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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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