CROSS Safety Report
Use of temporary barriers to control access to hazards
This report highlights the risks associated with the use of temporary barriers to control access to unsafe workplaces.
It discusses the issues when scaffolding is used as a barrier, and that this should only be considered for use as a short-term temporary barrier.
Key Learning Outcomes
For asset owners, contractors and managers:
- Be aware of your duty to ensure the health and safety of workplaces that are under your management or control (to any extent), including when temporary barriers are moth-balled or temporarily out-of-use, including the risk of access by unauthorised persons
- Recognise the importance of clear communications and good record-keeping with respect to any risk controls that have been put in place and ongoing review of those control measures
For structural design engineers:
- Understand the hierarchy of risk control measures and that eliminating or removing the hazard should be considered first, wherever possible, prior to considering other controls to minimise risks
- Recognise that the use of temporary barriers to control access to structural (or other) hazards is dependent on good record-keeping and is, therefore, an administrative form of control
- When carrying out any site inspection, undertake your own risk assessment and always ensure that there is safe access to the area to be inspected
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The reporter has been involved with a number of mining sites and port facilities where temporary barricades (e.g. using scaffolding) have been used to control risk due to structural hazards such as unsafe flooring, missing handrails, etc. In many cases, these barricades have been left in position for months or years and the reporter is concerned that this is not an appropriate long-term control for structural risks. The following examples are given:
1. A scaffold barricade was placed to prevent access to a corroded walkway. However, at some point in the following 12 months, the barricade was removed. During a subsequent site visit the reporter inspected the walkway from below and decided that, due to its poor condition, it required a closer and more detailed inspection. Whilst testing the soundness of the first-floor mesh panel from a ladder the mesh gave way and collapsed. Only the fact that the reporter was holding on to the ladder saved them from serious injury.
2. In this case the owner of a moth-balled plant requested that a structural engineer inspect a number of areas of the plant that had been barricaded off as structurally unsafe prior to the moth-ball process. However, no record had been kept of why the barricades had been placed. In some areas the reporter was able to identify structural defects that may have explained the barricade; however, in other areas, there was no obvious reason why the structure was not sound. It was therefore unclear whether the barricades had been placed incorrectly, or whether the reporter had missed an important issue jeopardising the safety of the structure and personnel.
Using the hierarchy of risk controls, many people assume that barricading would be a high-level control (equivalent to an engineered control) in that it prevents exposure to the hazard. However, barricading actually depends on an administrative control (which is at the low end of the hierarchy of risk controls) for its implementation. Usually, there would be some sort of “paper tag” system to indicate why the barricade had been put in position, and a record kept by someone somewhere that the barricade had been installed, both of which are error-prone administrative systems. For example, if the tag blows away or is damaged there is nothing to indicate the purpose of the barricade. With scaffold and other types of hard barricades, these tend to be removed for re-use elsewhere as part of general site clean-ups. This might explain what happened in example 1 above.
However, even if the tag remains in place, the reporter’s experience is that it usually does not contain significant detail about the hazard being controlled, leaving uncertainty in the future as to the nature of the hazard. This exposes personnel to hazards when trying to inspect or identify the problem and raises the risk that the issue could be missed and the barricade removed without addressing the underlying issue (as in example 2 above).
Discourage the use of temporary barriers
It is the reporter’s opinion that engineers and others involved in the operation and management of industrial and similar facilities should discourage the use of temporary barricading to control access to structural (or other) hazards and should encourage more direct (and appropriate) means of controlling these issues. These could include rectification of the original issue or installation of permanent handrails or guarding. If barricading is required, it should be considered to be a short-term administrative-type control only, until more permanent means of addressing the issue are implemented. Additionally, a clear reason for installing the barricade should be recorded somewhere easily accessible to other personnel, and someone made responsible for ensuring the barricade is inspected and maintained until the hazard is addressed permanently.
Expert Panel Comments
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Owners of assets have a duty to ensure the safety of these assets and the safety of anyone who might have access to them. This report highlights the importance of clear communications and good record-keeping with respect to any controls that have been put in place.
At the sites that the reporter describes it is very likely that there had been a safety management team with JSA (Job Safety Analysis) and SWMS (Safe Work Method Statement) and other similar administrative controls in place. However, as the reporter notes, records cannot always be relied upon, they are a low-level risk control at best, and may rely on retention of people and site history.
Owners of assets have a duty to ensure the safety of these assets and the safety of anyone who might have access to them
Always ensure a safe form of access
Ultimately, this report highlights that persons accessing a dilapidated structure have an obligation to themselves to ensure that the structure is in fact safe to access (noting that the person(s) with control and management of the site and/or the particular area also have this obligation). They should undertake preliminary inspections using a safe form of access or from a safe vantage point before entering any area that may potentially have hazards, structural or otherwise. If this is not possible, the matter should be referred back to the asset owner.
The risk of unauthorised access
Besides intentional and authorised access, there is always the risk that unauthorised persons may obtain access to structures. Therefore, removal and making safe is always preferable to precluding access and letting a structure continue to deteriorate as it will only become more expensive, dangerous, and time-consuming to rectify in the long term.
Scaffolding should only be used as a short-term temporary barrier
As the reporter notes, scaffolding should only be used as a short-term temporary barrier. The assumption made by scaffolding manufacturers and suppliers is that it is disassembled after use, inspected for damage and readied for re-deployment. This process does not allow for permanent or long-term installations as these pose risks the suppliers never considered, such as:
- Corrosion under long-term product build-up. This is especially prevalent on mine sites and port facilities.
- Internal corrosion not identified as the parts are not stripped and inspected as intended.
- Loosening of fastenings and couplings due to fatigue and corrosion.
Where scaffolding is used as a temporary short-term barrier, the following mitigating steps are suggested:
- Keep registers on-site of when the scaffolding was installed and ensure it is removed, inspected and rebuilt or replaced with permanent suitably-designed barriers.
- Keep scaffolding clear of any spillage encrustation.
- Avoid using scaffolding as a makeshift barrier in damp, corrosive areas or where there are dynamic loads present.
- Use a modified metal scaffold tag which includes the reason for the barrier, contact phone number of responsible engineer or inspector and the date of next inspection.
A risk assessment should always be undertaken to control a hazard or risk according to the hierarchy of controls. If a risk assessment determines that a control measure higher up on the hierarchy of controls (for example, a control measure that eliminates the hazard all together) other than a temporary barrier is reasonably practicable, then that control measure should be implemented.
A risk assessment should always be undertaken to control a hazard or risk according to the hierarchy of controls
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