Working at Height Policy/Procedure  

Last Reviewed: 20/03/26

Next Review Date: 20/03/2027

1. Purpose

The purpose of this policy and procedure is to ensure that all work at height is properly planned, risk assessed, supervised where necessary, and carried out safely in order to prevent falls and reduce the risk of injury or fatality.

The Company will, so far as reasonably practicable, avoid work at height where the task can be completed safely from the ground. Where work at height cannot be avoided, the safest suitable means of access and work equipment will be selected to prevent falls and, where necessary, minimise the distance and consequences of a fall.

This policy supports the Company’s Health and Safety Policy and forms part of the Company’s arrangements for managing work at height.

2. Scope

This procedure applies to all personnel involved in work at height on behalf of the Company.

This includes, where relevant:

• use of Mobile Elevated Work Platforms (MEWPs)

• work from fixed platforms

• access to silos and plant

• installation, maintenance, and deinstallation of HDS equipment on silos and plant at asphalt plants and quarries

• installation / deinstallation of site equipment on asphalt pavers and rollers

• any other task where a person could fall a distance liable to cause injury

3. Legal Requirements

This procedure is intended to support compliance with:

• the Work at Height Regulations 2005

• the Health and Safety at Work etc. Act 1974

• the Provision and Use of Work Equipment Regulations 1998 (PUWER)

• the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER), where applicable.

4. General Principles

Work at height must be:

• properly planned

• appropriately supervised where necessary

• carried out by competent persons

• undertaken using suitable equipment

• supported by suitable risk assessments, RAMS, and rescue arrangements

The hierarchy for work at height must be followed:

• avoid work at height where reasonably practicable

• where work at height cannot be avoided, prevent falls using the safest suitable work equipment and working methods

• where the risk of a fall remains, minimise the distance and consequences of a fall.

5. Responsibilities

Managers

Managers are responsible for:

• ensuring suitable risk assessments and RAMS are completed

• ensuring the safest suitable method of work and access equipment is selected

• ensuring work is planned and supervised where necessary

• ensuring rescue arrangements are in place before work begins

• ensuring workers are trained, competent, and medically fit where required

• ensuring permits to work are obtained where required by the site

• ensuring work does not proceed where conditions are unsafe or controls are inadequate.

Workers

Workers are responsible for:

• following the relevant risk assessments, RAMS, site rules, and safe systems of work

• using access equipment, PPE, and fall protection correctly

• carrying out required pre-use checks

• not working beyond the limits of their training or competence

• reporting hazards, unsafe conditions, defects, or concerns immediately

• ensuring permits to work are obtained where required by the site

• stopping work and informing management if the task cannot be carried out safely.

6. Risk Assessment and Planning

Before any work at height is carried out, a suitable and sufficient risk assessment must be completed.

This must consider, where relevant:

• the task and method of work

• the location and site conditions

• type of access equipment required

• condition of fixed platforms

• weather conditions

• access and egress

• dropped object risks

• proximity to overhead lines or plant

• surrounding traffic, site activity, and exclusion zones

• rescue arrangements

• competence and supervision requirements

Work at height must not proceed unless the assessment shows that the task can be completed safely with appropriate controls in place.

7. Planning the Work / RAMS

A suitable RAMS / method statement must be in place before work begins where required.

This must set out, where relevant:

• the work to be carried out

• the access equipment to be used

• control measures

• fall protection arrangements

• exclusion zones

• emergency and rescue arrangements

• PPE requirements

• training and competence requirements

The RAMS must be communicated to all relevant personnel before work begins.

8. Selection of Work Equipment

The safest suitable work equipment must be selected for the task and environment.

This may include:

• fixed working platforms

• MEWPs

• ladders or steps, only where suitable and justified by risk assessment

Equipment must be appropriate to:

• the working height

• duration of the work

• frequency of access

• condition of the surface / ground

• work activity being undertaken

• need to carry tools and materials

• rescue arrangements.

9. Permits to Work

Where required by the asphalt plant, quarry, or site operator, a Permit to Work must be obtained before work at height begins.

It is the responsibility of the site / client to determine whether a permit is required under their arrangements, but the Company must ensure:

• the requirement is checked before work begins

• any permit conditions are understood and complied with

• work does not begin until the permit is in place where required.

10. Competence and Training

All personnel involved in work at height must be trained and competent for the task they are carrying out.

Training may include, where relevant:

• Work at Height Awareness

• IPAF training / certification for MEWP use

• manual handling

• use of PPE and fall protection equipment

• emergency and rescue arrangements

• task-specific instruction

Managers must ensure that competence is maintained and refreshed where required.

Where a task involves specialist work equipment or rescue responsibilities, only suitably trained and competent personnel may undertake the work.

11. Personal Protective Equipment (PPE) and Fall Protection

PPE and fall protection equipment must be selected based on:

• the task

• risk assessment

• method of access

• manufacturer guidance

• site requirements

This may include:

• safety helmets, including chin straps where required

• suitable footwear

• high-visibility clothing

• eye or hearing protection where required

• harnesses and lanyards where required

Harnesses and lanyards must only be used where appropriate for the task and must be attached to suitable anchorage points in accordance with the relevant safe system of work and manufacturer guidance.

12. Inspection and Maintenance of Equipment

All equipment used for work at height must be suitable, maintained, and inspected as required.

This includes, where relevant:

• MEWPs

• harnesses

• lanyards

• anchor points

• ladders

• fixed platforms

• other access or fall protection equipment

Pre-use checks must be carried out before use.

Any defective, damaged, or unsuitable equipment must be removed from service and reported immediately.

Where equipment is hired, site-provided, or supplied by others, its suitability and condition must still be checked before use, and relevant inspection, maintenance, or examination records must be confirmed where required.

Inspection, maintenance, and examination records must be available where required.

13. Working at Height Safety Measures

Suitable control measures must be in place before work at height begins.

These may include:

• guardrails and toe boards on fixed platforms

• suitable and certified anchor points where fall protection is required

• exclusion zones below the work area

• securing tools and materials

• avoiding overreaching or leaning from platforms

• limiting materials taken to height to those necessary for the task

• ensuring surfaces are stable, clean, and suitable.

14. Ladders and Access

Ladders must only be used where the risk assessment shows they are suitable for the task, the work is low risk and short duration, and more suitable work equipment is not justified.

They must not be used as the default working platform where a safer alternative is available.

Where ladders or stairs are used for access:

• they must be in good condition

• access must be safe and stable

• three points of contact must be maintained where appropriate

• handrails must be used where provided.

15. Safe Access and Egress

Safe access and egress must be maintained at all times.

This includes:

• ensuring platforms, stairs, and ladders are safe to use

• keeping access routes clear

• maintaining adequate lighting where required

• ensuring exclusion zones are in place where necessary

• preventing unauthorised access into hazardous areas below the work zone.

16. Weather Conditions

Weather conditions must be assessed before and during work at height.

Work at height must be suspended where conditions create an unacceptable risk, including:

• high winds

• heavy rain

• snow

• ice

• poor visibility

• other adverse conditions affecting stability or safe use of equipment

Wind speeds must not exceed manufacturer limits for equipment.

If conditions change unexpectedly, work must stop and the task must be reviewed.

17. Rescue and Emergency Procedures

Work at height must not begin unless a suitable rescue plan is in place, communicated, and understood by those involved.

The rescue plan must be appropriate to the specific task, access method, and site conditions.

This must consider:

• operator incapacitation

• MEWP failure

• entrapment

• fall arrest activation

• emergency communication

• emergency services access

• trained ground support where required

Emergency contact arrangements must be known before work begins.

See Annex A – Rescue Plan.

18. Lone Working Considerations

Where work at height may involve lone working, the rescue arrangements must be carefully assessed before work begins.

If a second operator is not present:

• there must be a designated trained person on the ground who can operate emergency descent or assist in the rescue arrangements, where required

• communication arrangements must be in place

• work must not proceed unless suitable rescue arrangements are confirmed

If suitable rescue arrangements cannot be achieved, the task must not go ahead.

19. Incident Reporting

All incidents, near misses, unsafe conditions, equipment defects, or concerns relating to work at height must be reported immediately in accordance with the Company’s incident reporting arrangements.

Managers must ensure incidents are investigated where appropriate and corrective actions implemented.

20. Documentation and Records

The Company will maintain records as appropriate, including:

• risk assessments

• RAMS

• permits to work where relevant

• training and competence records

• equipment inspection / examination records

• rescue arrangements where relevant

• incident and investigation records

These will be maintained through the Monday.Com platform and supporting documentation.

21. Related Documents

This procedure should be read alongside:

• Health and Safety Policy

• Risk Assessment and RAMS Procedure

• Lone Working Policy

• PPE Policy / Procedure

• Training and Competence Policy / Procedure

• Accident, Incident, Near Miss and Work-Related Ill Health Reporting and Investigation Procedure

• relevant work at height risk assessments

• IPAF and other competence records

• site-specific permits and RAMS where applicable

Annex A – Rescue Plan: Working at Height on a MEWP or Fixed Platform

1. Task Overview

This rescue plan applies to work carried out at height using a MEWP or a fixed platform.

It is intended to ensure a safe and effective response in the event of:

• operator incapacitation

• equipment failure

• entrapment

• fall arrest activation

• inability to descend normally.

2. Emergency Contact and Communication

A mobile phone or suitable communication device must be available and operational while work at height is being carried out.

The relevant site / plant management must be informed of the work taking place.

Where required, a check-in procedure must be followed.

Emergency contact details and site access arrangements must be known before work begins.

3. Rescue Procedure

Scenario 1 – Operator Incapacitated or Trapped in the MEWP

• trained ground-based personnel will use the MEWP’s ground-level emergency descent controls to lower the platform safely

• if another trained operator is present in the platform, they may attempt to lower the platform using the onboard controls where safe to do so

• if descent cannot be achieved or the operator is unresponsive, emergency services must be contacted immediately

Scenario 2 – MEWP or Fixed Platform Failure

• the operator should attempt safe use of the controls in accordance with training and manufacturer guidance

• if unsuccessful, trained ground personnel must use the available emergency lowering or override controls where applicable

• if descent or safe recovery is not possible, emergency services must be contacted.

Scenario 3 – Fall Arrest Activation

• if a worker is suspended in a harness, action must be taken immediately to reduce the risk of suspension trauma

• the preferred method is prompt recovery using the planned rescue method for that task

• if immediate recovery cannot be carried out safely, emergency services must be contacted immediately.

4. Lone Working Considerations

A second operator is preferred but may not always be present.

Where only one person is working at height:

• the site must have a designated trained person available on the ground where required by the rescue arrangement

• communication must be maintained

• if no suitable rescue support is available, the work must not proceed.

5. Training and Competence Requirements

• MEWP operators must be suitably trained and competent

• ground-based personnel involved in rescue must be trained in emergency descent / rescue procedures where required

• where fall arrest equipment is used, workers must be trained in its correct use and the risks of suspension trauma.

6. Emergency Services and Access

Where a situation cannot be resolved safely using the planned rescue arrangements, emergency services must be contacted immediately.

The location of the work area, site access points, and any relevant site contact details must be known before work starts.

7. Rescue Equipment

Where relevant, rescue arrangements may rely on:

• MEWP emergency lowering system

• communication device

• first aid kit

• site emergency contact arrangements

• any additional rescue equipment identified in the RAMS or site arrangements.

8. Key Responsibilities

Operator

• carry out pre-use checks

• ensure communication is maintained

• stop work if conditions are unsafe or rescue arrangements are unclear.

Ground-Based Support / Designated Person

• understand the rescue arrangement

• know how to use emergency descent / lowering controls where required

• summon assistance promptly in an emergency.

Management / Site Coordination

• ensure work does not begin until rescue arrangements are in place and understood

• ensure relevant personnel are trained and informed

• ensure emergency arrangements and access are confirmed before work begins.

Joe Charlesworth

Director - Highway Data Systems Ltd