Coaling and watering - working at height

Apologies in advance if his is in the wrong place

The 4150 Fund's November 2022 restoration update included the following:

[We] were looking at where it could be possible to fit a low level filler for the water tanks [..] All of this because it may be against working at height regulations in the future for footplate crew to climb up onto the tanks or tenders.

http://4150.org.uk/news/4150_nov22.html

I wouldn't read too much into one report but are other owning groups or railways thinking the same way? Should this come to pass IMO it would be a shame not to see watering from towers. Would another way be to have fixing points on the loco tanks/tenders, and harnesses?

 

Don't most mainline approved locos have low level filling points?

 

As far as I know they all do to avoid the risks of contact with OHLE.
Likewise coal cannot be trimmed forward under the wires.

Cheers, Neil

 

I suspect that ground level filling will become the norm within 5 years. It has long been a requirement on NR steam operations. Some heritage line locos are already fitted for this. Working at Height is a subject under close ORR scrutiny.

Harnesses are a non starter as they need the wearer to fall some distance before they arrest the fall and attaching them in this context is problematic.

If you have ever climbed up onto a BR Std/Bullied, other high tender or tank loco you will realise that there is little or nothing preventing a fall.

I don't want to see the demise of working water columns but I suspect this is inevitable when other means are fairly easily possible.

This does'nt address the issue of cleaning & other steam loco tasks which involve working at height which will no doubt provide further challenges.

Before anybody complains about "nanny state", "no need we have always been fine" etc consider how you would feel personally being interviewed under caution as part of a likely prosecution under existing H&S legislation. Already a real situation.

 

I might have more respect for strict interpretation of Working at Height and other such rules if they were applied consistently. But I often see men working on house roofs with no sign of any protective measures, and when scaffolding was removed from my house after it had been needed for some work, the men demolishing it were climbing around in a frightening manner.

 

The Regulations do apply consistently - the onus is on those carrying out the work to adhere to the Regulations, devise and implement a safe system of work.


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At which point this layman struggles somewhat with such wide variation in the implementation of "safe" systems of work between and even within industries. While he's at it, he also wonders - with full respect to those who do clamber on tanks - what is leading to this change in what is considered legally acceptable when the regulations are nearly 20 years old.

 

Please explain what you mean by "legally acceptable".

 

Depending on context, would not result in enforcement under HASWA or expose the organisation to having to pay damages.

 

I suspect that either someone has fallen off somewhere or alternatively it has been picked up somewhere as part of a wider inspection process.

It reminds me of a time a fair few years back when the directors at my employer were made aware that they could personally be held liable to corporate manslaughter charges if something dreadful happened, never seen quite so much cash thrown at H&S and making sure paperwork was in place to risk assess just about everything.

 

Do they though, because whilst for example when our paint gang were spraying an aircraft from a cradle they had to be attached by a significant harness, although some of that may have been because if there was afire they were supposed to leap off the cradle and hope the inertia reel will get them to the ground in one piece.
However using the roofing example, like most towns there have been lots of new builds around here and I have NEVER seen a roofer with any form of harness or other safety equipment, not even hard hats. I am also unsure how you would construct some harness set up for the way roofers have to work, as but one example.

 

The regulations do apply consistently (note the regulations do not prescribe how you do a particular task, that is up to the employer who is responsible for ensuring a safe system of work). What is inconsistent is how different folk approach their responsibilities. Waiting for something to go wrong and then fixing it is not a good strategy.

 

ORR have placed the heritage railway sector "on notice" that this is an area of priority for their inspectors. Why? At least one individual has suffered life-changing injuries at a heritage railway following a fall from a loco whilst preparing it, and there have been a number of reported near-misses or obviously dangerous occurrences.

 

Sorry to correct you there but that is not true. While most locos that operate on Network Rail have lower tank fillers, and have had them for years, that is for convenience and not due to any legislation. It makes the job so much easier if you are filling a tender from a hydrant or a road tanker. But I know of two Network Rail locations where water cranes are regularly used. Sure there are Working from Height risks involved, this is why you have method statements and risk assessments for the tasks concerned.

Peter

 

Harnesses DO NOT require you to fall some distance to be effective- some systems would potentially mitigate the consequence of a fall, but there are multiple modes for use.

That is dependent on the way the harness is used and what work methodology is implemented.

Work restraint, using a harness would prevent you reaching an unprotected edge by securing personnel either on a fixed, or adjustable lanyard system but allowing them to move along the edge, not in suspension.

Work positioning would imply that the harness based system is being used to position the worker with a system under tension, again not allowing a fall.

Fall arrest, either inertia system based or using a fall arrester would potentially allow a fall from height and is a injury/fall mitigation system.

What this all comes back to is being reasonably practicable and making good, reasoned informed judgements about risk and risk management.

This is nothing new, or different to many other industries- agriculture being the one that immediately springs to mind with regard to climbing on machinery using steps/ladders/catwalks.

Is it a reasonable thing to consider having a ground level filler as an option- yes absolutely, it's already used by mainline operators as an option- if there was the option to fill-up easily from ground level from a hydrant on the MPD why wouldn't you?

But is it reasonably practicable to equip every preserved loco, and watering location to enable the same- I very much doubt it.

Would I consider potentially training people to a basic level of working at height......absolutely!

 

In fact.....along this subject, and potentially more concerning in many ways.

How do railways consider confined spaces....

Boiler work, water tanks?

 

Confined spaces is already becoming an issue. Entering fireboxes already has multiple procedures and are due to get tighter. Temperature and air monitoring equipment for fireboxes are to become standard as to when it’s safe to enter a firebox. The days of expanding tubes with a fire only just dropped are long gone.

 

I will take your confined space and raise you (no pun intended). Prepping a loco, working in a pit (confined space), On a step ladder (WaH), Climbing up into the valve gear (Confined space). Combine these with COSHH for the oils, slips trips and falls. The same then applies to disposing a loco. Working in a pit (CS), Hot ash (risk of burns), The gasses from the ash lying in the bottom of the pit.

However much we like the rose tinted view. Times they are a changin'. Chris, you mention equipping every preserved loco and location with the facilities for ground level filling. Most of the SVR tender loco fleet have it already in place. 4930, with the new tender tank has had this fitted during its overhaul. The only tender loco without a ground filler, and Im open to correction is 600 Gordon. Tank engines would need some thought as to achieving a good balance in the tanks and a suitable location on both sides.
There has been a trial conducted where a tender tank was filled from a column, that water transfered to another loco so as not to waste water and then the tank refilled by 4in hose and a pump. Both were timed and the result was the ground filler took just over 5 minutes more than the column. What footplate crew wouldnt mind an extra 5 minutes break?

Going back to your previous post regarding Harness wearing. There is a misconception about wearing a harness. The harness doesn't prevent the injury or worse. They are bloody uncomfortable to wear and that is deliberate so you dont wear them for long periods. There are a vast number of different fall arrest systems available, each essentially do the same job. An intertia block doesnt allow the person to "fall" it is designed to stop you falling. They take very little to activate.

Reasonably practicable and Reasonably foreseeable. Risk Assesments and SSOW are what the ORR and HSE are drilling down on. Having the correct policy documentation as well.