Scaffold Inspection Requirements on Closed Sites
The Coronavirus crisis is unprecedented and not since the second world war has the UK faced such a challenging situation. Much of the UK is at a standstill, while construction employers wrestle with unclear Government advice as to what they should and should not do, with many torn between business survival and keeping their workforce safe. At the same time, many self-employed construction workers face the stark choice of working or not earning.
The situation is dynamic and arrangements to constrain the pandemic are changing daily. The Government has expressed its desire for key industries, including construction, to maintain productivity, so far as possible. One question our team is frequently asked is, “What do we need to do about scaffold inspection, if we can’t get to site?”
Here’s our response…
Firstly, while all efforts should be made to ensure that statutory requirements are adhered to, it is likely that enforcement will be relaxed for the short-term. The Health and Safety Executive’s workforce is in exactly the same situation as the rest of the UK, and for this reason they will be well aware of the extenuating circumstances faced by the construction industry and the operational difficulties these bring about, including the inspection of scaffolds.
Most in the industry will be aware that scaffold inspection is a statutory requirement, brought about by Regulation 12 of the Work at height Regulations 2005. The types of inspection required by the Regulations are:
- Pre-use Inspection (following installation or assembly)
- After conditions causing deterioration (i.e. severe weather, vehicular impact and interference, etc)
- Seven-day Inspections
In the context of seven-day inspections, section 12 (4) of the Regulations states, “…every employer shall ensure that a working platform used for construction work; and from which a person could fall 2 metres or more is not used in any position unless it has been inspected in that position or, in the case of a mobile working platform, inspected on the site, within the previous 7 days.”
So what does that mean?
In a nutshell, it means that scaffolds only need to be inspected at seven-day intervals, when and if they are being used as working platforms and therefore, on a closed site, or on a site where scaffolds are not in use, the seven-day inspection requirements of the Regulations do not apply.
Where scaffolding is taken out of service, reasonable steps must be taken to restrict access to the working platforms and warning signs must be displayed at prominent locations to identify that the scaffolding is not in service. This is a two-fold duty and you can’t do one without the other and this is the same duty as if the scaffold was incomplete.
Any warning signs used must comply with the Health and Safety (Safety Signs and Signals) Regulations 1996.
Does this mean a scaffold never needs inspecting if it is not in use?
On closed sites, or where access has been restricted to scaffolding structures, a judgement needs to be made (a risk assessment) to determine the suitable frequency at which scaffolding should be inspected or checked for a deterioration in condition. These inspections may be less frequent than the seven-day inspections and the actual required frequency will depend on the risk of deterioration. As an example, they may be assessed to be required monthly, quarterly or even half-yearly.
As a word of caution, the statutory inspection requirement still applies for scaffolds that may have been affected by an event or conditions causing deterioration, such as high winds or impact by a vehicle or items of mobile plant and they must not be used until an inspection has taken place.
Our customers frequently ask whether long-standing scaffolds that are only used periodically (for example occasional maintenance tasks) need to be inspected weekly. The short answer is no, but they definitely need to be inspected before use and after events that could cause deterioration to the safe condition.
The Construction (Design and Management) Regulations 2015 apply to all construction work in the UK. Regulation 19 of CDM (Stability of Structures) states, “All practicable steps must be taken, where necessary to prevent danger to any person, to ensure that any new or existing structure does not collapse…”
This means that consideration must be given to the ongoing stability of scaffolds and they cannot be simply forgotten about because they are not in use. This applies to all temporary scaffolding structures including special purpose structures, falsework, formwork and not only access scaffolding that includes working platforms.
Our advice in this instance is to risk assess each scaffold and give consideration to the particular factors that may impact its stability. From there, a judgement can be made as to how often the scaffold should be inspected. Factors to be considered might include:
- Scaffold configuration – is it sheeted or netted? Or is it fully boarded?
- Location – Where is the scaffold situated? Is it exposed to wind, or other conditions that could impact stability?
- Environment – Are there any adjacent activities that could negatively impact the scaffold?
In our experience, as long as a scaffold remains safe and stable and a considered approach to periodic inspection can be demonstrated, this will usually be enough to satisfy the enforcing authorities.
Virtual scaffold inspection service
We’re keen to support the UK’s construction industry however we can and as the crisis moves on and construction activity reduces and the industry evaluates what it can and can’t do without compromising the safety and well-being of its workers – we’re pleased to announce a virtual scaffold inspection service.
We’ll walk any scaffold by video link and give free advice and guidance to anyone who needs it. We can check photos against design specification, or even just offer reassurance and opinion based on a verbal description.
Anyone needing such assistance can contact us through any of our social medial channels, telephone – 0345 602 2418 or via email through firstname.lastname@example.org.