Health & Safety Tallescope update
Author - Euan Turner
This update is for all FST members and provides a copy of the update that the Health and Safety Executive (HSE) have recently distributed to all Local Authorities.
What this means in practice is that any Environmental Health Officer (EHO) inspecting your premises or work activity has a standard to judge these against and is likely to ask you questions on the tallescope’s use.
What am I likely to get asked by an EHO?
The first question is likely to be do you have a tallescope! Then, they will be interested in what you do with it… The EHO should be looking to you to explain to them how you manage the risk of working at height, and in particular, an understanding of this industry practice.
If you don’t move people in a tallescope, then you do not need to have these arrangements in place – but you still do need to show how you are managing the risks of working at height.
If you do move people in a tallescope, you should be able to demonstrate that your working arrangements meet the standards as detailed in the HSE guidance and your tallescope has had the modifications fitted as described in the attached guidance.
If you do move people in a tallescope but have not yet made these changes, then the best thing to do until you have these changes done is to not move people whilst up the tallescope. Although technically speaking this is just guidance, so you are at liberty to use your tallescope differently as long as you manage the risks properly, this is not a recommended approach as the manufacturer’s recommendations also mirror the HSE guidance and the TMA and ABTT have signed up to this approach and you run the risk of:
- Being found to contravene an industry agreed practice
- Receiving an Improvement or Prohibition notice – as described below.
If the EHO is not happy with your approach, they are likely to issue a notice, which will either require you to change your approach within a certain timescale (an Improvement Notice), or stop using the tallescope for moving people until you have made the changes (a Prohibition Notice). If this is threatened or actually issued, please contact the FST H&S Advisor immediately who will try to help you with this.
If you want to impress the EHO, then you could also explain what your thoughts are on the ‘hierarchy in regulations 6 and 7’ referred to in the HSE note - i.e. the other safer access methods that you use wherever possible, and your ongoing involvement with FST’s Technical and Production Forum in looking for safer alternatives for working at height.
So what next?
If you want to move people on a tallescope…
Ensure that you can demonstrate it is only for certain activities where other options aren’t reasonably practicable, and that you have the tallescope amendments in place before allowing this to happen.
If possible, find other methods of working at height…
Obviously this won’t always be practicable, but we need to get better at demonstrating to enforcing authorities that we’re trying to actively reduce risks of injury through improving working practices and equipment, rather than defending current practice, unless we can demonstrate beyond any doubt it is the least risky approach. FST will continue its Technical and Production Forum to look at what these alternatives can realistically be, so if your Technical or Production Manager isn’t involved, suggest that he or she does this year!
If you have a raked stage…
Technically speaking, you can’t move a tallescope with someone in the basket, although informal discussions that FST has had with the HSE suggest that when they are referring to a rake they mean something more than the gentle ones (1:24) found in most theatres.
If you want to use a tallescope as a static piece of access equipment…
Then you need not make the changes in the attached guidance – i.e. tallescopes do not need to have the updated outriggers and wheels fitted, but you still need to ensure that any people using it are competent to do. In practice this means at least understanding how to apply the brakes, anti-raking devices and outriggers properly. A properly set-up tallescope which will not be used to move anyone in the basket can also be used on a raked surface.
Start thinking about rescue arrangements from working at height positions…
Whilst many FST members are already considering this, and some have good arrangements in place, this is less consistent across the industry. The HSE has given the TMA and ABTT two years to come up with suitable solutions for providing adequate rescue arrangements, so the onus is on us to come up with practical arrangements that are widely used by 2014.
The ABTT are keen to ensure as wide a distribution of their working procedure as possible, and as of Autumn 2011, were offering a free copy to every working theatre technician – all you need to do is send an application by email to email@example.com.
If you have any other questions about the use of tallescopes or working at height more generally, you can contact the FST H&S Advisor by phone on 07854 915874 or via email at firstname.lastname@example.org
Use of Tallescopes in Theatres
Since the ABTT withdrew its Code of Practice in view of the HSE’s concerns, much work has been carried out by the theatre industry, not only on Tallescopes but also on other methods for working at height in theatres. Involved parties were the Theatrical Management Association (TMA), The Federation of Scottish Theatre (FST), the Association of British Theatre Technicians (ABTT), the Ambassador Theatre Group (ATG), the manufacturer of the Tallescope, Aluminium Access Products (AAP) and a number of other theatre organisations from Scotland and Wales. HSE were also involved.
Work at Height in Theatres.
Selection of equipment for work at height in theatres should follow the hierarchy shown in Regulations 6 and 7 of the Work at Height Regulations 2005. The following, depending on individual circumstances, are examples of reasonably practicable methods for working at height.
- No work at heights – Remote or low level focusing of lights. All scenery etc completed at ground level and lifted into place.
- Work from existing workplace – Existing gantries, walkways, catwalks or trampoline grids.
- Work platforms – Mobile towers and MEWPS.
- Work positioning– Fixed length wires and harnesses.
- Fall mitigation – Airbags/nets etc. Fall protection using inertia reel harnesses or similar. Rescue plan must be in place.
- Other equipment requiring detailed systems of work – Ladders, Zarges, Tallescopes etc.
Following the work referred to previously, the ABTT have now released their revised ‘Code of practice (COP) for the selection and use of temporary access equipment for working at height in theatres’. It contains a great deal of information about the topic generally, including the use of Tallescopes. The ABTT have kindly offered to give a free copy of this guidance to all Local Authorities, please email ABTT direct at email@example.com making sure you include your full name and official address. Members of the Joint Advisory Committee for Entertainments (JACE) may also request a copy and should email ABTT direct at firstname.lastname@example.org making sure they include full name, job title and official address.
The ABTT, an independent association offering guidance on safety in theatres, has issued the revised COP which contains a section concerning the use of Tallescopes. This was written taking into account expert opinion from within the industry and a number of technical studies from both internal sources and HSL. HSE strongly recommends that users follow this guidance and the system of work outlined therein when using this equipment and will continue to support enforcement action where necessary to ensure Tallescopes are used safely.
The ABTT COP includes the requirement for modifications to the Tallescope. The modifications come as a kit of parts which the manufacturers of the Tallescope AAP, have designed and are supplying as a kit. The kit includes:
- A second pair of outriggers (4 fitted in total)
- A set of 4 castor wheels which do not ‘lift’ when the brake is applied.
- A set of 4 pushing bar extensions which stand vertically at the 4 corners of the base frame.
The photograph below shows a Tallescope with the kit fitted:
Members of the working group above are continuing work to try to devise a method for rescuing a person who becomes incapacitated whilst working in the basket of a Tallescope. They are also continuing to research other options for working at height in theatres but the differing types and designs of theatres makes a generic method unlikely. HSE will publicise the detail of this work as it becomes available.
For further information please contact the Entertainment and Leisure Sector of HSE at: 1st Floor Mercantile Chambers Bothwell Street Glasgow G2 6TS Or: Melvin.email@example.com
A note on the context…
The Working at Height Regulations 2005 require all employers to actively reduce the risks associated with working at height, starting with considering if the work can be achieved without any working at height at all. In many cases this will not be practicable, so for the many situations where working at height can be justified, employers then need to be able to demonstrate how they have planned the work in relation to the following hierarchy of risk control:
- Can working at height be carried out from an existing place of work – i.e. something fixed and permanent, such as a lighting bridge, with fixed access (such as stairs) to it?
- If access equipment is required, can it be designed and used to minimise the likelihood of a fall from it – for example, the use of specific LX trusses which people cannot fall from once in them?
- If a fall is still likely can the distance or consequences be minimised, for example through fall arrest equipment to minimise the distance, or nets to minimise the consequences?
In relation to tallescopes, the argument has centred on the second requirement in the hierarchy, as the HSE believe that moving a tallescope around with a person in it gives rise to a significant risk of people falling, unless the ABTT/TMA approach summarised in this update is followed.
However, it should also be noted that the HSE see this as a temporary measure and are expecting us as an industry to demonstrate how we will work towards finding other ways for:
- Working at height without the need to move people in a tallescope
- Providing failsafe rescue arrangements for people working at height more generally.