Unsafe Ladder Use at ABC Glazing Ltd (work at height)

1.1 Introduction:

This presentation delves into an incident involving the unsafe use of a ladder by an ABC Glazing Ltd
employee during a window installation at a domestic client's house. The analysis focuses on
understanding the circumstances of the incident, evaluating contributing factors, and proposing viable
solutions to enhance safety practices during ladder use.

By scrutinizing this incident, ABC Glazing Ltd can derive valuable insights to implement preventive
measures and foster a safety-conscious work environment. The presentation not only highlights the
importance of addressing the specific incident but also emphasizes the broader context of safe ladder
use. It aims to provide actionable information and guidelines to ensure that employees are equipped
with the knowledge and practices necessary for secure ladder operations, ultimately contributing to the
overall occupational safety and well-being of ABC Glazing Ltd's workforce.

1.2 Applicable UK Health and Safety Regulations:

The specific UK health and safety regulations and applicable regulation numbers related to
work at height are as follows:

 The Work at Height Regulations 2005 (WAHR 2005):

The Work at Height Regulations 2005 (WAHR 2005) establishes crucial guidelines for ensuring
the safety of employees engaged in work at height.

Regulation 4(1) places a fundamental responsibility on employers to ensure that work at height
is meticulously planned, organized, supervised, and executed in a manner that prioritizes safety.
Regulation 5(1) reinforces the need for employers to implement adequate measures to prevent
falls from height, emphasizing the proactive nature of risk mitigation.

Additionally, Regulation 6(3) outlines that when work at height is unavoidable, employers must
utilize work equipment or alternative measures to prevent falls, underlining the importance of
adopting preventive strategies even when height-related tasks are essential. These regulations
collectively aim to safeguard workers engaged in tasks involving elevation, promoting a
comprehensive approach to risk management and accident prevention.

 The Provision and Use of Work Equipment Regulations 1998 (PUWER 1998):

The Provision and Use of Work Equipment Regulations 1998 (PUWER 1998) delineates critical
provisions for the safe use of work equipment.

Regulation 4(1) imposes a primary obligation on employers to guarantee that work equipment is
constructed or adapted to be safe for use, considering all relevant circumstances. This
 emphasizes the importance of designing, selecting, or modifying equipment with safety in mind.
Regulation 5(1) underscores the need for employers to ensure that work equipment is
consistently maintained in efficient working order and good repair, preventing potential hazards
arising from equipment malfunction.

Regulation 6(1) establishes that employers are responsible for ensuring the safe use of work
equipment, emphasizing the significance of proper training, supervision, and adherence to
safety guidelines during equipment operation.

PUWER 1998 collectively aims to mitigate risks associated with work equipment, fostering a
secure working environment.

 The Management of Health and Safety at Work Regulations 1999 (MHSWR):

The Management of Health and Safety at Work Regulations 1999 (MHSWR) establishes fundamental
principles to safeguard the health and safety of employees.

Regulation 3(1) mandates employers to conduct a comprehensive risk assessment to identify and
evaluate potential hazards that may affect the health and safety of their workforce, ensuring a proactive
approach to risk management. This regulation emphasizes the need for a systematic evaluation of
workplace risks to the extent reasonably practicable.

Regulation 5(1) further reinforces employer responsibility by requiring the implementation of suitable
measures to secure the health and safety of employees based on the outcomes of the risk assessment.
MHSWR 1999 integrates a risk-based approach, guiding employers in taking preventative actions to
create a safe and healthy work environment for their staff.

1.3 Recommendations for Improved Health and Safety:

The following are recommended for improved Health and Safety

 Use appropriate safety equipment according to Work at Height Regulation (2005):

The Work at Height Regulations 2005 (WAHR 2005) outlines crucial measures to enhance safety
during elevated work. To adhere to these regulations, the use of suitable safety equipment is
imperative. For tasks surpassing 2 meters, the regulations advocate the preference for
scaffolding or mobile elevating work platforms (MEWPs) instead of ladders. When ladders are
unavoidable, it is essential to ensure they are the appropriate type for the specific task and meet
relevant safety standards. Moreover, the regulations stress the importance of utilizing a fall
arrest system, including a harness and lifeline, when working at height. These safety measures
are designed to mitigate the risks associated with elevated work, providing a robust framework
for the prevention of falls and enhancing overall workplace safety in compliance with the
regulations. Adherence to these guidelines not only ensures legal compliance but also prioritizes
the well-being of workers engaged in tasks at height.

 Implement safe working practices and safe use of ladders and stepladders (HSG36) :
To ensure safe working practices and the proper use of ladders and stepladders, the implementation of
guidelines from the Health and Safety Executive (HSG36) is crucial. Employees should adhere to the
three-points-of-contact rule and refrain from exceeding the top three rungs of a ladder, aligning with
British Standards (BS EN 131: 2019). Additionally, working alone at height should be avoided to enhance
overall safety. Regular inspections of ladders for defects and ensuring proper maintenance are essential
components of these guidelines. By incorporating these measures, organizations can not only promote a
safer work environment but also comply with regulatory standards, fostering a culture of responsibility
and well-being among employees engaged in activities at height.

 Provide effective training:

Ensuring the provision of effective training is paramount for promoting a culture of safety and
compliance with regulations. Companies should supplement in-house training with accredited courses
tailored to working at height and ladder safety, leveraging resources such as the Construction Industry
Training Board (CITB). Regular refresher training sessions further reinforce proper practices and keep
employees updated on safety protocols. Encouraging open communication about safety concerns and
unsafe practices cultivates a proactive approach, allowing employees to voice their apprehensions and
contribute to continuous improvement. This commitment to ongoing education and communication
establishes a robust foundation for safety within the workplace, reducing the likelihood of accidents and
enhancing overall risk management.

1.4 Fitness of Method Statement and Risk Assessment:

 Based on the information provided, it appears that the method statement and risk assessment
were not fit for purpose because:
 Despite mentioning safe ladder use, it failed to effectively deter the occurrence of risky actions.
 The evaluation should have recognised the risks pertaining to working on the window ledge and
the hazards connected with working alone.
 The implementation of specific control measures such as scaffolding or a Mobile Elevated Work
Platform (MEWP) should have been clearly defined.
 The need of doing a comprehensive risk assessment and preventative actions was not clearly
emphasised.
 The evaluation should have clearly indicated alternative work equipment to be used for
operations that exceed the safe height for ladders.

1.5 Enhancing Practical Application of Training:

The real-life execution of the training may be achieved via the following methods:

• Implement scenario-based training: Utilise realistic simulations of operating at elevated

locations to enforce adherence to safe protocols.
 • Direct observation and feedback: Conduct frequent direct observations and offer comments to
personnel about their compliance with safety protocols when operating at elevated heights.

• Safety performance incentives: Promote safe work habits by implementing award programmes.

• Foster transparent communication: Establish a work atmosphere that encourages workers to

openly report any harmful activities and seek clarity on safety protocols.

• Peer-to-peer mentoring: Implement peer-to-peer mentoring to foster knowledge sharing and

facilitate the exchange of experiences among workers.

• Toolbox talks: Discuss and provide instructions on safety problems and procedures that are
directly relevant to the impending duties.

1.6 Appeals against Prohibition Notice:

The probability of a successful appeal against the prohibition notice is minimal, primarily because of the
compelling reasons supporting the Health and Safety Executive's (HSE) intervention. The evident and
clear violation of the Work at Height Regulations 2005 (WAHR 2005) and the Provision and Use of Work
Equipment Regulations 1998 (PUWER 1998) leaves little room for disputing the notice. The HSE's
observation of unsafe work practices further strengthens their case, as tangible evidence establishes a
basis for the prohibition.

The lack of justification for non-compliance with the risk assessment, a fundamental element in ensuring
workplace safety, adds another layer of challenge to the appeal. The regulations are in place to
safeguard workers, and the absence of a reasonable explanation for disregarding risk assessment
requirements weakens any attempt to challenge the prohibition. Overall, the circumstances surrounding
the notice, including regulatory breaches and evidence of unsafe practices, make the success of an
appeal highly improbable. Addressing the root causes of non-compliance and implementing corrective
measures would be a more viable and responsible course of action for the company.

1.7. Safe Ladder Use Requirements:

The requirements for safe use of ladder are:

 Choose the right ladder: Select the appropriate type and length of ladder for the specific task
and working environment.

 Inspect the ladder: Ensure the ladder is in good condition before use, checking for cracks, loose
rungs, and worn rubber feet.

 Position the ladder securely: Place the ladder on a stable and level surface, extending it beyond
the landing point by at least three feet.

 Maintain three-points-of-contact: Always keep two hands and one foot or two feet and one
hand on the ladder while climbing or descending.
  Never exceed the top three rungs: Do not stand on the top three rungs of the ladder.

 Do not work alone: Always have someone present to assist and provide help in case of an
accident.

Additional Innovative Provisions for Safe Ladder Use:

 Ladder stabilizers: These increase the base of the ladder, providing additional stability.

 Fall arrest systems: These systems attach to the ladder and the employee, preventing falls from
height.

 Work platform ladders: These ladders incorporate a platform at the top, providing a secure work
surface.

 Ladder leveling devices: These devices help ensure the ladder is positioned correctly on uneven
surfaces.

Conclusion:
ABC Glazing Ltd is urged to take prompt and comprehensive action to rectify the unsafe working
practices highlighted by the Health and Safety Executive (HSE). Essential measures should be
implemented immediately, encompassing the provision of appropriate equipment, stricter
supervision protocols, enhanced training programs, and a stringent enforcement of safe ladder use.

The company must prioritize the safety of its workers and adhere strictly to health and safety
regulations. Providing suitable equipment, such as scaffolding or mobile elevating work platforms
(MEWPs) when necessary, is crucial to ensuring employees can carry out tasks at height securely.
Additionally, enhancing supervision practices and refining training programs will contribute to a
safer working environment, reducing the risk of accidents and injuries.

Failure to comply with health and safety regulations not only jeopardizes the well-being of workers
but also exposes the company to potential fines, legal repercussions, and damage to its reputation.
Implementing corrective measures promptly is not only a legal obligation but also a moral
responsibility to ensure the welfare of the workforce. ABC Glazing Ltd must view these
recommendations as an opportunity to fortify its commitment to the safety and well-being of its
employees, fostering a workplace culture that prioritizes compliance and employee welfare.