Installed Systems Documentation

a conversation around information:
manufacturer – installer / certifier – asset owner

Unfortunately it is common for those in the at height industry to face gaps in documentation. This may be where information has not been provided by the manufacturer of the fall protection system, not supplied by the installer / certifier or is even missing from the asset owners records.

Manufacturers may choose to only provide proprietary technical installation or inspection information to trained and approved installers as a means of ensuring the safe and auditable installation of their systems and as a means of maintaining quality. Using only “approved” design and installation partners ensures all personnel are trained correctly and also appropriate user training is included in the handover. This helps manufacturers cover their duty of care obligation to asset owners and end users alike. However, there may also be instances of a lack of disclosure being made for commercial gain, as a means of retaining continual work, for future re-certifications. This type of business practice is against the WAHA philosophy and does not serve the best interests of safety.

WAHA accepts that these decisions around disclosure are based on a variety of reasons, but there may be consequences for each of the stakeholders where:

a person is not certified to inspect or install certain manufacturers’ products leading to incorrect and/or unsafe installation and certification
the manufacturer or installer refuses to release information / documentation for the certification process to be undertaken
a client or asset owner wishes to use another business for other reasons

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At this point, an issue arises if the manufacturer or installer refuses to release information / documentation for the certification process to be undertaken.
If they do so, they may not be operating in accordance with the law.

The Workplace Health & Safety Act (NSW) 2011 (and its recent amendments) refers to the supply of safety systems under Section 25 – Duties of persons conducting businesses or undertakings that supply plant, substances or structures. A link to the full sub-section of the Act is here.

Specifically, the section of greatest interest is in Part 4:

The supplier must give adequate information to each person to whom the supplier supplies the plant, substance or structure concerning—

(a) each purpose for which the plant, substance or structure was designed or manufactured, and

(b) the results of any calculations, analysis, testing or examination referred to in subsection (3), including, in relation to a substance, any hazardous properties of the substance identified by testing, and

(c) any conditions necessary to ensure that the plant, substance or structure is without risks to health and safety when used for a purpose for which it was designed or manufactured or when carrying out any activity referred to in subsection (2) (a)–(e).

In essence, this section of the Act compels a manufacturer to supply information about the safety of a system installed to the end user. Failure to do so – or in fact a refusal to do so – may mean they are in breach of the law.

Ultimately, WAHA has no specific interest in the intellectual property secrets of different manufacturers nor do we engage in competition with installation / certification companies.

WAHA's primary interest is in the safety of all who undertake work at height: all the way from manufacturing, to the installer, the end-user and (often neglected) the asset owner.

When technical information such as technical notices or manufacturer’s instructions are supplied, it provides the end client with the evidence that their systems have been installed in accordance with the manufacturer’s instructions and that the systems are compliant.

This documentation should be accessible at all times by any contractors or employees that may have a need to access the subject fall protection system. It will also provide critical information about the timing for re-certification inspections, identified inherent hazards, and any other important considerations regarding system use.

It is important that a documentation handover is not just a process of sending the information in the mail or passing it over without explaining the contents to the relevant person/s to ensure they understand their obligations and know how it can be used to manage the safety of operators of the systems on their site.

The WAHAs 'Best Practice Standard'

of handover manual or system information pack will include, but not necessarily be limited to the following:

Conformance certificates - This might be in the form of individual certificates for each anchor or system, or a summary sheet detailing a site compliance certificate;

Conformance Report / Risk Assessment – Even though a safety system might be installed on a building, the means of access might not provide safe access across the entire site/structure as the frequency of access in some locations is may be infrequent/unnecessary. In these circumstances it is wise to provide a risk profile for these locations so operators understand the limitations of the current systems in place.

Forms / General Safety Information - Although not mandatory, the utilisation of a roof access permit system is something many companies choose to implement as a risk control measure. Samples of such documents can be a good starting point for entities wishing to pursue the use of such documentation.

Inspection Records / Register - These are the records of the initial and subsequent inspections completed by a competent person for the products installed on a structure. This history is an important record of ongoing compliance over time and provide evidence that the procedures for maintaining the safety systems is are in place and are effective.

Layout Plans/Details - This is a visual representation of the system layout on a typical roof / overhead structure across the site. These layouts should be of a size or resolution that can be read / zoomed out so that detail, position or reference numbers can be easily read. Scanned system design, e.g. “CAD” drawings, are often unreadable or with such poor resolution they are not tenable as a reference document.

Load Calculations documents - These are documents supplied by the manufacturer that provide summary model engineering calculations for the combination of components for the horizontal lifeline system specifically designed for the customers site. They provide evidence that the system loadings are within the correct tolerances for safely containing the applied ultimate loads to the structure in a fall event.

Manufacturer testing / certification document - These verify that the systems and anchors used on your specific roof structures and profiles have been tested by the manufacturer and have demonstrated conformance. These documents are essential and are a requirement of the Work Health and Safety Act 2011, clauses 22, 23, 24 & 25.

Personal Protective Equipment (PPE) – A listing of all items of PPE, including any special components required (E.g., lanyards, self-retracting lifelines, mobile traveling devices, slings, rope protection etc.) to use the system safely should be provided and explained.

Rescue – The intended (designed) rescue method should be detailed and all necessary rescue equipment identified.

Product brochures / user instruction manuals – Such documentation will be specific to the system installed on the site. These documents are generally provided by the manufacturer and provide useful/critical information about product use and limitation requirements.

Site / Product Photos – Although not mandatory, these images are a useful tool for Workplace Managers and system users to understand the nature of the products on the structure prior to gaining access to the structure.

Exclusion Zones – These should be identified as areas to avoid accessing, or that are inaccessible utilising the as-installed system. Many structures do not have a system for height safety access across the entire structure as there may be no foreseeable need to provide one. By identifying the exclusion zones, a the Workplace Manager and operator are better informed regarding the safe places to access and egress a the safety system.

Requirements for testing and re-certification inspections – Generally this procedure is done in Accordance with standard inspection timeframes (generally annually, however, items of PPE require inspection by a Competent Person at least 6 monthly). There may also be locations where the operating environment is harsh or extreme and therefore more frequent inspection may be required. These details should be noted in the handover manual. Note also that inspection requirements differ between jurisdictions, with some requiring 6 monthly inspections while others are 12 months. The documentation should be specific regarding inspection frequency, levels of inspection (including load testing where required).

Whilst the above information should be available in a hard copy hand-over folder/manual, some companies may also provide this information electronically, which can be a useful strategy to manage the loss and/or updating of this important documentation.

This also facilitates the sharing of this information amongst those who require access to it.

If you are having difficulty accessing the information you need you should ...

Seek to understand.

Continue to learn

As a professional membership organisation, WAHA is a centre for the working at heights, safety, engineering and design communities to come together to advance safety, increase knowledge and advocate for best practice in the discipline.

The WAHA would recommend that you seek additional information from clients or asset owners, and encourage workers and PCBUs to undertake training with the manufacturer, where reasonably practicable to do so.

In the pursuit of keeping worker knowledge up to date, the WAHA will always recommend undertaking additional training when available – regardless of how long a person(s) has been in industry – it is a way to ensure workers are refreshed and informed on new technology and equipment, changes to industry standards and any technical details of products.

Additional training may provide a cost effective solution to your concerns; as you would then be an authorised installer / certifier of their systems, and be able to provide continue services to existing and new clients who utilise those products; rather than quoting replacement systems.