The MEWP – a beast to be tamed?
Mobile elevated work platforms (MEWPs) can provide a reliable and adaptable means of safely working at height. Yet there are still prosecutions arising from inadequate controls concerning their use.
A MEWP enables individuals to work in difficult to access spaces and/or at height. MEWPs are used in many different applications in construction, facilities management, landscaping, highways management and manufacturing, as well as having fire fighting and rescue applications.
MEWPs, broadly, fall into four categories: self-propelled booms; trailer mounted booms; vehicle mounted booms; and vertical scissor lifts. This article will not attempt to look at each type in detail but, rather, how wider risk assessment concepts can help make the selection and use of MEWPs more appropriate.
MEWPs, on first impression, seem an ideal solution to working at height or where there are complex access issues. Surely, MEWPs are safer and more adaptable than ladders, abseiling or other more time-consuming solutions such as scaffolding? This is not always the case and, in any event, MEWPs need to be carefully selected and deployed to operate both safely and in a cost-effective way, ie a risk assessment must be done for each work application.
This means that if a MEWP is chosen for a task and that task is then outsourced, it is equally important that the contractor is skilled in both that type of MEWP and the work application required. A contractor who is highly experienced with particular types of scissor lifts may only have limited skills with trailer-mounted booms.
It is also vital that not only individual MEWP operators, but also their managers, are properly trained; often just the operators’ training records are checked, but this should never be considered adequate. The MEWP operator is, of course, vital, but so is his or her manager’s role in terms of risk assessment, providing proper resources for the MEWP and ensuring that it is only used in suitable, safe environments.
Thinking outside the box
MEWPs are a diverse range of kit and their use does not come under one set of regulations. The Provision and Use of Work Equipment Regulations 1998 (PUWER), Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) and the Work at Height Regulations 2005 (as amended) (WAH) can all apply in certain circumstances – and this is not an exhaustive list. For example, there has been at least one successful prosecution under the Construction (Design and Management) Regulations 2007 (CDM) concerning a fatality when using a scissor lift.
Whether a work activity comes under CDM or not, the requirements of CDM can actually provide a helpful reference point for designing any strategy for safe systems of work for working at height. Can we design the structure, plant or even maintenance routine in such a way as to minimise the need to work at height? If so, how do we forward plan, then manage and monitor the way that work is eventually carried out?
This trend is likely to continue as built environment and plant design move towards four-dimensional Building Information Modelling (BIM), over the next few years, where the whole life cycle of the plant or building will be enhanced further with more intelligent, integrated engineering and facilities services designs at an early stage of the process.
Choosing and deploying a MEWP is something that should flow from these decisions, rather than being considered the sole, generic solution to working at height.
Arguably, there is often a cart before the horse scenario with the use of MEWPs. Sometimes there seems to be more emphasis on operator training rather than the design, planning and selection of the safest and, therefore, most appropriate method of work.
In short, deploying the MEWP is simply part of a process of risk assessment and procurement; there should be nothing random or assumed about their selection or use.
For fire and rescue services in the UK, there is usually a concept of dynamic risk assessment employed with most fire and rescue operations, including the use of MEWPs such as hydraulic platforms and combined aerial rescue platforms (CARPs).
Dynamic, in this context, refers to rapidly changing circumstances. The risk assessment is a continuous process of identifying hazards, assessing risk and taking appropriate responses at the incident being attended. In other words, the generic risk assessment is modified in a fast-changing operational situation, it is not slavishly followed. However, this is not a licence to do whatever one likes – dynamic risk assessment requires a high level of training and teamwork to be effective in providing a safer working environment.
This article is not suggesting that dynamic risk assessment takes the place of one of the existing MEWP training methodologies (such as the International Powered Access Federation or IPAF). Rather, it is simply one model that can be used to reinforce the importance of training to both managers and operators, and the type of practical issues they will often face on site.
For example, ground conditions are one area where dynamic risk assessment could focus a useful learning point. In a recent case, where the Bradford Metropolitan District Council pleaded guilty to various health and safety offences regarding the overturning of a “cherry picker”, inadequate ground conditions for using the MEWP were found to be one of the causes of the accident, along with risk assessments that did not identify, among other things, the correct type of mats for stabiliser feet in those uneven conditions.
More generally, with all MEWPs, stability is one of the essential parameters for safe operation. Stability will vary according to ground conditions. Both managers and their operators need to understand the working requirements of their particular MEWPs and how individual ground conditions or any specific jacking requirements can be affected by changes to these. Dynamic risk assessment would help both managers and operators better understand how to apply and – check – the adequacy of risk assessments on site. Arguably, dynamic techniques are already implied, in any case, with some MEWP operator training.
When things go wrong
One thing that assists risk assessments is to have an element of planning for emergencies. In fact, WAH requires that “every employer shall ensure that work at height is… properly planned and… planning of work includes planning for emergencies and rescue”. The competency requirements, later stated in WAH, also apply to this emergency planning process.
One element of emergency planning is that, properly done, it indicates where the location or purpose is not suitable for a MEWP, e.g. where a MEWP is going to have to be jacked up on soft ground. Second, it can simply inform a safe system of work by bringing up an issue not previously considered. The author once visited a food processing site where maintenance work was done on silos with connecting aerial walkways. The silos had been surrounded by landscaped grass. This greatly limited the type of MEWP that could be jacked on them and, equally, any rescue MEWPs (such as a fire service CARP) if, for example, an employee was taken seriously ill while on one of the elevated walkways. The emergency planning greater influenced the day-to-day process and future refurbishment of the silo landscaping.
MEWPs can be complex beasts with the need for complex risk assessments. This article has suggested just a few strategies that could revitalise your organisation’s thinking about how to drive the safe message home on MEWPs.