Collective Controls don't prioritise well when using the hierachy of control.
Working at Height Good Practice Advocacy
Ask that the GPG recognise that most working-at-height controls are collective and include multiple elements of the hierarchy of control and, as such, the hierarchy of control is a poor way to prioritise working-at-height controls and leads to confusion or dismissal of the guidance.
Set prioritisation based on risk, rather than the hierarchy, ideally with a simple comparator, such as man-hours at risk vs man-hours protected across the lifecycle of the risk being managed.
With this, the metric is clear, and the data for the metric is easy to infer and communicate, and lastly the prioritisation is based on the balance of risk, as it should be.
Within this, the hierarchy of control can be sensibly applied to configuring the collective control. Ideally, include as many elements as possible.
Deploying harnesses anyway -
--Eliminate dropped objects where possible
--Substitute when the opportunity is available to do so
--Isolate risks within your control scheme if not everywhere
--Recognise the engineered controls you already use, and look for innovative solutions to isolate or substitute your risks
--Provide knowledge and signal above what the default expectation would be.
--Use PPE as often as possible, because if the rest fails, your PPE is the last barrier.
Examples
--Scaffolding needs PPE to be build and removed.
--MEWPs require PPE to use and include engineered controls such as limit switches.
--Guardrailing must be installed by a lower control
--Even PPE on a roof requires anchor systems (Engineering controls) & Training (Admin Controls)
Let lowering risk be the recipe, and the hierarchy be the ingredients and explain the collective controls in those terms, where the hierarchy represents optimisation of element selection, rather than the primary filter.
Don’t make it hard to comply with unrealistic binary choices; make it easy by showing how the cake is made, and what it is made of.