We send our workers to courses for Confined Space Entry and Working at Heights to ensure they can work safely in either of these situations. Both CS and WAH involve serious potential risk to the worker, and can be extremely dangerous. It is for this reason that we prepare workers to deal with these hazardous situations, but the goal is to eliminate as many hazards as possible so that the worker is faced with the least amount of potential hazards while in these situations. Due the the danger inherent in these work activities, reducing or eliminating the time spent working under these conditions is the first step in prevention and control of hazards.
When it comes to the prevention of on-the-job hazards, the process usually includes the following steps: job completion, writing the appropriate safe work procedures, safe work instructions and new policy and procedure, the bang the worker over the head with the paperwork until they understand and conform.
This model ignores the most important part of hazard control: Hierarchy of Controls.
The Hierarchy of Controls model is reinforced at every course and induction, but how many workers, managers and OHS/WHS professionals really concentrate on the higher level controls, especially elimination? From my observations and speaking to hundreds, perhaps thousands, of trainees, managers and supervisors it rarely happens. Most often, the focus of hazard control lies in steps 4, 5 & 6.
It is far easier for an OHS/WHS individual or manager in an office and write procedures or wander around a site and find workers doing the wrong thing when they fail to comply with Admin and PPE requirements, which are the lowest controls.
Ask yourself, how many hazards have I eliminated or controlled with higher level controls today? Write it up on a white board, in a diary or weekly reports, if you have nothing to write about for the week.
- Instead of working at heights, did I consider if the job could be done on the ground or on a fall prevention structure? For example, could scaffolding be used in place of a lift?
- Could that confined space be opened up so it has great ventilation, access, and egress? Some boat yards are cutting the sides out of boats to allow better access for workers and rescue personnel. They are, in fact, eliminating confined spaces in many cases.
- Did I consider rotable spares so workers were not carrying out repairs in situ in a chute or tank, instead the repairs are carried out in a workshop with the chute fully open at both ends, ready for the next shutdown?
- Are there better means to access a job than working off a ladder?
- Can components be assembled on the ground and transported to elevated work positions?
- What can be done to reduce exposure time to CS and WAH for workers?
- How can I avoid having workers relying on harnesses for fall protection? Have I investigated suspension trauma, rescue, harness design, and medical issues post rescue? Is the focus on fall arrest or fall protection?
- Have you put into place an effective rescue plan, or is the plan to call emergency services and hope they arrive in time. I recently audited a mine site emergency response team and their response time could be 1 hour if they were called away to another emergency. The existing rescue plan was call the ERTs.
We need to eliminate CS and WAH wherever possible; if we don’t try we will never know what can be achieved.