Tom D

Broadly speaking I agree with your sentiments on MEWP's, and I spent £30k buying one last year! I think if they are widely adopted in tree work the number of MEWP related accidents will undoubtedly rise as you say. But as far as the regulations go its, work from ground...no? Work from MEWP...no? then work from a rope and harness.... Not saying I agree with that but there it is.

I saw 'The Mule' on the plane to Minneapolis this summer. It was a good film. Clint looks old now though.

I think any argument based on extra difficulty / cost is going to fall flat since 'what price do you put on a life?' This is why I have only seriously considered specific operations where 2 rope working is going to be more dangerous than a single line. There is however an accepted term: 'where reasonably practicable to do so' so if the extra effort of something out weighs the safety benefit then you are allowed to consider a more practical alternative. An example of this is: under the current WAH regs WAH should be avoided if possible. This means that a MEWP is preferable to climbing. So the justification needs to be made as to why a MEWP is not being used. This is where "reasonably practicable" comes in. If the additional time / effort / cost of the MEWP is beyond what is considered reasonably practicable then you may not use it. This has to be justified in the RA though.

It had crossed my mind that a line attached to a cambium saver / rope guide running through a crotch and down the back of the tree to a basal tie off as in an SRT setup would effectively back up that anchor point. But then I'm not sure how big an issue anchor failure really is? Ironically the one time I have snapped one was when I was tied in on two lines which allowed me to 'push the envelope' in a pollard full of weak attachments, as was mentioned in a post earlier.

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: 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.

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.

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.

Legal status of HSE guidance and ACOPs 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.

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.

I has a long chat with Simon Richmond today, we talked over this at some length. The upshot of this I will post in another thread as it needs a fresh start. Suffice to say that getting this ruling / legislation overturned will be very difficult, but the new icop for climbing (currently being written) will contain certain recommendations as to when a two rope system is not appropriate. As this document has not yet been produced there is the opportunity for the industry to have its say in the process. So I will start another thread to get the ball rolling. This won’t be tonight though..

The more I think about 2 rope working the more problems I find with it. I accept (annoying though it is) that for access where the strength of an anchor has not been assessed two ropes on separate anchors is ‘technically’ safer. However when actually cutting stuff off a tree this is insane. Regarding industry standards, we already have the AAAC scheme of which we are members. Making things tougher won’t make more people want to comply. In fact it will have the opposite effect. I’m going to make contact with the HSE and take this up directly with them, I do feel that the AA’s decision to simply do a rec climb as a demo was a huge mistake. I’ll be looking for additional constructive inputs once I have made contact. Watch this space.

Paul, I think the issue of commonly having climbing ropes at other than vertical angles close to falling material make this a completely different situation to IRATA type roped access. I would be very keen in speaking to the HSE or AA to highlight these crucial differences.

What was the HSE reasoning behind this decision? I understand that while cutting there is a risk of severing a line and that therefore a back up line is a good idea, and also when retying a second line is required. But what do they think is going to happen whilst moving around the canopy? I mean if you're tied in correctly to a suitable anchor what could happen? The risk of falling material snagging on a line with two lines in the tree is going to be much higher and that is a serious safety concern. If as I understand it the two lines are not to be tied in to the same stem that implies that there will be an angle between the two lines, so if I'm out on a branch I have one line heading back to the tree in one direction and the other in a slightly different direction. Now imagine I'm removing an upright section of the limb Im standing on, I have a drop zone but it is partially obscured by one of my lines... do I disconnect the line and work off one line? Do I fell it anyway and take the chance? Do I stop and rethink the whole situation. I have had many situations where I barely had room to get material past a single line let alone two. This problem is only made worse when rigging. When a limb swings back in under the pulley, as they must do, it is important that the climbers ropes do not contact the rigging lines, a rigging line will burn through a climbing line very quickly in such a situation, this is a significant part of the NPTC Rigging course. Rope management. In a two line situation we are asking for accidents here. I can already see that any job which involves material being cut from above the climber will be dangerous, and likewise any rigging job. I will amend our RA to say that any job that falls into either of the above categories will be done off a single line on safety grounds. Jobs which only require material to be cut from below the climber such as crown lifting and some one side reductions may be safe with two lines. I think the AA should setup a new demo for the HSE involving some real world dismantling, using complex rigging techniques and then they will gain a better understanding of the risks involved.

I received this today. I hope as many of you as possible write to your own mp’s to get the HSE to take the views of the industry seriously. to Tom Dixon.pdf

I've used two lines in the past Stevie and its definitely slower. The big concern is that you have double the chance of catching your rope with falling material.

Paul I appreciate all the time you're putting into this and hope that you can get someone from the HSE to hear our concerns. Heres the letter I sent to my MP, I urge all those who take issue with this to do the same, please feel free to copy mine. Dear... I am writing to express my concerns that the HSE has now redefined Arboricultural work from ‘Work Positioning’ to ‘Rope Access’. This may sound like a tweak of little consequence, but it will not make the industry safer, in fact it will likely have the opposite effect. For information Rope Access is systems are used to access the exterior of buildings and structures, not trees. This change to the guidance has been brought in with no industry consultation. The issue arises from the fact that in a Rope Access situation the operator or climber is required to be tied in twice; that he has two separate ropes or strops connecting to his harness, and that these two ropes are secured at two separate anchor points. Should he inadvertently disconnect or damage one connection the other will catch him. This is made possible by the fact that Rope access technicians generally descend to their working position and they do not need to disconnect their lines for the duration of their job, they climb and position themselves using their ropes before returning and removing the ropes at the end of the job. In arboriculture things are quite different, trees themselves are climbed and the ropes are generally there as a failsafe or to help with work positioning, arborists will use a second point of attachment only when cutting with a chainsaw to mitigate against inadvertently cutting a rope. When climbing around the tree one connection is always maintained in case of a slip. The three-dimensional nature of trees makes the use of an additional third line problematic and slow, the risks of felled material contacting a rope are much higher with an extra rope in the tree (potentially a fatal incident). My issue with this change is that because the tree work industry is not well regulated and that most tree work businesses are extremely small companies this change in the guidance will put thousands of workers at risk of falling foul of the law. Those who comply with the changes will be forced to increase prices significantly. Many others will just flout the new guidance leading to a race to the bottom in terms of worker safety. In an industry dominated by micro-businesses (there are only a handful of UK companies who have more than 30 employees) we have been traditionally slow to adopt new working practices. Some small firms see the opportunity to cut corners as a way to make money, this change is grist to the mill of these corner cutting firms. Those of us who choose to comply with this change will face bills for extra equipment and our productivity will fall drastically. This change will likely result in compliant firms in the competitive domestic sector being forced to go non-compliant or face winding up. While these types of changes to regulations work well in other industries where businesses are much larger and have much more to loose from HSE prosecution in the Arboricultural industry many firms will simply ignore these changes. And since they will be non-compliant in this respect why comply in others? I fear that these changes will drive many firms into a downward spiral of non-compliance which will put lives at risk. I hope that with your help the HSE can be persuaded to listen to the concerns of the Arboricultural Industry before pressing ahead with these changes. Further information on this issue can be found here: https://www.trees.org.uk/Help-Advice/Public/Background-to-the-HSE-decision-on-two-rope-working And here: https://arbtalk.co.uk/forums/topic/116973-background-to-the-hse-decision-on-two-rope-working/#comments Please get in touch if you have any queries. Regards

I'll have read more into the definitions of work positioning and rope access, so can't comment further on that. making direct comparisons between rope access and tree work is a mistake. I think the point that has been missed when the demonstrations were taking place that in rope access work the climber almost always ties in at the start of the job and then decends (usually) to his working position. His two tie in points are chosen and affixed before he sets off and they don't get touched again until he finishes his task. In tree work a climbing on two lines will involve regularly changing lines, disconnecting and reconnecting to cross from one side of the canopy to the other. SRT will help as friction won't be an issue but retrieving the lines might be. But for DDRT users managing two lines in a busy canopy will be a nightmare. I started out climbing on both ends of a long rope as was taught at the time, it was a massive PITA and as soon as my ability improved I ditched the second line. I can think of only a couple of occasions where I needed one since. Sadly many of the 'industry leaders' by whom I mean those who are consulted on these matters are out of touch with the realties of day to day tree work. Much of the training industry, who fall into this category, work on the same college trees every day, the bark is smooth and shiny from the constant climbing. These trees are never topped, dead wood is removed and epicormic cleared, if you climbed on 3 lines in these trees it would be relatively easy. In other trees it won't be easy, it will be slower and more difficult. The risks of felled or lowered material contacting, snagging or ripping out a climbers line will have doubled. Yet another safety issue.

That is a closed sector though isn't it. They could insist on every climber wears a sumo suit or tea breaks every 20 minutes if they wanted, it wouldn't matter since any competitors will have to do the same. The only loser will be the client who pays for their time. In all other markets where work is awarded on a price basis, this is going to be a huge problem. Anyone who thinks they can work off two constantly tensioned lines in an ivy covered epicormic filled lime tying in thrice to cut quicker than they could off a single line and side strop is not a proper climber. Maybe if you're straight out of college slow, or you've only ever climbed college or arboretum trees with no ivy, epicormic or dead wood then you'll think that this change doesn't make much difference. A real production climber will know for sure that this is in fact going to make a massive difference to his or her speed.

To quote the article: This will be a change that will take time to implement and filter through our varied workforce; it will add time and cost to tree climbing operations but will also demonstrate the increasing professionalism and drive to maintain compliance in our sector. There is no doubt that, as larger and more compliant contractors will be the first to adopt this approach, there will be a cost (in time, resources and money) which will add to the burden of the most compliant companies to remain competitive in our unregulated sector. The last line is crucial, just a few words to sum up a massive change in the industry. I remember debating with Paul on here years ago before we joined the AAAC scheme. My beef was always that the AA didn't allow the bottom of the industry to catch up with the top. By bottom I mean the very non compliant and by top I mean the fully compliant. When those at the bottom can clearly see a path to the top, and that path doesn't look too difficult they are much more likely to start along that path. When however the path looks hard or ridiculously overburdensome they are less likely to engage. This clearly falls into the ridiculously overburdensome category in case you hadn't guessed. We have come a huge distance as an industry with virtually every cutter out there these days having NPTC quals as a minimum, (that wasn't the case when I started out). This I fear will be a huge retrograde step, after all if you're not complying with the WAH regs, which as of now 80% of the industry won't be, then why bother complying in other areas? I mean what's the point in having your kit LOLER'd if you aren't complying with WAH anyway? why bother with NPTC's? The worry is that unlike changing training compliance such as the introduction of refresher training this has a huge effect on the bottom line. As a business we can afford the £2k or so it costs to put a member of staff through another NPTC or whatever. But to introduce something that will slow our production by as much as half...... that is another question. TD TREES have always been highly productive tree surgeons, we have made our money by doing the job faster and more efficiently than competitors. Sometimes through the use of bigger or better equipment but mostly through having highly productive safe climbers. By asking these climbers to adopt this 3 rope system we will undoubtedly slow our production, in some cases such as complex dismantles or reductions this could double the time required. Fair enough just charge double right? But then we return to the point I made earlier what about our competitors? What will they do? Do the job off one line and a side strop like they always have done and undercut our prices. Then what do we do? Abandon the AAAC scheme and go back to doing things the old way just to survive? or embrace the changes and try and persuade our clients that its worth paying 30% more because we brought an extra rope? This drives a massive wedge between the compliant and non compliant. And those who want to cross the divide will find it increasingly difficult.

Then there's your rigging line too, it will be like a spiders nest. How come I don't need two points of attachment in a MEWP basket? I believe that only one is required?

There should be some proper industry consultation before something as ground breaking as this is announced. I suggest that all those who disagree with this decision write to their MP. It's easy to do and if enough people do it questions will be asked. I'll draft a letter and post it here.

I appreciate that the AA has had an input into this farce but I have to say that as a long term member and AAAC I feel let down here. There should have been a massive push back against this. Where was the public consultation? This is clearly bullshit, having 2 or 3 anchor points will be counter productive and unsafe as I'm sure it will only be a matter of time until someone unclips the wrong line thinking that the other one is still attached only to find that it isn't or that it has 20 foot of slack in it. Having one main line is safest because the climber KNOWS that that is his lifeline; cut that or unclip it and you're free climbing or free falling. That kind of logic sharpens the mind. The parallels between IRATA rope access and tree work end with the Geotech jobs cutting trees on steep slopes and cliffs. working in the canopy as a 3 dimensional structure is not remotely the same as hanging off a building. The complexity of moving around a crown whilst constantly maintaining 2 anchors is not to be understated. It will lead to accidents. Many people have rightly pointed out previously that the stats for falls do not support this change. How many falls have there been due to single point attachment? That is vital information we don't seem to have. The fact is that a landscaper with no training who falls off a ladder whilst pruning a tree seems to be classed as an arb industry statistic. Where as in fact it should not be. I'd love to know the data for the number of accidents where the 'old' guide to good climbing practice was correctly followed. I'll bet it's close to none. What is the AA's proposal to get this nonsense overturned?

Yep, it was a one day job IIRC.

We've done several at £3k, I'm struggling to think of one more than that. I once looked at a job for a management company, I thought £1800 for 3 elms to fell, then just before I sent the quote I noticed the original email was the end of a long string of messages. I scrolled down several messages to find a quote from the other competitor who we often quoted against with this firm. £5400! They were delighted with my extremely competitive quote of £3800.

This stuff rarely turns up on eBay or gumtree. It's all going to the continent. Van loads every day.