Falls from height in mineral industries (ceramic, concrete and glass)

SIM 03/2009/12


This SIM provides information on circumstances where falls from height could occur in situations which are specific to mineral industries (ceramics, concrete and glass) covered by the Manufacturing Sector's, Metals and Minerals Team.  An awareness of these issues will form a useful part of any inspection concerning falls from heights when visits are carried out in relevant factories.


This SIM does not deal with generic risks such as falling through fragile roof lights or from unprotected edges.  Neither does it restate matters relating to falls from height, which are covered elsewhere (eg Falls from Height Topic Inspection Pack ).  It concentrates on issues that are specific to mineral industries, specifically ceramics, concrete and glass.

The Initial Enforcement Expectation section repeats the minerals text from the Falls from height, Topic Inspection Pack.  (Section 4.1 HSE Sectors, Manufacturing Sector, Ceramics, Pottery, Heavy Clay Refractories, Glass, Concrete and Cement)


The Ceramics Industry Advisory Committee (CERIAC), reconstituted as C3HARGE (Ceramics, Cement, Concrete, Heavy Clay, Refractories and Glass manufacturing Industries Joint Health and Safety Advisory Committee) discussed the following:

  • accidents caused by falls through pottery/brick dryer roofs within buildings - which highlighted the lack of knowledge about risks and precautions; and
  • fall through a brick factory roof caused by badly corroded roof beams - which suggested industry-specific factors were at play.

There are similar problems to the above in concrete and glass industries.

Occupiers may not be familiar with these problems, particularly the second, hence maintenance staff, roof workers and contractors may not be fully briefed about the dangers and the precautions required before commencing work on roofs.

Weakened roof beams

There is evidence in the ceramics, concrete and glass industries that emissions from the firing / curing or process equipment can cause accelerated corrosion and weakening of roof members.

A particular incident, which occurred in the ceramics industry, highlights this issue.  Key points from the investigation were:

  • A roofing contractor was working at a brick factory on the roof of a large portal steel framed building clad with single skin corrugated asbestos sheeting.
  • The contractor was in the process of sliding back sheets on the roof to expose a Z shaped purlin, which was going to be replaced. The adjacent purlin gave way and a section of the roof collapsed.
  • Examination of the failed roof purlin and others in the vicinity showed they were badly corroded, most probably from the emissions from the kiln (specifically hydrogen fluoride from the clays) and the corrosion had taken place over a prolonged period.

This matter was raised with trade associations representing both concrete and glass industries, initially with a view to reminding companies of the general risks associated with roof work. However, both industries recognised the problem of localised corrosion caused by their own industry-specific factors and further enquires via the industry trade associations produced the following picture.  Not surprisingly, the level of awareness varies considerably:


Companies identified the roof areas over kilns, particularly around flue areas and at the outlet end of tunnel kilns where condensation occurs were the most likely areas to be affected. Many companies had pre-existing routine inspection procedures in place.

One company reported that:

  • the galvanised beams appeared to corrode quite rapidly exposing the steel;
  • parts of a purlin had fallen to the ground; and
  • examination of other purlins had revealed holes.

Others reported problems:

  • above biscuit intermittent kilns;
  • above dryers; or
  • because exhaust stack heights were low, there was inefficient dispersal of emissions.

Clearly, good collection and removal of emissions from the factory should reduce the potential problem.


Roofs above curing chambers are known to be at risk and many companies have routine inspection procedures in place.


One company reported areas above furnaces and mixed batch conveyors as potentially at risk. Additionally, it is recognised that materials such as stannic chloride formerly used in the industry could have an effect on older buildings.

Internal dryer roofs

Dryer roofs may be constructed of fragile materials.  Accidents have occurred at both brick and pottery factories where maintenance workers have gained access onto dryer roofs either without proper access facilities or without the correct precautions being taken.  In one case, a walkway above a dryer, which was not provided with edge protection on the roof side, led to a number of strengthened panels used as an access platform to plant.  There was no protection between the strengthened and un-strengthened panels.  The injured person fell onto the un-strengthened panels, which gave way beneath them.

Initial enforcement expectations (IEE)

Companies should be aware of these potential problems and have considered the arrangements necessary to identify them in advance of any maintenance work and implement the necessary precautions.  The following guide on enforcement action is based on the Enforcement Management Model (EMM) version 3.0 and applies to situations where there is a risk of falling 2 metres or more with the potential to cause injury.

Benchmark standards and risk gap

Benchmark standards for controlling the actual risk of falling will be no different in these circumstances from any other situation where fragile materials are concerned. The following are relevant to deriving the authority of standards for use in EMM Table 5.1 and hence for deciding the IEE.

Title Standard

Work at Height Regulations 2005


Management of Health and Safety at Work Regulations 1999 and ACOP (L21)


SIM 03/2009/12 - Falls from heights in mineral industries (ceramic, concrete and glass)


Immediate risk

There have been accidents arising from these specific risks in which people have fallen through or from dryer roofs or building roofs due to inadequate edge protection, working on fragile materials or weakened roof beams.

If no regard has been given to the risks from clearly fragile dryer roofs or patently weakened roof members and work is underway, inspectors should consider issuing a prohibition notice (PN) in line with EMM Section 2: Risks of serious injury.

Whilst action to reduce the risk could be simple, account should be taken of the nature of the job underway and the need for working platforms to rest on strong structures. This is particularly important in the case of weakened roof beams, where the extent of the problem can be underestimated. Alternative working procedures, eg mobile working platforms, may also be possible.

Detailed guidance on suitable precautions should be sought from Construction Inspectors where necessary.

Management arrangements

The specific issue is whether a company has considered the matter of fragile dryer roofs or corroded roof beam in risk assessments and in advance of work being carried out. These matters relate to compliance and administrative arrangements (EMM Table 5.2).

Inspectors may use the scenarios to assess actual risk, and the risk gap. Inspectors must ensure that they base their assessment of risk on the factors they find at site.

Scenario Compliance and Administrative - descriptor Initial Enforcement Expectation

Where plant with fragile roofs exist and no systems exist to ensure precautions are implemented before work commences


Letter/ improvement notice*

Where processes known to cause weakening occur and no systems exist to ensure precautions are implemented before work commences on roofs


Letter/ improvement notice*

*Depending on whether work is underway or planned

Action by inspectors

This SIM provides industry specific information, which should be considered when dealing with falls from height in these industries.


Inspectors should be aware of who (in terms of diversity eg 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).

Cancellation of instructions

SIM 03/2002/52 - cancel and destroy.

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Updated 2022-11-08