Prevention of Falls when Working at Heights

'Ladder licences' do not exist under Victorian Occupational Health and Safety (OHS) legislation. Individuals required to work at heights must complete the competency-based ‘work safely at heights’ training course (RIIWHS204E).

Policy

The purpose of this policy is to prevent falls by outlining the requirements for safely working at height.

Summary

• For the purposes of this policy, 'working at heights’ means working in any place where there is a risk of falling more than 2 metres, measured from the soles of your feet to the ground.
• For policy relating to working at 2 metres or less in height from the ground, refer to: Slips, Trips and Falls Prevention.
• Activities commonly associated with working at heights in schools include, but are not limited to:
  • cleaning of gutters
  • retrieving objects from a roof or gutter (for example, balls)
  • setting up lights in a theatre
  • decorating high ceiling classrooms.
• Schools are encouraged to engage a contractor to complete tasks that require working at heights, where possible.
• Principals or their delegates, in consultation with affected individuals, and health and safety representatives (where elected), must identify, assess and control risks associated with working at heights to prevent or minimise risk of injury.
• Individuals must not work at heights unless it is discussed with the principal or their delegate as being a part of their role.
• School staff and volunteers who have discussed with their principal working at heights as part of their role must complete the competency based Work safely at heights training course (RIIWHS204E), complete the refresher course every 2 years, and complete a Safe Work Method Statement (SWMS) prior to commencement of work at height.
• Principals or their delegates must review, sign and record SWMSs submitted by individuals undertaking work at heights.
• Individuals who are not specifically trained to work at heights must not undertake work at a height of more than 2 metres in any circumstance.

Details

Working at heights means working in any place where there is a risk of falling more than 2 metres, including working above a hole, trench or pit. The risk of serious injury from this height is much greater than falls from less than 2 metres.

For work required to be completed at height, schools are encouraged to engage a contractor to complete this work, where possible. Contractors must provide the principal or their delegate with a Safe Work Method Statement (SWMS) before commencing any tasks requiring working at heights (a new SWMS is required for each time they complete a task at height). Template and example SWMS are available in the Resources tab. For further guidance on SWMS see section 2.4 of this policy ‘Safe Work Method Statements’.

School staff and volunteers are not permitted to work at heights unless they meet all of the following conditions:

• they have discussed working at heights as being a part of their role with the principal or their delegate
• they are appropriately qualified (that is, have successfully completed, at a minimum, the competency-based Work safely at heights training course (RIIWHS204E) and the refresher course every 2 years. These courses are searchable online, using the RIIWHS204E code, and are delivered through registered training organisations (RTOs)
• they provide the principal or their delegate with a SWMS before commencing any tasks requiring working at heights (a new SWMS is required for each time they complete a task at height).

This policy should be read in conjunction with the Contractor OHS Management and Volunteer OHS Management policies, whenever contractors or volunteers are engaged to undertake a task that involves working at heights.

This policy does not cover situations that involve working 2 metres or less in height from the ground. Refer to the Slips, Trips and Falls Prevention policy for this information.

For excursion or camp activities involving working at heights (such as rock climbing), schools must refer to the relevant guidelines and requirements outlined in the department’s Excursions policy.

This policy does not cover maintenance tasks for building and grounds including roofing, gutter systems, anchor points or fall arrest systems, schools must refer to the relevant guidelines and requirements outlined in the Buildings and Grounds Maintenance and Compliance policy.

Roles and responsibilities for the ongoing management of prevention of falls when working at heights

Department roles and responsibilities

The department must maintain, so far as is reasonably practicable, a safe and healthy working environment for school staff to avoid injuries from working at heights.

Principal or delegate roles and responsibilities

The principal or their delegate must:

• identify, assess and control the risks that are associated with working at heights in consultation with individuals who are or are likely to be affected and health and safety representatives (HSR), where elected
• ensure school staff and volunteers who are required to work at heights as part of their role complete the competency-based work safely at heights training course (RIIWHS204E) and refresher course every 2 years, prior to the commencement of any tasks requiring working at heights
• review and sign off (to confirm sighting) all SWMS completed by school staff, contractors and volunteers before any work from height task commences, and retain copies
• ensure training records for school staff and volunteers are retained – refer to the OHS Induction and Training policy and Volunteer OHS Management policy.

School staff roles and responsibilities

School staff, including volunteers, must:

• take reasonable care for their own health and safety and the safety of others who may be affected by their actions or omissions while at work, which includes assisting principals or their delegate to prevent, identify and manage hazards and risks associated with working at heights
• not work at heights unless their role specifically requires them to do so, as discussed with their principal or delegate
• where their role specifically requires working from heights:
  • ensure they are appropriately trained in the competency-based work safely at heights training course (RIIWHS204E) prior to commencing any tasks at height
  • complete the associated work safely at heights refresher course every 2 years
  • provide a SWMS prior to commencing work at heights – the SWMS must be signed by the principal or their delegate to verify it has been sighted
• report hazards, risks, incidents and near misses in the workplace using eduSafe Plus.

Department supports for schools

Central and regional offices provide a range of supports and services to assist principals and employees to be safe and well, including access to the OHS Advisory Service and Statewide OHS Services Team who can provide free advice in relation to managing risks associated with working at height tasks.

Using eduSafe Plus to report and manage hazards identified allows OHS service officers to provide assistance and advice. Guidance for reporting and managing hazards on eduSafe Plus is located in the How to report a workplace hazard guide (PDF) (staff login required) on the knowledge base in eduSafe Plus.

Definitions

Fall arrest system
Equipment or material, or a combination of equipment and material, that is designed to arrest the fall of a person. These can include industrial safety nets, catch platforms or safety hardness systems (other than a travel restraint system).

Risk assessment
Process undertaken to identify the hazards, risk controls, and level of risk associated with a task or activity.

Safe Work Method Statement (SWMS)
A document that describes the high-risk work being performed, the health and safety risks associated with the work and the risk control measures that will be applied to ensure the work is carried out in a safe manner.

Safe work procedure
A step-by-step documented procedure on how to safely conduct a task or operation on an item or piece of equipment.

Travel restraint system
Equipment that is worn by, or attached to, a person and is designed for the purpose of physically restraining the person from reaching an edge or elevated surface from which the person may fall.

Working at heights
Undertaking a task at a height of more than 2 metres (measured from the soles of feet to the ground). This also applies in situations where a person may fall more than 2 metres into a hole, trench or pit.

Related policies

• Contractor OHS Management
• Occupational Health, Safety and Wellbeing Management in Schools
• OHS Induction and Training
• OHS Risk Planning and Management
• Records Management – School Records
• Volunteer OHS Management

Related legislation

• Model Code of Practice: Managing the Risk of Falls at Workplaces (Aus) (PDF)
• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)

Prevention of Falls when Working at Heights Procedure

This Prevention of Falls when Working at Heights Procedure sets out the practical step-by-step instructions that individuals must follow to implement the Prevention of Falls when Working at Heights policy. This procedure should be implemented in consultation with individuals who are or are likely to be affected, and health and safety representative/s (HSR) (where elected), and the health and safety committee or any other OHS forums (if established).

It contains the following steps:

1. Identifying working at heights hazards
2. Assessing and controlling the risks
3. Hazard, incident and near miss reporting

1. Identifying working at heights hazards

The principal or their delegate must identify potential hazards that might increase the risk of falling for any working at heights related tasks. Quarterly workplace safety inspections must be undertaken by the principal or their delegate in consultation with relevant staff and the health and safety representative (HSR), where elected, to identify hazards in the workplace, which may include those that pose a risk of falling from a height.

Common activities in the school environment that may cause a risk of falling when working from a height include, but are not limited to:

• cleaning of gutters
• cleaning and opening high windows
• retrieving balls or other objects from a roof or gutter
• set-up and use of lights in a theatre or gymnasium
• decorating high ceiling classrooms or hanging signs
• general roof maintenance work
• changing lightbulbs.

Contributing factors to consider when identifying hazards associated with working at heights can include, but are not limited to:

• weather conditions
• suitability and maintenance of equipment being used
• unlevel or worn surfaces
• incorrect use of ladders
• the health condition of the individual carrying out the task
• unsuitable footwear
• low light levels
• an overloaded workspace
• overreaching.

The OHS Advisory Service and Statewide OHS Services Team can also support schools with a visit to identify tasks where working at heights may be an issue.
Once hazards and risks are identified, they must be assessed and controlled so far as is reasonably practicable.

2. Assessing and controlling the risks

2.1 Assessing working at heights risks

The principal or their delegate must determine the level of risk by assessing the identified hazards in consultation with health and safety representatives (HSRs) or affected individuals.

Template risk assessments and safe work procedures for common working at heights tasks (such as setting up theatre lights, cleaning gutters and windows and retrieving items off roofs) can be used by schools as a reference tool to help inform the development of the required SWMS. These provide information on the components of the hazard, the associated risks and appropriate example controls, and are available for schools to download from the Resources tab.

Before any working at heights related work is undertaken, individuals must provide the principal or delegate with a Safe Work Method Statement (see section 2.4 Safe Work Method Statements).

The OHS Advisory Service and Statewide OHS Services Team can provide advice on preventing and managing working at height hazards and risks, including assessing the level of risk.

2.2 Controlling working at heights risk

The principal or their delegate must ensure risk controls are documented in the school’s OHS risk register in consultation with affected school staff and HSRs, where elected.

When identifying and implementing appropriate controls, consider the following when discussing the task with individuals undertaking the work:

1. Is this task appropriate for the trained individual to undertake or should this be completed by a qualified contractor?
2. Can this work be undertaken completely or partially from the ground or a solid structure (for example, installing equipment such as an air-conditioner at ground level, where possible)?
3. If this work does need to occur at heights, where is the safest space to complete this work? Consider the ground surfacing, positioning of equipment to access the hazardous area.
4. Does the trained individual feel comfortable completing the task at height?
5. What changes can be made to reduce access to the hazardous area? For example, designated reinforced walkways, provision of appropriate edge protection in accordance with AS/NZS 1657 (for example, guard rails, handrails and so on).
6. What equipment can be used in order to prevent falls from occurring? For example, the use of work positioning systems to restrict an individual’s range of movement so they cannot physically travel to the fall hazard (for example, travel restraint systems) and the installation of roof anchor points in accordance with AS/NZS 1891.
7. What equipment can be used to keep someone safe if a fall does occur? For example, the use of a fall arrest system (for example, safety harness and lanyard) which is set up in such a manner that if a fall occurs, the fall is arrested within acceptable force and clearance margins.

In many cases a combination of controls will be required to eliminate or reduce the risk of a fall.

Note: As there are considerable hazards involved, as well as maintenance and inspection requirements, it is strongly recommended that tasks at heights are undertaken by qualified contractors, particularly those requiring the use of safety fall arrest systems.

For further information regarding safety fall arrest systems, including the regular inspection and maintenance of anchor points, please refer to the relevant guidelines and requirements outlined in the Asset Information Management System (AIMS) policy and the Buildings and Grounds Maintenance and Compliance policy. The School Asset Leadership Unit can be contacted for further support or guidance: schoolasset.leadership@education.vic.gov.au

2.3 Work safely at heights training

The principal or their delegate are to ensure that school staff, including volunteers, who as part of their role are required to work at heights, are trained in the competency-based Work safely at heights training course (RIIWHS204E). The nationally recognised course covers theoretical and practical aspects of working at heights and is available through Registered Training Organisations. At a minimum, the refresher course must be completed by school staff and volunteers every 2 years (refresher course requirement not applicable to contractors).

2.4 Safe work method statements

The principal or their delegate must ensure that the trained individual undertaking the work has supplied a Safe Work Method Statement (SWMS) for all tasks where there is the potential to fall more than 2 metres. The SWMS must be sighted and signed (to acknowledge sighting) by the principal or their delegate prior to the commencement of works, and retained in accordance with the Records Management – School records policy.

A template SWMS is available for schools to download from the Resources tab.

The SWMS at a minimum must include the following:

• controls identified to prevent a fall from height, for example:
  • work from ground so far as is reasonably practicable
  • all work platforms, scaffolds are fitted with toe boards
  • roof condition, such as condition, pitch, type of material, is assessed from the ground prior to accessing
  • all work platforms have secure handrails
• controls identified to prevent objects falling onto persons below, for example:
  • barricade area below to prevent access to work area
  • secure the construction site
  • loose objects are secured
• access and egress to/from worksite, for example:
  • installation of support systems to brace the trench (benching, shoring)
  • spotter is positioned at bottom of ladder
• isolation of worksite and signage, for example:
  • use of trench covers to secure trench when unattended
  • signage is available indicating works are being carried out
• installation and use of passive fall prevention device(s) or work positioning systems, where required, for example:
  • persons working at height and using fall arrest systems have been properly trained
  • persons wear full fall arrest type harness secured to anchorage points or static lines
  • use of passive fall prevention devices, for example, scissor lift by a licenced contractor
• emergency response procedures and personal protective equipment (PPE), for example:
  • rescue from height/fall procedures are in place
  • PPE is worn at all times
• safe use of ladders, for example:
  • all ladders are inspected for damage and deterioration
  • all ladders are secured to prevent movement
  • always maintain 3 points of contact (for example, two feet and one hand, or two hands and one foot) with the ladder at all times
  • never hold tools or materials and always face the ladder when climbing or descending
  • use non-slip secure footwear
  • ladders to extend at least one metre above upper landing or roof
  • all ladders have a load rating of 120 kg, are industrial rated and comply with Australian Standards
  • a spotter is positioned at bottom of ladder.

Note: As ladders are often used when working at heights, it is important that the ladder that offers the highest level of protection is selected prior to commencing work. Ladders should only be used for short-duration tasks. “A-frame” ladders provide the least stability and flexibility and should only be used for light work of a short duration.

The principal or their delegate has the power to stop/halt work where they believe the relevant SWMS is not being followed.

3. Hazard, incident and near miss reporting

If a working at heights hazard is identified, it must be reported to the principal or their delegate or the health and safety representative (HSR). Hazards, incidents and near misses involving falling from heights must be reported in eduSafe Plus. eduSafe Plus can help with the allocation of tasks and management of hazards. For more information on reporting hazards and incidents, go to the Managing and Reporting School Incidents (Including Emergencies) policy.

If a fall from height results in a serious injury or emergency, call 000 and provide first aid assistance.

If a fall from height results in a ‘notifiable incident’, it must be reported to WorkSafe as per the Managing and Reporting School Incidents (Including Emergencies) policy.

Resources

Guidance

• WorkSafe Victoria – Fall prevention: A guide to falls prevention
• WorkSafe Victoria – Fall prevention: Falls prevention checklist
• Safe Work Australia – Working at heights
• Safe Work Australia – Model code of practice: Managing the risk of falls at workplaces
• Useful health, safety and wellbeing contacts for schools

Templates and forms

• Safe Work Method Statement (DOCX)
• ‘A’ frame ladder – sample safe work procedure (DOCX)
• Extension ladder – sample safe work procedure (DOCX)
• Use of step-platform – sample safe work procedure (DOCX)
• Risk assessment template (DOCX)
• Cleaning gutters – sample risk assessment (DOCX)
• Cleaning windows – sample risk assessment (DOCX)
• Retrieving balls off roof – sample risk assessment (DOCX)
• Set-up and use of scaffolding – sample risk assessment (DOCX)
• Set-up and use of theatre lights – sample risk assessment (DOCX)

Useful websites

• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)