Guidelines for Window Cleaners when Working at Height.

Wayne Smith
Oct 1
7 min read

This blog is designed to give you some guidelines for working at height safely. The following information covers procedures and processes that can be implemented to ensure best practice.

Working at Height Regulations:

All work at height activities must be in accordance with current legislation and guidance.

In summary, working at height means any height from which people could fall and injure themselves. You are working at height if you:

Work above ground/floor level
Could fall from an edge, through an opening or fragile surface
Could fall from ground level into an opening in a floor or hole in the ground

The Work at Height Regulations 2005 place a duty on employers and contractors to ensure that all work at height is:

Properly planned and organised - including planning for emergencies and rescue
Assessed for risks using the hierarchy of control measures
Appropriately supervised
Done in a way that is - as far as is reasonably practical – safe
Always done by competent people, including managers and supervisors, who are appropriately trained and supervised
Done using appropriate equipment that is regularly inspected and maintained

Keeping up to date with HSE and industry guidance will help you meet your duties under the Work at Height Regulations.

Hierarchy of control:

For every task that needs to be done at height you need to assess the risk and put appropriate control measures in place. There is a hierarchy of control measures that you need to follow. You only move down the hierarchy when you decide that the control is not practicable.

Broadly the hierarchy is:

Avoid the need to work at height, for example by using extending equipment from the ground
Prevent falls using appropriate access equipment such as work platforms (cradles or MEWPS)
Reduce the distance and consequences of a fall should one occur

NOTE: Collective measures must always be considered before fall prevention.

As always, the hierarchy of control must be considered before any work at height is carried out. There must be sufficient evidence escalated through the management chain to demonstrate that other equipment/systems cannot be used and as a result, you have done all that is reasonably practicable to reduce the risk in accordance with hierarchy of control. This should be documented and evidenced as part of your risk assessment before any work is carried out.

Recommended Procedures and Processes for Working at Height

Competency:

Only trained, authorised and competent persons can work at height and use working at height equipment. Competency must be evidenced through obtaining certificates, checking experience and verification through supervision. Relevant certificates should always be reviewed and provided to sites before works commence.

Supervision:

Working at height activities should have an appointed supervisor to oversee that works are carried out in a safe manner and to make sure procedures and processes are adhered to.

Personal Protective Equipment:

All PPE must be worn correctly and used following manufacturing guidelines. If PPE is damaged operatives must not use the equipment, report this to management immediately and quarantine the equipment correctly. Suitable fall prevention/ fall arrest equipment (full body harness with energy absorbing lanyards or/ restraint lanyards) must be used at all times. PPE must adhere to BSEN standards. Also Consider additional requirements such as wearing hard hats when accessing roof areas.

Inspection of Equipment:

Equipment is subject to pre-use checks by the operative, documented and detailed inspections are required to be carried out by an appointed, competent person on specific frequencies depending on the equipment. Consider increasing this frequency if used regularly and in harsh condition i.e. harnesses are a minimum of every 6 months but if regular use or harsh conditions then this should be 3 months. This principle must be applied for any working at height equipment, including PPE and access equipment. In addition, operatives must check equipment is in date and complying to LOLER or PUWER regulations if applicable.

Equipment General:

It is recommended that operatives must only use equipment provided to them by the company they work for, this ensure full traceability and accountability. Only trained and competent persons can use the equipment. Operatives must understand site specific instructions on accessing and using the equipment safely. Equipment must be used as instructed during training and as the equipment was designed for. In addition, safe working loads must be adhered to.

Falling Objects:

The tethering of all tools and equipment, removing everything that is capable of falling from pockets and creating exclusion zones with barriers/warning signs is a must.

Always Stay Attached:

Operatives must never disconnect from their safe system of work whilst working at height.

Extreme Weather:

Working at height activities will be subject to extreme weather, operatives must discuss the conditions with management and cease work if there is a risk of injury or ill-health. All working at height activities must cease if wind speeds are above 23 mph, unless wind speed is stipulated on the equipment.

Stop Work:

If an operative believes something Is unsafe, they must immediately stop work and report this to management for review before works recommence. A stop work procedure is always a good way to encourage positive safety culture amongst your teams.

Documents and processes:

Operatives should have access, review and complete relevant documentation before and after works are completed.

Equipment Access Log Book:

Your company should follow on site processes in regards to any working at height access equipment, but if nothing is provided consider creating and providing an access log book to your clients. This aids in creating clear communication between all contractors on site. The documentation will require reviewing and completion by all parties, whilst control should sit with site based management teams. Consider having this electronically to avoid loss of paper work.

Risk Assessments and Method Statements:

For any work task, there must be site-specific RAMS in place. All operatives must have read and understood them before starting a task, evidenced by an operative sign off sheet is also recommended. RAMS and safe systems of work must be understood and followed. Operatives should risk assess before every task to check there are no additional hazards since the RAMS were created.

Emergency descent procedure:

Working at height RAMS should also have an associated emergency decent procedure and be site specific. This should also consider requirements during the access and egress process.

Work at Height Permit:

For any working at height activity a work at height permit is recommended. Most clients will have this in place and will require all relevant certification and documentation to be submitted prior to approval. Your teams should be fully aware to follow this process. Before work commences operatives should ensure they have received written acknowledgment of the works being authorised by the client. This process ultimately avoids various contractors working in the same area at the same time, where conflict could occur.

Reporting:

Reporting of safety issues should be encouraged within your teams. Any concerns, queries or misunderstandings should be reported to management immediately. Any matters which may affect safety, or any near misses or incidents should also be reported immediately. If an operative witnesses an unsafe working at height act, they must stop work and report this to management immediately. Whilst reporting is important the follow up actions must be completed to ensure safety and a positive culture.

Video/Recording:

Having a procedure in place to record all visual and tactile equipment checks for any working at height activity, can be useful in the event of an incident but supportive in training and site familiarisation.

Key Principles

Rope Access (IRATA):

Only operatives who hold a level 1, 2 or 3 training certificates are authorised to carry out rope access.
Minimum of two IRATA operatives on site with one being an IRATA level 3.
Rope access methods must involve rigging to a suitable and sufficient anchorage point as a safe system of work depending on site requirements. i.e. eyebolts, deadweight trolleys, a
frame etc.
Minimum of two connections should be made by operatives when in work positioning.
Exclusion barriers/ warning signs must be used on ground and roof level in accordance wit site requirements.
Communication must be in place at all times in form of e.g. radio or phone.

Rope access activities must adhere to IRATA guidelines. IRATA is the internationally recognised trade association for rope access and you should consider their guidelines for current best practice. IRATA is recognised as the world’s leading authority on industrial rope access.

BMU’s:

Only site-specific trained operatives are authorised to use BMU’s.
Valid LOLER and insurance inspection certificates must be obtained and checked before work commences.
Pre and post checks on BMU’s should be carried out and recorded with every use, by operatives.
BMU’s must be used and stowed in accordance with manufacturing guidelines and site rules.
Exclusion barriers/ warning signs must be used in accordance with site requirements.
Communication must be in place at all times in form of e.g. radio or phone.

MEWPs:

Only operatives who hold relevant IPAF card or certification in accordance with appropriate category is authorised to use MEWP’s.
Consideration should be given to nearby hazards i.e. overhead obstacles, ground conditions etc.
To stop persons falling from the platform a harness with a suitable work restraint lanyard must be secured by the operative to the correct anchor point within the basket.
Valid LOLER and insurance inspection certificates must be obtained and checked before work commences.
Communication must be in place at all times in form of e.g. radio or phone.

Ladders:

Ladders should always be used at the correct angle (1 1n 4/75 degrees).
Recommended that operatives only use company provided ladders and are required to carry out pre-use checks before work commences.
You must maintain 3 points of contact e.g. two feet and one hand and maintain a firm grip at all times.
Never work off the top three rungs.
Always face the ladder rungs while climbing or descending
The ladder must always be secured to prevent it slipping or falling i.e. all the stiles are secure and in contact at the top and bottom.
Operatives must always ensure a tool belt or carrier is worn at all times.

NOTE: Operatives should be instructed to prioritise their safety, adhere to company and on-site procedures and comply with legislation and guidance.

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