Safe Working at Heights Procedure UKCS-SOP-033

Contents

Authorisation for Issue

Amendment Record
Amendment Summary
Distribution List
Preface

Paragraph Page
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1 Introduction 1

2 Emergencies 1

3 Task Pre-conditions 1

4 Fall Arrest Equipment 2

4.1 Requirements 2
4.2 Standards 3
4.3 Fall Arrest System 3
4.4 Full Body Harness 3
4.5 Safety Lanyards (With Integral Shock-absorber) 4
4.6 Connectors 5
4.7 Anchorage Slings/Strops 5

5 Control 6

6 Inspection 8
6.1 Textile Equipment 8
6.2 Metal Equipment 9

7 Use 10
7.1 Hierarchy of Measures 10
7.2 Fall Arrest Equipment 10
7.3 Personal Suspension Equipment 10

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UKCS-SOP-033 Safe Working at Heights Procedure

Contents (cont’d)

Figure Page
1 Example Record Card 7
2 Hierarchy of Measures Flowchart 11

Addendum 1 References

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 Safe Working at Heights Procedure UKCS-SOP-033

Authorisation for Issue

Issue Authority
Name: John Watson

Signature: ________________________________________________

Date: ________________________________________________

Position: Operations Delivery Team Leader, GFU

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Technical Authority
Name: John Robertson

Signature: ________________________________________________

Date: ________________________________________________

Position: Health and Safety Consultant, Sullom Voe Terminal, NES

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 Safe Working at Heights Procedure UKCS-SOP-033

Amendment Record

For Audit Use

Amendment Incorporated By
Checked
Number
Name Signature Date Signature Date
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AMOSAF.171

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 Safe Working at Heights Procedure UKCS-SOP-033

Amendment Summary

Issue No Date Description

Issue 1 August 2001 First issue.
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 Safe Working at Heights Procedure UKCS-SOP-033

Distribution List

Holders of Controlled Hard Copy

Copy Copyholder Location

01 To be advised

Virtual Copyholders

Copy Copyholder
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01 Document Issue Authority (John Watson)

02 Document Technical Authority (John Robertson)

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 Safe Working at Heights Procedure UKCS-SOP-033

Preface

Purpose
The purpose of this document is to provide guidance to managers, supervisors and employees
on the standards and procedures which need to be followed in the use of fall arrest equipment.
Following the guidance set out in this document will assist in meeting regulation 6 of the
Construction (Health, Safety and Welfare) Regulations 1996, SI 1996/No 1592.
The Bookshelf Owner and Technical Authority for this document should be consulted if further
information on the control procedures or the specification is required.
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Review and Update

This document will be subject to 12-monthly review and update, when document holders will
have the opportunity to express opinions and suggest improvements.
However, the document control system allows for continuous update of this document. As
such, any user may at any time identify an error or suggest an improvement using an
Amendment Proposal proforma which is available electronically on the UK Upstream SMS
website, from the Data Control Centre (DCC) Supervisor or from the Technical Authority.
All holders of this document are registered so that they can be sent updates and be kept
informed of changes or reviews.

Responsibility of Copyholders
It is the responsibility of the registered copyholder of controlled hard copy versions to
maintain the accuracy of the document by ensuring that all updates are promptly
incorporated and acknowledged.
Furthermore, the registered copyholder of controlled hard copy versions must at all times
maintain custody of this document unless prior approval is given by the relevant
Technical Authority.
The roles and responsibilities of copyholders and ‘virtual’ copyholders are detailed in Section 1
of the Document Control Procedure (UKCS-DCM-001).

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 Safe Working at Heights Procedure UKCS-SOP-033

1 Introduction
The Construction (Health, Safety and Welfare) Regulations 1996, SI 1996/No 1592 apply
to all onshore and offshore Installations in the United Kingdom and its territorial waters.
Regulation 6 seeks to safeguard the health of employees who may be exposed to the
risk of falling whilst carrying out their work.
The principal requirement of Regulation 6 is:
• Where any person is to carry out work at a place from which they are liable to fall a
distance of 2m or more, or
• Where any person is to use a means of access or egress from a place of work from
which they are liable to fall a distance of 2m or more
• So far as is reasonably practicable, suitable and sufficient steps should be taken to
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prevent any person falling

Note: This does not cover work undertaken on certified scaffolding.
This document provides guidance on meeting the requirements of Regulation 6 and in so
doing reducing the risks to personnel to as low as reasonably practicable.

2 Emergencies
The Installation shall ensure that sufficient trained and competent personnel are available
for the task. Personnel shall be aware of the response required in the event of an
emergency, including subsequent rescue/recovery.

3 Task Pre-conditions
Prior to work commencing, the following minimum standards must be adhered to. It is
recognised that this list is not definitive and facility and Company instructions/procedures
must be followed.
• Risk assessments appropriate to the task shall be carried out, eg task-based/manual
handling to include, where necessary, rescue provision
• A valid Permit to Work (PTW)/procedure shall be obtained to control the planned work.
This may vary in type according to the task to be undertaken
• An onsite pre-task assessment and toolbox talk shall be carried out and documented,
including discussion with the Area Authority for local restrictions, eg location of
sensitive equipment
• Barriers shall be erected around the worksite (including levels below the worksite if
appropriate) to prevent unauthorised access
• Weather conditions and standby vessel arrangements (for overside working), shall be
considered prior to the task and monitored throughout. Communications will be
tested and emergency procedures established should communications fail

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• The radio room/control room shall be informed at all times of worksites involving
exposed locations
• Appropriate safety equipment shall be taken to the site and used as required,
eg interia reel and harness, lifejackets (overside), as determined by the risk assessment
• Atmospheric checks shall be undertaken in accordance with confined space entry
requirements and risk assessments where appropriate
• All tools used shall be checked for condition and shall be ‘fit for purpose’
• Mechanical lifting aids are to be used wherever possible to move equipment to and
from the worksite
• All small items of construction material, eg fittings, clamps, clips shall be transferred if
the working area is either above or below main deck level contained within a
suitable carrier

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• Safety behavioural toolkits shall be used at all times during the task, eg Safety
Training Observation Programme (STOP)/Time Out for Safety (TOFS)
• Overside work must not be carried out during hours of darkness unless the work
cannot safely be posponted until daylight. When work is necessary, adequate lighting,
connected to the emergency power system, must be provided
• Access to the vent stack shall be denied until the production and processing plant has
been depressurised and isolated and the vent snuffing system has been inhibited.
Access shall also be denied during high winds or conditions where lightning
may occur
Access to the vent stack is not to be attempted until the gas production and processing
plant has beeen depressurised and isolated, and the vent snuffing system has been
inhibited. Also, calm weather conditions should prevail.

4 Fall Arrest Equipment

4.1 Requirements
The requirements for fall arrest equipment are defined in Schedule 4 of the construction
regulations. These can be summarised as follows:
• Equipment means any equipment provided for the purpose of arresting the fall of any
person at work and includes any net or harness provided for that purpose
• The equipment shall be suitable and of sufficient strength to safely arrest the fall of
any person who is liable to fall
• The equipment shall be securely attached to a structure or to plant and the structure
or plant and the means of attachment there to shall be suitable and of sufficient
strength and stability for the purpose of safely supporting the equipment and any
person who is liable to fall
• Suitable and sufficient steps shall be taken to ensure, so far as is practicable, that in
the event of a fall by any person the equipment does itself cause injury to that person

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4.2 Standards
Specific standards have been established for all items of equipment and these should be
referred to before using, choosing or purchasing any equipment. A CE mark on a product
indicates that the product conforms to a European Standard.
Addendum 1 should be consulted for details of the European Standards relating to fall
arrest systems. Standards for the principal items of equipment are as follows:
• Fall Arrest Systems BS EN 363
• Full Body Harnesses BS EN 361
• Lanyards BS EN 354
• Energy Absorbers BS EN 355
• Connectors BS EN 362
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• Anchor Devices EN 795

4.3 Fall Arrest System

When working at or above 2m in height (feet to ground level), or when working within
2m of an unprotected edge where a fall could potentially occur, personnel are required to
effectively use the correct Personal Protective Equipment (PPE). This equipment and
correct training in the care, maintenance and use of such, shall be made available by BP
or the employee’s company if a contractor. Where it is deemed that other measures of
eliminating the hazards or controlling the risks of a person falling are not reasonably
practicable, a fall arrest system may be chosen.
The minimum requirement for a fall arrest system is as follows:
• ‘Full’ type body harness
• Shock absorbing lanyard
• Connectors
• Anchor point
The system is used in such a way that the operative is permanently attached to the
structure from which they are working.
The system will arrest a fall, should one occur, dramatically reduce the shock loadings
generated by such and keep the operative in an upright position (post fall) to limit
further injury.

4.4 Full Body Harness

A full body harness provides total body support and security in the event of a fall.
In encapsulating the body, the design of the harness ensures maximum security against
the possibility of an operative ‘falling out’. It also ensures that any shock transmitted to
the operative as the result of a fall is spread throughout the body, particularly around the
upper thigh area, thereby minimising any resulting injury.

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The harness is fitted with one or more dedicated fall arrest attachment points.
These attachment points will always be sited high at the back of the harness and/or high
at the front and are where shock absorbing lanyards should be attached. High attachment
points serve to ensure that the operative is kept in an upright position after a fall has
taken place. A low attachment point (say at waist level) would be near to the centre of
balance of the operative and would promote an unconscious body to ‘flop back’ thereby
increasing the possibility of spinal compression.
Being kept in a vertical plane also means that a casualty will provide less resistance to
any small aperture that has been entered when a hauling rescue may be required.
In general, the front attachment point is used whilst climbing or making progressive
movement utilising lanyards. The rear attachment is used whilst work is in progress,
when the operative remains stationary for a relatively lengthy period of time.
Not withstanding this, either attachment point can be utilised at the user’s discretion.

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The harness should not be used as part of a suspension or positioning system, being
designed only to arrest a fall and contain the body effectively.

4.5 Safety Lanyards (With Integral Shock-absorber)

The single or double slinging lanyard provides the attachment from the harness to the
anchor point. Both of these lanyards have an integral shock absorber built into them.
The lanyards, by law, cannot be longer than 2m. An operative could potentially fall 4m on
a 2m lanyard.
The shock absorber must be capable of limiting the force generated by 100kg (a large
adult) falling 4m, to below 6kN (approximately 600kg). The actual force generated by
100kg falling 4m is approximately 15kN (approximately 1.5 tonnes). This can be related
to the weight of a medium-size estate car.
Without a shock-absorber in the system, all the force of the fall would be absorbed by
the operative, with potentially fatal results.
The shock-absorber end of the lanyard should always be attached to the harness
(user end), this attachment being made by the fitted connector (refer to Paragraph 4.6).
The other end of the lanyard should be attached via the fitted connector to one of
the following:
• A dedicated tested anchor point, eg safety eye bolt
• A suitable sling or strop wrapped around an anchor point of unquestionable reliability,
eg structural steelwork (ensuring that the sling or strop does not effectively increase
the length of the lanyard to over 2m)
• An anchor point of unquestionable reliability and connected back into the fall arrest
harness attachment point
• A suitable fall arrest device forming part of an in-situ safety system, eg rail lock, glide
lock, latchway system etc
The lanyard should never in any circumstance be wrapped around an anchor point and
then attached back onto itself, ie ‘choke hitch’ or ‘lark’s foot’.

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The lanyard should always be attached to the structure or appropriate anchor points in as
high a position as possible in relationship to the user – an operative attached by a 2m
lanyard anchored 2m below him could potentially fall 4m, an operative attached with the
same but anchored 2m above cannot fall at all.
If safe, progressive movement is required to be made, two lanyards must be used,
or the Spanset ‘Double Slinging Lanyard’. Before one lanyard is detached from the
structure, the second is attached, thus constantly maintaining one point of attachment.
WARNING: NEVER USE THE LANYARD AS A METHOD OF SUSPENSION.

4.6 Connectors
A connector is the generic term used to describe items of equipment that can be
opened/closed and provide safe linkages within a safety system, or enable the operative
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to link him/herself directly or indirectly to an anchor.

Examples of connectors are:
• Twistlock
• Karabiner
• Screwgate karabiner
• Double action scaffold hook
All these connectors must have a double locking action when used within the system.
The connector must only ever be loaded along the axis of its length. It is not designed to
withstand side loadings and may fail if subjected to such.
Attaching the connector to more than one item of equipment, to items of too large a
diameter or items of irregular shape (eg angular steelwork) may load the connector in
such a way as to promote failure.
Where a semi-permanent or permanent attachment is required to be made, or where a
multi-directional load-bearing capacity is required from the connector, a maillon rapide
may be used.

4.7 Anchorage Slings/Strops

Attachments may be made to anchor points utilising appropriate webbing slings or wire
strops. The sling, or strop, to the anchor point by being clipped in to the connector on
the lanyard (opposite end to the shock-absorber), passed around the anchor, then clipped
back into the connector. The sling should never be passed around the anchor point then
back through itself (‘choke hitch’ or ‘lark’s foot’), as this makes only one attachment with
the connector into the resulting loop.

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Operatives should be constantly aware of the damage that may be caused to webbing
slings or wire strops, by being placed around sharp-edged, abrasive or hot anchor points.
Attaching to anchor points of this nature should be avoided. As a second option, the
sling or strop should be protected by using appropriate means, eg padding, sleeving etc.
If there is ever any doubt about the integrity of an anchor point, in that it may not be
‘unquestionably reliable’, or that it may cause damage to items placed around it (and that
these items cannot be adequately protected), it should not be used.

5 Control
A system of controls shall be established to ensure that all fall arrest equipment is in
good condition and only used by trained personnel. These controls shall include
the following:

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• Each piece of equipment shall have a record card on which shall be entered the name
of the user, where used and the date of issue (an example record card is shown in
Figure 1)
• Issues shall be on a daily basis only, ie no long term loans
• All equipment shall be inspected prior to issue (refer to Paragraph 6)
• Equipment shall only be issued to trained personnel who have a valid certificate of
competency from a recognised training facility
• Equipment shall only be issued to the person who will wear it
• On return, all equipment shall be inspected. Any defective equipment shall be
quarantined and line management notified. Details of any defects and the action taken
shall be entered on the equipment record card

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HARNESS No SERIAL No
Date Name ID Company Area Used/Comments Sign Back
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UKCSSOP033_001.ai

Figure 1 Example Record Card

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6 Inspection
The manufacturer of any PPE should provide information on use, care and maintenance
of the product. It is then the responsibility of the user to follow this information correctly.
Note: The inspection of PPE must be carried out by personnel who are trained and
competent to do so. Familiarity with all equipment is essential if deviations from
the norm are to be detected.
In addition, the following guidance should be followed.

6.1 Textile Equipment

Textile equipment consists of harness, rope, tape slings etc. Rope and webbing should
be given a visual and tactile inspection, both before being placed into storage and before

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being issued back into service. In the case of kernmantel rope, a tactile inspection
should be conducted by physically running the rope through the hands and feeling for
any deformities to both the mantel (outer sheath) and the kern (inner core), whilst
visually checking the sheath for signs of cuts, abrasion etc.
Webbing equipment should be inspected for cuts, nicks, tears, abrasion, broken stitches,
chemical contamination and distortion of the weave pattern (this indicating that the
product has been subjected to undue loadings).
Abrasion is the most common cause of strength loss in textile equipment. This is usually
caused by equipment rubbing against sharp or rough edges or against itself. Another
significant cause of abrasion which is often overlooked, is that caused by the ingress of
dirt and/or grit working its way into the weave or inner core of the product and abrading
the internal textile fibre. This will cause strength loss but may not be easily detectable in
its early stages.
To control this effect, textiles may be washed in clean water at a temperature of no
greater than 40°C. If the textile is especially dirty, a suitable cleaning agent may be used,
this should be carefully chosen so as to be compatible with polyester or nylon.
Equipment should be rinsed thoroughly after washing. If a washing machine is used it is
advisable to place the equipment in a suitable bag to protect against mechanical
damage. Any wet equipment should be dried naturally in a well aired room away from
direct heat or sunlight.
Mechanical damage will also have a detrimental effect on textile equipment, with the
strength loss being directly proportional to the severity of damage.
Overloading and/or shock loading will have a weakening effect on ropes and webbing,
this being proportional to the amount of load that the textile is subjected to. Ropes and
webbing which have been subjected to a high load should be scrapped immediately and
in such a way that they cannot be returned into service.

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Any textile that has been subjected to adverse chemical contamination should be
withdrawn from service immediately. Information on the effect a particular chemical has
on textiles can be gained from the equipment manufacturer.
Notes: (1) Polyester has a better resistance than nylon to acids.
(2) Nylon has a better resistance than polyester to alkalis.
Chemical damage to textiles is often difficult to detect until the rope/webbing begins to
disintegrate and can therefore be missed during an inspection. White powdery residues
on the surface of the textile or a notable change in texture may be an indication of this.
If in doubt, destroy and dispose of the suspect item of equipment in such a way that it
cannot be returned into service.
Textile equipment which has a burnt or glazed appearance has been exposed to high
temperatures, either by coming into contact with hot surfaces or suffering the effects of
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heat caused by friction from the descending device or the rubbing of textile against
textile. All of these, depending upon the severity, can have a detrimental effect on
equipment strengths ranging from minor strength loss to rope/webbing failure.
Care should be taken to protect ropes and webbing from high temperatures, as most
manmade textiles will begin to change in character, and therefore performance,
at temperatures of in excess of 50°C.

6.2 Metal Equipment

Metal items such as karabiners, maillon rapides, descenders, harness buckles etc should
be inspected to ensure that their mechanical function is not impaired in any way. Ensure
that springs, hinges and threads work smoothly and that bolts and rivets are tight.
Signs of deformation, wear, cracks, or other deviations from the norm should be sought.
Equipment with moving parts should be checked to ensure that its action is regular.
Equipment should be kept clean and dry, with all moving parts (excluding those that may
come in to contact with textile equipment) lubricated. Any item proving to be defective
should be taken out of service immediately.
Damage most commonly caused to textile equipment is usually visually detectable
before significant strength loss occurs. However, metal equipment can suffer internal
damage, which may be extensive though not visually detectable. This is often caused
through the incorrect care of such equipment, eg dropping, overloading etc, and can
result in equipment failure without any prior warning. It is therefore vital that this
equipment is afforded the correct care and maintenance.
Metal equipment may be cleaned by submerging in clean hot water (maximum 100°C)
and using a detergent or soap. A non-metallic (eg nylon) abrasive pad or scrubbing brush
may assist.

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7 Use
7.1 Hierarchy of Measures
Regulation 6 of the construction regulations has established a hierarchy of measures
which should be applied before electing to use fall arrest equipment. This hierarchy is
as follows:
(1) Prevent all fall hazards so far as is reasonably practicable.
(2) If this is not possible, install guardrails, toe-boards, barriers etc, and working
platforms.
Working platforms are defined as any platform used as a place of work or as a
means of access or egress from that place and includes any scaffold, cradle,
mobile platform, trestle, gangway, run, gantry, stairway and crawling ladder.

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(3) If this is not reasonably practicable, provide personal suspension equipment.
Personal suspension equipment is defined as suspended access equipment (other
than a working platform) for use by an individual, including a boatswain’s chair and
industrial rope access equipment, but not including a suspended access platform
or cradle. For further details refer to Paragraph 7.3.
(4) Finally, if all the above are not reasonably practicable, fall arrest equipment in
compliance with Paragraph 4.1 of this document should be provided.
A hierarchy of measures flowchart is shown in Figure 2.
Not withstanding any of the above, prior to using any of the equipment described in this
document, a full task-based risk assessment should be carried out.

7.2 Fall Arrest Equipment

Detailed information on specific equipment should be obtained from the manufacturers’
documentation.

7.3 Personal Suspension Equipment

Schedule 3 of the construction regulations defines the requirements for personal
suspension equipment. These can be summarised as follows:
• Personal suspension equipment shall be suitable and of sufficient strength for the
purpose for which it is being used having regard to the work being carried out and the
load, including any person, it is intended to bear
• Personal suspension equipment shall be securely attached to a structure or to plant.
Such structure or plant and the means of attachment to it shall be suitable and of
sufficient strength and stability for the purpose of supporting that equipment and the
load, including any person, it is intended to bear
• Suitable and sufficient steps shall be taken to prevent any person falling or slipping
from personal suspension equipment
• Personal suspension equipment shall be installed or attached in such a way as to
prevent uncontrolled movement of that equipment

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TRY TO PREVENT ALL FALLS

ACHIEVE YES NO FURTHER

FALL PREVENTION ACTION NECESSARY
IN FULL?
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NO

FALL
MORE THAN 2m DISTANCE? LESS THAN 2m

A INSTALL GUARDRAILS,
INSTALL GUARDRAILS, TOE-BOARDS, BARRIERS ETC,
TOE-BOARDS, BARRIERS ETC, WORKING PLATFORMS TO
WORKING PLATFORMS TO GUARD AGAINST FALLS AS
GUARD AGAINST FALLS AS FAR AS IS REASONABLY
FAR AS IS REASONABLY PRACTICABLE
PRACTICABLE

NO FURTHER
B ACTION NECESSARY
IF ‘A’ IS NOT REASONABLY
PRACTICABLE, PROVIDE
PERSONAL SUSPENSION
EQUIPMENT

Note: Items 'A’ and ‘B’ installed and/or used correctly should
eliminate the risk of a fall.
C Item ‘C’ will not do this and will only limit the effects of
IF ‘B‘ IS NOT REASONABLY a fall.
PRACTICABLE, PROVIDE Therefore item ‘C’ should always be considered as the
FALL ARREST EQUIPMENT last option and only used when other means or
methods are not reasonably practicable.

UKCSSOP033_002.ai

Figure 2 Hierarchy of Measures Flowchart

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Addendum 1
References

(1) Personal Protective Equipment Against Falls from Height – Sit Harnesses, BS EN 813.
(2) Mountaineering Equipment – Harnesses – Safety Requirements and Test Methods,
Pr EN 12277.
(3) Mountaineering Equipment – Helmets – Safety Requirements and Test Methods,
Pr EN 12492.
(4) Personal Protective Equipment Against Falls from Height – Connectors, BS EN 362.
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(5) Mountaineering Equipment – Connectors – Safety Requirements and Test Methods,

Pr EN 12275.
(6) Personal Protective Equipment Against Falls from Height – Work Positioning Systems –
Rope Adjustment Devices, Pr EN 12841.
(7) Mountaineering Equipment – Rope Clamps – Safety Requirements and Test Methods,
BS EN 567.
(8) Personal Protective Equipment Against Falls from Height – Low Stretch Kernmantel
Ropes (Type A), Pr EN 1891.
(9) Mountaineering Equipment – Dynamic Mountaineering Ropes – Safety Requirements and
Test Methods, EN 892.
(10) Personal Protective Equipment Against Falls from Height – Descender Devices,
BS EN 341.
(11) Personal Protective Equipment Against falls From Height – Guided Type Fall Arrestors
Part 1: Specification for Guided Type Fall Arrestors on a Rigid Anchorage Line, BS EN 353-1.
(12) Personal Protective Equipment Against Falls from Height – Guided Type Fall Arrestors
Part 2: Specification for Guided Type Fall Arrestors on a Flexible Anchorage Line,
BS EN 353-2.
(13) Personal Protective Equipment Against Falls from Height – Lanyard, BS EN 354.
(14) Personal Protective Equipment Against Falls from Height – Energy Absorbers, BS EN 355.
(15) Personal Protective Equipment Against Falls from Height – Work Positioning System,
BS EN 358.
(16) Personal Protective Equipment against Falls from Height – Retractable Type Fall Arrestors,
BS EN 360.
(17) Personal Protective Equipment Against Falls from Height – Full body Harness, BS EN 361.
(18) Personal Protective Equipment Against Falls from Height – Connectors, BS EN 362.

References
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UKCS-SOP-033 Safe Working at Heights Procedure

(19) Personal Protective Equipment Against Falls from Height – Fall Arrest Systems,
BS EN 363.
(20) Personal Protective Equipment Against Falls from Height – Test Methods, BS EN 364.
(21) Personal Protective Equipment Against Falls from Height – General Requirements for
Instructions for Use and for Marking, BS EN 365.

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References
Add 1-2 August 2001 Issue 1