EWP use by contractors
Janet Mary Houston
Would be grateful for any insights into a recent conundrum ... We have engaged a subcontractor to do paint on a high commercial building (Work Safe have been notified). Our Subcontractors have hired a knuckle boom EWP and scissor left to assist in the project. I went on site yesterday to ascertain all was in order and found neither pre-start checklist on either plant had been completed, nor that any of the workers had qualifications to operate the vehicles. According to EWP Association and Best Practice Guidelines for Mobile Work Platforms - even though licensing is not mandatory in New Zealand, machinery operator training most certainly is. Section 6 of the guidelines states the following MEWP operator training should cover at least:
getting to know the operator’s manual
hazard management – identifying, assessing and controlling hazards
equipment and safety features
prestart (pre-operational) inspection
use of logbooks
control facilities and positions
limits of the machine – rated capacity, wind rating – and machine weight
moving and positioning a MEWP
transporting – including loading and unloading (where required)
working near overhead power lines
using a harness
refuelling tools and battery charging
reporting problems and incidents
emergency retrieval systems
emergency rescue plan.
When I spoke with the Project Manager, he advised that his employees had operated EWP's for over 20 years and the Hire company does not require qualifications. (I've checked with a couple of Hire Companies and this is absolutely the case, all you need is money to hire a EWP or scissor lift - not even a drivers licence).
My question is if our subcontractor can not prove that the employees operating the EWP have had training in the above topics, then they should not be operating the plant ... am I right in that? I admit I was surprised to learn you can operate these without qualifications, in most places I've worked, staff are put through NZQA EWP training so this has never arisen.
Any insights would be very gratefully received..
Janet Mary Houston
Hi, I agree those operating a EWP should be trained but its not uncommon to come across those who haven't been as this is a relativey new requirement. Pre-starts should always be done - no excuses!
At the end of the day, it all comes down to managing risks and what is reasonably practical, and requiring evidence of appropriate competence to operate any equipment safely would be reasonably practical.
There are still many gaps in NZ's system, so PCBUs cannot expect to rely entirely on other PCBUs to hold up their end of the work - for many people, if they can get away with doing less, they will, and if they have successfully used those EWPs without any formal systems or qualification, they will just keep doing it until someone pulls them up on it. Since all PCBUs have shared responsibilities, either insist on appropriate risk management systems and practices, or find a contractor who will do the right thing. If a PCBU knowingly accepts contract work from a contractor who doesn't manage the risks, you are effectively taking on those risks yourself. In addition, every PCBU that allows the requirements to slip just makes it that much more difficult to manage other aspects of contractor work, making a rod for their own back.
There is no legal requirement for formal qualifications for EWPs but standard practice for all reputable organisations is rapidly becoming: "If there is a qualification available then operators must have it".
During site audits I'm happy to allow years of experience (competency) to take the place of an operator's ticket but I do want to see pre-starts, TAs and a filled in log book. All too often, especially with internal work like ceiling installation, people just hop on and use without any pre-start risk assessment or hazard id whatsoever. Not acceptable.
Hi Jan, i have come across this dilemma as well and agree that this is a case of mitigating risk for your company, at the end of the day. We have a process under our contractor management policy that states that all contractors must prove they are 'competent' to operate machinery or equipment, if at risk work is involved (and therefore a list of "at risk" work is defined). If at risk work is to be carried out, a safety plan must be completed which covers off the methodology, who will be on site plus their 'credentials', what type of equipment is going to be used etc. We subsequently wouldn't engage a contractor who could not provide these details.
There are some large companies in New Zealand who have these policies in place and therefore contractors who cannot provide these 'credentials' would not be able to step onto their sites. Contractors who do not feel they need to be formally trained (particularly if they are carrying out "at risk" work) are a risk to themselves and everybody working around them. I often hear "ive been doing this job for 20 years and i've never had an accident". In my humble and personal opinion these people are the biggest risk.
External training can be a big, if not substantial, cost to any business and some small businesses struggle with this. I hear this often from contractors. At the end of the day...training is a good investment and at the very least 'reminds' people how and why they should be working safely and of their obligations under the HSW Act.
I make a point of obtaining evidence of training and licences before engaging contractors.
I recently had a similar situation to yours when trying to get a warehouse roof fixed. I choose not to engage the first three contractors I contacted because they either did not have up-to-date training or they had the training but were unwilling to work with me on a risk assessment. Contractor #4 had experience, was prepared to do a risk assessment and agree to a safe work plan as well as refresh his training prior to doing the job!
In terms of EWP training, the NZQA outline recommends refreshers every three years with US23966 "Describe types of elevated work platforms" being a prerequisite for specific work platform training (US23960 for scissor lift and US23962 for self-propelled boom lift).
In addition, self-propelled boom lifts require the use of a safety harness which is covered by US23229 "Use a Safety Harness". This is because boom-lifts can catapult people out.
I found the
website very informative. This organisation aims "to promote and support best and safe practices in the use and maintenance of Elevating Work Platforms".
I agree with Carolyn; by ensuring the contractors have training, the risk to your business is reduced. And yes, anyone telling me that they've been doing this job for 20 years etc is of concern and refresher training can help address any complacency.
All the best
Hi Janet, In alignment with what Michelle is saying, there are unit standards that can be obtained surrounding working with EWP's. While I appreciate it is not mandatory, it would be best practice to ensure staff who operate this high risk bit of kit have training and can certainly demonstrate their understanding not only of the machinery and the risks involved in its operations but of hazard identification within the worksite; Part of this would be pre start checks. It's good the company has been working with EWP's for 20 years so should be very familiar in their operations and should not have a problem documenting their competencies. If they do have an issue with this they may be more of a risk to your company than you would like. As a PCBU under the new law we must not only show our people have been trained but they are competent to use the plant/equipment aswell. This would be no different for the subcontractor you are using and I would seek evidence of a satisfactory H&S system before they are engaged to do the work
The previous comments have covered this really well - great advice.
I'd would add, that where a good practice guideline exists (and has been around for several years I might point out), that states what 'should' be done (as you have so clearly referenced in the initial post), should anything go wrong, a PCBU would be hard pressed to stand up in court and justify it not being reasonably practicable to do so. The construction industry largely accepts that unit standards to MEWP's are a requirement, so the fact that it's not explicitly legally mandatory is not relevant.
Plus, how can you know the quality of the 20 years of experience? Without reputable training, the decades of 'experience' could be worse than being without the experience at all (bad habits, complacency etc.)! The fact that they've not carried out the pre-start checks could give a pretty good indication of the quality of their experience, or their normal practices at least.
Lastly, MEWP training is not very expensive. I cannot imagine any decent organisation failing to see the benefit as warranting the cost.
Knuckle booms are a differing breed from a scissor lift both referred to at times as EWPs. They can be confused especially in regards to training requirements. With a knuckle boom there is a higher risk of falling out of the basket, and definitely use of a harness is required. With Scissor lift the risk is not as extreme (although still risk involved). With both EWP types operators need to understand the precheck process..if they don't get that, to me raises red flags to letting them onsite. At least a JSA should be presented for a scissor lift or knuckle boom. Prefer quals, more so if knuckle boom. But if needed walk away if you are relying on the " we've been doing this for xx years" ..it just doesn't cut it anymore. (My 2 cents ☺
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