Background to the HSE decision on two rope working
Background to the HSE decision on two rope working
15/0 Modified: 15/08/2019
History
The issue of guidance to climbing arborists on the use of ‘two separate and independently anchored lines’ as a legal requirement goes back to 2003 when the EU Directive on Work at Height was circulated and to the subsequent introduction of the Work at Height Regulations (WaHR) in 2005, under the Management of Health and Safety at Work Regulations.
Prior to this, the first edition of the Guide to Good Climbing Practice in 1998, published jointly by the Arboricultural Association (AA) and the Forestry and Arboriculture Safety and Training Council (FASTCo), recommended the use of supplementary anchor points and the use of two separate lines ‘wherever possible’.
When the EU Directive first came to my attention I was employed as Development Manager for Forestry and Arboriculture at Lantra Awards. As part of that role I managed a network of 12 Training Standards Officers (TSO) and Regional Verifiers (RV) on behalf of both Lanta and NPTC, each of which supervised and set the standards for training and assessment for craft-level skills, including aerial tree work, for all UK registered instructors and assessors. We organised annual standard setting with the TSO/RVs who then cascaded the standard setting in their respective regions to the instructors and assessors.
In a similar pattern to the recent developments, we met with the HSE representative for arboriculture at that time, Adrian Hodkinson, to explain how the proposed EU Directive, if brought into UK law, would impact on the arboricultural industry (in particular Schedule 5 of the proposed regs, the requirement for a ‘safety back up line’). The initial response from HSE was that the arb sector was too small to justify re-writing or amending the wording which, in its estimation, was perfectly suitable (and reflected existing practice) for the majority of industrial work at height activity.
We then offered to carry out research during 2004 into the possibility of changing arboricultural work practice to comply with the proposed regulations. We arranged for our annual standard setting meeting with the TSO/RVS to explore the issues. Then each TSO/RV delivered their local standard setting by inviting comment, practical demonstrations and explorations in a range of tree forms with all the attending instructors and assessors. This process resulted in 12 separate practical demonstration events, involving around 250 professional climbing arborists, which were recorded, along with conclusions from each group, during the summer of 2004.
Meanwhile, a meeting was set up with HSE at Myerscough College, for the 3rd–5th November 2004, to discuss and then demonstrate the issues to HSE personnel.
HSE agreed to commission a report on the outcomes of this process which resulted in the publication of: Determination of rope access and work positioning techniques in arboriculture www.hse.gov.uk/agriculture/pdf/wahreport.pdf
This document was used as the basis to update the guidance for industry with the 2005 publication of the Guide to Good Climbing Practice (GGCP), published by the AA. While this version of GGCP accurately reflects the conclusions of the report, it has been observed that it does not fully describe all the detailed requirements for compliance with the WaHR 2005.
Jump forward 10 years and the Industry Code of Practice for Arboriculture – Tree Work at Height (ICoP) was published in 2015. This document is written for the ‘Responsible Person’ within arboricultural contracting companies, setting out the principles for managing work at height. It sets out the principle that all tree climbing activities using rope and harness can be described as ‘work positioning’ and in doing so removes the requirement under WaHR Schedule 5, Part 3 for a higher level of compliance when using ‘rope access’ techniques. While this was broadly accepted by HSE at the time (the arb representative at the time was Frances Hirst), the current arb representative, Stuart Parry, has informed us that the HSE cannot support this approach now.
Recent events
In early 2019 the HSE was invited to comment on the first of the AA’s five Technical Guides: Tree Climbing and Aerial Rescue (TG1). While broadly supportive, it has taken issue with the way in which climbing systems have been defined in the draft and, regardless of the specific definitions of ‘work positioning‘ or ‘rope access’, suggests that our industry has not embraced the spirit of the WaHR in respect to Schedule 5. The HSE has observed that there is an assumption that a single line will suffice in most situations and that while supplementary anchors may be widely used at point of work, most access and movement around the crown is carried out on a single line (whether a doubled/moving rope or a single/stationary rope technique is employed).
Following correspondence on this issue, Stuart Parry, HM Inspector of Health and Safety, Forestry, Arboriculture and Agricultural Machinery Team, Engagement and Policy Division, confirmed HSE is adamant that its definitions of work positioning and rope access will not be changed and its inspectors will use these definitions in any investigation they may need to conduct, e.g. following an accident or incident.
The AA arranged a meeting with HSE and Chris Cooper-Abbs, the lead author of the TG1, on 11th March. The meeting was attended by Dr Andrew Turner, Acting Head of Vulnerable Workers, Agriculture, Waste and Recycling Team, Operational Strategy Team, Engagement and Policy Division, and Stuart Parry of HSE, plus Chris Cooper-Abbs and Simon Richmond. We drew attention to the fact that the ICoP takes the ‘work positioning’ approach for all climbing systems used in tree work, but, as outlined above, Andrew and Stuart stated that despite the HSE support for the ICoP they could not endorse this approach.
We then re-drafted the relevant section in TG1, Section 8, with a broader approach and stronger emphasis on the use of two points of attachment, highlighting the risks of fall from height and other amendments which we hoped HSE would see as supporting its objectives. However, this too was rejected as not meeting the full requirements of WaHR, albeit with some helpful suggestions for re-phrasing.
In a subsequent phone call Stuart offered to meet with us for a demonstration day, where we would have the opportunity to explain how current arboricultural climbing systems were planned and undertaken, to demonstrate where use of two-rope systems could increase risk and to answer any questions the HSE might have on technical issues.
Demonstration day: 10 June 2019
We set up a demonstration day at Stoneleigh Deer Park Golf Club, Coventry, on 10 June. The following were present:
- Simon Richmond, Senior Technical Officer, AA
- Chris Cooper-Abbs, lead author for TG1
- Matt Brooker, author for TG1 and demonstration climber
- Ben Rose, demonstration climber and SRT expert
- Jo Hedger, demonstration climber and world tree climbing champion
- John Trenchard, tree climbing trainer/assessor and representative for Lantra Awards
- Rob Blake, tree climbing trainer/assessor and representative for C&G NPTC
From HSE:
- Andrew Turner
- Stuart Parry
- Paul McGann (WAH specialist)
- David Wooley (HSE Photographer)
David Wooley took video footage and still photos of the demonstrations and of some discussions around the tree climbing demonstrations.
Demonstrations were provided of basic and advanced climbing techniques using both doubled/ moving rope and single/stationary rope systems, in small trees, trees with limited main anchors and large open-grown and dense-canopy trees. There was constructive and detailed discussion about how techniques were used in the industry and clarification provided on HSE’s understanding of different applications.
A meeting was then arranged at AA HQ with Stuart Parry and Andrew Turner, with Chris Cooper-Abbs and AA staff, on 2nd July. At this meeting Stuart confirmed that HSE will not alter its position on interpreting the definitions relating to rope access and work positioning. He acknowledged that this does not mean substantial change to the interpretation of the use of two ropes during work positioning – the use of a ‘reasonably practicable’ judgement is still applicable, although he said that HSE inspectors would expect the norm to be that two points of attachment are used ‘for most of the time’. However, Stationary Rope Technique (SRT), whether used for direct access into the tree or as a work positioning technique (SRWPT), will be defined as ‘rope access’ and thus be subject to the higher requirement for compliance, i.e. that:
‘the system may comprise a single rope where:-
A risk assessment has demonstrated that the use of a second line would entail higher risk to persons; and
Appropriate measures have been taken to ensure safety.’
(WaHR 2005, Schedule 5, Part 3)
A risk assessment has demonstrated that the use of a second line would entail higher risk to persons; and
Appropriate measures have been taken to ensure safety.’
(WaHR 2005, Schedule 5, Part 3)
Accident statistics
The HSE has consistently argued that, despite the good practice guidance that we have been working with for the last 15 years, the number of accidents in our sector remains unacceptably high – indeed, it states that the arboricultural sector has the highest accident rate per capita of all UK industries.
Clearly this is something we all would wish to change. However, there has always been some scepticism of these claims, as there are no hard and reliable statistics specifically for our sector.
There is no SIC (Standard Industrial Classification) code for accidents specifically in arboriculture, and despite prolonged lobbying from the AA and other sector representatives, the HSE claims it is unable to introduce this because the codes are tied to international standards. This means that while it is relatively easy to keep records of fatal accidents within the sector, it is much harder to maintain reliable data for the details of injuries.
However, in 2018, HSE analysed RIDDOR reports for the period April 2017–March 2018 by searching for key words. Although heavily caveated as not being a comprehensive record, the findings were published in an open paper (AFAG 33/02) which was presented at the November 2018 AFAG meeting. According to the analysis, there were 117 recorded RIDDOR-reportable incidents in arboriculture during that period. Of these, 23 were falls from height, of which one was fatal, 6 resulted in fractured vertebrae, 3 multiple fractures, 5 lower limb fractures and fracture to ankle, ribs and wrist.
At this point there is no comparable set of accident statistics for previous years that might allow us to make a better-informed judgment of an improved safety record or otherwise. Having said this, there is no doubt that accidents do occur, some of which result in fatal or life-changing injuries. As the lead body for the sector it is our responsibility to do all we can to prevent such accidents.
The way forward
This will be a change that will take time to implement and filter through our varied workforce; it will add time and cost to tree climbing operations but will also demonstrate the increasing professionalism and drive to maintain compliance in our sector. There is no doubt that, as larger and more compliant contractors will be the first to adopt this approach, there will be a cost (in time, resources and money) which will add to the burden of the most compliant companies to remain competitive in our unregulated sector.
However, we have seen how the effects of imposed change become implemented over a period of years. For example, the requirements of the ‘Hierachy of Work at Height’ encouraging the use of Mobile Elevating Work Platforms (MEWPs) for tree work have resulted in a period of significant technological development, producing MEWPs that are suitable for tree work and becoming more and more competitively priced. It is very likely that technology will also answer some of the current challenges to the use of two ropes.
The decision to fully adopt the two-rope approach will also have a significant effect not only on current practitioners but also on the training and assessment network related to these activities. As a result of this shift in approach we will also be revising the Industry Code of Practice for Tree Work at Height (ICoP).
The imminent publication of the Technical Guides and subsequent revision of the ICoP represent an opportunity to provide industry standards that will reduce the risk of accidents and promote safe working and compliance with the law. We are putting plans in place to revise the wording in the current draft of TG1 and also identifying areas in the ICoP that may need to be revised in light of these decisions.
The Arboricultural Association is committed to helping our industry achieve an improved safe working environment. We are therefore keen to work with all stakeholders in a positive, constructive and collaborative approach to making this change, which can only be seen as positive if the outcome is to reduce the number of accidents.
We have had further meetings with HSE, to press for more detailed information on accident statistics and to request support for better recognition of the professionalism of our industry. We will also work with the HSE to agree parameters and provide guidance on the mitigating circumstances where it might be appropriate to conclude in a risk assessment to use a single rope, and these details will be set out in the Technical Guide.
Simon Richmond,
Senior Technical Officer, Arboricultural Association.
Senior Technical Officer, Arboricultural Association.
15 August 2019
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