This is just my opinion, but we are a fairly tough audience, and any H&S guy that comes on here has to put his subject across in a way that adds interest.
He could site real examples or give us for instances, but quoting legal test cases from 1934 and defintiions of competent persons is not the way forward.Who is competent to shut an airport for H&S, an airline pilot of thirty years standing or a recently qualified air traffic controller? Who is the most qualified, the most competent?
As regards ladders, a flat surface, 75degree angle, and an appropraite ladder safety device would seem a good basic starting point. Larger businesses and commercial work probably need more consideration, but if even the basics can't be gotten across i doubt more complicated situations would have been made any clearer for us.
When you by a ladder it will have warning on it about the angle, and of course ladder safety devices are always a good step forward. That is not just a starting point every should be following that without fail, and if you have an accident, because you failed to do that then you are at fault.
What I feel would be wrong is someone knocking over someones ladder with them on it, the ladder hitting a car and injuring the person on the street, and the window cleaner being fined because he was on the job for more the 30 mins, and depending on how you interpretate the waffle, he gets the blame.
Thats where you need clarity and not just that, I have one job with a small extention with a flat roof, which I use a ladder to get onto then clean a window above it, I dont secure it, or use laynards, its just one window, the extention is actually a curboard thing for tools so its only about 7 feet high. and not that deep so I wouldnt be the recomended distance away from the ladder. But I can assure you it is very safe.
Now it would be inpractical for me to take all the suggested saftey precautions in this intance, and infact would mean I spend so much more time on the roof and ladder fitting implementing these precautions I would argue that, the act itsself is just as dangerous as me just cleaning the one window in the first place.
What I am trying to say, is sometimes it comes down to common sense and rules can at times have you doing something senseless. Rules should only cover the musts, the never break rules, and those rules should be achievable, not rules that double the time of a job and make it not worth your while, rules that simple, sensable and practically achievable.
If we go by the figures of HSE we would never get in our car. Infact by the fatility rates we are in more danger driving to a job than we are 20 feet up a ladder cleaning a window. But you dont have HSE going round at every driver with a clipboard when they are doing reverse parks in tescos. Yes the things we do are dangerous and it is part of our job, we understand that when your are working at heights you must apply a hell of allot of common sense, and not to take unessasary risks but it only takes that one mistake.
I do believe there is a need for tighter legislation on the use of a ladder, but so far away from a ladder on a flat roof, and only so much time per job is crazy if that is how we are to interpretate that. These are not clear rules, they are not sensable, they don't help make our job safer and are inevitably not achievable rules that we are going to follow.
As for resonable alternative, and interpretating that to mean the if you can afford to go out and buy a WFP then you shouldn't be using a ladder. That is another barmy interpration of waffle.
Also you made a point to more safety precautions on commercials, but that is not our policy we treat every job with the same precautions regardless of size. You can injure yourself just the same on a small house as on a large commercial.
