Guideline For Working at Height PDF
Guideline For Working at Height PDF
Guideline For Working at Height PDF
136
No.
No. Guidelines for Working at Height
136
136
(June
(cont) A. Preamble
2014)
A1. This Recommendation has been developed to provide guidance to Classification
Societies (hereinafter referred to as CS) when developing their own internal safety
procedures and / or instructions relating to the hazards faced by survey personnel when
working at height in the field (hereinafter referred to as WAH). Detailed calculations / testing
of the equipment to be used when carrying out WAH activities are not required or intended
under this Recommendation.
A2. The objective is to promote the safety of classification society personnel when required to
work at height. Individual CS are encouraged to develop and / or modify their own internal
procedures based on these and other similar references. All personnel, when WAH, should
be familiar with, and conscientiously apply the applicable procedures / instructions, in the
interest of their own safety.
A3. This Recommendation has been developed by drawing extensively on the latest versions
of the references listed in Section B of this document, in addition to the existing procedures
and practical experience of the member societies.
A4. The word ‘shall’ where used in any of the quoted references has been replaced in these
Recommendations by the word ‘should’ reflecting the intended recommendatory guidance of
this document. Specific wording taken from any of the quoted references may also have been
amended, as necessary, to maintain consistency of presentation.
B. References
B3. UK – MCA Marine Guidance Note MGN410 (M+F) on The Work at Height Regulations.
B4. Republic of Ireland - Guide to Safety, Health & Welfare at work (General Application)
Regulations – Pt. 4.
C. Scope
D1. WAH is inherently hazardous and may expose personnel to injury and possible death.
Research carried out by various agencies shows that falls from height usually occur as a
result of poor management control and/or risky behaviours rather than because of equipment
failure.
D3. In general, referenced regulations do not specify the height above which those
requirements apply. Their focus is on the duty to prevent injuries, since a fall from a relatively
low height may also cause serious injury. The WAH regulations require that the risk of a fall
be mitigated wherever a fall is liable to cause personal injury. This means that measures
should be taken for working at any height where there is a risk of a fall causing personal
injury. This encompasses working:
d. in or entering or exiting spaces, such as ballast tanks, cargo holds, deep tanks, etc.;
D4. In ship surveys and other marine inspections, WAH is often unavoidable. Therefore,
adequate awareness, training and preparation on the part of all stake holders are essential to
promote the safety of all involved personnel.
D5. Responsibility for the provision of the means of access, working platforms and related
equipment lies with the shipyard / ship owner / crew / repairer / industrial unit or other party as
applicable. Therefore, it is recommended that the CS include, in their procedures, means to
make their specific procedural requirements known to the responsible party well in advance
of the work to be carried out (e.g. in work planning meetings). The requirements provided
should be considered by the surveyor during survey planning meetings and reviewed as
changes occur.
D6. Various regulations, such as Quality Management System (QMS) standards, Safety
Management System (SMS) standards and the IMO International Safety Management
System (ISM) Code, may require employers to carry out a risk assessment and / or take
appropriate measures to remove or mitigate the risks in work situations. Considering that
most shipyards and industrial units have a certified QMS/SMS, and ships and ship owners
and managers have certified safety management systems in accordance with the ISM Code
in place, it is reasonable for CS’s personnel to require and receive adequate support from
them for WAH.
D7. National and international regulations usually also place an onus on personnel to protect
their own safety. This is the main focus of this Recommendation. All CS’s personnel should
apply their own organisation’s requirements and follow the relevant procedures when WAH.
See also the relevant parts of IACS UR Z10 requirements for Access to Structures.
E. Definitions
a. Work at height means work in any place where, if precautions are not taken, a person
could fall and be injured. This includes working at or below ground level if a fall is still
possible such as a fall from an edge or through an opening.
E2. Surveyor
a. Work restraint is a system that prevents persons from reaching a point where they can
fall. Examples are: Guard rails, scaffolding, tower scaffolds, cherry pickers, scissor lifts.
a. Work positioning is a system that allows a person who has reached a point of work at
height to secure themselves to allow work to take place without the risk of a fall.
b. A work positioning system is a personal fall protection system that enables a surveyor
to work while supported in tension or suspension in such a way that a fall is prevented
or restricted. An example would be a boatswain’s chair.
a. Fall arrest equipment is used in situations where a potential to fall cannot be avoided.
Equipment used will both arrest the fall and absorb some energy of the fall. Examples
would be the traditional harness plus lanyard incorporating energy absorbance, safety
nets, air bags.
a. Work over sea means work taking place outside permanent railings where there is a
risk of a surveyor falling into the sea.
F. Training
F1. All surveyors who are expected to work at height should be trained in safety requirements
for such activities according to CS’s internal procedures.
a. Recognising a WAH situation, including access to and exit from such locations.
b. Recognising, evaluating and managing the hazards and the risks associated with WAH.
F3. Competency in the areas covered by the training identified in F2 should be periodically
assessed, either as a part of activity monitoring or some other suitable means. The maximum
period between these assessments of competency should be 3 years. Assessment records
should be maintained.
F4. CS should document in their internal procedures situations when these competency
assessments are not held as required by this Recommendation and when surveyors do not
pass these competency assessments.
G2. When deciding which type of equipment is most suitable for a particular task, the
following should be considered:
c. fragile surfaces;
d. floor loading;
e. job duration;
f. weather conditions.
G3. It is essential that a sensible and pragmatic approach is taken when addressing low falls.
Precautions may only be needed when the scope and duration of the work presents a risk of
injury. If the risk is minor and it is not reasonably practical to take other precautions, then no
action may be needed provided proper training has been carried out.
G4. Personal protection equipment protects only the user/wearer and requires action by the
individual, such as properly wearing and adjusting it, for it to work. Examples include work
restraint equipment which prevents a fall and fall arrest equipment which minimises the
consequences of a fall.
G5. Procedures for WAH are in place, are current and are being followed.
G6. Safety measures, including the following, should be taken by a responsible person prior
to survey / inspection to the satisfaction of the attending surveyor:
a. The equipment’s range of use should be agreed with the operator before using the
equipment;
G7. The operation and training in the use of applicable equipment should be addressed by
the Ship’s Safety Management System / Shipyard’s Occupational Health Management
System and other facility’s management systems (e.g. Vendors).
G8. Barriers, or other equivalent arrangements, should be in place to prevent objects falling
from the work area which may harm any personnel in the vicinity below.
G9. Rescue facilities and procedures and support personnel should be readily available to
permit evacuation in the event of imminent danger and / or to meet an emergency.
G10. When surveyors are working in the vicinity of flush manholes and other small openings
of comparable size in the deck and other working surfaces, such openings should be suitably
covered or guarded, except where the use of such guards is made impracticable by the work
No. actually in progress. In such situations use of appropriate signage should be considered.
136 G11. When surveyors are working around open hatches not protected by coamings or around
(cont) other large openings, the edge of the opening should be guarded in the working area, except
where the use of such guards is made impracticable by the work actually in progress. In such
situations use of appropriate signage should be considered.
G12. When surveyors are exposed to unguarded edges of decks, platforms, flats, and similar
flat surfaces more than 1.5 m above a solid surface, the edges should be guarded by
adequate guardrails, unless the nature of the work in progress or the physical conditions
prohibit the use or installation of such guardrails. In such situations, use of appropriate
signage should be considered.
G13. When surveyors are working near the unguarded edges of decks of vessels afloat, or in
situations where there is a danger of falling into water, they should be protected by personal
flotation devices, in lieu of personal fall protection equipment.
G14. Sections of bilges from which floor plates or gratings have been removed should be
guarded by guardrails except where they would interfere with work in progress. If these open
sections are in a walkway, suitable planks should be put in place, side by side, or equivalent,
should be laid across the opening to provide a safe walking surface.
G15. Gratings, walkways, and catwalks, from which sections or ladders have been removed,
should be barricaded with adequate guardrails.
G16. Surveyors should be familiar with the procedures, preconditions, risks and safety
precautions relating to the work.
G17. Equipment related to WAH is in compliance with relevant and applicable standards.
G18. Class rules normally require that Owners’ / site managers’ ‘Responsible Person(s)’ are
responsible for providing means of access which are suitable and safe for the work to be
carried out. The equipment, where applicable, should be operated/erected by qualified
personnel. Evidence should be provided that the equipment has been properly maintained
and inspected before each use; that formal inspections have been held annually, as a
minimum; that re-inspections have been completed if any modifications from the original
configuration have been carried out.
G19. It should be demonstrated by the Responsible Person that the equipment provided has
been inspected, maintained and operated by trained and qualified persons. These should be
demonstrated to the surveyors by the production of applicable documents, prior to the
equipment being used.
G21. Suitable and sufficient steps should be taken to ensure, so far as is practicable, that in
the event of a fall by any person the fall arrest equipment does not itself cause injury to that
person.
G22. The access and exit arrangements should be safe and clear of obstacles.
G24. Lighting should be adequate to allow safe working. Lighting in a work area may be a
No. temporary arrangement cabled into the area requiring additional protection against possible
trip induced falls. Whenever possible, natural lighting should be provided in the work area
136 during inspection.
(cont)
G25. The tools and equipment used for WAH should be secured against falling.
G27. Surveyors should verify that the necessary arrangements for WAH are suitable for the
intended activity.
G28. No surveyor should carry out a survey from a ‘one-man’ lifting basket.
G29. No surveyor should perform survey using rope access, unless specifically trained,
qualified and authorized.
H1.a. For shipboard work, this aspect should be addressed in the Safety Management
System manual of the ship as part of the risk assessment of ‘shipboard operations’, which is
a requirement of the ISM Code.
H1.b. For work in shipyards and factories, this should be a part of their ‘emergency
preparedness planning’ particularly when the shipyard / factory is certified for Occupational
Health and Safety as per the international standard OHSAS18001.
H1.c. In the event that this is not addressed as stated above, then a situation specific plan
should be prepared to the satisfaction of the surveyor.
i. A rescue operation can only be performed by personnel trained for the task and having
knowledge of emergency procedures and arrangements in place, agreed
communication arrangements, escape routes, status of availability and readiness of the
support team, etc. A surveyor does not meet this standard and should not be a formal
part of any rescue team.
H2.a. Work over sea may be permitted provided the ship is not being navigated and weather
and sea conditions are satisfactory. As a guidance the following may be applied:
i. The weather and sea condition does not exceed Beaufort Sea State Scale 3 which
corresponds to wind speed of 17 to 21 knots, moderate waves of height of about 2 m,
many white caps and possible spray;
iii. A rescue boat is operative and can be launched/retrieved in case a person falls into the
sea;
iv. the visibility is good enough to perform the work and rescue any person that may fall
No. into the sea.
136 H2.b. When working over sea, a safety guard should be present and monitor the surveyor’s
(cont) location over sea at all times. The safety guard should be familiar with and carry out tasks
stated in the safety guard’s duties in connection with work over sea.
H2.c. A life buoy with line and light should be readily available.
H2.d. Everyone working over open sea should wear a life vest and/or flotation device.
H2.e. Overboard discharges etc. should be secured, for example from fire water line.
H3.a. A fall arrest system should be fitted such that there is adequate clearance for it to
deploy, and to prevent the surveyor from hitting an obstruction or the ground before the fall is
stopped.
H3.b. Many recognized practices specify either a guardrail system, safety net system, or
personal fall arrest system to protect the surveyor when exposed to a fall of 1.8 m or more
from an unprotected side or edge. See also D3.
H3.c. Fall arrest procedures should provide for a rescue to be carried out if the surveyor is left
suspended from the working place.
H3.d. Safety nets or airbags should be located as close as possible to the working level to
enhance their effectiveness.
H3.e. Safety nets should be installed as close as practicable under the walking/working
surface on which surveyors are working. As acceptable practice:
ii. The maximum size of each safety net mesh opening should not exceed 230 cm2 nor be
longer than 0.15 m on any side;
iii. The openings, measured centre-to-centre, of mesh ropes or webbing, should not
exceed 0.15 m;
iv. All mesh crossings should be secured to prevent enlargement of the mesh opening;
v. Each safety net or section should have a border rope for webbing. Safety nets should
be installed with sufficient clearance underneath to prevent contact with the surface or
structure below.
H3.f. Safety nets should, as a good practice, extend outward from the outermost projection of
No. the work surface as follows:
H3.g. A fall arrest system should incorporate an integral shock absorbing device for limiting
the forces applied to the surveyor’s body.
ii. where its safe use requires a clear zone (allowing for any pendulum effect);
iii. which otherwise inhibits its performance or renders its use unsafe.
H3.i. Life-lines and anchorages should not be shared. As a good practice, harnesses with
double lanyards should be used.
H3.j. Independent securing should be used for fixing all fall arrest equipment, man-riding belts
or nets. They should not be attached to the scaffolding.
H3.k. When using fall arrest equipment, at least one person should be present in the area
nearby at all times in order to alert and start basic rescue work in case of a fall.
H3.l. Prior to commencement of work, a realistic and safe rescue plan should be in place. The
plan should take into consideration the time for a safe rescue in order to be able to rescue a
person as quickly as possible to prevent consequential injuries (e.g. blood circulation
injuries).
H3.m. There should be a site specific instruction on how required competent personnel are
organized (for instance a rescue team).
H3.n. Surveyors should only use any work equipment or safety device provided to them for
work at height by an employer, or by a person under whose control they work, in accordance
with training or instructions received by them in the use of such equipment or device.
H3.o. Surveyors should always visually check their fall arrest system and anchor point. If
there is any doubt regarding anchor points, defects in harnesses or harnesses that lack the
inspection tag for approval, that harness should not be used.
H4.b. These consist of an anchorage, connectors, and a body belt or body harness and may
include a deceleration device, lifeline, or suitable combinations.
v. correctly worn;
vi. rigged so that the surveyor can neither free fall more than 1.8 m nor contact any lower
level;
vii. fitted with a snap hook on a lanyard or lifeline which is self-locking. When in use, a
carabineer or similar connecting hardware is to be secured to prevent inadvertent
opening;
viii. able to effectively protect a vertical lifeline, lanyard, or safety strap at points of
attachment and elsewhere, as necessary, to prevent chafing or abrasion caused by
contact with sharp or rough edges.
H4.d. Safety harnesses should be used, as necessary, as a PFPS, for fall arrest.
H4.e. Body belts with lanyards should not be used as body support in a fall arrest system due
to the possibility of death or injury from the following causes:
H4.f. PFPS should be inspected prior to each use for wear, damage, and other deterioration.
Defective components should be removed from service.
H4.g. PFPS designed for use with an anchor should be securely attached to at least one
anchor, and each anchor and the means of attachment thereto should be suitable and of
sufficient strength and stability for the purpose of supporting any foreseeable loading.
i. a device that has been purposefully manufactured and installed as an anchor to support
a personal fall protection system;
ii. a substantial structure, such as a beam, column or similar substantial portion of the
No. structure, selected as a point of anchorage where no dedicated anchor device is
available.
136
(cont) H4.j. These points of anchorage generally require some supplemental rigging, such as a
sling, to allow the anchorage connector of a personal fall protection system to connect to the
anchorage.
H4.k. An anchor should be located so a lifeline attached to it is not deflected over a guardrail
or other part of the structure which has insufficient strength to support the maximum potential
load from a fall arrest.
H4.l. Equipment for PFPS should have appropriate marking. Normally, this is in accordance
with the applicable PPE standards and regulations.
i. There are three categories of personal protective equipment (PPE) – most fall
protection equipment is classed as PPE category III, “equipment for mortal danger”, for
example harnesses.
H4.m. Marking does not necessarily mean that a piece of equipment is safe for the task.
H4.n. The manufacturer’s instructions should be checked, for example, to consider whether
the particular piece of equipment is compatible with others being used. Some equipment may
have a lifespan date given by the manufacturer and generally should be disposed of after this
date.
a. use limitations and protection classes suitable for different levels of risk;
H4.p. Any accessories or other equipment should also be checked to verify that they meet the
above requirements.
H4.r. As a minimum, this involves inspection before use on each work shift, and after each
use to arrest a fall. It is also recommended to inspect equipment just before each use if not
already covered by one of the other inspection scenarios. Such inspections are only one
aspect of the overall review and monitoring of conditions and procedures.
a. integrity of stitching throughout the harness, on both outer and inner surfaces;
d. signs of any part of the harness being cut, stretched, frayed, or otherwise damaged;
No.
e. integrity of shackles and straps on the harness;
136
(cont) f. signs of exposure to high temperatures.
ii. With other equipment such as shackles, carabineers, lines, and deceleration control
devices, the examination of equipment should include the following:
a. all metal and other materials for any sign of deformation, wear, stretching, cracks, or
kinking;
b. all metal and other materials for any signs of corrosion or other chemical deterioration;
c. all lines for wear on surfaces, and any potential or actual fraying, kinking, bird caging,
heat fusion, or other damage;
d. moveable parts to verify proper action, and the capability of all locking and other
immobilizing devices to perform their function.
H5. Scaffoldings
ii. have scaffold poles made of metal and scaffold tubes linked by rigid angle couplers;
iv. have good stability with a stable structure and be anchored with diagonal bracing at
regular intervals;
v. have an adequate platform fully boarded with toe boards and guard rails fitted at all
open ends;
ix. have suspension points made of steel wire ropes or chains evenly spaced and as near
vertical as possible;
H5.d. A scaffold tagging system or equivalent method should be in place to record that the
scaffolding or staging is fit for use.
H5.e. Barrels, boxes, cans, loose bricks, or other unstable objects should not be used as
No. working platforms or for the support of planking intended as scaffolds or working platforms.
136 H5.f. Scaffoldings should have sufficient dimensions to allow safe passage, and wide enough
(cont) to allow a person at shoulder width to pass along them easily. This width would normally be
considered to be at least 0.6 m. Where this is impracticable, the situation should be
specifically addressed by the surveyor prior to his or her use.
H5.g. Staging platforms should be fitted with fall prevention arrangements such as guardrails:
i. fixed or rigidly connected; top rail at least 0.95 m above the walking or working
surface;
ii. have an intermediate rail not higher than 0.47 m above the surface;
iii. guardrail systems should be surfaced to protect surveyors from punctures or lacerations
and to prevent clothing from snagging;
iii. so as to prevent any person getting caught between the system and the adjacent
structure;
H6.a. Portable ladders may be used for access to any structural members as a supplement to
and/or additional to permanent means of access.
H6.c. The minimum clear distance between side rails for all portable ladders should be
according to a recognized standard. (For example ANSI A14.2 – Portable Metal Ladders; BS
EN 131 Ladders (Specification for terms, types, functional sizes; Specification for
requirements, testing, marking; User instructions; Single or multiple hinge-joint ladders)).
viii. slip resistant feet should not be used as a substitute for the care in placing, lashing or
holding a ladder upon a slippery surface;
ix. having another worker “foot” the ladder is not an effective means of securing the ladder
and would only be suitable when other means are impracticable;
x. portable ladders should be used on top of bottom or deep stringer platforms so that the
free falling height does not exceed 6 m; if it is necessary to exceed this height, there
should be at least 3 m of water above the highest structural element in the bottom to
provide a "cushion" or a safety harness is to be used; the free falling height above the
water surface should not exceed 6 m.
H6.e. Surveyors should use fall protection equipment when accessing a height more than 4 m
using a vertical ladder.
H6.h. Portable ladders should have rubber caps at both ends and have no visual deformation.
H6.i. Hanging ladders and ladders more than 5 m long may only be utilized if fitted with a
mechanical device to secure the upper end of the ladder.
H6.j. No interlocking or extension ladder should be used unless its sections are prevented
from moving relative to each other while in use.
H6.k. When climbing ladders in tanks containing water, the surveying personnel should wear
“flotation” aids. A flotation aid is a simple form of lifejacket which does not impede climbing or
a self-inflatable lifejacket.
H6.l. Aluminium ladders may be used in cargo tanks, but cannot be stored in the cargo area
or other gas dangerous spaces.
i. where the work is of short duration – ladders are not suitable for work where they are in
one position for 30 minutes or more; longer duration or regular jobs generally justify a
better standard means of access (e.g. a tower scaffold, podium step or cherry picker)
rather than a ladder or stepladder;
ii. where the risk is low, i.e. because the nature of the work makes a fall unlikely or, in the
event of a fall, the nature of the fall would be unlikely to cause injury;
iii. for “light work” – ladders are not suitable for strenuous or heavy work;
iv. for work that does not involve carrying heavy or awkward tools or equipment;
v. where a handhold is available both for climbing the ladder and in the working position;
No.
vi. where three points of contact (hands and feet) at the working position can be
136 maintained. On a ladder where the surveyor cannot maintain a handhold, other than for
(cont) a brief period of time, other measures will be needed to prevent a fall or reduce the
consequences of the fall.
H6.n. New ladders should be marked in accordance with their conditions and class of use.
H6.o. Before using a ladder or stepladder, surveyors, should check for satisfactory condition
of the ladder and confirm that it is marked in accordance with recognized standards. (For
example ANSI A14.2 – Portable Metal Ladders; BS EN 131 Ladders (Specification for terms,
types, functional sizes; Specification for requirements, testing, marking; User instructions;
Single or multiple hinge-joint ladders)).
H6.p. Over reaching is a significant risk when working from a ladder. It may appear tempting
to try to complete all the work without having to go down the ladder and move it. Over-
reaching while working from a ladder is a major cause of falls, even for experienced
surveyors.
ii. fitted with controls at the bottom able to override controls in the basket;
v. inspected and have controls and safety functions tested before each use;
H7.b. The MEWP should be subjected to a thorough examination at least every six months.
H7.d. MEWP should be operated from within the basket, by a trained person.
i. MEWP operators should have attended a recognised operator training course and
received a certificate, card or ‘licence’, listing the categories of MEWP the bearer is
trained to operate;
iii. in addition to formal training for the type of MEWP, operators should have
familiarisation training on the controls and operation of the specific make and model of
MEWP they are using.
H7.g. When working over water a personal floatation device should be worn instead of a
harness.
H7.h. Hydraulic arm vehicles or aerial lifts (‘‘Cherry Picker’’) may be used to enable the
examination of the cargo hold structure on bulk carriers not accessible by permanent ladders.
i. ‘cherry pickers’ may be accepted, for use up to 17 m above the tank top;
ii. the standing platform should be clean and fitted with anchor points for attaching fall
arrest systems;
iii. the work platform should be fitted with effective guard rails and toe boards.
H7.i. For equipment provided with a self-levelling platform, care should be taken that the
locking device is engaged after completion of manoeuvring to ensure that the platform is
fixed.
H7.j. Lift controls, including safety devices should be serviceable and should be operated
throughout the range prior to use.
H7.k. Potential crushing hazards (for example booming into the overhead, pinch point) should
be considered.
H8.a. Basket platform and lifting gear should be certified for applicable safe workload and
certified for transportation of personnel.
H8.b. Crane-hook should have a safety latch and an extra safety wire between the hook and
the basket.
H8.c. Crane hoisted appliances should not be used during adverse weather conditions.
H8.e. The basket should be connected to a crane hoist line that is fully braked. No free fall
rigs should be used. Hydraulic cranes should have “power-up” and “power-down”.
H8.f. Surveyors should be briefed about proper use of the basket prior to boarding a crane
hoisted basket.
H8.g. Cranes, winches and other devices used for hoisting and lowering movable work
platforms should:
iii. not be equipped with a free running boom or hoisting winch controlled only by brakes.
H8.h. If a moveable work platform is suspended from a crane, winch or other device over a
No. structure that cannot safely support its weight or if other hazards exist below the platform
(e.g. water deep enough to present the hazard of drowning), lower limit travel devices
136 compatible with the hoist system should be used to ensure the platform cannot be lowered
(cont) beyond the safe lower limit of travel.
H8.i. If the lower limit travel devices required above are not practicable, the Responsible
Person should ensure that work procedures that will minimize the risk of the platform going
beyond the safe lower limit of travel are used.
H8.j. A trial lift for a work platform suspended from or attached to a crane or hoist or mounted
on lift trucks should be performed at all work locations before the platform is occupied.
H8.k. High lift trucks should not be moved from location to location while a surveyor is on the
work platform. Minor adjustments in horizontal positioning should only be carried out at the
request of the surveyor on the work platform.
H8.l. Work platforms that can be elevated to a height of greater than 1.2 m should have a
means of fall protection such as guardrails or a means for securing surveyors such as a body
belt or lanyard.
ii. fall protection should be selected and used in circumstances where a fall can occur;
I.a. The following minimum set of Personal Protective Equipment should be made available to
surveyors when WAH:
i. protective clothing;
vii. strap provided flashlight, as necessary and optional head torch where appropriate;
I.b. The surveyor should use the necessary personal safety equipment according to the
specific conditions and the survey being carried out.
End of
Document