Last reviewed 24 October 2017
Mike Sopp looks at the importance of adequate assessment, planning and competency, when undertaking any work on a roof, with reference to the Work at Height Regulations 2005.
According to the Health and Safety Executive (HSE) “all work on roofs is highly dangerous, even if a job only takes a few minutes”.
The main causes of death and injury are falling from roof edges or openings, through fragile roofs and through fragile rooflights.
The HSE website details numerous prosecutions, many of which indicate that the main causes of accidents involving falls from roofs are a lack of adequate planning by those responsible for the roof work.
The need for planning
Working on roofs can be undertaken for various reasons from initial construction through to maintenance, cleaning, repairs and refurbishments.
Accident statistics from the HSE indicate that falls from height at work are the biggest single cause of workplace fatalities and the second biggest cause of major injuries.
Under the Work at Height Regulations 2005, employers are required to apply a hierarchy whereby work at height should be avoided if reasonably practicable to do so. Where this is not practicable, measures must then be taken to prevent falls and where this is not practicable, measures to minimise the distance and consequences of a fall should be taken.
To ensure this requirement is met, Regulation 4 of the above requires employers to ensure that work at height is properly planned and that “its planning includes the selection of work equipment in accordance with regulation 7”. Such planning must also include planning for emergencies and rescues.
HSE guidance document HSG33 Health and Safety in Roof Work, states that “planning is vital to ensure safety in any size of building or roof project, from short-duration minor work... to major refurbishment of an existing property” and that planning “helps to make sure the work is carried out safely, efficiently and without undue delay”.
Although the requirement to plan roof work is placed upon the employer, HSG33 recognises the need for all parties to be aware of the issues involved with roof work, particularly where the Construction (Design and Management) Regulations 2015 apply.
Indeed, HSG33 further states that it is “essential that the hazards associated with working at height are recognised and understood by the client or customer who commissions or arranges for the work to be carried out and the designer, where there is one”.
Therefore, where roof work is to be commissioned, it is important that the client ensures that any contractor being utilised is competent and aware of the need to undertake sufficient planning of the work to be completed.
Assessment and planning factors
A key element in the overall planning process is the completion of a risk assessment. Factors to consider will be the following.
The work activity including the duration of the work.
The location of the roof where the activity will be undertaken.
The type of roof including current condition and fragility.
The equipment to be used during the roof work.
As part of the overall assessment, the employer can then consider the application of the hierarchy and how they can plan the work activity. The hierarchy has to be followed systematically and only when one level is not reasonably practicable may the next level down be considered.
A key element in the planning process is to consider the presence or otherwise of fragile roof elements. Indeed, the Work at Height Regulations contains specific requirements in relation to “fragile surfaces”.
HSG33 states that “any work on fragile roofs, however trivial it may seem, should be carefully assessed, planned and supervised” and that “all roofs should be treated as fragile until a competent person has confirmed they are not”. Therefore, as part of the planning and assessment process, the employer should be addressing the following.
The general deterioration of the roof due to ageing and lack of maintenance that may make it fragile.
Corrosion of any elements such as fixings or metal clad roofs.
The quality of installation and materials used.
Deterioration of any supporting structures, sheeting or other elements.
Damage from environmental conditions, impacts and abuse, etc.
In addition to fragile roofs, logistical factors will need to be given consideration including the need for safe access, competency to manage, supervise and undertake the work, the handling of materials during the work activities, how risks from overhead electrical cables will be avoided (if present) and any issues relating to prevailing weather conditions.
A significant planning element often neglected is the need for emergencies and rescue. Emergency procedures must be considered for circumstances such as stuck access equipment and deployed fall arrest equipment, so that a person or people can be rescued. According to HSG33, the rescue plan should include:
details of the rescue equipment to be used
configuration of the equipment for different types of rescue
identification of anchor points where necessary
limitations of the plan for adverse weather such as high winds
the need for trained rescue personnel.
Once the above issues are all considered during the planning stage a method statement can then be prepared that describes the precautions and systems of work required that were identified as part of the assessment and planning process.
Planning and competency
HSE statistics indicate that many incidents occur because those involved in carrying out the work are not trained or competent to do so.
Clearly, competency of those undertaking the roof work is essential, including any supervisory or managerial elements. However, legislative requirements also consider the need for competency in planning.
The Work at Height Regulations requires employers to ensure that “no person engages in any activity, including organisation, planning and supervision in relation to work at height…unless they are competent to do so”.
To determine competency to undertake the planning of roof work, reference can be made to the Advisory Committee for Roofsafety (ACR) publication Guidance Note for Competence and General Fitness Requirements to Work on Roofs (The Black Book).
This publication defines organising and planning roof work as to “price for, make appointments for and set out arrangements including: method statements, provisions for safety and programme for work on roofs”. To fulfil the criteria, the Black Book then suggests competency as having:
a knowledge of which health and safety legislation is applicable to roof work and how it should be applied to the task in hand
an understanding of the hazards associated with the type of roof or system
the ability to carry out and implement comprehensive risk assessments to deal with associated hazards
the ability and authority to select the most appropriate working equipment for the task, regardless of financial constraints
an understanding of the method statements and what needs to be included within them
an understanding of available techniques (including rescue) which can be employed to safely access and carry out work on a roof
delegated authority to grant permission to access the roof.
As with any competent appointment, the employer will need to identify the person within the organisation who will be fulfilling the planning function and determine their current level of competency and what learning and development they may require to fulfil the function successfully.