Risk Assessment for Working at Height: A Step-by-Step Guide for Irish Contractors

Falls from height are the leading cause of construction fatalities in Ireland. This step-by-step guide explains how to carry out a suitable and sufficient...

# Risk Assessment for Working at Height: A Step-by-Step Guide for Irish Contractors Falls from height are the single biggest cause of fatalities on Irish construction sites. The HSA's annual statistics consistently show that falls account for more deaths in the construction sector than any other cause. Despite this, risk assessments for working at height are frequently inadequate — either too generic to be useful, or focused on the wrong hazards. This guide explains how to carry out a suitable and sufficient risk assessment for working at height under Irish law, what it must include, and the common mistakes that leave contractors exposed. ## The Legal Framework The primary legislation governing working at height in Ireland is the Safety, Health and Welfare at Work (General Application) Regulations 2007, Part 4 (Work at Height). These Regulations implement the EU Work at Height Directive and set out the specific requirements for planning, organising, and carrying out work at height. The Regulations require that work at height is properly planned, appropriately supervised, and carried out in a manner that is, so far as reasonably practicable, safe. They also establish a clear hierarchy of controls that must be followed when planning work at height. The general duty to carry out risk assessments comes from the Safety, Health and Welfare at Work Act 2005, Section 19. ## When Is a Specific Risk Assessment Required? A specific risk assessment for working at height is required whenever work is to be carried out at a place where a person could fall a distance liable to cause personal injury. There is no minimum height threshold — even a fall from a relatively low height can cause serious injury or death, particularly if the worker lands on a hard surface or on an object. In practice, a specific risk assessment for working at height is required for any work that involves: - Working on or near the edge of a roof - Working from a ladder, stepladder, or podium steps - Working from a scaffold or mobile scaffold tower - Working from a mobile elevated work platform (MEWP) - Working in a ceiling void or roof space - Working on or near fragile surfaces - Working over or near water or other hazardous substances ## The Hierarchy of Controls Before carrying out a risk assessment for working at height, it is important to understand the hierarchy of controls required by the Work at Height Regulations. This hierarchy must be applied in order — you cannot move to the next level until you have considered and rejected the level above. **Level 1: Avoid work at height where possible.** Can the work be done from the ground? Can the component be assembled at ground level and lifted into position? Can remote monitoring or inspection technology eliminate the need for a person to work at height? **Level 2: Use work equipment or other measures to prevent falls.** If work at height cannot be avoided, use collective fall prevention measures — guardrails, edge protection, or working platforms with toe boards and handrails. These measures prevent a fall from occurring. **Level 3: Use work equipment or other measures to minimise the distance and consequences of a fall.** If fall prevention is not reasonably practicable, use fall arrest systems — safety nets, airbags, or personal fall arrest equipment (harnesses and lanyards). These measures do not prevent a fall but limit its consequences. The hierarchy is clear: collective measures (guardrails, platforms) are always preferred over personal protective equipment (harnesses). A risk assessment that jumps straight to harnesses without considering collective measures is not following the required hierarchy. ## Step-by-Step Risk Assessment for Working at Height ### Step 1: Identify the Hazards The first step is to identify all the hazards associated with the specific work at height activity. For most working at height tasks, the hazards will include some or all of the following: - Falling from height (the primary hazard) - Falling objects striking workers below - Fragile surfaces (roof lights, asbestos cement sheets, corroded metal decking) - Adverse weather conditions (wind, rain, ice, lightning) - Unstable or unsuitable access equipment - Inadequate edge protection - Overhead obstructions - Proximity to live electrical services ### Step 2: Identify Who Might Be Harmed Working at height creates risks not just for the worker at height but also for workers and members of the public below. The risk assessment must consider both groups. ### Step 3: Evaluate the Risks and Decide on Controls For each hazard identified, the risk must be evaluated — considering both the likelihood of harm and the severity of the consequences. Working at height typically involves a high severity of harm (falls can be fatal), so even a low likelihood of a fall represents a significant risk. Controls must be selected following the hierarchy described above. The risk assessment must document why each level of the hierarchy was considered and, if a lower-level control was selected, why the higher-level control was not reasonably practicable. **For roof work:** Edge protection (guardrails and toe boards) should be the primary control. Safety nets or soft landing systems may be appropriate where edge protection is not practicable. Personal fall arrest equipment should only be used as a last resort. **For ladder work:** Ladders should only be used for work of short duration (no more than 30 minutes) or where the nature of the work makes other access equipment impracticable. The risk assessment must justify the use of a ladder rather than a more stable platform. **For MEWP work:** The risk assessment must address the risk of the MEWP overturning, the risk of the worker being ejected from the platform, and the risk of the worker being trapped between the platform and a fixed structure. **For scaffold work:** The risk assessment must address the risk of falls from the scaffold, the risk of falls through the scaffold, and the risk of the scaffold collapsing. ### Step 4: Record the Findings The risk assessment must be recorded in writing. The record must include: - The work activity being assessed - The hazards identified - Who might be harmed - The existing controls in place - The additional controls required - The residual risk after controls are applied - The name of the person who carried out the assessment - The date of the assessment ### Step 5: Implement the Controls The controls identified in the risk assessment must actually be put in place before work begins. A risk assessment that identifies the need for edge protection but does not result in edge protection being installed provides no real protection. ### Step 6: Review and Update The risk assessment must be reviewed if circumstances change — if the work changes, if the access equipment changes, if weather conditions deteriorate, or if an accident or near miss occurs. ## Common Mistakes in Working at Height Risk Assessments **Using a generic risk assessment.** A risk assessment that simply says "working at height — use appropriate PPE" is not suitable and sufficient. The assessment must be specific to the actual work being carried out. **Failing to follow the hierarchy.** Jumping straight to harnesses without considering collective fall prevention measures is a common and serious mistake. **Failing to address fragile surfaces.** Fragile surfaces are a significant cause of falls through roofs. The risk assessment must identify fragile surfaces and specify how they will be managed. **Failing to address adverse weather.** Wind, rain, and ice significantly increase the risk of falls from height. The risk assessment must address adverse weather and specify the conditions under which work will be stopped. **Failing to address falling objects.** Workers below a working at height activity are at risk from falling tools, materials, and debris. The risk assessment must address this risk and specify the controls — exclusion zones, netting, toe boards. ## Conclusion A risk assessment for working at height must be specific, must follow the hierarchy of controls, and must result in real controls being put in place before work begins. Falls from height are the leading cause of construction fatalities in Ireland, and the risk assessment is the foundation of the controls that prevent them. If you need assistance preparing risk assessments for working at height, or if you need a review of your existing Safety Statement and risk assessments, Safety Check can help. Contact us at [safetycheck.ie/contact](https://www.safetycheck.ie/contact). ## References [1] Safety, Health and Welfare at Work (General Application) Regulations 2007, Part 4. Available at: https://www.irishstatutebook.ie/eli/2007/si/299/made/en/print [2] Safety, Health and Welfare at Work Act 2005, Section 19. Available at: https://www.irishstatutebook.ie/eli/2005/act/10/enacted/en/html [3] Health and Safety Authority - Working at Height. Available at: https://www.hsa.ie/eng/your_industry/construction/safety_topics/falls_from_height/