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Work at Height Regulations 2004 - Single Rope Working Group - Arboriculture and Forestry Advisory Group (AFAG) Meeting (22/01/2004)

This meeting was held between the HSE and representatives of the Arboricultural and Forestry Industries to discuss the proposed Work at Height Regulations 2004.

The aim of the meeting was to discuss issues arising from the European Directive 2001/45/EC and the UK legislation that will be used for its implementation. This will be called the Work At Height Regulations 2004. The meeting concentrated on Personal Fall Protection Systems; Interpretation of Schedule 5; Risk Assessment concerning twin and single rope use (including past experiences of using a ‘back- up' safety rope) and current industry guidance; and, the development of a strategy for responding to the Health and Safety Commission's Consultation Document.

The main issue was, and still is, the use of a safety back-up rope whilst tree climbing, and the provision of two anchor points in case one anchor point should fail. The group discussed current working methods, current industry guidance, current risk assessment systems, and the limitations of working with a back-up rope etc.

The Regulations will be similar in nature to recent legislation such as PUWER and LOLER. They will contain a framework in which all work at height will have to take place. Simply put, it will mean that, if possible, work shouldn't be done at height; otherwise working platforms and other collective safeguards should be used. If this isn't possible then personal fall protection systems such as rope access and work positioning can be used.

The Arboricultural Industry currently uses the Arboricultural Association/FASTCo Code of Practice A Guide to Good Climbing Practice and associated AFAG Safety Guides e.g. AFAG 401 Tree Climbing Operations . To support these, the Arboricultural Association provides a Risk Assessment package for commercial arboriculture, which has been recently updated. (Contact the Arboricultural Association for details of associated courses - Tel. 01794 368717)

Unfortunately, the Guide to Good Climbing Practice is now out of print. Bearing in mind that a revision of the guide is due in order to bring it up to date and to meet the Work at Height Regulations, the group decided to take this on board and produce a new Code of Practice for work positioning techniques etc. This revision is currently being undertaken.

In summary, if the arboricultural and forestry industries continue to work to ‘current best practice' and carry out appropriate risk assessments, they should be able to work within the regulations.

Schedule 5, Part 3 (3) of the new Regulations as currently written states: -

“The system may comprise a single rope where: -

a risk assessment has demonstrated that use of a second line would entail higher risk to persons;

and (b) appropriate measures have been taken to ensure safety.”

Therefore, with some fine tuning the industries should be able to work within the regulations.

The HSC Consultation Document has to be returned by 2 nd April 2004 with a view to the Regulations being implemented from 19th July 2004. The meeting agreed to return one document from each representative body i.e. Arboricultural Association, International Society of Arboriculture (UK /I), Forestry Contracting Association, European Arboricultural Council, Tree Care Industry Association and Forestry Commission. This is also in hand.

Representatives present:

  • Liam McKeown & Chris White (AA)
  • Mick Cottam (EAC)
  • Simon Richmond (LANTRA)
  • Jim Dewar (FC)
  • Ben Hudson (FCA)
  • Paul Elcoat (ISA UK /I)
  • Adrian Hodkinson (HSE)
  • David King (HSE Policy)

I hope the above will ease any anxieties that treeworkers may have about the proposed regulations. Please be aware of our good working relationship with HSE, which enables us to maintain an avenue of negotiation on issues like this.

Thanks to all the above volunteers who attended the meeting, and a special thanks to John Cousins and Mountain Leader Training UK who hosted an Adventure Activities Sector meeting here in North Wales . This meeting, which I attended, discussed similar issues in relation to the Outdoor Activities sector and was extremely useful in providing comparisons with the arboricultural and forestry sectors. But that's another story!

Liam McKeown (Treevolution)

The consultative document which includes the draft regulations, guidance, mother EU Directive and background details can be found at: www.hse.gov.uk/consult/condocs/cd192.pdf

(The consultation period ended April 2nd 2004).


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