This SIM aims to give inspectors illustrations of possible solutions to the issue of working at height on tail-lifts.
HSE research carried out in 2004/05 estimate the human and economic cost of 'falls from vehicle' incidents that we know about was over £36.5 million. A sizeable proportion of these are falls from tail-lifts.
Tail-lift manufacturers have developed guard-rail solutions and increased slip resistance of surfaces. It is not a legal requirement that tail-lifts are supplied with these. The legal duty is on the user to decide, through risk assessment, whether these safety measures should be provided. Inspectors can provide advice to help dutyholders to decide what is most appropriate for their activities.
Examples of guardrails, and further information on preventing falls from tail lifts can be found in the IRTE guide 'Preventing falls and falling loads from tail lifts'. This can be found at Society of Operations Engineering - technical guides.
Current design standards don't require manufacturers to provide handrails below two metres. HSE is actively seeking to revise this standard.
The main duty is currently on the dutyholder to risk assess and ensure they have provided adequate safety measures for their workers.
At present, the most practical solutions for tail-lifts that operate below two metre height appears to be providing guard rails on both sides, but not on the rear end. This should then be coupled with safe systems of work, such as positioning and unloading loads in such a way that keeps the operator away from the edge of the tail-lift platform.
Some industries, such as gas cylinder delivery, have been using guardrails on all three sides for some time, and three-side solutions may be applicable to others where risk assessment so determines.
There are also further economic advantages of using guard-rails, such as reducing property damage from fallen loads.
The purpose of this SIM is to help inspectors raise awareness, with users and vehicle bodybuilders, about fall protection systems, when selecting new equipment, or retrospectively where residual risks are not well controlled through safe systems of work or training.
Guardrails on tail lifts also give greater protection against the risk of objects, including goods and roll cages, falling from the tail-lift during unloading. In particular, side guard-rails can give greater protection against goods falling on members of the public during kerb-side delivery. This can be a compelling argument for providing guardrails for this type of task.
Surfaces should be slip resistant. Research has found that friction values of 0.36 or above are recommended (assuming the tail-lift platform will be used on level gradients). Otherwise, slips charts may be useful. More can be found at Role of manufacturers and suppliers of flooring, and the HSL Research report RR437 – The underlying causes of falls from vehicles.
A common contributing cause of slip accidents on tail-lifts is the failure to provide, or wear, suitable slip resistant footwear. Research report RR437 – The underlying causes of falls from vehicles gives useful information on this, in particular, the importance of matching footwear to the environment, trialing footwear, and consulting with employees. The HSE slips website provides further advice.
Guard-rails and slip resistant surfaces will reduce the risk of accidents. Safe systems of work will help reduce the risk further, and will be particularly necessary where it is not reasonably practicable to fit guard-rails on all sides of the tail-lift, to ensure the operators remains within the protection of the guard rail system.
Safe systems of work include providing a tail-lift that is suitable for the goods being carried (for example, giving the operator plenty of space if they ride on the tail lift with the load); planning loading to minimise the time spent on the tail-lift; designing a loading and unloading pattern that allows operators to push goods from the vehicle, rather than pulling them backwards onto the tail-lift; maintaining handling equipment (such as roll cages); securing goods in the vehicle, so they don't topple towards the operator during unloading.
Design and operation of tail-lifts vary. Operators should be given proportional training for each type of tail-lift they will use. Training should include how to operate the equipment, and do's and don't for using the tail-lift, and any potential residual hazards. More detail can be found in the SOE Tail Lift Specification guide for road vehicles. This is in addition to the normal manual handling training associated with handling loads.
LOLER applies to tail-lifts, so where people are lifted by the tail-lift (i.e. most deliveries), the tail-lift must be thoroughly examined by a competent person every six months, or to timing in accordance with an examination scheme, decided by a competent person. Routine maintenance should be carried out as specified by the manufacturer. More detail can be found in the SOE Tail Lift Operators - a simple guide and Tail Lift – Specification Guide for Road Vehicles.
Many tail-lifts will suffer hard use between these examinations. A system should be in place for routine checks on the tail-lift. Any safety defects noted should be rectified immediately.
Action by inspectors will normally involve only giving advice to dutyholders. It is important to recognise that many tail-lifts in existing use do not have guard-rails in place.
Inspector action should include enquiring about policies for specifying new equipment, and encouraging dutyholders to specify fall protection (principally guardrails) and ask about options for slip-resistant flooring material on new equipment.
Where inspecting or investigating existing tail-lifts, inspectors should satisfy themselves that dutyholders have adequately risk assessed the use of the tail-lift, including whether provision of guardrails would be reasonably practicable, and whether the slip-resistance of the tail-lift surface has been maintained. The examples of guardrails solutions to prevent falls which are given in the IRTE guidance may be useful to dutyholders. Regulation 7 of the Work at Height Regulations gives a list of factors dutyholders must consider. Retrofitting may often not be reasonably practicable, however it may be appropriate where residual risks are significant and are not well controlled.
In certain cases, improvement notices (IN) requiring a dutyholder to carry out a risk assessment may be appropriate. It will not normally be appropriate to serve INs to retrofit guardrails. If inspectors feel there are aggravating factors that could justify an IN requiring additional safety measures, they are advised to discuss with HSE Transportation Section of STSU.
Inspectors should be aware of who (in terms of diversity, e.g. men, women, disabled etc) is the target group in the sector they are dealing with. Give consideration to, and factor into the approach, any issues that may surround this audience such as literacy issues, English as a second language and disability (access needs).
The Diversity and Delivery pages give more information on these areas and others, including the Communications and EIA toolkits.
SOE IRTE 'Tail Lift Operators - a simple guide' - and SOE IRTE 'Tail Lift - Specification Guide for Road Vehicles' both available via Society of Operations Engineering - technical guides