Work at Height in Construction has some Special Complications.
https://www.change.org/good_practice_working_at_height_update_Steve_Tilling
Working at Height Good Practice Advocacy
Construction is Special. Ask that the GPG focus a section on the nuance of construction risks, particularly around the use of harness systems where environmental anchor provisions are not available.
Construction is rarely short-duration, rarely just a few individuals. Construction has structures that can be used as anchorages, but during construction, they may not be performant enough to actually work. So the timing of their usage matters. An arrested fall that causes a structure to collapse doesn't solve problems for anyone.
The GPG for working at height should support construction, especially as these complications more often require collective controls or passive protections during a lifecycle where the permanence of main anchorages is still being established.
Some other construction problems that are common.
Low fall clearances, underperforming anchor systems, anchors of convenience rather than performance, expectations that a harness worker will figure out where to connect rather than this being a planned and managed control, fall arrest systems without attenuation, particularly lanyards and lifelines, multi-elevation work crews, task control conflicts and priorities.
The GPG should restate that the duty to identify and manage risks is explicitly a PCBU duty and not a worker duty, so planned work with a harness must establish safe anchoring systems for that work. A worker with a harness should not be expected to figure it out absent guidance and approvals.
Provide guidance about the engineering minimums for safe anchorages, and the options to minimise forces where full performance cannot practicably be realised. These are known controls, but they are not widely known.
Provide specific guidance for the construction risks, including context and thresholds that are acceptable, require risk assesment and controls, or are straight up prohibited.
If you see benefit in this, let me be your voice and sign the petition to show support so I can advocate on your behalf.
https://www.change.org/good_practice_working_at_height_update_Steve_Tilling