Portable ladders and the HSE
October 1st 2004 Andrew Lee, Health & Safety Officer of the Federation of Master Window & General Cleaners talks about the impending new regulations and the effect it will have on the use of portable ladders
Over the past few months many members; after visiting the Cleaningpro /Clean-it-up website and other information websites have been contacting the federation very concerned about what would appear to be the HSE banning portable ladders.
THE HSE IS NOT BANNING THE USE OF PORTABLE LADDERS.
New legislation in the form of the work at height regulations is due to come into force later this year i.e. 2004 / early 2005. What the work at height regulations say is; If you don’t have to work at height….then don’t. So the initial reaction would if you can use a water Fed pole system, you shouldn’t use a portable ladder - but that is not to say that ladders cannot be used. All that the regulations will do is to make it more difficult to justify the use of a portable ladder. That said; window cleaners cleaning domestic houses will be hard pushed to use a water fed pole (WFP) with the same result as “hands on” cleaning of the windows using portable ladders for access. Some customers will be reluctant to have trailing hose pipes being dragged over gardens and flower beds, and it would be difficult and almost impracticable to pull the hoses round houses or to get portable trolleys round houses, gardens and up and down steps etc. So certainly for domestic houses a risk assessment would show that portable ladders could be justified.
The use of portable ladders could also be justified on commercial premises; if there are only a few first and second floor windows to clean, you couldn’t justify bringing in a ‘Cherry Picker’,Tower Scaffold or using a WFP to clean just a few windows.
Window cleaners may well have clients that don’t like WFP and prefer conventional window cleaning to be used. In these situations you are going to have to use conventional means of access.
So again there is room,after conducting a Risk Assessment to justify the use of portable ladders on some commercial premises…..having said that, if you have large commercial premises where you have 200 first floor windows to clean, then it might be justifiable to use a hoist, Scaffold tower or a WFP. The work at height regulations also mention 9 metres being the maximum height that portable ladders should be used.
The new regulations have within them, a schedule for the use of portable ladders and that schedule says that all portable ladders must be secured before use. The interpretation of secured can mean tied, or lashed to a secure fixing, or the use of a propriety ladder stability device (LSD) that has the equivalent effectiveness. The HSE has commissioned research at Loughborough University to test ladders and ladder stability devices, and Loughborough have produced a software model that will allow ladders manufacturers and LSD manufacturers to test their devices against this model. The model will tell them whether the device can be deemed equivalent to tying a ladder. I.e. whether it passes the test…this model has only just been produced and is only just in the market place now at this date, so ladder manufacturers and LSD manufacturers have not had the opportunity to test their products.
So when the work at height regulations do come in, there will be a lead in period and the HSE have suggested it will be two years in order for people who have portable ladders, to either change them for ladders that pass the test themselves, or to acquire LSD that when attached to a portable ladder, satisfy the criteria of the LOUGHBOROUGH test.
In the meantime, the use of current ladder stability devices and manufacturers claims to their effectiveness needs to continue because window cleaners have not got access to devices and ladders that have passed the Loughborough test. So currently you should be securing your portable ladder when you have extended it above 6 metres, by either tying or lashing or, using a LSD.
When the work at height regulations come in, you are going to have to use LSD’s or tie or lash every ladder. The work at height regulations state that it has to be every ladder, even if you are on a pointer on a ground floor window. Because that is classed as work at height. The pointer, if used correctly i.e. placed on a level sound surface that is not slippery because the pointer has a splayed bottom and can’t twist at the bottom, and because the point of the ladder is trapped by the corner of the window reveal, the ladder can be deemed secure, sufficient to the equivalent to tying or lashing.
Window cleaners can therefore continue to use portable ladders.
For further information Andrew can be contacted on: More articles from Federation of Window Cleaners: | 
