Dealing with emergencies when working at height

When it comes to estates management, a large amount of PPM, reactive, or installation work occurs on rooftops across the country on a daily basis, and healthcare estates are no different. HVAC systems, lift motor rooms, mobile phone antenna sites, photovoltaic systems, fume extracts, lightning protection systems, water storage tanks, and many other types of systems and equipment, are located on the roofs of our healthcare buildings.

So, the question is, are the people who are doing this work, working at height? ‘Working at Height’ is defined in The Work at Height Regulations 2005 (WaHR 2005) as any work undertaken in any place above, at, or below, ground level, from which, if measures were not taken, a person could fall a distance liable to cause injury. This includes gaining access to or egress from such a place of work except by means of a staircase in a permanent workplace.

What this means is that any person who is working on a roof that they have had to gain access to via an external fixed ladder, a scaffold, a portable ladder, a MEWP (mobile elevating work platform), or any other similar means of access equipment, is indeed working at height. This in turn means that the requirements of the WaHR 2005 must be followed in full.

Properly planned and adequately supervised

Regulation 4, ‘Organisation and planning’, states that every employer shall ensure that all work at height is properly planned, appropriately supervised, and carried out in a manner which is as safe as is reasonably practicable. Essentially this means that a full Safe System of Work is required, and the use of the word ‘shall’ also implies that this is an absolute requirement. (If a requirement in a regulation is ‘absolute’, then the requirement must be met regardless of the cost, time, or effort incurred in doing so. In other words, it is not optional; it is mandatory). This point is important, as there have been multiple Health and Safety Executive notices and fines issued, and even prosecutions in the past, specifically for organisations working at height without written Safe Systems of Work.

Regulation 4 then goes on to say that reference to proper planning of work includes planning for emergencies and rescue. It is this point I wish to focus on further. Unfortunately, I have seen so often in the past that organisations will either not have an Emergency and Rescue Plan for Work at height at all, or — on the rare occasion that they do — it is normally only one or two lines to the effect that ‘in an emergency we will phone 999’. It is important to note that reliance on the emergency services alone will not be sufficient to comply with the regulations (as stated in the 2020 HSE document HSG33 — Health and safety in roof work).

So, now we have established what working at height is, and what the requirements of the regulations are, what elements should be considered in relation to a Work at height Emergency and Rescue Plan?

Training

Those who are involved in the execution of the Emergency and Rescue plan should be competent, and will need appropriate training in order to fulfil their role. Most times this will mean that those performing the work will also need to be trained, and will be ‘self-sufficient’ in terms of emergencies and rescue. There are plenty of training providers who can teach rooftop safety and casualty extraction courses, for example. For extreme circumstances where there is high-risk work being undertaken, or where the location requires it, it is not uncommon to see organisations contract in a dedicated specialist, highly trained, rescue service, much like you would see for Confined Spaces work. Whatever the level of risk, and whichever training you decide is suitable, it should be listed in the Emergency and Rescue Plan, and individuals should be checked for competency and currency, i.e. is their training still in date, before the work commences.

 Equipment

It is important that the correct equipment is identified and procured in order to enable workers to carry out the Emergency and Rescue Plan if needed. This will require an assessment of the work being undertaken, and the location of the work, to ensure that the equipment selected will be suitable. Training will normally have a bearing on which equipment you go for, as the equipment procured will need to be something that people are familiar with, and quite often the manufacturer’s instructions will dictate that this type of equipment requires formal training before its use, so it’s always worth asking a training provider for their advice when it comes to sourcing equipment. Once equipment has been sourced, then it will need to be properly inspected, maintained, and stored, in accordance with the manufacturer’s instructions.

First aid

The Health and Safety (First-Aid) Regulations 1981 require employers to provide adequate and appropriate equipment, facilities, and personnel (via training) to ensure that their employees receive immediate attention if they are injured or taken ill at work. What is ‘adequate and appropriate’ will depend on the circumstances — including the location and the nature of the work. This will require a risk assessment to determine the specific requirements for your organisation.

The trap that many fall into here is that they arrange a standard one- or three-day training course for everyone across the board, and hope that this will be sufficient (often it will be sufficient for office-type work). Remember that the training should be relevant to the location and nature of the work; we should be cognisant of what the foreseeable injuries may be, and then we can plan to deal with those injuries.

In the context of work at height, the foreseeable injuries may include (depending on the location and nature of the work) one or more of the following:

Suspension intolerance.
Hypothermia and Hyperthermia.
Radio Frequency (RF) burns (exposure to high RF fields and contact burns).
Unconsciousness and impact trauma.
Fractures (closed or open) and dislocations.
Open wounds and serious bleeding.
Spinal cord injury.
Impaling.
Electric shock.

Now, you may be thinking that a one-day or three-day standard first aid course does not necessarily cover all of those foreseeable injuries, and you would be right. So, what are the options? In fact there are plenty of specialist training providers who can provide bespoke first aid training, and there are even specific work at height first aid courses available.

Your Emergency and Rescue Plan should include fully comprehensive first aid arrangements that ensure that any injury can be dealt with in a timely and efficient manner. Remember, you cannot rely solely on the emergency services; this includes hoping that a paramedic or ambulance crew will put themselves at risk to go up onto a roof to treat someone — they may refuse if they think it is unsafe.

Communication

It seems like an obvious thing to ensure that we communicate correctly, but unfortunately, we don’t tend to be very good at this. There is always an assumption that if there is a problem, then it will get resolved. It is an assumption, however, that has a habit of catching us out.

There should be measures in place to enable those performing the work to communicate to others (e.g. permit issuers and site security), and vice versa. From this communication we can then initiate rescue or evacuation procedures, or we can summon further help if required. The emergency can be communicated in a number of ways — for example by mobile phone or radio, or by means of a ‘lone worker’ alarm, or we can even utilise the ‘old-school’ method of going and telling someone that something is wrong.

Whatever communication tools and methods you use, be sure that your emergency communications are clear, contain specific and adequate information, are ‘in sync’ with other information being disseminated, and that they are tested regularly, including before and during the work. Communication is especially important when considering emergency situations like a fire evacuation. Not every building has call points, sounders, or visual beacons on the roof, and this is an important but often overlooked point.

I experienced the downside to this myself a few years ago. I was on the roof of a large building teaching the Facilities staff how to attach themselves to a safety line system correctly, when we looked down into the car park and noticed it was full of people, including some who appeared to be wearing hi-vis vests. There had been a fire evacuation, and we were none the wiser.

Luckily for us it was only a small fire, and dealt with very quickly, but if it had been anything significant, we may have become stuck on the roof with no way down. I learned that day the importance of checking that there is a suitable means of communicating the need to evacuate to anyone who may be working on a roof where there are no alarm systems. You can’t always assume that someone will come to get you.

Firefighting

If the work itself presents a risk of fire, and a hot works permit is required, we may also need to consider suitable firefighting methods. However, firefighting should only be carried out by someone with the correct training and the correct equipment; otherwise it is not safe.

Once effective communication is established, then it is important to agree on a method of evacuation should the need occur. The following will need to be considered:

Evacuation route: What is the primary route for evacuating the work area? Equally, where possible, a secondary route should always be identified in case the first is compromised. This should be agreed prior to the work starting, and written into the plan.

Muster points: Where will everyone move to once they have evacuated? Although site inductions often tell people they are to go to ‘a muster point’ in the event of an evacuation, it is often an overlooked point that this isn’t followed up. People should actually be shown the muster point closest to their point of work, and we should ensure that they are familiar with how to get to it, especially if they are working on the roof. Remember that a muster point should be in a safe location away from other hazards.

Method of rescue and casualty extraction

The last thing to consider is: How do we rescue someone who is need of help, and how do we recover them to a safe location where they can receive further treatment, or be moved to another location, such as A&E? Now this initially seems complicated, and I sometimes get ‘pushback’ on this, with people (including rescue professionals) telling me ‘It’s impossible to predict every scenario, so therefore we can’t write this part down.’ Consequently, this part of the plan tends to look pretty predictable, with most people writing something to the effect that: ‘We will see what happens when it gets to it, and take it from there.’

My answer is that the belief that a method can’t be written is wrong. The trick for those who need to write this part of the plan is to start with talking yourself through the steps you would take in a casualty recovery situation, and to remember to use your training. The conversation normally goes something along these lines: I ask them what the first step of casualty management is? They reply: ‘I would assess the immediate area for any danger to myself or ongoing danger to the casualty.’ ‘Good,’ I respond, ‘write that down and call it step 1.’ ‘What’s next?’ They respond: ‘Then I would try to get a response from the casualty, verbally at first.’ ‘OK, so write that down; that’s step 2; lets carry on’, and so on.

A comprehensive method

If we break it down in this way, then we can begin to write a comprehensive method of casualty extraction that begins with assessing the casualty etc, before progressing all the way through to actually extricating the casualty from the scene. I appreciate that there may well be variations, and that the casualty extraction progresses will be dictated by how the casualty was injured, and where they injured themselves in the first place. In this instance we simply need to write different versions of the method to allow for different foreseeable outcomes. For example, I would write an extraction method for someone who was hanging from a harness and lanyard, and a separate one for someone who has slipped on the roof and broken their leg. I would then write a third method that covers medical situations such as a heart attack etc.

The good thing is that you will not have to do it from scratch every time someone performs work at height-related activity on your site. As regards your own internal staff, once the initial work is done, and plans are in place for all areas of concern, then hopefully things won’t change too often, and they will just need to be reviewed as part of an annual audit. However, if you are bringing contractors in to perform any work at height on your behalf, then the responsibility is placed onto them. Given that you would normally ask them for the usual information prior to them attending site, such as a copy of their risk assessment, and for evidence of their staff’s competency etc., you should also be asking them to provide you with a detailed Emergency and Rescue Plan that ensures the safety of their staff while they work on your site.

The key thing to remember is that there should be a suitable and sufficient plan in place for all work at height, and that it should be agreed upon before the work starts, not as an afterthought. Please feel free to contact me if you have any questions or would like help with your plan.