Forklift trucks are intended primarily for lifting materials and not people. Historically though, they have been used in many warehousing applications in conjunction with working platforms to allow staff to be elevated for a variety of reasons. However, some 18 months ago the Health and Safety Executive introduced guidance that effectively outlaws working at height using forklift trucks and what is termed ‘non-integrated’ working platforms.
A non-integrated working platform is defined as an attachment for use in conjunction with a forklift truck to elevate people so they can work at height, that has no controls in the platform to control the platform’s lift height or move the truck. Both truck and platform movements are controlled by the forklift operator at ground level. Integrated working platforms are attachments with controls that are linked to and isolate the truck controls so that only a person on the platform can control the lift height of the platform and truck movements.
It is a concern that when drafting its PM 28 – Working Platform (non integrated) on Fork Lift Trucks guidance note, the HSE has sought to address a problem that doesn’t actually exist.
The UKWA has written to the HSE seeking some evidence that working at height using non-integrated platforms or cages is indeed more dangerous than using integrated products. So far, none has been forthcoming. In fact, the HSE tells us that, although there are no industry statistics, “anecdotal evidence” suggests non-integrated platform-related injuries are on the increase. UKWA has surveyed its members (leading third party logistics and warehousing companies).
More than 100 companies responded: none of them had ever had an injury as a result of using non-integrated cages at height, and 78 per cent continue to use that method to carry out stocktaking at height because it is impractical to use another mode.
Bizarrely, PM 28 does allow “occasional use” of non-integrated platforms for non-routine maintenance tasks such as the replacement of light fittings in high rise warehouses, checking on high-level damage to racking suspected of causing an immediate risk or assessing the condition of damaged roof lights, but only if these jobs are “not carried out as part of periodic maintenance operations”.
However, the guidance note also states that: “Routine or planned tasks particularly associated with production or pre-planned activities such as periodic maintenance or stocktaking, are not exceptional circumstances and are thus not examples of occasional use”.
I have little doubt that UKWA members will continue to be law abiding, however] UKWA will continue to press the HSE to alter this apparently pointless restriction.