Working at height inspection explained: two meanings, one set of duties

A working at height inspection means one of two things: an inspection carried out in a place where a person could fall a distance liable to cause injury, or the inspection of the equipment and places used for work at height, such as scaffolds, working platforms, ladders and edge protection. Both meanings carry duties.

The ambiguity causes real confusion on site. A manager asking whether the working at height inspections are up to date may mean the scaffold tags, or may mean the gutter survey. Say which one you mean.

What counts as work at height?

In Great Britain the Work at Height Regulations 2005, published at legislation.gov.uk, define it as work in any place, including a place at or below ground level; obtaining access to or egress from such place while at work, except by a staircase in a permanent workplace, where, if measures required by these Regulations were not taken, a person could fall a distance liable to cause personal injury.

Read that carefully, because two things follow that people get wrong constantly:

• It is a risk test, not a height threshold. The definition turns on whether the fall could cause injury, not on clearing a set number of metres.
• Below ground level counts. Falling into an excavation, a pit or an open chamber is work at height in law, which surprises most people the first time they read it.

Access and egress are inside the definition too. Getting to the inspection point is part of the job being regulated, not a preamble to it.

The hierarchy: avoid, prevent, minimise

Regulation 6 opens with avoidance: Every employer shall ensure that work is not carried out at height where it is reasonably practicable to carry out the work safely otherwise than at height. Only when that fails do you move down.

• Avoid. Do the work from the ground, or do not do it at all. Extendable tools, ground level inspection, remote viewing, relocating plant so it can be serviced from a walkway.
• Prevent. Where height is unavoidable, stop the fall happening: an existing safe place of work, guardrails, a tower or MEWP, work restraint that physically prevents reaching the edge.
• Minimise. Where a fall remains possible, cut the distance and the consequences: nets, airbags, fall arrest systems.

HSE's practical version is blunter. Do as much of the work as possible from the ground. Its guidance also warns against overloading or overreaching on ladders, resting one against a weak upper surface, or using ladders for heavy or strenuous work.

What has to be inspected, and how often

This is the second meaning of the term, and Great Britain sets specific intervals:

• Before each use. Regulation 13 requires that, so far as is reasonably practicable, the surface and every parapet, permanent rail or other fall protection of a place of work at height is checked on each occasion before the place is used.
• Every 7 days for working platforms. Under regulation 12(4), a working platform used in construction where a person could fall 2 metres or more may not be used in a position unless it has been inspected in that position, or on site for a mobile platform, within the previous 7 days.
• Reports. For those platforms, a report is prepared before the end of the working period and provided within 24 hours, containing the particulars in Schedule 7, kept on site until construction is complete and then at an office for 3 months.
• Lifting equipment. A MEWP lifts people, so under LOLER it falls into HSE's 6 month thorough examination interval rather than the 12 months applied to other lifting equipment.
• On deterioration or exceptional circumstances. Regulation 12(3) adds inspection at suitable intervals and after events liable to jeopardise safety, such as a storm hitting a scaffold.

All of the above is Great Britain. The duties are jurisdictional, not universal, and other countries set their own thresholds, intervals and record keeping. Check the local regime before applying any of these numbers elsewhere.

Working at height inspection in practice: a worked example

A facilities team needs quarterly condition checks on gutters and rooftop plant across six sites. The old method was a ladder and a torch. The revised plan applies the hierarchy: two sites are inspected from ground level with a pole camera, three are done from a MEWP with a current thorough examination certificate, and only the sixth, which has a fixed walkway and anchor points, involves anyone stepping onto the roof. The inspection frequency did not change. The exposure dropped by two thirds.

How it relates to permits and other inspections

• Permit to work. Many sites permit control higher risk height work such as fragile roofs, rope access or scaffold alteration. The permit authorises the job to start. It does not perform the inspection.
• Risk assessment. Written in advance, covering the type of work. The pre use check under regulation 13 happens on the day, at the place.
• Roof inspection. A common instance of the first meaning of the term: an inspection whose subject is the roof, and whose method is work at height.

A last point worth stating out loud, because the paperwork tends to obscure it. Regulation 6 asks whether the work needed to happen at height at all. That question is not answered once when a procedure is written. It is worth reasking every time the technology for looking from the ground gets better.

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