Falls prevention for pest control operators

The Occupational Health and Safety Act 2004 (OHS Act) provides a broad framework for improving standards of workplace health and safety to reduce work-related injury and illness. It aims to:

• protect employees’ health, safety and welfare at work
• protect the public from the health and safety risks of business activities
• eliminate workplace risks at the source.

The design and implementation of health, safety and welfare standards should involve employers, employees and their organisations.

WorkSafe Victoria is responsible for administering the occupational health and safety legislation in Victoria, to improve the health and safety of Victoria’s workforce. WorkSafe Victoria is able to advise pest control operators (PCOs) and their businesses about their legal requirements and ways to improve workplace health, welfare and safety.

Falls prevention – Occupational Health and Safety Regulations 2017

Part 3.3 ‘Prevention of falls’ of the Occupational Health and Safety Regulations 2017 apply to all employers and employees operating within the pest control industry.

The Regulations are designed to stop workplace incidents involving falls of more than 2 metres, and to prevent or reduce resulting injuries should a fall occur.

Falls commonly occur from equipment, ladders, vehicles and roofs. If a fall occurs from a height of less than 2 metres, the employer may be liable under the general safety obligations of the OHS Act. Therefore, the necessary precautions should be taken against this type of workplace accident wherever a fall hazard exists.

Occupational Health and Safety Regulations – summary

In regards to fall prevention, employers must:

• identify the falls hazards
• perform a risk assessment to determine the likelihood of a fall
• control the risk and maintain the controls
• provide information, instruction and training to employees
• have emergency procedures in place
• consult their health and safety representative (HSR), if they have one.

In regards to falls prevention, employees must:

• participate in the information, instruction and training provided by their employer about working at heights
• follow the procedures and use any safety measures their employer puts in place.

Falls hazards – identification

According to the Regulations, a fall hazard is a situation or work practice where there is the potential to fall at least 2 metres.

Before starting work, all the current tasks that may present a fall hazard should be identified.

PCOs may come across fall hazards under the following circumstances:

• inspections or treatments done on roofs or near fragile surfaces, such as skylights, badly rusted corrugated iron or fiberglass, where there is no guarding or fall protection measures used
• mezzanine levels in large storage areas where there are no guards or hand rails installed
• elevating work platforms, such as cherry pickers or boom lifts, with no secure line or safety harness in place connecting the worker to the basket to reduce the risk of a fall from a basket
• treatments on commercial or industrial sites where there is no guarding, railing or signage around holes, pits or shafts
• a person being lifted up by a piece of equipment not designed for the job
• ladders set up on slippery or uneven surfaces, and not secured to prevent them slipping forwards, backwards or sideways
• using an inappropriate ladder for the task – for example, a ladder that is too short or does not have an adequate load rating for the loads being carried on it, or using a straight ladder as a horizontal working platform
• fumigation tarps fitted by climbing across objects such as shipping containers
• employees not provided with adequate training, instruction and supervision on how to
  • set up, undertake and complete a task safely that involves work at height
  • use fall prevention equipment safely
• where ropes, harnesses or lanyards are used for fall protection, the equipment is not checked regularly and before use for signs of decay, cracks, knots, frays or other potential damage or danger.

Risk assessments for falls

After identifying all the workplace tasks involving a fall hazard, employers should work with their HSR to determine the risk of a fall occurring.

When conducting a falls risk assessment, the Regulations require you to consider:

• the nature and duration of the task
• the physical surroundings in which the task is to be performed
• the conditions during which the task is to be performed
• the height employees will be required to access or work
• the training and experience of employees undertaking the work
• weather conditions, lighting, sloping surfaces or other hazards nearby, such as power lines, trees or sharp objects.

If the risk assessment indicates that the risk of a fall from height is likely, precautions must be taken to eliminate the risk. If this is not practicable, precautions must be taken to reduce the likelihood of a fall or injury.

Falls risk control

Where you have identified tasks or situations where a fall from a height is likely, you must implement measures to control the risk as soon as practicable.

The Regulations state that you must eliminate the risk of a fall or if this is not practicable, reduce the risk as far as is practicable.

Practicable definition

The OHS Act indicates that the following must be considered in determining what is (or was at a particular time) reasonably practicable:

(a) the likelihood of the hazard or risk concerned eventuating

(b) the degree of harm that would result if the hazard or risk eventuated

(c) what the person concerned knows, or ought reasonably to know, about the hazard or risk and any ways of eliminating or reducing the hazard or risk

(d) the availability and suitability of ways to eliminate or reduce the hazard or risk

(e) the cost of eliminating or reducing the hazard or risk.

Falls prevention – hierarchy of control

The fall prevention measures listed in the hierarchy of control must be applied in order. If it is not practicable to use a specified measure, a control at the next level may be considered.

1. Can the risk be eliminated by completing the task on the ground or on a solid construction? For example, if you are spot treating the eaves of a house, can you use an extension nozzle on your spray unit?
2. Can a passive falls prevention device be used to prevent a fall occurring? This includes devices such as scaffolds, guard railing, scissor lifts, cherry pickers, roof safety mesh, step platforms and work boxes.
3. Can a work-positioning system be used to safely support employees at height? Examples include industrial rope access systems, travel restraint systems and drainer’s hoists.
4. Can a falls injury prevention system be used to minimise the distance of the fall or reduce the severity of injury? Such systems include safety nets, catch platforms and safety harnesses.
5. If none of the above falls prevention measures are reasonably practicable, then a fixed or portable ladder, or administrative control must be used.

Falls prevention – administrative controls

Administrative controls are systems or procedures to help reduce the exposure of employees to fall hazards. This includes directing employees not to approach a place where a fall is likely.

If administrative controls alone are used to control the risk of a fall, the employer must record a description of the task and the administrative control implemented. The record must be kept by the employer for as long as the task to which the administrative control relates is being undertaken.

Falls risk control – ladders

Ladders should only be used where better fall prevention control systems are not practicable, and working at a height is essential. If a ladder is to be used, then it must be:

• appropriate for the type and duration of the task
• in good working condition
• set up properly to avoid slipping or becoming unstable.

Falls prevention – physical edge protection

A system of physical fall protection should be provided under any of the following circumstances:

• where a worker may be exposed to the risk of a fall greater than 3 metres
• where a 2-metre clear zone cannot be established
• where the 2-metre clear zone is no longer being maintained
• the pitch of the roof is greater than the critical angle.

Note: The pitch of the roof is one of the key risk factors to be considered when determining the type of risk control measures to be put in place for roofing work.

The critical angle is the roof pitch below which is considered that roof workers may reasonably be able to work and walk across the roof. The critical angle can be taken as greater than:

• 26 degrees, or
• 10 degrees where there is a likelihood of surface moisture, oil or other conditions makes the roof slippery.

Also give consideration to the fact that the critical angle may be reduced in the presence of fully glazed and wet tiles.

Where there is a risk of a fall from a height of 2 metres or more, you must set up external, physical edge protection. Examples include guardrailing or perimeter scaffolding.

Falls prevention – emergency procedures

If the risk of a fall has been identified as likely, and control measures have been implemented to control the risk, employers must also ensure that appropriate emergency procedures are in place. The procedures must enable the safe rescue of an employee in the event of a fall and ensure first aid is provided as soon as possible.

Falls prevention – equipment maintenance

Employers must ensure that any equipment that is used to control the risk of the fall – such as scaffolding, ropes and harnesses, cherry pickers or ladders – are:

• properly maintained
• used as prescribed
• are not used in such a way that endangers employees.

Falls prevention – providing information, instruction and training

Employers must provide information, instruction and training to any employee who is required to complete a task where a fall hazard has been identified. The information, instruction and training must address the:

• nature of the task
• risk of a fall
• need for, and proper use of, risk control measures.

Health and safety representatives

The Act makes provisions for the appointment of a HSR for a group of employees (a work group). The Regulations require that where a HSR has been appointed for a work group, the employer must consult with that representative when identifying fall hazards, and assessing and controlling the risk where decisions may affect the safety of any employee.