Safety Statement for a Window and Curtain Wall Installation Contractor

What must a Safety Statement cover for a window and curtain wall installation contractor in Ireland?

Window and curtain wall installation is one of the most hazardous activities on a modern construction site. You are working at height, often on the external face of a building, handling large and heavy glass units, and working in close proximity to the building's structural frame. The risks are significant, and the Safety Statement for a window and curtain wall installation contractor must reflect that reality.

I have reviewed many Safety Statements for specialist subcontractors over the years, and the most common failing I see is a document that is too generic. It covers the standard hazards, ticks the boxes, and sits in a folder on the site cabin shelf. What the HSA wants to see, and what will actually protect your workers, is a Safety Statement that is specific to the work you do, the equipment you use, and the sites you work on.

This post covers the key hazards that a Safety Statement for a window and curtain wall installation contractor must address, the legal requirements under Irish law, and the practical steps to make your Safety Statement a working document rather than a compliance exercise.

The Legal Requirement

Under Section 20 of the Safety, Health and Welfare at Work Act 2005, every employer in Ireland is required to prepare a written Safety Statement. The Safety Statement must be based on a risk assessment of the hazards associated with your work activities, and it must specify the protective and preventive measures taken to control those hazards.

For a window and curtain wall installation contractor, the Safety Statement must also comply with the Safety, Health and Welfare at Work (Construction) Regulations 2013, which impose additional requirements on contractors working on construction sites. In particular, the Construction Regulations require that your Safety Statement is compatible with the Construction Phase Safety and Health Plan prepared by the PSCS, and that your workers are aware of the relevant parts of that plan.

Key Hazards for Window and Curtain Wall Installation

Working at height: This is the primary hazard for window and curtain wall installation. Workers are typically operating from mobile elevated work platforms (MEWPs), suspended access equipment, or internal working platforms at significant heights above ground level. The Safety Statement must address the selection, inspection, and use of access equipment, the competency requirements for MEWP operators, and the procedures for working safely at height in adverse weather conditions.

Manual handling of glass units: Large glass units can weigh several hundred kilograms. The Safety Statement must address the use of mechanical handling aids such as vacuum lifters and glass trolleys, the procedures for manual handling where mechanical aids cannot be used, and the competency requirements for workers involved in glass handling. The Safety, Health and Welfare at Work (General Application) Regulations 2007 require that manual handling risks are assessed and controlled.

Fragile surfaces: During installation, workers may need to access areas adjacent to fragile surfaces such as roof lights, fragile cladding panels, or partially installed glazing. The Safety Statement must address the identification of fragile surfaces, the use of crawling boards and other protective measures, and the procedures for working in proximity to fragile surfaces.

Falling objects: Glass units, tools, and fixings can fall from height during installation, posing a risk to workers below and to members of the public adjacent to the site. The Safety Statement must address the use of exclusion zones, netting, and other measures to prevent falling objects, and the procedures for working over occupied areas.

Structural loads: Curtain wall systems impose significant loads on the building's structural frame. The Safety Statement must address the procedures for verifying that the structural frame is capable of supporting the curtain wall system before installation begins, and the coordination arrangements with the main contractor and the structural engineer.

Sealants and adhesives: Many window and curtain wall systems use sealants and adhesives that contain hazardous substances. The Safety Statement must address the Control of Substances Hazardous to Health (COSHH) assessment for these materials, the use of personal protective equipment, and the ventilation requirements for areas where sealants and adhesives are applied.

Temporary works: During installation, temporary supports, props, and bracing may be required to hold glass units and curtain wall components in position before they are permanently fixed. The Safety Statement must address the design, installation, and removal of temporary works, and the competency requirements for persons involved in temporary works.

What the Safety Statement Must Include

In addition to addressing the specific hazards above, a Safety Statement for a window and curtain wall installation contractor must include the following elements as required by the Safety, Health and Welfare at Work Act 2005:

Company policy statement: A signed statement from the most senior person in the organisation committing the company to the management of health and safety.

Organisational responsibilities: A clear description of who is responsible for health and safety at each level of the organisation, from the managing director to the individual worker on site.

Risk assessments: Written risk assessments for all significant hazards associated with the company's work activities. These must be specific to the work carried out and must identify the control measures in place to reduce risk to an acceptable level.

Safe systems of work: Written procedures for high-risk activities, including working at height, glass handling, use of MEWPs, and working with hazardous substances.

Emergency procedures: Arrangements for dealing with accidents, fires, and other emergencies, including the names of first aiders and the location of first aid equipment.

Welfare arrangements: Details of welfare facilities provided for workers, including sanitary accommodation, rest areas, and drinking water.

Consultation arrangements: How the company consults with its employees on safety matters, including the appointment of a safety representative where required.

Training records: Evidence that workers have received the training required for their roles, including MEWP operator training, manual handling training, and any other task-specific training.

Making Your Safety Statement Work on Site

A Safety Statement that sits in a folder and is never referred to is worse than useless. It gives a false sense of security and will not protect you if the HSA comes calling. To make your Safety Statement a working document, you need to:

Bring it to every site. The Safety Statement must be available on site for inspection by the HSA, the PSCS, and your own workers. Keep a copy in the site cabin and make sure your site supervisor knows where it is.

Review it before starting each new project. Every site is different, and the hazards on a high-rise curtain wall project in Dublin city centre are not the same as those on a low-rise residential development in Wicklow. Review your Safety Statement before you start each new project and update it to reflect the specific conditions of that site.

Use it as the basis for your Method Statements and Risk Assessments. The Safety Statement sets out your general approach to managing safety. Your Method Statements and Risk Assessments for specific activities should be consistent with the Safety Statement and should reference it where appropriate.

Train your workers on it. Every worker employed by your company should be aware of the relevant parts of the Safety Statement. This does not mean reading it out to them word for word, but it does mean making sure they understand the key hazards and control measures relevant to their work.

Conclusion

A Safety Statement for a window and curtain wall installation contractor is not a generic document. It must reflect the specific hazards of your work, the equipment you use, and the sites you work on. If your Safety Statement was prepared years ago and has not been reviewed since, it is almost certainly out of date and may not reflect your current work activities. Contact Safety Check for a review of your Safety Statement and practical advice on bringing it up to date.