Work at Height Policy

Falls from height continue to be the biggest single cause of fatal injuries and the fourth biggest cause of major injuries in the workplace. Imperial College Union is committed to ensuring the health, safety and welfare of its members, staff, customers, suppliers, visitors, and all others who may be affected by its activities and recognises its responsibility for ensuring the safety of those working at height under:  

  • The Work at Height Regulations 2005.  

  • The Lifting Operations and Lifting Equipment Regulations 1998.  

  • The Provision and Use of Work Equipment Regulations 1998. 

1. Definition

Work at Height This is work in any place at, above or below ground level where a person could be injured if they fell from that place. This can also include means of access and/or egress to a place of work. 

Scope and Exceptions to the Procedure  

This policy applies to all staff, students, contractors, and visitors who are either controlling, conducting or that could be affected by working at height activities. This policy applies to all Imperial College Union premises, work operations (indoors, outdoors, and off-site) and equipment used in working at height activities under the management and control of Imperial College Union.   

This policy sets out what all staff and students must do to prevent, so far as is reasonably practicable, any person/object falling a distance likely to cause personal injury at any height, but only where the fall would not be considered to have occurred at the same level (e.g., tripping on the stairs or a curb). This policy does not apply to sporting events or Slips, trips, and falls on the same level. 

The overriding requirement is that all staff, students, and contractors must avoid working at height, wherever possible, and implement suitable and sufficient controls where working at height cannot be avoided. This includes ensuring the safety of those who may be impacted by the work at height (e.g., those working beneath the work at height activity).

Recognising that falls from height are a significant cause of workplace fatalities and major injuries, it is Union's Policy to:    

  • Organisational arrangements are clearly defined for achieving compliance (see roles and responsibilities section of this Procedure). 

  • Work at height is avoided wherever possible, where established from a risk assessment, or where a more suitable alternative course of action is available.  

  • All staff, students and others are protected from the risks associated with working at height. 

  • All work at height is carefully planned, organised, and supervised, with a suitable and sufficient risk assessment carried out by a competent person, and control measures implemented prior to any work commencing.  

  • Work at height is never carried out alone and is always supervised.  

  • Where weather conditions endanger health or safety, work at height activities are postponed.  

  • Those personnel involved in work at height activities receive appropriate training and are provided with suitable access/work equipment so that they can operate safely and without risk to themselves and others. 

  • To keep a record detailing the tracking and inspecting of access equipment (excluding kick-stools). 

  • All equipment provided for work at height will be constructed of sound materials, be of adequate strength and be properly maintained.  

  • Access Equipment Inventory and Inspection

    An inventory and details of inspection regime of all access equipment (excluding kick-stools) owned by ICU must be maintained. A standard system involves issuing a tag (Scafftag for example) for each ladder, on which the date of next inspection is recorded. Each tag has its own identification number and is attached to the access equipment in a position whereby it does not hinder its use. 

    The inventory requires basic information to be recorded such as: specific location of the access equipment, owner, age, place and type of use, last inspection date, and next inspection due date must be recorded. Inspection will be carried out on a 12-monthly basis, but 6 monthly intervals are required for the more frequently access equipment. 

    Any defects that arise from an inspection must also be recorded, including when any equipment is decommissioned or disposed of.

  • Access Equipment - Pre-use Inspections

    User should carry out a visual pre-use inspection before commencing work, if competent to do so. This will enable identification of any obvious defects and will ensure the equipment is safe to use. Pre-use inspections should be carried out by the user, at the beginning of the working day (before the task commences) and after something has changed (e.g., if the equipment is moved to a different location for use). Users should inform their supervisor or Line Manager of defects that arise from an inspection. 

  • Work at Height Risk Assessment

    Risk assessment is the tool used generically to evaluate the risk arising from the conduct of an activity. The most common product of a risk assessment is a range of measures that will be applied to eliminate or minimise the risk arising from a hazardous work activity. 

    Due to the diversity and varied activities carried out by Imperial College Union, the Union will ensure that Work at Height Risk Assessment guidelines as set out in the Code of Practice is adhered to by Imperial College Union.

  • Training

    Suitable training is an essential element of any safety management system; all staff who are required to work at height as part of their role will receive training in accordance with the range of tasks and equipment they are required to use.  

    It is the duty of the Facilities, Health, and Safety Manger to determine (by using the ICU H&S Training Matrix) the training needs of ICU in respect of their activities and roles and ensure that all staff working at height receive sufficient information instruction, and supervision necessary for them to work safely. 

    New employees will be particularly vulnerable to injury and therefore must not be allowed to work at height until suitable training has been provided. 

  • Falling Objects and Danger Areas

    The person responsible for the work at height must ensure that:  

    • The fall of people, material or objects is prevented (e.g., using toe-boards, netting etc.) Where it is not reasonable practical to prevent falling materials or objects, steps are taken to prevent such materials hitting persons below;

    • Danger areas – where there is a risk of people being struck by falling objects (including persons falling from height) – are demarcated and entry by unauthorised persons is prohibited. 

2. Responsibilities

  • ICU Board of Trustees

    The Health and Safety at Work Act 1974 places a statutory duty on organisations to ensure, so far as reasonably practicable, the safety, health, and welfare of its employees at work and other people who may be affected by their activities, e.g., membership, volunteers, members of the public.  

    The Board of Trustees, as the governing body of the Union, has overall and final responsibility for Health and Safety matters within the Union, and for ensuring that Health and Safety legislation is complied with. 

  • Managing Director (MD)

    The Trustee Board has devolved day-to-day responsibility for Health, Safety and Welfare to the Managing Director.  

    The MD, and those acting on their behalf, will ensure:  

    • Ensure that adequate arrangements are in place to achieve compliance with the policy. 

    • MD delegates responsibility for undertaking aspects of these duties through line management & identified roles.

  • Senior Leadership Team

    The Managing Director will delegate to the membership of the leadership team the following responsibility:   

    • Monitoring and reviewing the effectiveness of Health and Safety activities and the Union’s Health and Safety Policy and associated policies and procedures, and for ensuring that, at the strategic level, performance standards and timescales are adhered to.  

    • Chairing the Students' Union's Health and Safety Committee and ensuring it has the time, facilities, and resources to carry out its business effectively.  

    • Keeping under review this Health and Safety Policy and the Health and Safety performance of the Students' Union. 

  • Facilities, Health and Safety Manger (FHSM)

    The FHSM is appointed by the MD to undertake the following: 

    • There is an adequate supply and range of access equipment (including access and personal protective) available for the work at height tasks being conducted, it is suitable for the task being undertaken, and staff use it as required. 

    • A planned preventative maintenance programme is in place for all Imperial College Union owned access equipment used for working at height. 

    • Ensure that access equipment is inspected in accordance with relevant regulations (i.e., PUWER and LOLER), with records of such inspections maintained, including the retention of a ladder register and associated inspection log. 

    • Ensure that work at height activates are subject to a suitable and sufficient Risk Assessment and that adequate safety controls are implemented, monitored and reviewed. 

  • Imperial College Union Line Managers

    Health and Safety is a delegated line management responsibility requiring managers to undertake operational Health and Safety duties identified in this policy. Imperial College Union Line Managers to undertake the following:  

    • Lead by example by following policies and challenging inappropriate behaviours, should check that staff have received information and encourage them encourage new staff to read and follow the guidance provided.  

    • Where work at height will be avoided and tasks completed using alternative working methods. 

    • All working at height is planned and organised. 

    • A suitable and sufficient risk assessment is in place for working at height operations. 

    • Ensuring any incidents involving working at height are reported and investigated, where necessary, in consultation with the Facilities, Health and Safety Manager. 

  • ICU Employees are required to:

    Individual members of staff, students and visitors have a legal duty to co-operate and always comply with the ICU Health and Safety Policy, instruction and training provided. Staff and students are responsible for: 

    • Cooperate and enable implementation of this policy;

    • Immediately report to their Supervisor /Line Manager any defects to work at height access equipment;

    • Immediately report to their Supervisor /Line Manager unsafe practices which they believe to be likely to endanger the safety of themselves or others;

    • They use all work equipment or safety devices provided to them for work at height by ICU;

    • Should employees become aware that any work at height hazard is not covered by a risk assessment, they must report it to their manager or supervisor. They should also take steps to minimise the risk themselves. 

  • Imperial College Union - Student Led Groups

    This policy applies to all Imperial College Union - Student Led Groups have a legal duty to co-operate and always comply with the ICU Health and Safety Policy, instruction and training provided. Student Led groups are responsible for:   

    • Cooperate and enable implementation of this policy 

    • All working at height is planned and organised. 

    • A suitable and sufficient risk assessment is in place for working at height operations. 

    • Provide an updated inventory of access equipment on annual basis without an updated inventory the access equipment will not be approved to be used.  

    • Ensure their members are sufficiently trained to undertake work at height activities. 

  • Imperial College London

    The Students' Union, whilst an independent charity in its own right, is an integral part of the Imperial College community and could not exist without the College. The Union and College work in partnership to ensure that adequate measures are in place to ensure health, safety, and welfare within the Union. The Union is committed to working with the Imperial College London Safety department and where appropriate, ensuring that the Union's Health and Safety Policy, Codes of Practice and arrangements are in accordance with the College Health and Safety Policy, Codes of Practice, and arrangements. 

    The Union is in an unusual position in that whilst colleagues work directly for the Students' Union their contracts of employment are with the College. Whilst the Union accepts its duty of care and responsibilities, the College also has a duty to ensure, and support, the safe management and operation of the Students' Union. 

Further Information

Review date: March 2025