NGC2 Element 1 Web Version

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NEBOSH NGC2element 1www.praa.org.uk

NGC2/1 General workplace hazards and their control

1 Introduction ........................................................................................................... 31.1 Unit NGC2 in general .......................................................................................31.2 Coverage of element NGC2/1 .......................................................................... 41.3 Links across the syllabus .................................................................................51.4 Recommended reading ....................................................................................6

2 Welfare and work environment issues .................................................................. 72.1 What exactly is ‘welfare’? ................................................................................. 72.2 Welfare facilities ...............................................................................................72.3 Work space, workstations and seating ........................................................... 122.4 Ventilation .......................................................................................................132.5 Lighting ...........................................................................................................142.6 Temperature ...................................................................................................15

3 Violence at work .................................................................................................. 193.1 Definition and size of the problem .................................................................. 193.2 Management of work-related violence ........................................................... 20

4 Substance misuse at work ..................................................................................254.1 Alcohol ............................................................................................................254.2 Drugs ..............................................................................................................30

5 Safe movement of people in the workplace ........................................................ 325.1 The key issues ...............................................................................................325.2 Traffic routes ...................................................................................................335.3 Slips, trips and falls ........................................................................................345.4 Falls into dangerous substances .................................................................... 375.5 Falls from height .............................................................................................385.6 Vehicles in the workplace ...............................................................................385.7 Being struck by moving, flying or falling objects ............................................. 395.8 Striking against fixed or stationary objects ..................................................... 405.9 Other pedestrian hazards ...............................................................................40

6 Work at height ..................................................................................................... 416.1 Background ....................................................................................................416.2 Risk factors .....................................................................................................416.3 Control hierarchy ............................................................................................426.4 Temporary work platforms .............................................................................. 436.5 Ladders ..........................................................................................................486.6 Fall protection systems and equipment .......................................................... 536.7 Falling objects ................................................................................................54

7 Excavation work .................................................................................................. 567.1 Overview ........................................................................................................567.2 Collapse of sides and falling materials ........................................................... 567.3 Persons, plant and vehicles falling into excavation ........................................ 587.4 Excavation plant and machinery .................................................................... 587.5 Fumes and gases ...........................................................................................597.6 Buried services and ingress of water ............................................................. 597.7 Contaminated ground .....................................................................................607.8 Adjacent structures .........................................................................................607.9 Inspections .....................................................................................................60

Appendix A Maintaining thermal balance ................................................................ 62

We have removed about half the

pages from this 60 page book.

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1 Introduction

1.1UnitNGC2ingeneralAs we explained at the start of your Certificate studies, and as the titles sug-gest, unit NGC1 of the NEBOSH Certificate addresses the general management aspects of health and safety while unit NGC2 looks at the actual problems (or hazards) that might be encountered in the workplace and shows how solutions to such problems might be found. It can be argued, therefore, that NGC2 has fewer abstract concepts than NGC1 and many people find the more tangible or techni-cal issues in NGC2 easier to comprehend and describe. However, in practice of course, if we have a health and safety problem at work, we have to apply both the management and technical aspects in order to arrive at a sensible solution - we cannot hope to come up with suitable control measures unless we have an appropriate policy in place, robust processes for identifying hazards and assessing risks, and principles of control that can be applied ap-propriately. Therefore, throughout the NGC2 unit you will see references to key parts of these management systems, in particular to risk assessment and the control hierarchy. Try to keep everything you have learned from NGC1 in mind as you work your way through the NGC2 elements.You will also notice as you proceed through the NGC2 unit that there is rarely one simple solution for controlling a workplace hazard - rather, what is normally re-quired is a suitable mix of technical, procedural and behavioural controls. There-fore, the way to ensure that a dangerous machine is made safe for the persons using it is not just to put a guard on it but also to have robust procedures in place to make sure that the guard is an effective one and continues to provide protec-tion as well as providing suitable information and training to operators and main-tenance staff on the use of the machine and its safety features.A complete revision of the Certificate syllabus in 2002 changed the structure of the award and introduced a number of new topics, such as occupational stress and violence at work, which were receiving increasing attention at the time (and have continued to do so). There was also an increased emphasis on risk as-sessment. Further changes to the syllabus in October 2009 involved some slight restructuring of content and led to:

The introduction of new subject areas, the main ones being the effects of tak-ing certain substances (ie alcohol and drugs) at work (element NGC2/1) and the risks to employees and others of driving on public roads during the course of work (element NGC2/2). These issues, again, have received greater atten-tion by health and safety practitioners and enforcers in recent times and so have rightly been added to the syllabus.The removal of a specific element on construction activities, although two key construction issues - excavations and work at height - have been retained in a new element on ‘general workplace issues’ (NGC2/1). In addition, construc-tion management requirements are now specifically covered in the ‘founda-tions’ element of NGC1 (even though this might have been better placed in the element on ‘organising’!). Those who deal with construction activities as part



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of their job, of course, have the option of taking the NEBOSH Construction Certificate instead of the General Certificate. However, most organisations have construction work carried out at some time and, since clients have some onerous duties placed upon them in this respect, it is perhaps a shame that construction topics have been dispersed in this way. Nevertheless, issues like work from height aren’t solely related to construction work and so there are arguments either way.A re-focusing of environmental safety issues, from waste disposal and the con-trol of air and water pollution to a slightly vague section on the ‘safe handling and storage of waste’ (NGC2/7). Despite the syllabus stating that this relates to basic environmental issues, the detail suggests that this is as much to do with personal health and safety as with the environment. Strangely, there is no mention any more of disposing of waste in an environmentally friendly way following its handling and storage. Perhaps the new Environmental Certificate (NEC) is the reason for the change.

1.2CoverageofelementNGC2/1This is a new element in the Certificate syllabus that has been formed mainly from issues that were distributed amongst other NGC2 elements before 2009. The only brand new issue covered here relates to substance misuse at work, as was mentioned above. This essentially refers to employees’ use of alcohol and drugs (prescribed and non-prescribed) while at work, where such use might sometimes be better termed as misuse or abuse.The actual title used by NEBOSH for this element is ‘Workplace hazards and risk control’. However, since the whole of unit NGC2 is about controlling workplace hazards, this is obviously quite a poor title. We have therefore called it ‘General workplace hazards and their control’ in order to try to differentiate it from the more specific hazards in other NGC2 elements.It appears at first sight, then, that this element is intended to deal with some of the issues that relate to workplaces generally - in particular those issues gov-erned by The Workplace (Health, Safety and Welfare) Regulations 1992. Cer-tainly, welfare issues and pedestrian safety would fall into this category. How-ever, on further examination many of the issues dealt with are not general issues at all but are actually quite specific - such as violence, work at height and excava-tions. These issues are just as specific as transport safety and the handling of loads, which have their own elements. So, as well as welfare and work environ-ment issues, the element also becomes a collection of mainly safety-related is-sues, none of which are large enough to justify an element of their own and which do not slot in particularly well elsewhere - perhaps ‘Miscellaneous workplace hazards’ might have been a better title! Indeed, the issues dealt with have little connection with each other, which supports the idea that this element is actually a ragbag of things with no obvious home. Be that as it may, this is where we need to start.


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Having suggested that a large part of this element covers the requirements of The Workplace (Health, Safety and Welfare) Regulations 1992, it is worth not-ing that few of the regulations here apply to construction sites. The Construction (Design and Management) Regulations 2007 contain specific requirements with respect to health, safety and welfare on construction sites and these should be referred to by those with responsibilities for construction work.Talking about construction, there are two topics in this element that are particular-ly relevant to construction work. These relate to working above or below ground level; in other words, ‘work at height’ and ‘excavations’. While people may work at height in a number of industries and occupations outside construction, it is difficult to imagine many other situations where excavation work takes place (a couple are mentioned later on but see if you can think of any). So, if NEBOSH’s idea was to remove construction activities from NGC2 because it offers a sepa-rate Construction Certificate that covers such issues, it is hard to understand why excavation work remains. But it does so we have to cover it here. It is worth noting incidentally that, while work at height and excavation work are considered as two separate issues, excavation work can create a situation where those working at ground level face the risk of effectively falling from height (ie into the excavation) - so there is something of an overlap between the two topics.

1.3LinksacrossthesyllabusThe problem in identifying links across the syllabus for the issues discussed in this element is that they have few links with each other. However, as with all NGC2 elements, there are key links with all the management and legal issues covered in NGC1, in particular with risk assessment and the principles of control (NGC1/4). Nearly everything that you learned in NGC1 will need to be applied here, and throughout NGC2.There is quite a large overlap between this element and NGC2/2 as far as the in-teraction between pedestrians and vehicles in the workplace is concerned. How-ever, there is more to pedestrian safety than simply trying to avoid contact with vehicles; prevention of slips, trips and falls is a key consideration, for instance. Issues such as this are considered in this element whereas the specific dangers caused to pedestrians by vehicles in the workplace are discussed in greater de-tail in NGC2/2.Other links will become obvious as you work your way through. For instance, various types of equipment are mentioned in this element with regards to excava-tions and work at height but some of the general issues relating to work equip-ment (suitability, selection, maintenance, etc) are described in NGC2/4. Similarly, violence as a workplace issue is discussed in this element but, since the constant fear of violence can be very stressful, this links with the topic of occupational stress, which is found in NGC2/8.



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In order to provide an introduction to some of the issues that we will be dealing with in NGC2/1, try to answer the following questions as fully as you can. Hope-fully, when you have finished studying this element, you will be able to add to your answers.Question 1 As you will recall, section 2 of the Health and Safety at Work etc Act 1974 requires employers to ensure, so far as is reasonably practicable, the health, safety and welfare of employees. In a couple of sentences, explain, with some examples, how you think ‘welfare’ differs from health or safety.Question 2 Given that ‘violence at work’ can be defined as ‘Any incident in which a person is abused, threatened or physically assaulted in circumstances relat-ing to their work’, which group or groups of employees in your workplace do you think are most at risk, and why? Would you say that the risk of violence to these employees is high, medium or low? (Don’t forget that risk is a function of both likelihood and consequences.)Question 3 Have a quick look around your workplace (or part of it) and list the items that could cause a person to slip or trip, whether or not these items are evi-dent at this particular time (for instance, you might include icy paths even though it may not be winter).

1.4RecommendedreadingThe hyperlink sheet for NGC2/1 provides links to and details of the website infor-mation and useful publications that you should look at as part of your studies for this element. As usual, our little spider graphic will appear at various points in the text and this will alert you to turn to the hyperlink sheet to take you to the required webpage.Since element NGC2/1 covers a number of disparate issues, there are several HSE leaflets and other publications that cover the relevant issues. However, you might find the following HSE books particularly useful:

Workplace health, safety and welfare: a short guide for managers INDG 244Preventing slips and trips at work INDG 225

The Work at Height Regulations 2005 (as amended): a brief guide INDG 401

These and other useful sources of information will be referred to later in this element.

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2 Welfareandworkenvironmentissues

2.1Whatexactlyis‘welfare’?The term ‘welfare’, in effect, refers to the conditions at work that are needed to make employees free from discomfort and which contribute to their well-being. Issues such as cleanliness, temperature, provision of fresh air, work space and lighting are all related to welfare and we shall be looking at some of these later in this section. Very often, particularly at the extremes, the same issues become health or safety issues. For instance, working in a warm or cool office can be uncomfortable whereas working in very hot or very cold environments may have serious health implications. Similarly, a poor level of lighting can make someone feel uncomfortable but poor lighting also has health and safety implications in terms of eyestrain or not being able to see a hazard clearly. So welfare is inextri-cably linked with health and, very often, with safety.You will hopefully remember the requirements of section 2 of The Health and Safety at Work etc Act 1974 and will be able to identify their relevance to this part of the syllabus. But in case you need a reminder …Section 2(1) of the HSW Act states that:

It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare of all his employers.

and, in order for the employer to fulfil this duty, section 2(2)(e) requires:

the provision and maintenance of a working environment for his employees that is, so far as is reasonably practicable, safe, without risks to health, and adequate as regards facilities and arrangements for their welfare at work.

Don’t forget that the legal requirement for employers to look after someone’s wel-fare applies only to employees. With regards to other persons, section 3 of the HSW Act makes no mention of welfare and refers only to health and safety. How-ever, out of common decency, employers normally provide basic welfare facilities where members of the public or other visitors are likely to use their premises.

2.2WelfarefacilitiesWelfare facilities are the physical amenities, such as toilets, that address some of the basic needs of employees. A schedule to the HSW Act suggests that welfare facilities also include the places and equipment required to administer first aid treatment. For some reason, though, first aid is included by NEBOSH in element NGC1/3 so it will not be discussed any further here.Regulations 20–25 of The Workplace (Health, Safety and Welfare) Regulations 1992 (WHSWR) set out the legal requirements for welfare facilities in the work-place (other than first-aid facilities, which are dealt with by The Health and Safety (First-Aid) Regulations 1981).



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Specifically, WHSWR covers:sanitary conveniences (regulation 20)washing facilities (regulation 21)drinking water (regulation 22)accommodation for clothing (regulation 23)facilities for changing clothing (regulation 24)facilities to rest and to eat meals (regulation 25)

Regulation 25A of WHSWR, in relation to disabled persons, is also relevant here. This requires that all parts of the workplace that are used or occupied by disabled persons at work must be organised to take ac-count of such persons. Therefore, welfare facilities - as well as doors, passageways, workstations, etc - must be adapted where necessary to allow any disabled workers to use them. The Equality Act 2010, which has replaced The Disability Discrimination Act 1995, also applies in this respect.A brief summary of the requirements for workplace welfare facilities can be found in HSE’s INDG 244 publication, which we mentioned earlier. For more detailed information, reference should be made to the HSE’s Approved Code of Practice that applies to the ‘Workplace Regulations’

(publication L 24).

2.2.1SanitaryconveniencesSuitable and sufficient sanitary conveniences must be provided at readily acces-sible places. All sanitary conveniences and the rooms containing them should be kept clean and the facilities must have adequate ventilation and lighting. Men and women should have separate facilities unless each facility is in a sepa-rate room with a lockable door and is for use by only one person at a time. As mentioned above, access for disabled persons should be taken into account where appropriate.The Workplace ACOP sets out the minimum requirements regarding numbers of conveniences - see tables below. The right-hand table may be followed as an alternative to the centre column in the left-hand table in cases where sanitary ac-commodation is used only by men.

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Sufficient sanitary facilities for any given workplace may require a greater number of conveniences than the minimum provision suggested by the ACOP. Account should be taken of, for instance, the layout and number of buildings in the work-place and, where facilities provided for employees are also used by members of the public, the number of conveniences should be increased accordingly.The ACOP also states that suitable sanitary accommodation should: • provide adequate protection from the weather• be connected to a suitable drainage system• be provided with means for flushing with water• contain toilet paper in a holder or dispenser• have a facility for hanging coats (ie a hook)• contain suitable means for the disposal of sanitary dressings where used by

female workersThe facilities do not have to be in the specific workplace but they should be within the same building. This means that where two or more employers share a build-ing, they may wish to make use of common sanitary facilities. In such cases, the number of conveniences should take into account the total number of employees (plus, if relevant, use by other persons). The use of public facilities is acceptable

Toilets used by men only

1–15 1 1 16–30 2 1 31–45 2 2 46–60 3 2 61–75 3 3 76–90 4 3 91–100 4 4 For every 50 men above 100 (or fraction of 50), one additional WC is needed, provided that there is an equal number of urinals

Toilets and washstations for mixed use (or women only)

1–5 1 1 6–25 2 2 26–50 3 3 51–75 4 4 76–100 5 5 For every 25 people above 100 (or fraction of 25), one additional WC and one additional washstation is needed

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only as a last resort. In remote workplaces without running water or a nearby sewer, chemical closets should be provided. The closets should incorporate a suitable deodorising agent and should be emptied at suitable intervals.

2.2.2WashingfacilitiesSuitable and sufficient washing facilities must be provided at readily accessible places (see table above for minimum requirements for washbasins). Showers should be provided where the nature of the work means that workers become particularly dirty or contaminated, especially where there are health implications. Washing facilities will be considered suitable if they: • are in the immediate vicinity of every sanitary convenience (whether or not

they are provided elsewhere)• are in the vicinity of any changing room (whether or not they are provided

elsewhere)• have a clean supply of hot and cold (or warm) water - where practicable it

should be running water• have soap (or other means of cleaning) and towels (or other means of drying)• are sufficiently ventilated and lit, and kept in a clean and orderly conditionSeparate washing facilities must be provided for male and female workers, ex-cept where the facilities are provided in a room intended for use by one person at a time that can be secured from the inside. Separate facilities are not required if the washing facilities are intended for washing the hands, forearms and face only. For the same reasons that were discussed in relation to sanitary conveniences, sufficient washing facilities for any given workplace may require a greater number of units than the minimum provision suggested by the ACOP.Sanitary and washing facilities, including showers, should ensure the privacy of users at all times. Showers should be fitted with thermostatic mixers to prevent scalding. In remote workplaces, water for washing may need to be provided in suitable containers.

2.2.3DrinkingwaterAn adequate supply of wholesome drinking water must be made readily accessible at suitable places in the workplace. Normally this will be mains water, which should be conspicuously marked as drinking water where necessary for reasons of health and safety. The signs should comply with The Health and Safety (Safety Signs and Signals) Regulations 1996 - ie they should be square or rectangular with a green background and white pictogram / writing.Water should be provided in refillable enclosed containers only in situations where it cannot be obtained directly from a mains supply. Such containers should be refilled at least daily (unless they are chilled water dispensers where the containers are returned to the supplier for refilling). Bottled water or water dispensing systems may still be provided as a secondary source of


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drinking water. In fact, in many offices water dispensers may be considered by employees as the primary source but, even then, they should not be relied upon entirely. In places where drinking water is provided, there must be a sufficient number of suitable cups - unless the drinking water is in the form of a jet from which people can drink easily.

2.2.4AccommodationforclothingSuitable and sufficient accommodation must be provided for personal clothing not worn at work and for ‘special’ clothing (uniforms, overalls, thermal clothing, labo-ratory coats, food hygiene clothing, etc) that is worn at work but not taken home. Such accommodation must: • be suitably secure when personal clothing not worn at work is being stored.

As a minimum, there should be a separate hook or peg for each employee but, for added security, a lockable locker may be needed

• provide separate accommodation for clothing worn at work and other clothing where this is necessary to avoid risks to health or damage to the clothing

• include facilities for drying clothing where appropriate (so far as is reasonably practicable)

• be in a suitable location; for instance, accommodation for outdoor clothing should not be in a place where an employee would have to go outdoors to reach their normal place of work!

2.2.5FacilitiesforchangingclothingSuitable and sufficient facilities must be provided to change clothing where employees have to wear special clothing for work and where they cannot, for reasons of health or propriety (ie personal privacy or decency), be expected to change in another room. Separate facilities (or separate use of the same facilities) must be provided for men and women where necessary for reasons of propriety.The Workplace ACOP specifies that the facilities should be readily accessible from workrooms, washing facilities and eating areas, ensure the privacy of the user and be provided with seating. The facilities should be large enough so that the maximum number of persons at work expected to use them at any one time can do so without overcrowding or causing unreasonable delay.

2.2.6FacilitiesforrestandtoeatmealsSuitable and sufficient rest facilities must be provided at readily accessible places in the workplace. This applies particularly to workers who have to stand in order to carry out their work. Where necessary for health and safety reasons (such as exposure to airborne contaminants), the rest facilities must be provided in one or more rest rooms. In other cases (ie where there are no health and safety implica-tions), they may be in rest rooms or rest areas. Canteens may be used as rest facilities provided that there is no obligation to purchase food.



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Suitable rest facilities must specifically be provided for employees who are ex-pectant or nursing mothers, including the facility to lie down if necessary. Where food eaten in the workplace is liable to be-come contaminated, suitable facilities for eating meals must be provided. (Work areas can be counted as rest areas and as eating facilities provided they are adequately clean and there is a suitable surface on which to place food.) Where provided, eating facilities should include a facility for preparing or obtaining a hot drink and a method of heating food (eg a micro-wave oven) if hot meals cannot be obtained easily.Regulation 25(3) of WHSWR states that rest facilities must have suitable ar-rangements for protecting non-smokers from tobacco smoke. However, this should no longer be an issue following the smoking ban in indoor workplaces. The facilities must, though, include an adequate number of tables and seats with backs, as well as seating that is suitable in both number and design for any disa-bled persons who work in the premises.

2.3Workspace,workstationsandseatingRegulations 10 and 11 of WHSWR lay down some basic requirements regarding work space, workstations and seating at work.To ensure the health, safety and welfare of employees, every workroom must have sufficient floor area, height and unoccupied space.

The Workplace ACOP (and other HSE guidance) states that the volume of a workroom (when empty) divided by the number of people normally working in it should be at least 11 cubic metres (11 m3). Therefore, if six people nor-mally work in a workroom that measures 6 m x 5 m with a height of 3 m, then each person has 15 m3 of space (6 x 5 x 3 ÷ 6 = 15), which satisfies the basic requirement. (For the purposes of the calculation, any space above 3 metres should be ignored.) However, 11 m3 per person is a minimum requirement and, when deciding whether there is sufficient unoccupied space or floor area, account should also be taken of the layout of the room, its contents (furniture, fittings and equipment) and the nature of the work. Essentially, persons using the room should be able to move around free-ly and carry out their work without causing a danger to each other and without the room appearing to be overcrowded.

The space requirements of the Regulations, incidentally, do not apply to certain unusual working environments, such as the cabs of machines (tower cranes or similar) or to parts of the workplace that are used infrequently. 4 metres

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Workstations should be suitable for the people using them and for the work they do. This is largely a matter of ergonomics - ie workstations should be designed so that workers do not have to overreach or otherwise put undue strain on their bodies. It should also be ensured that there are no slip or trip hazards when ac-cessing or leaving the workstation and that it is possible to leave the workstation without delay in an emergency. Workstations for disabled workers may need par-ticular consideration. Workstations for users of display screen equipment (DSE) are subject to specific requirements under The Health and Safety (Display Screen Equipment) Regulations 1992 but the ergonomic principles apply to all worksta-tions, whether they are for machine operators, kitchen assistants or supermarket checkout staff. Outdoor workstations should be protected from adverse weather (so far as is reasonably practicable).If the work (or substantial parts of it) can or must be done sitting, seats that are suitable for the people using them and for the work they do should be provided. Seating should give adequate support for the lower back and footrests should be provided for workers who cannot place their feet flat on the floor. In many situa-tions - DSE use in particular - adjustable seating will be appropriate.

2.4VentilationRegulation 6 of WHSWR requires that ‘Effective and suitable provision shall be made to ensure that every enclosed workplace is ventilated by a sufficient quan-tity of fresh or purified air’. This requirement applies generally to all workplaces, not just those where air contamination might cause a danger to health. In order to comply with the legal requirement, all parts of workplaces need to be adequately ventilated with fresh, clean air drawn from an uncontaminated source outside the workplace. Ventilation should also, where appropriate, remove warm, humid air and provide air movement that gives a sense of freshness without causing a draught. In many workplaces, such as offices, these conditions can be achieved naturally without any need for mechanical ventilation equipment - particularly now that smoking is forbidden in indoor workplaces. However, air conditioning systems may offer a way of achieving improved air quality and offer greater flexibility with respect to the thermal environment. If the workplace contains process or heating equipment, or other sources of dust, fumes or vapours, more fresh air will be needed to provide adequate ventilation. Windows or other openings may provide sufficient ventilation but, where neces-sary, mechanical ventilation systems should be provided and regularly main-tained. The Control of Substances Hazardous to Health Regulations 2002 con-tain specific requirements in relation to ventilation in workplaces where airborne contaminants may pose a risk to health (see element NGC2/7). Where mechani-cal ventilation is used, it must include a failure warning device where necessary for reasons of health and safety.



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2.5LightingRegulation 8 of WHSWR requires all workplaces to have ‘suitable and sufficient lighting’, which should, so far as is reasonably practicable, be provided by ‘natural light’ (ie through windows or skylights). Other requirements regarding lighting can be found in The Provision and Use of Work Equipment Regulations 1998 (regulation 21) and the schedule to The Health and Safety (Display Screen Equipment) Regulations 1992. Lighting will therefore be mentioned further when we come to look at work equipment (NGC2/7) and display screen equipment (NGC2/3).Lighting in the workplace should enable people to carry out their work, to use facilities and to move about the workplace safely. In particular, appropriate light-ing is required to prevent eyestrain, to reduce glare and to be able to detect and negotiate hazards. The type and level of lighting will depend on the tasks to be performed and the hazards that are present. If necessary, local lighting should be provided at individual workstations. Good levels of lighting will be required at places of particular risk, such as on stairs and at crossing points on traffic routes. Lighting should not create a hazard. Care should be taken, for instance, that shadows are not cast over possible danger areas or that significant levels of glare are not created. Also, certain fluorescent lighting can create a dangerous stroboscopic effect with some machinery, causing moving parts of the machine to appear stationary. To reduce glare, and possibly heat as well, windows may need to be tinted or shaded with blinds and skylights may need to be painted with whitewash.All lighting should be subject to regular maintenance, including cleaning. Where natural light is utilised, windows and skylights should be kept clean. In situations where the failure of artificial lighting creates a danger, suitable and sufficient emergency lighting must be provided. This should come from an inde-pendent source and should be designed to come on automatically in the event of an emergency. Where provided, emergency lighting should be tested on a regu-lar basis.While it probably goes into rather too much depth in places for the General Certificate, the HSE publication on Lighting at work HSG 38 is a useful source of information for those who would like to find out more. For NGC students, the sections on ‘Managing the health and safety risks’ and ‘Good practice’ are worth a quick read but without becoming bogged down in any technical issues. Ignore the parts of the document that cover legal aspects since these are not cov-ered well and contain some errors. NGC2/1

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2.6Temperature

2.6.1GeneralworkplaceenvironmentsRegulation 7 of WHSWR requires that the temperature in all internal workplaces during working hours is ‘reasonable’. But although the regulation refers solely to ‘temperature’, the six key parameters in relation to thermal comfort (which is what we should be striving for) are in fact:

Air temperature - typically measured by a simple mercury thermometer, or similar.Radiant temperature, which is determined by the amount of radiant energy emitted from a source. Furnaces, infrared electric heaters and the sun emit high levels of radiant energy. (We shall briefly touch on this again when we discuss non-ionising radiation in NGC2/8.) An addition made to WHSWR regulation 7 in 2002 explicitly requires excessive effects of sunlight on tem-perature to be avoided. Humidity - the amount of moisture in the air, which affects the rate of sweat evaporation.Speed of air movement - typically known as ‘wind chill’ in outdoor environments but air movement in indoor settings can also significantly affect thermal comfort, either positively of negatively.Clothing worn, including protective clothing and PPE.Work rate, which will affect the heat generated by the body (or metabolic heat).

It is the combination of all these factors that determines whether or not employees have a suitable thermal environment. Personal preference makes it difficult to specify a thermal environment that satis-fies everyone but, for workplaces where the activity is mainly sedentary (such as offices), the Workplace ACOP recommends that the temperature should normally be at least 16 oC. If work involves physical effort, it should be at least 13 oC unless other laws, such as those relating to food, require lower temperatures. However, the other factors mentioned above should be taken into account when deciding on an appropriate temperature. The ACOP does not give figures for recommended maximum temperatures. However, it is suggested that where work processes or the design of a building could lead to temperatures that are uncomfortably high, then certain steps should be taken. For instance, windows could be shaded in sunny weather and fans could be installed either to increase air movement generally or to extract warm air from heat-producing sources. Air-cooling or air-conditioning systems might also be considered. In order to achieve a desired temperature, most workplaces require a method of heating - or, as just mentioned, cooling. WHSWR states that such methods must not allow dangerous or offensive fumes, gases or vapours to escape into the

In Appendix A at the end of this book, we look in more detail at the heat balance factors which together determine the thermal environment to which the worker is exposed.

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There are several ways of ‘tying’ a scaffold to a structure. They include the fol-lowing:

A through tie makes use of windows or similar openings in walls. A verti-cal tube crossing the opening on the inside is attached to the scaffold by a transom; and a horizontal tube crossing the opening on the outside, called a bridle, holds the scaffold tightly in place. The gaps between the tubes and the structure are packed or wedged with timber sections to ensure a solid fit.A reveal tie also uses openings in buildings but this time the tube is wedged in the opening. This method is less invasive (ie access to the inside of the build-ing is not required) but it is not as secure since it relies on friction to hold it in place. No more than 50% of ties should be reveal ties for this reason.An anchor tie (or bolt tie or eye bolt tie) attaches the scaffold to an eye bolt or similar fixing that is physically bolted into the fabric of the building. Large eye bolts can accommodate a scaffold tube directly; smaller ones must incorporate a mechanism for tying.A box tie attaches the scaffolding to a pillar or similar structural feature of the building.

Scaffolding must be erected by competent erectors and according to recognised standards. It must take account of the weight to be placed on the scaffold (eg by materials and equipment) as well as other forces that may act upon it (eg wind). The key requirements to ensure the stability and safety of an independent tied scaffold are as follows:• Components must be in good condition - all scaffold tubes should be ‘true’ (ie

straight) and free from rust and other damage; all boards, couplings and other fittings must be in sound condition.

• Standards, ledgers and transoms must be sufficient in number and adequately spaced, taking into account the loads im-posed (on a general purpose scaffold, the maximum bay size is normally 2.1 metres). All standards must be installed absolutely vertically. Transom spacing will be deter-mined by the thickness of boards used for the working platform.

• There must be sufficient bracing (ledger, façade and diagonal) to increase rigidity and to prevent distortion of the scaffold structure (façade bracing must be provided at least every 30 metres; ledger bracing must be provided at least on every alternate pair of standards; additional diagonal bracing may also be needed to maintain integrity). (See link 11 for diagonal bracing.)

• Standards must be properly footed on firm ground using square base plates placed centrally on, and usually pinned to, sole boards, which help to distrib-ute the weight (sole boards are not normally required on hard ground such as concrete).

Rather a long list of key requirements here; but every item is essential and waiting to be used in an examination answer. As always, you should attempt to interact with the text - what would constitute your key requirements? then look to see what we say.


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• There must be sufficient ties of the appropriate type(s) to ensure a constant spacing between scaffold and building and to prevent the scaffold coming away from the building. Ties must be placed at least every 8.5 metres (verti-cally and horizontally). Additional ties will be needed where strong forces may be encountered - for instance, where sheeting may be subject to the force of the wind. If it is not possible to provide sufficient ties, then rakers can be used. (Rakers are single tubes attached to a ledger extending out from the scaffold at an angle of less than 75° and securely founded; a transom at the base of the raker then completes a triangle back to the base of the main scaffold.)

• All working platforms must be sufficiently wide and must be closely and fully boarded so that there are no gaps. ‘Inside boards’ may be used to reduce the gap between the inner standard and the building. Boards must overhang the end transom by at least 50 mm but by no more than four times the thickness of the board. Schedule 3 to WAHR specifically requires that working platforms should: be of sufficient dimensions to permit the safe passage of persons and the

safe use of any plant or materials required to be used and to provide a safe working area having regard to the work being carried out there;

possess a suitable surface and, in particular, be so constructed that the surface of the working platform has no gap through which a person could fall, through which any material or object could fall and injure a person, or which gives rise to other risk of injury to any person, unless measures have been taken to protect persons against such risk;

be so erected and used, and maintained in such condition, as to prevent, so far as is reasonably practicable, the risk of slipping or tripping, or any person being caught between the working platform and any adjacent structure.

• Toe-boards of at least 150 mm high must be used at the outside edge of the working platform to prevent a person’s foot being placed over the edge and to prevent materials falling off the platform; brick guards, often made of metal or strong plastic mesh, are needed where there is a risk that materials could be stacked at a height above the toe-board.

• Working platforms should normally be provided with double guardrails, with the top one at least 950 mm from the working platform and with an intermedi-ate guardrail positioned such that no gap through which a person might fall is greater than 470 mm. There should be no break in the protective guardrail except where needed for access by materials or persons; any protection re-moved for this purpose must be replaced as soon as possible (hinged gates or bars might be installed at such places).

• Scaffolds must be protected against vehicles collision and against causing injury to people. This may entail the use of barriers, timber baulks or con-crete blocks, warning signs and markings, lighting, etc. Projecting parts of the scaffold may need particular protection against high-sided vehicles or against causing head injuries to pedestrians.



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• Incomplete scaffolds should be properly marked as such and their use by persons prevented until they have been completed and inspected for integrity and safety. Many companies use the Scafftag® or similar system to indicate the safety status of the scaffold. A scaffold should be inspected by a competent person before first use, following circumstances that may have affected its integrity and at suitable intervals (WAHR regulation 12). Work platforms involving the risk of falls over 2 metres must be inspected at least once every 7 days. The particulars that are to be shown on an inspection report are shown here ...

• Scaffolds must not be overloaded with materials or equipment, or loading applied (eg by sheeting) that was not included in the design. Schedule 3 (Part 1, paragraph 6) to WAHR requires that a working platform and any supporting structure ‘shall not be loaded so as to give rise to a risk of collapse or to any deformation which could affect its safe use’.

• Scaffolds should be kept clean and free from waste.• Scaffolding should be erected, altered, dismantled and used only by

competent and trained persons.Schedule 3 to WAHR also imposes requirements for the proper design of scaf-folding and for the drawing up of assembly and dismantling plans in more com-plex situations.

Having looked briefly at putlog scaffolds (which aren’t in the syllabus) and in more detail at independent tied scaffolds (which are), we turn now to the other type of scaffold specifically mentioned in the syllabus: mobile tower scaffolds.

A mobile tower scaffold - or mobile access tower - must possess many of the features of fixed scaffolding in terms of guardrails, toe-boards, bracing and a fully boarded work platform. In addition:• the tower should be made secure by placing it on

firm, level ground and, where necessary, by the use of outriggers and / or tying to the building

• wheels should be locked when the tower is in position• the tower should never be moved while there is any

equipment or person on it

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The name and address of the person for whom the inspection was carried out.The location of the work equipment inspected.A description of the work equipment inspected.The date and time of the inspection.Details of any matter identified that could give rise to a risk to the health or safety of any person.Details of any action taken as a result of any matter identified.Details of any further action considered necessary.The name and position of the person making the report.

use of an outrigger to provide stability


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• towers should be reduced to 4 metres or less before moving and checks should be made for overhead obstructions

• the ladder should preferably be integral to the tower (either internal or external) and provided with a hinged bar, gate or hatch door for access

• overloading should be avoided and, unless it has been specifically designed for the purpose, a mobile tower should never be sheeted, exposed to strong winds, loaded with heavy equipment or used to hoist materials or support rubbish chutes

The inspection requirements for mobile towers are the same as for other types of scaffolding; as before, the requirements are more demanding when the mobile tower is higher than two metres.

6.4.2MobileelevatingworkplatformsMobile elevating work platforms or MEWPs - also commonly known as ‘cherry-pickers’ - come in various types. They can be vehicle-mounted or independent and normally use a boom (ar-ticulated or telescopic) or scissor mechanism to lift the platform. Independent MEWPs, whether of the scissor, boom or mast-climbing type, may be self-propelled or static. Many self-pro-pelled MEWPs can be driven in the elevated position. ‘Static’ MEWPs are usually transported by being towed behind a vehi-cle and can be manoeuvred into position manually.To ensure the safety of persons working from the platform, the following are required:• the type of MEWP selected should be suitable for the particular task• all equipment should be well maintained and kept in good repair• the equipment should be inspected before use to ensure correct

functioning• where appropriate, brakes should be applied, outriggers used and

the MEWP should be protected at the base (with barriers, signs, etc) against collision and to ensure the safety of those on the ground

• the MEWP and outriggers should be positioned on firm ground and so the platform base is level; care should be taken not to set up over weak areas such as drains

• an assessment is required before the job starts to identify overhead obstruc-tions and other dangers such as power lines; fatalities have occurred when workers on platforms have been trapped against the controls by overhead obstructions

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• the platform must not be overloaded (by persons, equipment and / or materials)• MEWPs should not be used outdoors in adverse weather conditions• platforms should incorporate guardrails and toe-boards and workers should

wear harnesses; the platform should be positioned so that workers do not over-reach

• all workers must be trained and appropriately supervised; workers at ground level should be trained in emergency procedures

6.5LaddersAround a third of all reported ‘fall from height’ incidents involve ladders and step-ladders. On average, this accounts for about 12 deaths and 1500 major injuries to workers each year. A ladder may be used as a means of accessing a permanent or temporary work platform (such as a roof or scaffold) or it may sometimes be used as the only means of access to a work position at height (ie where work is done from the lad-der). Any work done from a ladder needs serious consideration.

There are various types of ladder but they can essentially be divided into fixed or portable. Portable ladders can be further categorised as leaning, roof or step ladders. Combination ladders can operate either as a leaning ladder or a stepladder. In addition, mobile ladders or steps are used in situations such as libraries, warehouses and other storage facilities, where they either run in guides or operate independently. Mobile ladders / steps are not discussed further.

Fixed ladders can be found in situations such as on chemical storage tanks, telecommunication masts and similar structures where access may be re-quired for maintenance and so forth. Fixed ladders are normally vertical and may be made up either of a series of rungs or of individual treads set into a wall. In construction, the most obvious uses of fixed ladders are for access to the cab of a tower crane and for access to an underground chamber, drain or sewer.All fixed ladders should be free from corrosion and other damage, be securely fixed to the structure and preferably arranged in staged sections where long runs are involved. Rungs or treads should be horizontal, give adequate foothold and incorporate non-slip features. The provision of safety hoops is normally advised for vertical ladders over 2.5 me-tres in height although research suggests that they might sometimes contribute to injury rather than prevent it. An alternative or additional measure,

a fixed ladder, incorporating fall-arrest equipment


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depending on the circumstances and the height involved, is the provision of a vertical, rigid anchor rail to which fall arrest equipment can be attached.Leaning ladders, or pole ladders, are normally constructed of either wood or alu-minium. They consist of two vertical stiles joined by a series of horizontal rungs. Wooden ladders usually incorporate a metal reinforcing rod under each rung. Leaning ladders may have more than one section to allow the ladder to be extended.Roof ladders, as the name suggests, are used as a means of climbing up sloping roofs - for instance, to access a TV aerial. The top end of the ladder hooks over the ridge of the roof and the ladder may incorporate wheels to enable it to be pushed up the roof more easily and to prevent damage to the roof tiles or slates.Stepladders are arranged in two sections that are hinged together at the top. They can be constructed of wood, alu-minium or fibreglass. Normally one section incorporates the treads and the other maintains equilibrium when in position although it is possible to obtain double-sided stepladders that have treads on both sections. The two sections are connected by a stay at a point along their length or by some other means so that an ap-propriate distance between the feet of each section is maintained and to ensure rigidity. From the side, a stepladder often resembles the letter ‘A’. Schedule 6 to The Work at Height Regulations 2005 states that a ladder should be used for work at height only in low risk situations and where ei-ther it will be used for a short duration or existing features on site cannot be altered in order to accommodate a more suitable means of working. There are many situations that fulfil these criteria and ladders will remain a standard means of undertaking tasks and accessing positions at height. The table on the next page shows all the requirements for ladders under Schedule 6 to WAHR ...

roof ladder in position, hooked over roof ridge



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Requirements for ladders

1 Every employer shall ensure that a ladder is used for work at height only if a risk assessment under regulation 3 of the ‘Management Regulations’ has demonstrated that the use of more suitable work equipment is not justified because of the low risk and …

(a) the short duration of use; or

(b) existing features on site which he cannot alter.

2 Any surface upon which a ladder rests shall be stable, firm, of sufficient strength and of suitable composition safely to support the ladder so that its rungs or steps remain horizontal, and any loading intended to be placed on it.

3 A ladder shall be so positioned as to ensure its stability during use.

4 A suspended ladder shall be attached in a secure manner and so that, with the ex-ception of a flexible ladder, it cannot be displaced and swinging is prevented.

5 A portable ladder shall be prevented from slipping during use by:

(a) securing the stiles at or near their upper or lower ends;

(b) an effective anti-slip or other effective stability device; or

(c) any other arrangement of equivalent effectiveness.

6 A ladder used for access shall be long enough to protrude sufficiently above the place of landing to which it provides access, unless other measures have been taken to en-sure a firm handhold.

7 No interlocking or extension ladder shall be used unless its sections are prevented from moving relative to each other while in use.

8 A mobile ladder shall be prevented from moving before it is stepped on.

9 Where a ladder or run of ladders rises a vertical distance of 9 metres or more above its base, there shall, where reasonably practicable, be provided at suitable intervals suffi-cient safe landing areas or rest platforms.

10 Every ladder shall be used in such a way that:

(a) a secure handhold and secure support are always available to the user; and

(b) the user can maintain a safe handhold when carrying a load unless, in the case of a step ladder, the maintenance of a handhold is not practicable when a load is car-ried, and a risk assessment under regulation 3 of the ‘Management Regulations’ has demon-strated that the use of a stepladder is justified because of …

(i) the low risk; and

(ii) the short duration of use.

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The following criteria should be satisfied in the proper selection and safe position-ing of a ladder:• The ladder should be suitable for the job in relation to its height, class, material

of construction, etc.• It must not be damaged or painted (paint can be used to hide defects).

Ladders that are twisted or show signs of unauthorised repairs should not be used. On wooden ladders, there must be no shakes (splits) in the stiles, no rung should be missing, loose, worn or split, and all reinforcing bars must be in place. Metal ladders should have no dents or distortions caused perhaps by vehicles or by being dropped. Ladder feet should be firmly attached. All ladders should be clean and free of grease before use.

• A leaning ladder should be positioned at 75º (ie with a horizontal : vertical ratio of 1:4)

• A ladder must always be used the right way up (ie with the reinforcement below the rungs on a wooden ladder and with treads uppermost on a metal ladder).

• A ladder should be placed on a firm, uncluttered and non-slippery surface (never on objects that can move such as mobile towers, pallets, bricks, etc). The surface should preferably be level in both planes (side-to-side and front-to-back) but a back slope of less than 6º can usually be accommodated. For angles greater than this, it may be possible to fix stop blocks in the ground to prevent the foot of the ladder from sliding down the slope. On side slopes of less than 16º, suitable (not makeshift) levelling devices can sometimes be used under one stile to maintain the rungs in a horizontal position.

• The top of a leaning ladder should rest on a strong upper resting point (ie not on a window or plastic guttering).

• There should be adequate overlap between sections on extended ladders.• The ladder should be prevented from moving at the top and at the bottom.

Where necessary to achieve this, it should be tied at the top and / or secured at the bottom.

• Where used for access, a ladder should project at least one metre above the landing stage and both stiles should be tied at the point where the ladder meets the landing stage.

• Ladders should be protected from vehicles and should be placed where they will not be struck by doors, windows, etc. Ladders should not be used in close proximity (<6 metres) to overhead power lines.

• The stays or restraints on a stepladder should be fully extended and locked in position where applicable.

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Users of ladders should:• never work from the top three rungs or treads (or the top two treads of a step-

ladder that does not have a tread at the top); this is so a handhold is always available

• always try to maintain three points of contact with the ladder• never over-reach (as a guide, the belt-buckle or person’s navel should always

remain within the stiles)• never work side-on from a ladder or stepladder (the

ladder should always be positioned in such a way that the worker faces the work position)

• never attempt to move a ladder, or extend it, while on the rungs of a ladder

• never attempt to use a ladder when it is in use by another person

• wear appropriate footwear that is free from mud and grease

• avoid holding equipment, tools, etc when climbing a ladder (tool belts should be used)

• not work from a ladder in adverse weather conditions• be sufficiently fit to climb and descend ladders

without difficulty• be trained in the safe use of laddersIn conclusion, work should be carried out from a ladder only when other more suitable means of access are not reasonably practicable and where, as a guide:• the ladder will not be used for more than about 30 minutes in one position• the work is not strenuous or heavy (the use of a ladder would be hard to justify

where someone is required to carry much more than 10 kg)• the work can be done without over-reaching• a handhold is available on the ladder or stepladder• three points of contact (hands and feet) can be maintained at the working posi-

tion - unless a risk assessment shows that the risk is low; devices (tool belts, hooks, etc) for supporting equipment or materials should be used in order to keep hands free to hold on

Further information on ladder safety is available from HSE. See, for instance, Safe use of ladders and stepladders - an employer’s guide INDG 402 and Top tips for ladder and stepladder safety INDG 405. Other ways of accessing places of work at height include staging plat-forms, cradles, hoists, rope systems and stilts. Other than hoists (see NGC2/3) and rope systems (see next section), these are not discussed further.

this figure is taken from the HSE Toolbox talk on ladders

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6.6FallprotectionsystemsandequipmentIn circumstances where collective restraint methods such as edge protection or scaffold and guardrails are impracticable, then personal work restraint, work positioning or rope systems may need to be considered. Where the risk of injury remains, then the use of fall arrest systems, either collective or personal, may be appropriate instead of, or in addition to, other systems.

Work restraint systems prevent workers from getting into a position where they might fall. In the main, they consist of a rope, or ‘lanyard’, that attaches the worker to an anchorage point. The length of the lanyard must be less than the distance from the anchor to the unprotected edge. In this way, the user is physically prevented from reaching the danger zone.Work positioning systems and equipment enable the user to work in tension or suspension to prevent or limit a fall. Exam-ples are a boatswain’s chair and a linesman’s pole strap. The latter is used typically by electricity supply workers and is used to free a linesman’s hands at the top of a pole. It consists of a strap that is passed around the pole and attached to a padded belt and harness worn by the worker, allowing the linesman to lean backwards. Normally with these systems, a back-up system or fall arrest system is needed in case the main support fails.Rope access systems use two ropes, a working rope and a safety rope, each secured to a reliable anchor. The user’s harness is attached to both ropes in such a way that (s)he can get to and from the work area and the risk of falling is prevented or limited. This type of system can be used to access the side of a tall building where a cradle cannot be used. Operatives can use abseiling techniques to reach the work position.Fall arrest systems do not prevent falls but limit the distance of the fall and prevent impact with the ground. They are often used in conjunction with other protec-tion systems. Fall arrest systems can be ‘collective’ (ie providing protection for all persons at risk) or ‘personal’ (providing protection only for the person by whom they are worn). Collective systems include mats, airbags and nets while personal systems consist mainly of harnesses that are attached to an anchorage point by a lanyard. Lanyards can incorporate energy absorb-ers to minimise the risk of injury from the harness. It must be ensured that

work restraint system

work positioning system (from HSE Tree-climbing operations)

rope access system(RopeTask Ltd)

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the length of the lanyard does not allow workers to fall a distance where they might strike a solid object or the ground. Other personal fall arrest systems utilise inertia reels (or stop blocks), which work on the same principle as a car seat belt and operate if the rope attached to the worker’s harness is pulled into tension suddenly.

Whatever system is used, workers must be very well trained and suitable arrangements must be in place to rescue workers who fall into nets or are left suspended at height, where so-called suspension trauma can be a very real and serious risk - see this link for more details.

6.7 FallingobjectsSome means of preventing falling objects while people are working at height (ie toe-boards and brick guards) were discussed earlier. Other means in-clude the complete netting or sheeting of a scaffold or the use of extending ‘fans’ (see picture) designed to catch anything that falls. Fans are commonly seen on scaffolding in town cen-tres to prevent objects falling to street level. Research suggests, however, that objects can bounce over or out of a fan and their effectiveness is increased when used in combination with sheeting.Measures such as sheeting and fans do not actually prevent objects falling but they are intended to pre-vent them falling to places where they could cause injury. One way of preventing an object from falling at all, though, is to make it secure. Items such as scaf-fold boards and pieces of equipment can be physically lashed to the scaffold, tools can be attached to work-ers or other anchors by lanyards and good housekeep-ing procedures will ensure that tools, rubbish and other objects are not left in positions where they could fall (or create a tripping hazard).

As explicitly required by regulation 10(3) of WAHR, nothing should be thrown or tipped from scaffolds or other workplaces at height. All equipment and materials should be lowered by hoist or by a rope sys-tem. Waste materials (eg rubble) should be lowered in similar ways or by transferring to ground level or into skips via waste chutes (‘elephant trunks’). The skip should normally be cov-ered to prevent objects bouncing out and / or to control dust.Although emphasis should be placed on preventing objects falling, a risk may nevertheless remain and steps should then be taken to prevent any falling object from causing injury. In

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this is a heavy duty scaffold fan


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some situations of course, such as demolition, falling material is practically inevi-table. The main way of preventing injury is by excluding people from the area. Regulation 11 of WAHR relates to ‘danger zones’ and requires that areas where unauthorised persons could either fall from height or be struck by a falling object should be clearly indicated and provided with means to prevent access. While it may not be practicable, or necessary, to set up exclusion zones in all situations where people are working at height, it is normally the case that some degree of exclusion will apply. Risk areas may be cordoned off by the use of fences, cones, bunting or similar means and signs should be used to indicate where the exclusion area applies.Where exclusion is not possible (eg where people need to gain access to, or to use a footpath alongside, a building where work at height is taking place), then it may be necessary to erect covered walkways or similar protective structures. Vehicles working in areas where there is a risk of falling materials must be fitted with FOPS (falling object protective structures) to protect the operator. This is particularly the case with demolition machinery.Exclusion zones and protective structures are often not practicable on all parts of a construction site and some risk will usually remain. Therefore, personal protection in the form of hard hats is a standard requirement in construction work.The Construction (Head Protection) Regulations 1989 require that every construction employee is provided with suitable head protection. Employers are obliged to make an assessment in order to select head protection that is suitable and to review that assessment if they sus-pect that it may no longer be valid or if the work changes. Employers must also maintain and replace head protection as necessary and provide suitable accommodation for it. They must ensure that head protection is worn by employees unless there is no foreseeable risk of head injury other than by falling. (There is a similar requirement placed on employers, self-employed persons and employees with respect to any person over whom they have con-trol.) The Regulations allow for the person in control of the site to make rules and give directions regarding head protection and require that employees and self-employed persons obey these rules or directions. In addition, employees are required to return head protection to the accommodation provided and to report any loss or defect.In practice, most employers require that head protection is worn at all times on site, regardless of the precise circumstances regarding risk of head injury. Work-ers on a roof where there is no crane operating, for instance, may not be at risk from falling objects or from bumping their heads, but they would nevertheless normally be required to use head protection. A blanket rule is simply easier to understand and to enforce.Hard hats may sometimes be necessary in non-construction situations, such as warehouses or other storage facilities.

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