Would adding working at heights to the high-risk licensing scheme reduce falls?
Falling from a height is the second most common mechanism of workplace fatalities, behind vehicle incidents. It has been that way, seemingly, forever.
Each and every year stories are published about lives cut short following an accident where a person was working in an unsafe situation and a fall has occurred. The number of these stories published each year has not decreased at all over the last decade.
The statistics for injuries resulting from falls are not much better.
One proposal put forward to address this has been to add working at height to the high-risk work licensing scheme. But to do so would require substantial changes to how height safety and fall protection are regulated not just in New South Wales, but across the country.
What and why of high-risk work licences
A high-risk work licence is a formal document, issued by a state’s workplace safety regulator, stating a worker has completed the relevant training (and thus possesses the relevant skills) to safely operate certain types of machinery and plant.
These machines or types of work have been determined to present a significant risk to health and safety of workers and others nearby if not operated or performed correctly.
The types of work where a high-risk licence is required is defined in Schedule 3 of the Work Health and Safety Regulation (NSW) 2025 and include tasks like operating forklifts, erecting scaffolding and securing loads for lifting with cranes.
To obtain a high-risk licence, a worker must complete training before being assessed by an accredited, and independent assessor. Upon successful completion of the assessment, they then apply to their state’s workplace safety regulator to receive their licence.
In short, these are licences to perform specific tasks that are known to require certain skills in order to be undertaken safely.
Working at heights is risky, but…
Working at heights represents the biggest risk to worker health and safety behind getting in the car and driving to work in the morning. However, determining when a worker starts and stops working at height may not be immediately clear.
Strictly speaking, just about any situation where a worker’s feet are off the ground could be considered working at height. Working at height is not defined as an act or doing something. Instead, its definition is based around the need to respond to a potential risk of a fall as assessed before work (and on a continual basis while working)
Under the regulation, someone is considered to be working at height when there is a need to mitigate the “risks to health and safety associated with a fall by a person from one level to another that is reasonably likely to cause injury to the person or another person.” There are no hard and fast criteria. Nowhere does it say working at heights starts at one, two or three metres off the ground. Everything is determined on a case-by-case basis through a risk assessment procedure.
Creating a work at heights licence
The biggest obstacle to creating a new licence for working at heights is defining the circumstances in which the licence would be required.
Would there be a minimum height? What would that height be?
If the minimum height were to be based around where most and serious and fatal falls occur, then that would be less than four metres. It seems counterintuitive but the higher a worker is from the ground the more likely they are to incorporate effective mitigations against those risks, thus reducing the likelihood of a fall. At lower heights, the risk of a fall is regularly miscalculated, leading to more serious incidents and more incidents overall.
Setting parameters around this would be incredibly difficult, and potentially prone to overwhelming training and licensing systems.
At the broadest end of the scale, a high-risk work licence would end up being needed by the same people that would also need their general induction (white card). In New South Wales alone this would represent around 110,000 people undertaking a high-risk licence course every year.
This is more than twice the number of workers that currently undertake the existing work safely at heights training course, and nearly three times the number of forklift licences issued every year, which is the most common high-risk licence sought out.
That is a substantial number of people to assess each year. And that is not accounting for the need for refresher training and licence renewal.
A more practicable solution
While adding working at heights to the high-risk licensing is definitely a solution to reducing the rate of fatal and severe falls from height, there are other more practical solutions.
For instance, given the incredibly small percentage of workers that complete any form of recognised height safety training, a push for employers, site supervisors and workers to engage with the nationally accredited RIIWHS204E Work safely at heights course be an easy first step.
The course equips participants with the skills and knowledge to accurately identify, assess and then mitigate a range of common height safety environments. Participants also become familiar with common equipment and PPE used when operating typical fall protection systems.
Part of a bigger height safety picture
Training and awareness of risks is not the only aspect of height safety that need to be looked at in order to reduce falls from height.
The decisions workers make, which can either lead them towards or away from a fall, are influenced by a variety of factors. Many of these factors are completely outside a worker’s ability to control.
Those supervisors, employers and building operators that require work to be undertaken at height need to understand the role they play in creating the work structures team members operate within, and how they contribute to building meaningful and sustainable cultures of safety within their workplaces.
Partners in protecting people
Height Safety Engineers have been protecting people working at height and in high-risk environments for over 20 years. From the design and installation of best practice fall protection systems through to ongoing compliance, training and supply of PPE and other equipment our team can assist in helping no matter your industry or need.
Start your safety journey with HSE by calling us on 1300 884 978, emailing enquiries@heightsafety.net or dropping us a line through our contact form.
