Article by Michael Biddle
I am often asked by asset owners how they can assure that the contractors they engage for working at height on their building and structures are up to the task. It’s not always an easy question to answer, as the reality is that there are many factors that determine a person’s competency.
There is a natural deferral point to this question – if the person holds a ‘Work Safety at Heights’ qualification with a Nationally recognised competency from a Registered Training Organisation (RTO), then surely this is the simple answer? In truth, it is only part of the answer to the question, and in many respects it might be that whilst people naturally defer to this answer, they may be ignoring the deeper risk in making decisions like this without considering all the key issues.
I have detailed below a summary of a number of key questions to consider when making a full assessment on whether to engage a contractor for working at height tasks or not and assess whether you’re placing yourself or your company at risk by using that person to perform tasks whilst working at height.
- Understand the tasks to be completed for the specific site / location – one of the first things to understand are the core tasks to actually be completed at height. Is there a possibility that these tasks can be done without having to work at height? Are there equipment or access methodologies to use that prevent the person from placing themselves at the risk of a fall in the first place? Ask your contractor to offer solutions or prescribe these methods before commencing work. That way you can assess if their proposed methods are valid / lowest risk.
- Are suitable documentation and procedures in existence to support the work to be carried out? – Can the contractor provide you with a suitable risk assessment of the individual site conditions that might be encountered during their work? What methods of access are they proposing and control measures will they implement to mitigate the risks? Typically the provision of well-documented Safe Work Method Statements (SWMS) incorporating methods of risk mitigation including rescue will be important to see. They should also detail the types of equipment to be used to perform the tasks and how and why these methods are used to mitigate the risks identified during the risk assessment process.
- Are they both theory and practicality qualified to perform the work at height? – A qualification is one thing, however with the current vocational training system in place, an RTO can deliver a ‘Safe Work at Heights’ qualification in alignment with the requirements of a Nationally recognised competency, however they do not need to prove their course is delivering safety of students.
The RTO system does provide adequate and relevant frameworks for the delivery of consistent training, however it does not participate in the quality control of the training itself. Once issued, a qualification does not expire. Technically therefore you could have successfully completed a course 10 years ago, however not be obliged to re-train or refresh your skills to gain a re-certification of your qualifications.
Additionally, quality training providers will also be able to demonstrate that their students have undertaken a practical assessment of a person’s ability to use height safety equipment and work safely. The qualifications for competent operators will also likely reflect training in rescue techniques, the deployment of temporary access systems and using ladder climbing techniques such as using twin lanyards, rope adjustment and diversion anchors. Vendors issuing these qualifications that do not provide practical training are not fully executing on their duty of care to their students. If you can imagine a person undertaking an online course or half day course on working at heights might be issued the same qualification as someone with the same competency issued for a 1-2 day course. There is therefore going to be a major inconsistency between the standard of both courses.
One of the best examples to illustrate why this is important is someone achieving their drivers license. You are obliged to study content and then sit a theory exam before you can then undertake a practical test of your skills to follow the road rules and perform the safe operation of a vehicle. These conditions are mandatory for all drivers, and yet are not mandatory for people working at height. So therefore the need to assess the merits of a qualification are the responsibility of the asset owner/their representative, in the absence of a formal / mandatory assessment process.
This issue is one of the greatest faults of height safety training in the VET system, as in my view as it gives both holders of the qualifications and the customers/companies they serve a false sense of security. To mitigate this risk, review the list of WAHA endorsed training providers and request other leading providers of training to provide evidence that they conduct/recommend refresher training at least every 2 years to overcome this area of concern.
- Does the person have previous experience in performing the specific work required to a high standard? – Experience is always a useful indicator of competency, but again, it’s only a part of the equation. Just because you have been doing a task for 5 years – perhaps you have been taking unnecessary risks in the way you’re performing those tasks and you’ve just been lucky that something serious hasn’t happened. Therefore do not rely solely on experience to make your decision.
- Does the company /operator promote the use of two-person teams when working remotely and at height or are they relying on someone using their mobile phone to call for help? – There are a significant number of companies that do not engage teams of two people to perform inspections at locations. Their belief and explanation is always – ‘if there is an incident, the operator can simply make a call for help from their mobile phone’.
What happens if the person has a heart attack and cannot move? What happens if the person falls over an edge and is injured in the process or drops their phone? How will a rescue be performed on that person if they are seriously injured and no-one knows of their injury for several hours? The use of single operators for inspection work may well be deemed appropriate if the inspection task can be done without other risks however you should be encouraged to contemplate this seriously in your decision making process before relying on a single-person operator or inspector to perform such tasks.
This list of areas for review is of course not exhaustive however it should provide adequate guidance for most decision making to assess a person / company’s ability to complete work at height. So I can only encourage you to look ‘beyond the ticket’ as a sign of capability to reduce your risk when choosing a company/person to perform work at height.
Michael Biddle has been the Chairman of the Working at Height Association (WAHA) for over 10 years, and has over 17 years experience in the height safety industry as a manufacturer, RTO Manager and Director of a height safety installation and distribution business.