens of different trades and industries, they cant very well spell out exactly what you can and can't do. All they can do is to lay down principles for us to follow. If a HSE inspector thinks we have not appropriately applied the principles, they have statutory power to stop us.
Here is an example:
One principle that the regulations state is that if a task can be done without working at height then it should be:
HSC Proposals for Work at Height Regulations, page 35, paragraph 26(1) Every employer shall insure that work is not carried out at height where it is reasonably practicable to carry out the work safely otherwise than at height.
Now, can window cleaning be done without working at height? Yes and No.
Yes IF :
you have a pole system
The building is not too high
The building doesnt have unusual features that make it impossible like wide window sills or sun blades
No IF:
It is a skyscraper
You dont have a pole system
Any other reason that makes the use of a pole system impractical.
Each situation is different, and a measure of judgement is involved.
Is the fact you dont have a pole system a good enough reason? Maybe, maybe not, it depends on your point of view.
My own personal opinion is that as the guidance note to this regulation says...
Page 68, paragraph 33Pole-cleaning systems may be used for cleaning windows so that the work can be carried out from the ground.
...that they'll probably take the view that if it could be done with a pole system, it should be, and "I dont have one" is not really an excuse. But thats just my opinion.
It seems to me that the purpose of this document is to move us away from working at height where it can be avoided, as this is responsible for many deaths and accidents.
And, to be honest, I think thats a good thing. Anything that makes our industry safer should be promoted and welcomed.
Note: There will be a seminar on this very subject (as well as other intersting ones) at the Windex show on the 8-9 October in London:
http://www.windex.co.ukMy advice is to go, and there will also be a chance to see a range of WFP systems too as most of the major manufacturers will be exhibiting.
-Philip
