Can you explain . . . . ''Comparing window cleaning to painting and decorating is like comparing apples to a spade. It's a metaphor that just won't work. '' . . . Both trades are up and down ladders like a you know what all day, its just that painters may stay in one position longer which according to this forums posts is even more against the way the regs here have been interpreted.
I think what Tosh had in mind here was that for window cleaning, a practicable alternative to work at height exists - WFP. Not only that, but even long before the WAH regs were around, window cleaners were adopting it for economic as well as safety reasons.
No such practical alternative exists for painters & decorators, therefore (though I am no expert on painting & decorating) the use of work at height could be justified.
If I am advised the wah rules are as per your interpretation I would have to conform immediately and give up work as the alternative is mobile scaffolding which is not only cost prohibitive but non workable in 90% of jobs.
The alternative must be practical, and as you say this situation would not be. It would be easy to justify the use of work at height for painting, as their isn't a practicable alternative. Also, using a scaffold tower is not avoiding working at height. WFP is.
However, could you argue that there isn't practicable alternative for a window cleaner to use? No, because we have WFP.
If the particulars of the building worked on mean that WFP is not practical (ie access over a flat roof is needed, or work on the upper floors of a skyscraper) then, again work at height could be justified.
and I take it you would be quite happy for me to be up and down a ladder on the outside of your house all day as a painter but not as a w/c-er - there is no diffference! Fact!
The difference is, there is no generally accepted method of painting high up without working at height, but there is for window cleaning.
As Tosh said, rightly in my opinion, painting and window cleaning is not comparing like with like.
the wah regs do not single out trades, they are a general guide to best practices for those who work at height ie one use being ladders
The Regulations are not merely a guide to best practice, they are the law, and you can be prosecuted for breaching them. You are quite right in that they do not single out individual trades, however, the guidance notes to the consultation document
do specifically mention window cleaning in several places. Among those it says that pole cleaning systems may be used.
-Philip
