This SIM replaces SIM 05/2004/13: the revision has been made to bring the SIM in line with the Work at Height Regulations 2005 (WAH). This SIM provides guidance for inspectors on means of preventing falls from height during the catering of aircraft, and when opening aircraft doors. The guidance is aimed primarily at caterers using high loader vehicles and is designed to complement the guidance contained in the falls from height topic pack. The guidance does not apply to hold loading of catering supplies. Some aspects of this guidance will be applicable to other workers such as air crew, maintenance engineers, security and cleaning staff who also open aircraft doors or use high loader vehicles.
1 There have been significant numbers of accidents resulting in serious injuries to airline catering staff caused by falls from high loader platforms. Risks exist when there is an unguarded edge or there is a significant gap between the high loader and aircraft, such that a person might fall. This situation arises either when opening aircraft doors from the outside, or during loading or unloading of catering carts from the aircraft. Falls have also occurred when opening doors from the inside without any Ground Support Equipment (GSE) in place, and when access steps have been withdrawn without warning.
2 Aircraft catering vehicles are designed to allow rapid transfer of catering trolleys and other supplies to and from aircraft as part of the preparation of aircraft for flight (turnround). They normally consist of a van body mounted on a standard vehicle chassis. The van body is raised up to the aircraft door by a scissor lift mechanism. Access to and from the aircraft door is via a platform, which is often fitted with an extending section (bridge or bridge plate). The bridge may be attached to the platform by hinges or flanges, or may be extended hydraulically from beneath the platform. The platform and bridge should be fitted with edge protection to all sides. It is the front part of the platform or bridge that interfaces with the aircraft. See Appendix 2 for terminology and definitions.
3 Design considerations with catering vehicles include aircraft door height, width and position, the layout of stands (space may be limited), and airport authority and Civil Aviation Authority (CAA) requirements in terms of airside driving standards and avoidance of damage to aircraft. Vehicles have either a full width platform, which rests above the vehicle cab when in its lowered position, or a half width platform which rests alongside the vehicle cab when lowered and can therefore be used with smaller aircraft with lower service doors.
4 All Ground Support Equipment (GSE) should be designed in accordance with BS EN 1915-1:2001 'Aircraft ground support equipment – basic safety requirements'. Specific requirements are also covered in BS EN 12312-2:2002 'Aircraft ground support equipment – catering vehicles'. Safety features and proposed systems of work should be considered at the design stage to ensure that the risk of falls is controlled so far as is reasonably practicable when operating catering vehicles and access into the aircraft. Vehicles manufactured after 2002 should meet both standards.
5 However, the design of catering high loader vehicles varies significantly between airports, individual companies, and to cater for different types of aircraft. Historically vehicles have been designed or modified for individual companies for specific catering operations or aircraft, and designs have been intended to give maximum flexibility of use as contracts change and different aircraft types are catered. Maximum flexibility often means that the vehicles may not be ideally suited to any particular operation or aircraft type. Vehicles have also been transferred from company to company, and some vehicles are of considerable age. The environment in which catering operations take place is out on the airport ramp with little protection from weather.
6 There is considerable emphasis during servicing of aircraft on avoiding damage to aircraft by contact or collision with plant, vehicles or equipment. Vehicles and equipment are positioned to avoid accidental contact with the aircraft, including allowance for the movement and settlement of an aircraft during loading and unloading of baggage and supplies, refuelling etc. An aircraft door sill may rise or fall by up to 38 centimetres during turnround, and loading platforms such as catering vehicles and systems of work must allow for this. The open door will also move and must not be allowed to contact the vehicle platform or bridge. Damage to an aircraft door may have serious implications for flight safety.
7 In common with most airside operations there is also time pressure, and a perception that aircraft turnround time is of paramount importance. There can lead to workers failing to follow established systems of work or procedures if they feel that time can be saved.
8 Catering workers are often expected to open the aircraft door from the outside. Aircraft door operation varies according to aircraft type and some aircraft have doors which swing open, out and to the side. In order to open such doors it may be necessary to lean out from the unprotected front edge of a high loader and open the door before the platform and its edge protection can be positioned. For the purpose of this guidance such doors are referred to as 'higher risk doors'. This is regarded as an extremely high risk operation and has resulted in a number of serious accidents. Further information on opening aircraft doors can be found in SIM 05/2005/05.
9 This guidance considers both the immediate steps which should be taken to reduce such risks (e.g. fall restraint equipment) and longer term aims such as improved vehicle, platform guarding and aircraft door design. Where aircraft doors can be opened from a guarded platform, further safeguards may not be necessary.
10 Guidance has been given to individual companies in the past on the use of bridge plates between the high loader and aircraft, acceptable standards of guarding and systems of work on opening aircraft doors. Such advice has not been developed into published guidance for the industry, and has therefore not become widely known or understood and best standards have not been maintained. HSE first published guidance on safe access in 2004 and this was made available to the industry. Standards should therefore be well known and understood.
11 More detailed guidance on equipment and the work activity can be found in Appendix 1.
12 There are other issues relating to catering activities including musculoskeletal injuries from moving heavy catering carts and the increased risk of slips, trips and falls. These risks are not covered in this guidance, however inspectors should be aware of such issues and deal with them according to the relevant guidance and Enforcement Management Model (EMM).
13 Every employer has a duty to protect so far as is reasonably practicable the health and safety of their employees whilst working at a height. Typically, this will involve providing access equipment with suitable edge protection and/or Personal Fall Protection Systems (PFPS). Further information on falls from height can be found in the FOD Inspection Topic Pack 'Falls from Height '
14 The Work at Height Regulations 2005 addresses all work at height where a person could fall a distance liable to cause personal injury. Guidance on the application of the regulations and the hierarchy of control measures to use can be found in OC 200/31.
15 The Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) also apply to catering vehicles. Further information on LOLER can be found in OC 234/11.
16 The CAA Safety Regulation Group (SRG) and HSE are both involved in enforcing existing legislation and standards at airports in line with their statutory responsibilities. The roles and responsibilities of HSE and CAA and a framework for liaison are outlined in a Memorandum of Understanding (MoU) and include a number of Annexes on specific areas.
17 Advice on aircraft catering undertaken at airports can be sought from the Transportation Section of STSU.
18 Inspectors are requested to:
19 The Transportation Section is also engaging with airlines and with vehicle and aircraft manufacturers and designers to raise awareness of requirements for safe access. Representatives of the major airline catering companies have worked with HSE in the production of this guidance. Inspectors are encouraged to enquire into manufacturers' and airline guidance on such things as opening aircraft doors and positioning of access equipment, and to ensure that safe access is covered as part of routine employee training programmes.
20. Where inspectors consider that an airline has responsibilities for safety such as allowing aircraft doors to be opened from the inside, they should contact the Transportation Section and the appropriate airline Head Office Principal Inspector to check the national situation before taking any enforcement action.
21 The following is a guide to when enforcement action may be appropriate. It is based on the EMM and applies to situations where there is a risk of falling with the potential to cause injury.
22 The relevant hazard is a fall from a height when opening/closing the aircraft door from a catering high loader and during routine aircraft catering operations.
23 Injuries sustained as a result of such falls have included multiple injuries, head injuries and fractured limbs. High falls and low falls are both considered a hazard with the potential for a fatal injury.
24 The risk of a fall will depend on various factors including:
25 Where a person is working at height without any means to prevent a fall, an immediate risk of serious personal injury is likely to arise. Inspectors should consider issuing a prohibition notice. Action to reduce the risk could be as simple as positioning existing guard rails on work platforms, or using PFPS already provided.
26 Inspectors are reminded of the possible implications of an immediate Prohibition Notice and should consider the impact such a Notice might have on other workers around an aircraft, and on overall air traffic control and flight safety at the airport. Where immediate prohibition could cause significant health and safety or air safety risks, a deferred notice should be considered.
27 Given the potential for injury it is essential that a suitable and sufficient risk assessment is carried out. Consideration should be given to risk control systems for equipment procurement, maintenance and thorough examination, as well as training in selection and use of equipment, systems for maintaining edge protection and restricting access to unguarded edges, and management control of contractors.
28 The long term aim should be better designed vehicles, better guarding, and improved design of aircraft doors and their opening mechanisms. Where current vehicles and guarding are obviously inadequate, we should be asking for immediate improvements. This may mean modifying the vehicles or using PFPS in the short term. In the longer term we should be asking companies to come up with a programme and timetable for replacement or improvement of vehicles and guarding.
29 Some airlines have already introduced door nets to protect against falls from open doors. Such nets or restraint systems must be adequately tested and secured. Door straps on many aircraft are simply a warning device and are not a form of edge protection.
30 Where there is a risk of a person falling a distance liable to cause personal injury, the benchmark should be considered as a 'remote risk of serious personal injury'. If it is reasonably practicable to provide edge protection, the benchmark should be achieved by providing the standards in Appendix 1.
31 The following standards are relevant:
32 The risk gap as derived from EMM for key scenarios that inspectors may encounter is summarised below. The examples given are however for illustrative purposes only. Inspectors must come to an enforcement decision that is based on what they find in a given situation.
|Scenario||Actual risk||Risk gap|
|Work at height where a person could fall a distance liable to cause personal injury. This might include exposure to risk while positioning guard rails, opening aircraft doors. PFPS not used or used incorrectly||Probable risk of serious personal injury||Substantial|
|Poorly maintained access equipment, damaged or missing edge protection. Other examples include structural damage and damage to base causing instability||Probable or possible risk of serious personal injury depending on nature and extent of damage||Substantial|
1 On approach and positioning of a catering vehicle, the vehicle should be positioned as close as possible to, and in correct alignment with, the aircraft door, allowing for aircraft damage avoidance. Airports can assist with this by designing aircraft stands that allow for correct positioning of all ground support equipment for all aircraft types using that stand.
2 Once the vehicle is positioned all guard rails (including adjustable ones), extension platforms or bridges should be engaged and locked in place. Guard rails and bridges should be positioned from a place of safety, for instance, pushing rails and bridges into position from the guarded platform. Workers should not be exposed to risk by approaching unguarded edges to pull guardrails into place. On some existing vehicles the workers may have to stand at an unguarded edge to pull or manoeuvre the guard rails into position. Some newer vehicles have automatically operated guard rails and bridges, activated by a switch within the main body of the vehicle.
3 Where possible, higher risk aircraft doors are to be opened from the inside in cooperation with cabin crew or by arrangement with the airline. This system is safer for the ground handlers. However, there are risks associated with opening aircraft doors from the inside, including accidental activation of the emergency chute and falling from an unprotected door opening. The door opening can be protected by provision of access steps or the high loader platform outside.
4 Inspectors should be aware of existing industry guidance on opening aircraft doors:
5 If a higher risk aircraft door must be opened from the outside, this operation should preferably be performed from a wide platform which allows the door to open within the confines of the area protected by guardrails. If it is not possible to open the door from such a platform, further precautions as detailed in this guidance, such as PFPS, must be utilised.
6 There are considerable limitations on the use and suitability of PFPS on aircraft and access platforms, including availability of attachment points that are rated and strong enough, actual height of work, the risk of hitting obstructions on the aircraft or vehicle during a fall, and the additional safety risks introduced in attaching and using harnesses. In particular aircraft structures and components are subject to stringent design requirements, and attachment points can only be provided according to manufacturers' specifications and approval.
7 Personal Protective Equipment (PPE). High visibility PPE and non-slip protective footwear must be provided for all catering personnel. High visibility clothing must be worn at all times airside. If PFPS are used, they must be compatible with any other PPE.
8 Inspectors may wish to contact the Section for advice when dealing with access equipment.
9. Options available to protect the workforce from falls from heights during access to and egress from the aircraft include:
10 The ultimate aim should be to seek engineered safety solutions, with vehicles designed with integral safety features in preference to PFPS. Engineered improvements such as guarding or gates should be retro fitted to vehicles in preference to using PFPS.
11 New catering vehicles should comply with BS EN 1915-1:2001 and specifically with BS EN 12312-2:2002. This includes a requirement for a minimum useable width of the loading platform of 700mm, and guard rails which can be adapted to the contour of the aircraft with a maximum gap of 150mm to the aircraft fuselage.
12 Vehicle platforms and extension bridges should be fitted with a combination of fixed and adjustable guarding so that all edges from which a worker could fall are guarded. Where the bridge or transit plate is narrower than the platform, there will be edges to the front of the platform from which workers can fall. If the gap between the leading edge of the platform and the aircraft is more than about 15cms these edges should also be protected.
13 Guards should be checked and maintained to ensure they are in good working order.
14 All guards must be positioned and used as soon as the vehicles and platforms are in position and occupied, and should be positioned from a place of safety.
15 Loose bridge plates or transit plates should only be utilised to bridge a narrow gap between the platform and aircraft, to enable the catering carts to be wheeled across. Wherever possible such bridges should be fixed or secured by means of pins, flanges or similar safety devices to prevent slipping or movement of the bridge. It is not acceptable to use a loose bridge plate across a gap which is wide enough for someone to fall through. If a wider gap has to be bridged, the bridge plate must be secured to the platform (e.g. hinged or pivoted) and fully guarded.
16 The provision of equipment with edge protection may not be reasonably practicable for some tasks of short duration or where guard rails cannot be positioned fully, for instance when opening aircraft doors outwards. In such circumstances the use of PFPS connected to a suitable anchorage point may be an acceptable solution.
17 Use of PFPS and anchorage points on aircraft are subject to CAA and manufacturers' approval if attached to the aircraft. PFPS (lanyards, energy absorbers, etc.) should be manufactured to recognised European personal protective equipment standards. PFPS should only be considered as a last resort and must be supported by a risk assessment that establishes that the PFPS can be effective.
18 The employer needs to be clear about what the PFPS is required to do and should base their decision on what type of equipment to use on a risk assessment of the work to be done. The assessment should take into account the type of aircraft and vehicle platform involved, and the location of the work. The two types of PFPS under consideration are:
20 It is vital that the clearance distance for a fall arrest system is sufficient to prevent the wearer hitting the ground. Consideration should also be given to components or structural parts of the aircraft or vehicle which an operative could strike during a fall. Employers should take into account the deflection of anchorages when in tension, as well as the effect of the deployment of any energy absorbers which have been fitted. Considerable clearance may be required. For example, a system comprising a full body harness and 2m long lanyard with an energy absorber anchored at the level of the wearer's feet could require up to 6.75m (2m lanyard + 1.75m deployment + 2m person + 1.0m clearance) of clearance below the anchorage point. As a result it is only to be used where there is sufficient clearance for the equipment to operate correctly.
21 When inspectors encounter personal fall arrest equipment being used during aircraft turnround activities they should question its use and verify that sufficient consideration has been given to the fall height required for the particular fall arrest system to stop a fall. This is the case regardless of the size of aircraft involved. With the aircraft currently in service it is unlikely that any service doors are sufficiently high, or clearance around the vehicle sufficient, to enable fall arrest equipment to operate effectively.
22 Fall arrest equipment is subject to the Personal Protective Equipment Regulations 1992 and regulation 7 lays out the requirements relating to maintenance. OC 282/19 contains further advice regarding PPE and information regarding inspection of fall arrest equipment can be found in OC 282/30 and leaflet INDG367.
23 PFPS needs to be properly designed, installed, maintained and kept well adjusted. Users must be trained in use of the equipment to a proficient standard and the employer should also consider how they will monitor and supervise correct usage, as well as plan how a worker wearing a harness will be recovered, should they fall.
24 HSE is aware that the majority of anchorage points on Mobile Elevating Work Platforms (MEWP) are only currently rated for work restraint and not fall arrest. Any anchorage points on catering vehicles may be similarly rated. Employers should seek confirmation of this issue from the MEWP/vehicle supplier prior to using it for anchorage.
25 Safe access must be provided to attach the harness to the anchorage point and will also be required during work on the anchorage points themselves.
26 The limitations of PFPS are such that it should only be considered as a last resort and must be supported by a risk assessment that establishes the system can be effective. Where it cannot be established that a PFPS can be effective due to anchorage points not being strong enough, insufficient space for restraint or insufficient fall height for effective deployment it should not be used. In such situations other available means of access (e.g. a different design of platform or a different type of vehicle) and/or protection should be considered, and the most suitable used for the specific task.
27 Assessment of work restraint equipment undertaken by the airline catering industry in cooperation with HSE has shown that positioning of attachment points and length of lanyard must be designed specifically for different designs of vehicle, platform and guard rail system, as distances from the vehicle to the end of the bridge may vary.
28 Attachment points must be of sufficient strength to support the load imposed by the weight of the worker in the event of a slip or trip and should be fitted and tested by a competent person. Where attachment points are on guard rails, the rails must be of sufficient strength to withstand foreseeable forces.
29 Where vehicle types vary it will be necessary to securely fix the lanyards to the vehicle to prevent the wrong length lanyard being chosen and used, or lanyards being moved from vehicle to vehicle.
30 Work restraint systems must be designed so that the user cannot reach and thus fall from an unprotected edge, however they must also allow the worker to position guard rails or reach the aircraft door to operate the opening mechanism, without excessive stretching and straining.
31 In some cases it has been found necessary to provide two lanyards of different length and with separate attachment points to allow the worker first to position the bridge plate and guard rails, before then detaching one lanyard and attaching the next to move further out on the bridge to open the aircraft door. There may also be a requirement to provide lanyards on each side of the platform to allow for left and right opening doors.
32 The more complex the work restraint system, the more likelihood there is of individuals making mistakes or neglecting to use the lanyards. Training, supervision and monitoring is therefore extremely important.
33 Airside employees involved in catering operations must receive specific training on airside safety awareness, catering vehicle familiarisation, aircraft approach and full use of safety features and procedures whilst catering and decatering aircraft. Users should also be instructed on the loading limitations of catering vehicles in relation to aircraft type (see CAP642 for further guidance on airside training).
34 People positioning, using and supervising the use of catering high loaders and other access equipment should be competent to undertake this work safely. This will require specific training to be provided for each type of vehicle or PFPS used.
35 Users should be instructed in the use and limitations of the access equipment, and the limits on their authority to modify it. Employees using PFPS should be trained in its safe use. Access to the vehicle bridge and body should be restricted to authorised personnel and it should be clearly indicated that access is not allowed to unauthorised personnel such as other ground support workers or flight crew.
36 Supervisors with a responsibility for ensuring that the workplace is safe must be able to recognise any inadequacies in equipment or work practices and will therefore need suitable training.
37 Where a company has specialist equipment, including equipment designed and constructed for use with only one type of aircraft or limited types, staff should be sufficiently competent to recognise and select the right equipment for the aircraft and task at hand.
38 PFPS equipment should be inspected and maintained according to relevant manufacturers' recommendations. Anchorages need to be proof tested when installed and when any usage changes. There should be checks of all equipment (vehicles, platforms, guard rails, harnesses, etc.) by users, inspections by competent persons, as well as any statutory inspections required by LOLER. This is all in addition to any maintenance that is specified by the manufacturer.
(BS EN 12312-2:2002 also contains definitions relevant to catering vehicles)
1 'Higher risk doors'. For the purpose of this guidance any aircraft door which swings out when opened, and cannot be opened with platform and guard rails in protective position, is referred to as a 'higher risk door'. Access for catering is normally via the aircraft galley door or service door.
2 Food Equipment Handlers (FEH). This is a generic term for Catering Workers, Drivers and Loaders. The loader may also act as a guide man or banks man during reversing and positioning of the vehicle.
3 Vehicle types and features
4 Platform Types: (BS EN 12312-2:2002 refers to 'loading platforms')
6 Guard or hand rails