Procedures

Working at Height Procedure

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1.0    Purpose and Scope

This procedure outlines requirements at The University of Queensland (UQ) for working at height and provides information about the hazards and precautions in place at UQ to reduce the risk of harm when working at height. UQ’s legislative obligations for managing working at height are provided under the Work Health and Safety Act 2011 (WHS Act).

This procedure applies to all UQ workers on all UQ campuses and sites, including controlled entities. For the purposes of this procedure, the definition of UQ workers is broad and is intended to ensure UQ meets its responsibilities under the WHS Act. The definition of UQ workers is provided in the appendix. 

In addition to the requirements of this procedure:

  • UQ’s Work at Height Management Plans describe the systems developed by UQ to identify and mitigate risks associated with work at height. UQ workers conducting work at height must refer to these plans in conjunction with the requirements of this procedure –

  • The Managing the Risk of Falls at Workplaces 2021 (the Code) provides practical guidance to achieving the standards of health, safety and welfare required under the Work Health and Safety Regulation 2011 (WHS Regulation). Additional information about safe work practices when working at height is provided in the Code. UQ will implement relevant and appropriate measures from the Code.

1.1    Scope

For the purposes of this procedure, working at height includes the following activities:

  • High-risk construction work (e.g. construction work that involves a risk of a person falling more than 2 metres).

  • Non-construction work above two metres (e.g. taking scientific measurements that involves a risk of a person falling more than 2 metres).

  • Work at height less than two metres (e.g. where there is a risk of fall from one level to another).

2.0    Process and Key Controls

The following requirements apply to all UQ workers proposing to conduct any work at height at UQ.

  1. Access to roofs and unprotected balconies at UQ is restricted and centrally managed by the Property and Facilities Division (P&F).

    1. Any proposed work on roofs at UQ must be arranged through P&F (pfassist@pf.uq.edu.au).

    2. Only authorised UQ workers are permitted to access roofs at UQ with the required roof access permit (PF-184).

    3. Contractors will work under their own permit systems and require authorisation from P&F to access roofs at UQ (refer to the Work at Height Management Plans for details).

    4. Roof space that has been allocated to Organisational Units for permanent or long-term use, in agreement with P&F, must adhere to the steps outlined in the Work at Height Management Plans.

  2. Where work at height cannot be undertaken on a solid construction, and where fall arrest is the main measure to control the risk, UQ will outsource the work to competent contractors (excluding operating elevated work platforms – refer to section 3.6 of this procedure and the Work at Height Management Plans for further information). 

  3. High-risk construction work that involves a risk of a person falling more than 2 metres must not be carried out without a relevant Safe Work Method Statement (SWMS) in place.

  4. A risk assessment must be undertaken to identify the hazards associated with work at height, and the controls proportionate and relevant to the activities being undertaken. The risk assessment must be completed in UQSafe and reviewed and approved by the relevant supervisor as outlined in the Occupational Health and Safety Risk Management Procedure and when the activities change.

  5. UQ workers who have permission to work at height must be appropriately trained and competent.

3.0    Key Requirements

3.1    Property and Facilities roof register

P&F will maintain a register of roof tops and unprotected balconies across all UQ campuses and sites. Access to these areas will be restricted and all roof access points will be appropriately signed. Any person requiring access to a roof or unprotected balcony at a UQ campus or site must contact P&F (pfassist@pf.uq.edu.au).

3.2    High-risk construction work

Construction work that involves risk of a person falling more than 2 metres is defined as high-risk construction work under the WHS Regulation. A Safe Work Method Statement (SWMS) must be prepared before any high‑risk construction work commences.

3.2.1    Safe work method statement (SWMS)

Organisational Units must ensure the preparation and implementation of a SWMS for high-risk construction work performed by UQ workers. SWMS may also be supported by a specific Job Hazard Analysis (JHA) or risk assessment.

3.3    Organisational Unit risk assessment and registers

Risk assessments for all other activities and infrastructure involving work at height must be undertaken in UQSafe by the Organisational Unit and should be included in local safety risk registers and Local Standard Operating Procedures (LSOPs) for tasks specific to the area.

The hierarchy of risk control must be considered for developing and implementing control measures in the risk assessment process. Refer to the Occupational Health and Safety Risk Management Procedure for more information.

Further guidance in conducting workplace risk assessments is available from UQ Health Safety and Wellness (HSW) Managers or Work Health and Safety Coordinators (WHSC).

3.3.1    Non-construction work at height above 2 metres

Organisational Units must ensure that risk assessments are completed in UQSafe for tasks and activities that require working at height greater than 2 metres. UQ workers should firstly consider whether the work needs to be conducted at height or if there is another way the work can be undertaken.

3.3.2    Work at height less than 2 metres

Organisational Units must ensure that risk assessments are completed in UQSafe for tasks and activities that require working at height less than 2 metres to determine:

  • the risk of falling from one height or level to another; and

  • risks from falling objects.

Appropriate equipment must be used for any work at height (e.g. platform ladders should be used instead of standing on furniture).

3.4    Emergency Response Plan (ERP)

UQ will outsource work at height that may require the performance of at-height rescues to external contractors with expertise and appropriate emergency procedures for such tasks.

For all other work at height, as determined by a risk assessment, an ERP must be developed by competent persons prior to working at height. The WHS Regulation and the Code stipulate the need for emergency and rescue procedures. Consideration should be given to:

  • communications

  • rescue and resuscitation equipment

  • capabilities of rescuers

  • first aid

  • local emergency services.

3.5    Competency and training

UQ workers that work at height, must have the skills and knowledge to understand the hazards associated with the tasks, the requirements of Roof Access Permits (PF-184) and their associated control measures.

Organisational Units must ensure that UQ workers responsible for installing, maintaining, using, and inspecting work at height equipment are trained and competent.

UQ workers that are required to work at height using work positioning systems must hold a certificate of competency from a nationally accredited Registered Training Organisation (RTO).

Organisational Units must ensure that UQ workers undertaking work above 2 metres (either construction or non-construction) have the necessary training, instruction, and supervision to undertake the task competently.

Records of all training provided to UQ workers for working at height must be kept by the Organisational Unit.

3.6    Elevated Work Platforms (EWP)

EWP may be used by UQ workers as a working platform. EWP must not be used as a means of entering or exiting a work area unless the risk assessment shows that it is safer than all other means of access. The following requirements apply to the use of EWP:

  • EWP must be operated in accordance with the manufacturer’s or supplier’s instructions and the safe operating procedure located on the machine;

  • only licensed EWP operators are authorised to operate EWP;

  • a competent person must act as a spotter and rescuer, remaining on the ground and in clear view of the EWP operator at all times;

  • harnesses and lanyards must be visibly inspected by the EWP operator prior to every use and be within certified inspection dates; and

  • work is not permitted and must cease in the event of high winds (wind speed specified on specification plate) or lightning.

3.7    Scaffolds

Where a person or object may fall 4 metres or less, a competent person with relevant information, instruction, training, and supervision may erect, move or relocate scaffolds. If a person or object may fall more than 4 metres from the scaffold, a licensed contractor must be engaged to erect, move or relocate the scaffold.

All fixed and mobile scaffold use must be carefully planned in consultation with all relevant UQ workers and key stakeholders impacted in the work area.

For more information about safe scaffold use, refer to the Work at Height Management Plans.

3.8    Use of ladders

Only appropriate, fit-for-purpose ladders should be used by UQ workers. Domestic ladders must not be used. When selecting a ladder, consider the duration of the task, the physical surroundings of where the task is to be undertaken and the prevailing weather conditions.

Organisational Units are responsible for ensuring that safe operating procedures are followed when ladders are used by UQ workers in their area and that ladders:

  • comply with Australian Standards and have a clearly displayed load rating of at least 120kg;

  • are manufactured for industrial use; and

  • are regularly inspected and maintained.

For more information about safe ladder use, refer to the Work at Height Management Plans.

3.9    Falling objects

Where work is being conducted overhead and there is a risk of being struck by falling objects, the area must be controlled by barriers cordoning off the area below.

Barricading and signage must be used, as far as practicable, to ensure all non-essential personnel and equipment are kept clear of any work area where there is a risk of falling from height or being struck by a falling object.

In access areas or doorways, if necessary, erect a barrier or lock the door shut.

3.10    Personal Protective Equipment (PPE)

PPE must be used where determined to be an appropriate control measure, either in combination with other controls or as a stand-alone measure, through the risk assessment process or where if stated in regulations or procedures. Refer to the Personal Protective Equipment Procedure for more information.

4.0    Roles, Responsibilities and Accountabilities

4.1    Heads of Organisational Units

Heads of Organisational Units are responsible for:

  • managing the risk of falls in their areas of responsibility in accordance with this procedure and the Work at Height Management Plans;

  • seeking advice from their local WHSC or HSW Manager on implementing the requirements of this procedure and the Work at Height Management Plans; and

  • ensuring that Managers and Supervisors in their areas of responsibility, who manage UQ workers required to work at height, are aware of this procedure and the Work at Height Management Plans and provide resources to meet the requirements of this procedure.

4.2    Managers and Supervisors

Managers and Supervisors are responsible for ensuring:

  • UQ workers under their supervision conducting work at height are suitably qualified, trained and competent (refer to section 3.5) and have been informed of the Work at Height Management Plans;

  • relevant equipment, information, supervision, training and instructions to UQ workers regarding working at height is provided;

  • equipment controlled and managed in their Organisational Unit (e.g. harnesses, lanyards, ropes and fall restraint devices) is inspected and maintained in accordance with AS/NZS1891 Industrial fall‑arrest systems and devices;

  • risk assessments are conducted in consultation with UQ workers; and

  • records of inspection and maintenance of all equipment is maintained and kept with the equipment.

​4.3    HSW Managers and Work Health and Safety Coordinators (WHSC)

HSW Managers and Work Health and Safety Coordinators are responsible for:

  • providing advice and guidance to UQ workers in their Organisational Unit on how to implement and operationalise this procedure and the Work at Height Management Plans;

  • assisting Managers, Supervisors and UQ workers to conduct and review risk assessments for work at height; and

  • consulting with HSW Division on any constraints to implementing the requirements of this procedure or the Work at Height Management Plans.

4.4    UQ workers

UQ workers conducting work at height are responsible for:

  • complying with the requirements of this procedure and any information, training or instruction they receive from their Manager or Supervisor;

  • inspecting equipment, such as harnesses, lanyards, ropes and fall restraint devices to ensure it is in good physical condition prior to every use; and

  • assisting Managers and Supervisors in conducting risk assessments before the commencement of any work at height.

4.5    Property and Facilities Division (P&F)

Property and Facilities Division (P&F) is responsible for:

  • maintaining UQ’s register of roof tops and unprotected balconies;

  • restricting access to roof tops and unprotected balconies;

  • conducting roof risk assessments in UQSafe for all UQ buildings and reviewing these risk assessments annually;

  • ensuring P&F workers undertake Job Hazard Analysis (JHA) before conducting work at height;

  • inspecting and maintaining anchor points for all UQ building roof tops in accordance with AS/NZS1891 Industrial fall-arrest systems and devices;

  • managing UQ’s Roof Access Permit (PF-184) system, including the application and approval process, and authorising access to roofs at UQ;

  • applying this procedure to P&F high-risk construction work and any other work involving work at height by P&F workers; and

  • providing contractors with information about all known risks for working on UQ roofs and ensuring they have the appropriate training and emergency plans to facilitate a safe rescue if required.

4.6    Health, Safety and Wellness (HSW) Division

Health, Safety and Wellness (HSW) Division is responsible for:

  • supporting P&F in the ongoing development and implementation of this procedure and providing health and safety advice to P&F when required or requested;

  • communicating this procedure to Organisational Units and UQ’s Safety Network for implementation; and

  • providing guidance and advice to Organisational Units, in collaboration with P&F, on the implementation of this procedure.

5.0    Monitoring, Review and Assurance

P&F is responsible for reviewing this procedure as required, in collaboration with the HSW Division, to ensure its accuracy, relevance and effectiveness. Review of the procedure will also be informed by feedback from Heads of Organisational Units, Supervisors and Managers.

HSW Division will conduct periodic audits of Organisational Unit compliance with this procedure, which may include checking:

  • the existence, adequacy and review of work at height risk assessments and ERPs;

  • Roof Access Permit approvals (PF-184);

  • UQ workers’ compliance with Roof Access Permit (PF-184) requirements;

  • UQ workers’ awareness of compliance obligations associated with this procedure;

  • UQ workers’ work at height competency and refresher training documentation; and

  • management of contractors regarding work at height.

Local Health, Safety and Wellness (HSW) Managers and Work, Health and Safety Coordinators (WHSC) will conduct regular inspections (at least annually) to review appropriate risk controls.

6.0    Recording and Reporting

HSW Managers and Organisational Unit Managers and Supervisors will ensure:

  • all work at height incidents and near misses are reported in UQSafe;

  • non-compliance with this procedure, the Work at Height Management Plans and relevant LSOPs is reported to the Head of the Organisational Unit, who will notify the HSW Division; and

  • approved Roof Access Permits (PF-184) will be recorded and held locally.

7.0    Appendix

7.1    Definitions

Competent person – a person who has acquired through training, qualification or experience, or a combination of these, the training and knowledge and skills to carry out that task.

Construction work – means any work carried out in connection with the construction, alteration, conversion, fitting-out, commissioning, renovation, repair, maintenance, refurbishment, demolition, decommissioning or dismantling of a structure.

Elevating work platform (EWP) – a device used to support a platform on which personnel, equipment and materials can be elevated to perform work. While EWPs come in a range of different configurations, the general types of EWP include:

  • Self-propelled scissor lifts

  • Self-propelled boom-type

  • Truck-mounted

  • Trailer-mounted.

Fall – a fall by a person from one level to another.

Fall arrest – plant or material designed to arrest a fall.

High-risk construction work – in the context of falls from heights, means construction work that involves a risk of a person falling more than 2 metres.

Job Hazard Analysis (JHA) – also called a Job Safety Analysis (JSA), is a technique to identify the hazards and risks of specific tasks in order to reduce the risk of injury to workers.

Scaffolding – the individual components, for example tubes, couplers or frames and materials that when assembled form a scaffold. Scaffolding is classified as plant under the WHS Act.

Safe work method statement (SWMS) – in relation to high-risk construction work, is a safe work method statement mentioned in section 299 of the WHS Regulation.

Solid construction – means an area that has:

  • a surface that is structurally capable of supporting all persons and things that may be located or placed on it;

  • barriers around its perimeter and any openings to prevent a fall;

  • an even and readily negotiable surface and gradient; and

  • a safe means of entry and exit.

Work at height – where there is a risk of falling from one level to another (e.g. falling from a step ladder).

Work positioning system – involves the use of equipment that enables a person to work supported in a harness in tension in such a way that a fall is prevented.

UQ workers – for the purposes of this procedure includes:

  • staff - continuing, fixed-term, research (contingent funded) and casual staff;

  • contractors, subcontractors and consultants working under UQ systems and control (e.g. contingent workers);

  • visiting academics and researchers;

  • affiliates - academic title holders, visiting academics, emeritus professors, adjunct and honorary title‑holders, industry fellows and conjoint appointments;

  • higher degree by research students; and

  • volunteers and students undertaking work experience.

Custodians
Director, Property and Facilities Mr Fabby Ernesta
Custodians
Director, Property and Facilities Mr Fabby Ernesta