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Two Rope Working Consultation


Tom D

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So following on from the other thread I’m starting this as a more serious discussion as to where we go from here.

 

Please keep any responses sensible and constructive, use the other thread for any banter / moaning. 

 

https://arbtalk.co.uk/forums/topic/116973-background-to-the-hse-decision-on-two-rope-working/#comments 

 

This is being read by the HSE so if we want to persuade them that we are a serious professional bunch whose concerns ought to be heard then we need to behave accordingly.

 

For staff of the AA or HSE  I have tried to summarise a lot in one paragraph, if I have got anything factually wrong please post corrections.

 

So to very roughly summarise how we got to this point: the EU passed a directive in 2004 which the U.K. adopted into our own HSE law, this stated ‘roughly’ that for rope access 2 attachments to separate anchors were required. At this point our industry through the AA and possibly others pushed back against this citing many of the issues that have been raised on the other thread. This push back was successful since at that time almost all tree work was being carried out using DDRT (doubled rope techniques) Helpfully DDRT is classified as work positioning by the HSE and not as rope access, ( basically if the rope is static and the climber moves up and down the rope it’s rope access and if the rope moves with the climber it’s work positioning, don’t ask why!) So we all carried on as normal using work positioning techniques, usually tying in twice when we were cutting and once the rest of the time.  More recently however SRT has been adopted in tree work, this shares much more with rope access and is classified as such by the HSE (fixed rope remember).  So at this point it became increasingly hard for the AA to argue that tree work was a special case since the techniques used appeared identical to the rope access industry which had been happily using 2 lines for a long time. At the same time as this decision was taken the HSE also decided that the current ICOP, which classes tree work as  work positioning techniques as an was no longer fit for purpose and that even DDRT would now require a permanent back up line. Hence we are where we are now.

 

It is worth pointing out at this point that the HSE are there to save lives and protect people from harm, as part of this review they have looked at a number of tree work accidents involving a fall from height. These included I believe anchor point failures, untying main line without second anchor and cutting line with saw. Now however much you may see these accidents as being preventable under our existing ICOP the fact remains that none of these people would have fallen had they had a second line. So think about that when considering the HSE’s stance on this.

 

There are however many circumstances where having a second line in the tree may not be appropriate and the purpose of this thread is to discuss these circumstances so that the new ICOP can take them into account. This is vital in that it will give much needed clarity to climbers and employers as to when it is appropriate and when it is not appropriate to use two lines.

So I will list here some of the circumstances where I feel that a second line is not appropriate, this is not an exhaustive list and I hope that others will contribute further suggestions to this thread.

 

1. When cutting material which is above the climber.

The risks of falling material contacting a climbers line are obvious and potentially serious. Tree work often involves the climber climbing the tree rather than his rope, in fact this is the norm. So the rope is not normally vertical, in fact it can often reach right across the canopy at an angle. This presents a risk that falling material catches or snags on the climbers rope. Climbers are trained to avoid this by careful work positioning and awareness of the path of falling material. Having a second line on a second anchor will dramatically increase the chances that falling material contacts the climbers line. Climbers will find their options restricted when felling or throwing material down. This may lead to increased risk taking that could put both the climber and ground staff at risk.  So my suggestion is that when material from above the climber is being removed only one line is used to keep the risk of snagging to an acceptable level.

 

2. When rigging lines are being used.

We all know that rope management is vital when rigging, and that poor rope management can lead to accidents. Indeed poor rope management would be a fail on the rigging and dismantling course. Contact between the climbers line and the rigging line is not acceptable, ideally they will be anchored in different parts of the tree. Adding a third line into the mix which also requires a separate anchor makes the job of rope management extremely challenging. In some trees perhaps it may be possible to have all three lines working independently without risking then conflicting with one another, but in most Trees this won’t be the case. When rigging branches will swing down under the rigging anchor, and in some cases well past the rigging anchor in a pendulum motion. The climber must counteract this by either installing a brake line on the material to that the pendulum can be arrested or by managing his ropes so that they are not caught by the swinging material. In either circumstance having an additional line will compound the problem and significantly increase the risks of a contact between the rigging line or material and the climbers line. We know that climbing lines can be cut by friction burns or by being pinched between rigged material and the tree itself.  So my suggestion is that second lines are not used when rigging is taking place.

 

3. When space on the ground is restricted.

We  Know that when working in tight spaces rope management on the ground can be an issue, accidents have happened when climbers lines have been cut by ground staff, or even fed into chippers with brash. I’m sure we have all been pulled around at some point when a ground worker tried to carry off a piece of brash with the end of our line caught in it. Having a cut in your line on the ground can be  fatal with DDRT if it’s not spotted. Indeed I can think of one such accident where a climber descended off the end of a line which had been inadvertently shortened. Even just having over enthusiastic ground staff pulling on a line which is entangled in brash can cause a climber to slip, the consequences of such a slip could be anything from no harm done through minor injuries to a serious chainsaw cut. Having extra lines in the tree will effectively double the risks of these types of incident occurring. So my suggestion here is that a second line is not used when space on the ground is restricted.

 

I have further thoughts on this but for now to get the ball rolling I’d like to invite further discussion of of these or any other circumstances in which you feel 2 line working may be inappropriate.

 

tree.thumb.jpg.c0d6212b13ba0e1e9467c0988c629bed.jpg

 

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I have been a climber for 15 years and feel the use of two ropes would over-complicate tree work, potentially leading to more mistakes and accidents. 

 

In addition to the points already discussed,  here are some other concerns I have. 

 

Shouldn't we be trying to minimise time spent at height? These regulations will increase time spent above ground, physical and mental fatigue, (potentially causing mistakes).

 

Increased reliance on the least experienced members of the team to manage ropes, (usually grounded are aspiring climbers, but not necessarily experienced).

 

Over-reliance on a secondary anchor point, that you would not normally have selected, (yes, you have another line, but a failure halfway through a cut could result in injury from a saw) 

 

If the current advice and rules had been followed, none of the past accidents would have happened, so shouldn't we be trying to work out why the incidents had occurred.  

 

How about looking into methods of reinforcing your main anchor point. In the past if I have had concerns about a main anchor, I have braced it with slings/ropes, so that if it failed, I would only fall a couple of feet- scary but not fatal. I think we could learn a lot from traditional rock climbing in this regard. 

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WWW.HSE.GOV.UK

Contains links to various pieces of legislation, as well as the Health and Safety at Work etc Act 1974

 

I feel that I should add this so that we can see where the ICoP lies in the legal framework. I should also point out that this ICoP will be written by the AA (hopefully taking into account the contents of this discussion) and approved by the HSE. You can see therefore that whatever the ICoP contains it must be acceptable to the HSE in order to be incorporated into the Law.

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5 minutes ago, Chamski said:

I have been a climber for 15 years and feel the use of two ropes would over-complicate tree work, potentially leading to more mistakes and accidents. 

 

In addition to the points already discussed,  here are some other concerns I have. 

 

Shouldn't we be trying to minimise time spent at height? These regulations will increase time spent above ground, physical and mental fatigue, (potentially causing mistakes).

 

Increased reliance on the least experienced members of the team to manage ropes, (usually grounded are aspiring climbers, but not necessarily experienced).

 

Over-reliance on a secondary anchor point, that you would not normally have selected, (yes, you have another line, but a failure halfway through a cut could result in injury from a saw) 

 

If the current advice and rules had been followed, none of the past accidents would have happened, so shouldn't we be trying to work out why the incidents had occurred.  

 

How about looking into methods of reinforcing your main anchor point. In the past if I have had concerns about a main anchor, I have braced it with slings/ropes, so that if it failed, I would only fall a couple of feet- scary but not fatal. I think we could learn a lot from traditional rock climbing in this regard. 

Some good points there especially the first one, I have another post coming on that very issue, I need to refresh my self on the WAH regs first. Regarding points 2 and 3, these issues should be corrected bey either more training and better anchor selection and I can't see HSE taking them seriously. Point 4 I made to the AA and then have made the same point to the HSE to no avail.

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Forgive me if I've posted this in the wrong thread,
As an arb contractor who doesn't climb, how does this affect employing climbing sub contractors?
What if they want to climb srt/drt?
Am I legally obliged to enforce a second line for each climber?
Or are they "bona fide" and self responsible?

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My personal opinion on this whole matter is the HSE don’t have a grasp on the exact nature of the job we do.

 

I have contract climbed for the last 15 years.  Some of the trees, the new guidelines would have been a pain, but the work doable.  I have lost count of the number of times I have worked a tree where adding an additional anchorpoint would have compromised my own safety and that of the team members.

 

IME, the addition of SRTWP, regardless of terminology has allowed me to ‘back up’ my Primary TIP.  Allowing the work to be completed safely and efficiently.  Introducing a second rope and climbing system would not only hinder progress but increase the risk of an accident.

 

SRTWP is much more ergonomic on the body and gives a climber longevity.  It isn’t for everyone, granted, but it utilises the larger muscle groups so should be less wear and tear on the body.   If the HSE are serious about actually looking out for individuals and reducing accident rates in the Arb sector...  surely a rewrite of the definitions would be better than making an all together dangerous practice mandatory.  (Certainly situations of course)

 

Surely, the need for better training is in order.  The more knowledge people have then they can make their own informed decisions.  Adding a second rope to a job isn’t going to stop a climber tieing into two crap anchor points.  Whereas a better education, should give them more knowledge as to what can handle the forces generated.

 

On the other hand, I have a question for the HSE if they are reading this...

 

How are you going to enforce the gardeners, builders and Bob-a-Job men who carry on working to unsafe practices and keep falling out of trees?

 

I look forward to hearing from the HSE.  I must admit, I am not holding my breath though.

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23 minutes ago, Rough Hewn said:

Forgive me if I've posted this in the wrong thread,
As an arb contractor who doesn't climb, how does this affect employing climbing sub contractors?
What if they want to climb srt/drt?
Am I legally obliged to enforce a second line for each climber?
Or are they "bona fide" and self responsible?
 

A good question, perhaps the AA can answer that one. Sorry Paul! Or maybe your insurer would know. I would suggest that in the case of a bona fide subby the onus would be on him to comply with the law, whereas with a labour only subby it would be your responsibility. But don't take my word for it.

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To return to the issue of when to use a second line and to echo Chamski's point the WAH regulations 2005 state right at the outset that: 

  1. Before working at height you must work through these simple steps:

    • avoid work at height where it is reasonably practicable to do so;

    • where work at height cannot be avoided, prevent falls using either an existing

      place of work that is already safe or the right type of equipment;

    • minimise the distance and consequences of a fall, by using the right type of

      equipment where the risk cannot be eliminated.

      Figure 1 gives further guidance and examples for each of the above steps to help you comply with the law.

      You should:

    • do as much work as possible from the ground;

    • ensure workers can get safely to and from where they work at height;

    • ensure equipment is suitable, stable and strong enough for the job, maintained and checked regularly;

  • make sure you don’t overload or overreach when working at height;

  • take precautions when working on or near fragile surfaces;

  • provide protection from falling objects;

  • consider your emergency evacuation and rescue procedures.

 

So we do have a potential conflict in terms of how much additional time the second line is adding to the job.  In terms of 'avoiding work at height where reasonably practicable to do so' we can already see that something which makes the job take longer may contradict what is the first rule in the WAH regs. Again 'do as much work as possible from the ground as possible' also suggests that anything which extends the time we spend off the ground is against the spirit of the WAH regs. 

 

Some further discussion / clarification in this area would be appropriate. 

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For the consultation why did the HSE, instead of using incredibly competent climbers who are experts in all types of climbing and training? Why not witness less competent climbers, guys or girls that are three years in say, or utility climbers?  These type of climbers are arguably at more risk of mistakes than more experianced climbers.

 

When I started climbing over twenty five years ago my mind was a lot different to how it is now, an older experianced brain is better at coping with more complicated climbing systems and managing those systems in a safer way than a young fresh still learning brain. Climbing systems should be, as a rule, as simple as possible  to enable the climber to carry out the tasks with as little risk as possible, two rope systems add unneeded complications to every day climbing operations.

 

Saying all this though I'm not totally against twin rope systems and used such recently on a victim of Ash die back, I couldn't trust just one TIP knowing the horror stories of the brittle nature of affected trees, so I used two ropes with two different devices in a safe controlled manner.

 

I believe the inventor of the RW has recently been climbing with two small diameter ropes running through one system, this could be an answer because you could tie in with two different TIPs but still use the two ropes as one, would this be acceptable?

 

So this has come about because of safety and prevent people from getting hurt and that's great but what it's also about is liability and who gets the blame and pays the price, or even doesn't when things go wrong.

 

How about enabling people to choose appropriate systems for individual tasks?

Much like we can choose to wear a different class of chainsaw protection in hot weather as long as we justify that decision in our risk assessments.

 

Accept that accidents happen no matter what precautions are taken, accept that minimizing risk is all you can do, accept that some tasks require different approaches and people should not be nannyed into using systems that on paper look really good but in practice can increase risk to the inexperienced.

 

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7 hours ago, Chamski said:

I have been a climber for 15 years and feel the use of two ropes would over-complicate tree work, potentially leading to more mistakes and accidents. 

 

In addition to the points already discussed,  here are some other concerns I have. 

 

Shouldn't we be trying to minimise time spent at height? These regulations will increase time spent above ground, physical and mental fatigue, (potentially causing mistakes).

 

Increased reliance on the least experienced members of the team to manage ropes, (usually grounded are aspiring climbers, but not necessarily experienced).

 

Over-reliance on a secondary anchor point, that you would not normally have selected, (yes, you have another line, but a failure halfway through a cut could result in injury from a saw) 

 

If the current advice and rules had been followed, none of the past accidents would have happened, so shouldn't we be trying to work out why the incidents had occurred.  

 

How about looking into methods of reinforcing your main anchor point. In the past if I have had concerns about a main anchor, I have braced it with slings/ropes, so that if it failed, I would only fall a couple of feet- scary but not fatal. I think we could learn a lot from traditional rock climbing in this regard. 

A redununt non load bearing base anchor may work in your re enforcing anchor scenario. Obviously the hardware would have to withstand the potential impact of anchor point failure..

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