Risk Assessment for Working at Height Using MEWPs on Irish Construction Sites

How do you carry out a risk assessment for working at height using mobile elevated work platforms (MEWPs) on Irish construction sites?

Mobile elevated work platforms (MEWPs) are one of the most widely used types of access equipment on Irish construction sites. Scissor lifts, boom lifts, cherry pickers, and spider lifts are all MEWPs, and they are used for a wide range of tasks from installing cladding and glazing to maintaining building services and carrying out inspections. When used correctly, MEWPs are a safe and efficient way to work at height. When used incorrectly, they can kill.

The risk assessment for MEWP use is a specific requirement under Irish law, and it must go beyond a generic "working at height" risk assessment. A MEWP risk assessment must consider the specific type of MEWP being used, the specific task being carried out, the specific site conditions, and the specific hazards that arise from the combination of these factors.

This post covers the legal requirements for MEWP risk assessment in Ireland, the key hazards that must be addressed, the operator competency requirements, and the practical steps for carrying out a compliant MEWP risk assessment.

The Legal Framework

The primary legislation governing the use of MEWPs on Irish construction sites is the Safety, Health and Welfare at Work (General Application) Regulations 2007 (S.I. No. 299 of 2007). Part 2, Chapter 2 of the General Application Regulations deals with the use of work equipment, including lifting equipment. Regulation 51 requires that lifting equipment is operated by a competent person and that lifting operations are properly planned, appropriately supervised, and carried out in a safe manner.

The Safety, Health and Welfare at Work (Construction) Regulations 2013 impose additional requirements for work at height on construction sites. Schedule 7 of the Construction Regulations sets out specific requirements for the use of mobile work equipment, including MEWPs.

The Safety, Health and Welfare at Work Act 2005 requires employers to carry out a risk assessment of any work activity that may pose a risk to the health and safety of their employees, and to implement appropriate control measures.

Key Hazards for MEWP Use

Overturning: MEWPs can overturn if they are operated on uneven or unstable ground, if they are overloaded, if they are operated in high winds, or if they strike an overhead obstruction. Overturning is one of the most common causes of serious injury and death involving MEWPs. The risk assessment must consider the ground conditions at the work location, the maximum safe working load of the MEWP, the wind speed limits for the MEWP, and the presence of overhead obstructions.

Falling from the platform: Workers can fall from the MEWP platform if the platform guard rails are inadequate, if the worker leans out over the guard rails, or if the MEWP moves suddenly. The risk assessment must consider the adequacy of the platform guard rails, the procedures for preventing workers from leaning out over the guard rails, and the use of a harness and lanyard as a secondary fall protection measure.

Entrapment: Workers can become trapped between the MEWP platform and a fixed structure if the MEWP is moved while the worker is in a position where they could be crushed. This is a particular hazard with boom lifts, where the operator may not be able to see the worker's position relative to overhead structures. The risk assessment must consider the procedures for preventing entrapment, including the use of a spotter and the establishment of exclusion zones around the MEWP.

Collision with plant and vehicles: MEWPs operating on busy construction sites are at risk of being struck by other plant and vehicles. The risk assessment must consider the traffic management arrangements on the site and the measures in place to prevent collisions between MEWPs and other plant and vehicles.

Ground conditions: MEWPs require a firm, level surface to operate safely. On construction sites, the ground conditions can change rapidly as excavations are opened, fill material is placed, and drainage is installed. The risk assessment must consider the ground conditions at the work location and the measures in place to ensure that the ground is capable of supporting the MEWP.

Overhead hazards: MEWPs operating near overhead power lines, scaffolding, or other structures are at risk of contact with these hazards. The risk assessment must consider the presence of overhead hazards and the measures in place to prevent contact, including the establishment of exclusion zones and the use of proximity warning systems.

Wind: All MEWPs have a maximum wind speed above which they should not be operated. The risk assessment must consider the wind conditions at the work location and the procedures for suspending MEWP operations when the wind speed exceeds the manufacturer's limit.

MEWP Operator Competency

MEWPs must be operated by competent persons. In Ireland, competency for MEWP operation is demonstrated by holding a valid IPAF (International Powered Access Federation) PAL Card for the relevant MEWP category. The IPAF PAL Card scheme is the recognised standard for MEWP operator training in Ireland and across Europe.

The IPAF PAL Card covers the following MEWP categories:

Category 1a: Static vertical (scissor lifts and similar). Category 1b: Static boom (boom lifts and similar). Category 3a: Mobile vertical (self-propelled scissor lifts). Category 3b: Mobile boom (self-propelled boom lifts and cherry pickers).

Operators must hold the appropriate PAL Card for the category of MEWP they are operating. A PAL Card for scissor lifts does not authorise the holder to operate a boom lift. The PSCS and the employer must verify that all MEWP operators hold the appropriate PAL Card before allowing them to operate a MEWP on site.

The IPAF PAL Card is valid for five years. After five years, the operator must complete a refresher course to renew their card. Employers should maintain records of their operators' PAL Cards and ensure that renewals are carried out before the cards expire.

Pre-Use Inspection

Before each use, the MEWP must be inspected by the operator to check that it is in a safe condition. The pre-use inspection should cover the following:

The condition of the tyres or tracks. The condition of the platform guard rails and access gate. The operation of the emergency lowering system. The condition of the harness anchor point (if a harness is to be used). The fuel or battery level. Any visible damage or defects.

The pre-use inspection must be recorded. Many MEWP hire companies provide a pre-use inspection checklist that can be used for this purpose. The completed checklists must be kept on site and made available for inspection by the HSA.

Thorough Examination

In addition to the daily pre-use inspection, MEWPs must be subject to a thorough examination by a competent person at intervals not exceeding six months. The thorough examination is a more detailed inspection than the pre-use inspection and must be carried out by a person with the necessary technical knowledge and experience. The results of the thorough examination must be recorded using the GA1 Approved Form, which is available from the HSA.

Conclusion

A risk assessment for MEWP use on an Irish construction site must address the specific hazards of the MEWP type being used, the specific site conditions, and the specific task being carried out. It must also address operator competency, pre-use inspection, and thorough examination requirements. If you are responsible for MEWP operations on an Irish construction site and you are unsure whether your risk assessment meets the requirements of the General Application Regulations 2007, contact Safety Check for a review.