Working at Height Training in Dublin: Employer Duties in Ireland

Working at height training is often discussed as if it were a single course, but the Irish rules are written around planning, risk assessment and preventing falls. Training and instruction appear within that framework. If you manage people in Dublin who use ladders, access platforms, scaffolds or roofs, this article sets out what the Safety, Health and Welfare at Work (General Application) Regulations 2007 say. For the control measures themselves, see our working at height regulations and hierarchy of control guide.

One point of accuracy first. Work at height is covered by Part 4 of the 2007 Regulations, which runs from Regulation 94 to Regulation 119. On the Revised Acts site, Part 4 is not divided into chapters. The sources used here are the Revised Acts pages for individual regulations, the Irish Statute Book, Citizens Information and a Health and Safety Authority (HSA) guide published in December 2007.

What counts as work at height

Regulation 94 defines work at height broadly. It means work in any place, including a place at or below ground level and a place reached in the course of obtaining access or egress (other than by a staircase in a permanent place of work), from which an employee could fall "a distance liable to cause personal injury" if the measures required by Part 4 were not taken.

The HSA guide adds that the Regulations set no minimum height, and that even short falls can cause serious injury. Its examples include using a stepladder in a stockroom and working on a lorry. That is a useful reminder for Dublin offices, shops and warehouses where nobody would describe the job as "working at height".

Planning, supervision and risk assessment

Regulation 95, as read on the Revised Acts site, requires the employer to ensure that work at height is properly planned, appropriately supervised and carried out in a manner that is, so far as is reasonably practicable, safe and without risk to health. When planning, the employer must ensure that:

• the selection of work equipment is in line with Regulation 100;
• an appropriate risk assessment and safety statement under sections 19 and 20 of the 2005 Act are prepared; and
• a plan is prepared for emergencies and rescues.

The risk assessment is therefore the starting point, and the measures chosen must take account of it.

Avoiding and preventing falls

Regulation 98 is titled "Avoidance of risks from work at height". Taking account of the general principles of prevention in Schedule 3 to the Act, it requires employers to:

• ensure work is not carried out at height where it is reasonably practicable to carry out the work safely otherwise than at height;
• where work at height is necessary, take suitable and sufficient measures to prevent an employee falling a distance liable to cause personal injury, for instance by working from an existing place of work or using an existing means of access where that can be done safely, or otherwise by providing suitable work equipment that complies with Regulation 100; and
• where those measures do not eliminate the risk of a fall, provide sufficient work equipment to minimise the distance and consequences of a fall and provide "such additional training and instruction or take other additional suitable and sufficient measures" to prevent, so far as is practicable, a fall.

This last point is the clearest reference to training in the regulations we read. It is a fallback layer in the sequence, not the first line of defence. The HSA guide summarises the order as avoid, prevent, then mitigate, and says collective protection such as guard-rails and scaffolding should generally take priority over personal protection such as harnesses.

Places of work, checks and weather

Several other regulations bear on day-to-day practice:

• Regulation 96 requires the surface and every parapet, permanent rail or other fall protection measure at a place of work at height to be checked visually before use and at appropriate intervals during use.
• Regulation 97 requires work at height to be carried out only when weather conditions do not place the safety and health of employees at risk.
• Regulation 99 ("Protection of places of work at height") requires, among other things, that the place of work is stable and of sufficient strength, has suitable and sufficient edge protection, and has no gaps through which an employee or material could fall.

Where the general training duty applies

Alongside Part 4, the Safety, Health and Welfare at Work Act 2005 sets the general training duty. Section 8(2)(g) covers the information, instruction, training and supervision necessary for employees' safety, health and welfare. Section 10, as read on the Revised Acts page, requires training to be given on recruitment, on a change of task and when new work equipment or systems are introduced, to be updated for new or changed risks, and to be given in a form reasonably likely to be understood. Citizens Information (page last edited 25 August 2022) says employers must provide instruction and training and allow paid time off for safety awareness training.

The HSA guide says workers need adequate instruction and, where necessary, training on their equipment, that supervision should match the risk and the experience of the people involved, and that site-specific briefings may be needed even for trained workers. It also says scaffolds should be designed and erected by competent people. If your Dublin team works on construction sites, our guide to Safe Pass in Ireland may also be relevant.

Ladders

According to the HSA guide, ladders are permitted only where a risk assessment shows that more suitable equipment is not justified, which the guide ties to low risk and short duration, and it adds that ladders are not suitable for strenuous or heavy work. It says ladders are not suitable for work where they are in one position for 30 minutes or more, and recommends three points of contact and going down and moving the ladder rather than over-reaching. These are statements from guidance rather than from the Regulations themselves, and the guide describes itself as not being a legal interpretation.

A practical approach

These are our suggestions, not legal requirements:

• List every task where someone could fall, including stepladder use in stores and access to roofs or mezzanines.
• For each, record why work at height cannot be avoided, and which equipment was chosen and why.
• Write the rescue plan down and make sure the people involved know it.
• Treat training as the layer that supports your equipment and supervision choices, and keep a record of who was instructed on what.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Is there a minimum height at which the Regulations apply?

The HSA guide says the Regulations set no minimum height. The definition in Regulation 94 turns on whether an employee could fall a distance liable to cause personal injury, including at or below ground level.

Does the law require a specific working at height course?

The regulations we read do not name a particular course or certificate. Regulation 98 refers to additional training and instruction where fall risk is not eliminated, and the 2005 Act requires the information, instruction, training and supervision necessary.

Are ladders banned?

No. The HSA guide says ladders may be used where a risk assessment shows that more suitable equipment is not justified, for example because of low risk or short duration, and that they are not suitable for strenuous or heavy work.

Do I need a rescue plan?

Regulation 95 requires that a plan is prepared for emergencies and rescues when planning work at height.

Are harnesses always the answer?

The HSA guide says collective protection such as guard-rails and scaffolding should generally take priority over personal protection such as harnesses.

Your own risk assessment decides the right measures, so check the primary sources for the detail that applies to your work.