News & Views

22nd June 2021

Safe Work at Heights Must Start at the Top of the Control Hierarchy

In the most recent reporting period from 2015 – 2019, Safe Work Australia states there’s been 122 workplace fatalities as a result of workers falling when working at heights, with most of these involving falls from roofs and ladders. (source: Safe Work Australia

Both employers and employees have obligations to identify and eliminate the hazards that pose a risk of a person falling. If it’s not reasonably practicable to eliminate these hazards, they must be controlled so that the risk of a person falling is as low as possible. This is not as simple as choosing a preferred means to prevent someone falling, such as choosing an Elevating Work Platform (EWP) or a platform ladder. In order to comply with the Occupational Health & Safety Regulations (OHS Regulations) in Victoria, employers and work groups must select the highest level of risk controls as is reasonably practicable, as the primary control, in conjunction with any lower level controls that may be applied or are otherwise mandatory. The performance of these control measures also must be monitored and reviewed to ensure new hazards are not introduced, or if controls continue to be the most effective available if circumstances on site change.

Before drilling down further on this priority level concept, it’s important to firstly define some key terms;

Working at heights is any work activity or task that is;

  • not performed from the ground level, or the surface level of any “solid construction” such as many suspended slabs in multi-level commercial building structures; &
  • there is a risk of a person falling due to the work being undertaken or the work environment.

A “solid construction” means an area that has:

  1. a surface that is structurally capable of supporting all persons and things that may be located or placed on it; &
  2. barriers around its perimeter and any openings to prevent a fall; and
  3. an even and readily negotiable surface and gradient; and
  4. a safe means of entry and exit.

The “risk of a person falling” is defined as a fall by a person from one level to another that is reasonably likely to cause injury to the person or any other person.

It is widely accepted that the distance travelled by a person during a fall is proportional to the severity of the injuries a fallen person may sustain. Based on this principal, work where there’s a risk of person falling more than 2 metres, is defined within OHS Regulations throughout all States & Territories  as a “High Risk Construction Work” activity, which imposes additional obligations on employers and employees including amongst others, the requirement for a Safe Work Method Statement (SWMS) to be implemented before the work commences. This more than 2 metre distinction has become a commercial construction industry benchmark, and is intended to be assumed in relation to the following information.

In case you weren’t already aware of how to measure the 2 metre distance, you might be asking this logical question right now. Measuring the potential distance a person may fall is simply the distance from the top of the surface they’re standing on, to the ground surface or the surface of the nearest ‘solid construction’ below. However, allowance must also be made for unprotected edges of surfaces below. This may apply if working on a ladder on a balcony in a multi-story building. See Example A & Example B below on how to measure the fall distance based on typical examples in the construction industry.

Example A

When working on passive fall prevention equipment such as a mobile scaffold or an EWP, the distance is measured from the top surface the person is standing on, to the top of the surface below. The same principal should also be applied when intending to work from a ladder, by measuring the distance from the ground surface or solid construction, to the top surface of the ladder step intended to be stood on during the work. 

Example B

If the surface below is not the ground or the surface of a “solid construction”, then the distance shall be measured until the ground or surface of any “solid construction” below. This is typical when working on a balcony. When standing on the balcony, the guardrail acts to form a “solid construction” however when working on a ladder, the guardrail is typically less than the standard height, and protection against a person falling is not effective. In this situation both distances must be added together.

The following 5 levels of risk controls to eliminate or reduce the risk of a person falling must be assessed and implemented on a priority basis starting from the top down, prior to commencing any work where there’s a risk of falling more than 2 metres.

  • Level 1: Eliminate the risk
  • Level 2: Passive Fall Prevention
  • Level 3: Work Positioning Systems
  • Level 4: Fall Arrest Systems
  • Level 5: Administration Controls & Fixed or Portable Ladder

Level 1:

Eliminate the risk

  • using hinged poles to allow access to lamps at ground level
  • using extension tools to increase reach from ground level prefabricating roofs at ground level
  • prefabricating frames horizontally, then standing them up
  • using precast or tilt-up concrete construction instead of concrete walls constructed in situ

The law says employers must eliminate the risk of a person falling as far as reasonably practicable, by ensuring work involving the risk of a person falling is carried out from the ground, or on a solid construction. If you decide to bypass this elimination priority, and proceed to work from a lower priority control level such as an Elevating Work Platform (EWP), Fall Arrest device such as a safety harness attached to an anchor point via a lanyard, or use of a platform ladder when the work could have been done on the ground and hoisted into position, then you have not complied with the OHS Regulations, and may be placing yourself and others at serious risk of falling, that is unnecessary and could have been avoided.

If elimination of the risk is not reasonably practicable, then the level 2 – Fall Prevention Equipment must be assessed. This could include control measures such as the use of scaffolding, or an EWP/s amongst others, which must be considered and used when reasonable to do so.


Level 2:

Passive Fall Prevention

  • scaffolds
  • perimeter screens
  • perimeter guardrailing
  • guardrailing edges of roofs
  • safety mesh
  • elevating work platforms

If the use of passive fall prevention is not reasonably practicable, then the level 3 – Work Positioning Systems must be assessed. This includes control measures such as a travel restraint system that prevents a person from being able to fall from an unprotected edge or penetration by physically limiting the distance a person can move from the anchor device. An Industrial rope access system is another work positioning system to allow access to difficult to reach positions such as on or around vertical faces of structures. A work positioning system  must be considered and used when reasonable to do so.


Level 3:

Work Positioning Systems

  • travel restraint systems
  • industrial rope access

If the use of a work positioning system is not reasonably practicable, then the level 4 – Fall Arrest Equipment must be assessed. This typically includes using a personal safety harness attached to a load rated anchor point via a lanyard or inertia reel to allow a fallen worker to safely arrest. A catch platform is another option to arrest a fallen worker or objects. In the absence of higher level controls not being reasonable to use, fall arrest systems must be considered and used when reasonable.


Level 4: Fall Arrest Systems

  • catch platforms
  • safety harness systems other than travel restraint systems

If the use of a Fall Arrest System is not reasonably practicable, then the level 5 – Administration Controls and Ladders must be assessed. This typically includes using a combination of safety systems including amongst others, a Safe Work Method Statement, Access Permit system in conjunction with the safest type of ladder for the work activities, in accordance with the requirements of the Victorian ‘Compliance Code - Prevention of falls in general construction (2019)’. Although this is the final and lowest level of mandatory controls required to prevent a person falling, it should always be implemented in additional to higher level controls.


Level 5: Administration Controls & Fixed or Portable Ladder

  • Single ladders
  • Extension ladders
  • Platform ladders
  • Fixed ladders (permanently fixed to a building or sctructure)

However, often when working at heights is required, many people tend to go directly to the use of a ladder as the primary means of getting the work done, without considering higher level risk controls. This approach represents a breach the OHS Regulations, and opens the door for potential enforcement action by WorkSafe Victoria. If this is the case in your organisation, in addition to opening the door to the wrong side of the law and more importantly, you’re limiting access to safer ways of working when there’s a risk of a person falling, and putting your valued employees at risk of a potentially life threatening injury.

To assist Electrical Contractors to discharge their legal obligations and comply with the prescribed hierarchy of controls specific to work where there is a risk of a person(s) falling more than 2 metres, there’s a couple of highly intuitive risk assessment templates now available to electrical contractors on the iAuditor App. These produce a high visible impact on the user through the utilisation of various popup signs, photos and diagrams. Both templates are available to download 100% to anyone with a free personal, or paid corporate iAuditor account.