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Wearing a hard hat on a roof.

prothos 4 months ago   Reply

Hi there

It has been brought up whilst on site numerous times, and no one is able to agree or give a straight answer. 

Is there health and safety legislation that states roofers MUST wear a hard hat while working on a roof. I understand this is a broad question as there could be a few variables, so below is the scenario to answer to, if you would.

  • An operative enters a roof via a scaffold whilst wearing a hard hat
  • He/she enters the roof and takes off the hat at the exit of the roof
  • The operative is working on a roof with nothing overhead such as; cranes, plant or air conditioning vents

 

Surely the above would merit a no hat policy for the operative as there is nothing gained from wearing a hard hat?

Thanks for your responses. Tom

prothos 4 months ago   Reply

Any advice would be appreciated, or advice on the correct body to approach so I can get the correct answers...

SteveCITB 4 months ago   Reply

There are no 'regulations' specifically about keeping your hat on in all circumstances on a roof. The closest you will come to this are the CDM Regs (Part 4, 2015) and Management Regs 1999. 'All risks must be assessed and managed'

Where there is no risk of head injury, proportional H&S says there is no need for a control, and the risk assessment should reflect that is there is no significant risk of injury.

Your policy or employee charter may of course, say different, but this is something to take up with the board. Too many companies rely on PPE as a first line of defence when this should not be the case (see Schedule 1, Mgmt Regs for the General Principles of Prevention).

SteveCITB 4 months ago   Reply

No regs directly relate to the idea that PPE must be worn on all roofs at all times.

Management Regs state that all risks must be assessed and controlled. If there is no discernible/significant risk, then this should be reflected by the risk assessment and the controls set to not include this at the company's discretion.

Companies may have a policy that says "wear all PPE at all times" but this is not the proportional response advocated by the HSE. If there is no risk/virtually no risk of head injury, you're unlikely to need a hard hat. It's a common sense thing, and company policies on such things must be tweaked accordingly if they are not reflective of common-sense safety.

andrew.kaye 4 months ago   Reply
Hi I have come across this before and it really comes down to site policy. I have been to sites where HH, HiVis, gloves, glasses, boots were mandatory for everyone all of the time. However Steve is correct when advocating proportionality. Agreed HH should be worn below and whilst accessing scaffold however if you move away from insisting they are worn all the time (introducing flexibility) then you should also consider that complacency can creep in and someone may forget to wear their hat when they should be.
Liz Bennett 4 months ago   Reply

Andrew is right. The Principal Contractor is required by CDM 2015 to make, and ensure compliance with, the site rules. Most large contractors will require PPE on all sites to protect the business from poor behaviour of the few on some sites. It can have unintended consequences for a few but generally is because most of us will forget at some stage when we should be wearing them. 

The best approach may be to consider them a badge of office and respect for each other. Nobody wants anyone to get hurt and industry works hard to find the best solutions. You are likely to find that if you are really positive about trying to do the right thing then this will get noticed and is good for your bottom line. Good luck.

PS I get furious sometimes with one size fits all solutions but I think this time the battle is unlikely to be won so suggest you grumble a bit, grin and move on. Make it work for you.

mjmcq 4 months ago   Reply
Whilst there are no Regs that state, hard hats must be worn on a roof, I would always advise hats to be worn as there is potential for an injury from materials sliding down the roof and striking a person below on the head. I know this from experience when I was younger. Or the operatives could fall and strike their heads. If you look at HSE, "Hard Hats on Construction Sites", it states:Even on a well run site head injuries can still happen so hard hats should be worn. It also states: There is nearly always a risk of a head injury on a construction site. For example: * Objects falling or being thrown from height * An unprotected end of a scaffold pole * Projections not being capped e.g. studs * Insufficient headroom on a scaffold If this happened and someone was injured, the HSE would question why Hard Hats were not required. The difficulty is controlling the wearing of Hard Hats when they exit the roof as well. I have seen operatives come down off a roof and they have left their hats up there. They are then at risk when climbing back to fetch it or when their colleagues throw it down. Whilst a blanket policy isn't always ideal, its a lot easier to manage and control.
Alasdair Revie 4 months ago   Reply

Down to interpretation of The Construction (Head Protection) Regulations 1989.

SteveCITB 4 months ago   Reply

The 1989 Head Protection Regulations were revoked by the 2007 CDM Regulations.... which themselves have now been replaced by the 2015 CDM Regs.

Chris 4 months ago   Reply

The PPE regs look after hard hats not CDM. I would suggest that you look at the activity. My roofers wear bump caps as there is no risk to anything falling on their heads whilst on the roof carrying out their work. They sometimes have to go under some plant and the hard hat restricts them but as the risk is a bump the caps are fine. 

Allan 4 months ago   Reply

The reason you need to wear a hard hat is to protect you from falling objects . If there is nothing above then no risk

Although a hard hat did save my life once they can cause quite a lot of injuries albeit minor ones. I have had to investigate more accidents  were people cant see what is above them because of the peak., especially climbing ladders. Most injuries have been to the neck were the individual , when going up a ladder say, hits the top of their hard hat causing sever neck injuries. Overall I would saywear one regardless as it is a good habit to get into and ones head makes a convenient place to store your hat !

Allan

 

Frank 4 months ago   Reply

 

Ø  One solution would be to introduce a hard hat exemption policy. For example;

Ø  Exemption from Use

Ø  You may be exempt from the requirements to wear a hard hat, however, you will be required to obtain a Certificate of Exemption;

Ø  You will receive a wallet-sized card stating your certification. You must carry this card with you at all times.

Ø  Basically, if your head meets the Government standards for head protection you do not need a hard hat. Contact your Safety Advisor to schedule you for testing at the earliest possible time.

Ø  The testing procedures consist of the following:

Ø   A 24-hour water immersion test. Maximum permitted absorption is 0.5% by weight. The company will supply free breathing air.

Ø  An impact test - while laying horizontally, with your head resting on a 0.75 steel plate, an eight pound steel ball will be dropped several times from a height of 5m. You will pass if there is no damage to your head.

Ø  Your head will be subjected to a variety of acids, gases, solvents, oils, and industrial gases. You must pass with no deformities or obvious colour change.

Ø  To determine fire resistance, your head will be subjected to a propane torch for five minutes. If it is only slowly burning, you will achieve only a class A or B rating. If, on completion, there are any holes in your head, you will be restricted to a B rating.

Ø  For the final test, you must sustain 2,200 volts AC, 50 Hz, for three minutes with leakage current not exceeding 9 milliamps. Breakdown threshold has been established at 300,000 volts.

Charlie Says 4 months ago   Reply
Hard hats are to protect a vulnerable part of your body (the head) from impact, and not just from falling objects. If the operative had impacted with the hard hat sufficiently to cause neck injuries just imagine how much more severe the injuries would be if it was the top of the skull instead. In a perfect world, people would wear a hard hat when anything is above your shoulder height respective to what level you are currently working on - can people be trusted to manage this themselves??
Bill Sowerbutts 4 months ago   Reply

I didnt want to try to deflate Frank's analysis of the scenario....but Charlie you have a very valid point. I've had roof cladders not wearing hard hats and they need to when accepting and depositing loads. Many of the inicidents Ive witnessed over my career have been glancing blows, rather than falling materials. The fork truck landinga load juat wavers slightly on rough ground when landing his load, por maybe as sheets ar eremoved, the forks adjust slightly to cope witht he different weight.  Or maybe someone on the roof simply doesn't expect the driver to move the load slightly to land it? 

Now all these may result in a glancing blow or a spill of materials at a low level, and the hard hat my be the difference between opening the head like a boiled egg or a minor injury.  People simply don't seem to realise that a sideways swing of the forks - especially loaded forks - maybe a couple of inches, could really do some serious damage  so (having investigated an incident where a hard hat save a man's life when some concrete reinforcing was unloaded and fell all of 18 inches onto the peak of his hat) do not underestimate the value of head portection at such times - whether up or down! - Bill

peter gotch 3 months ago   Reply

Bill - standard hard hats are NOT designed to offer lateral protection.

There's a relatively recent BS EN standard for helmets that DO offer lateral protection, but not many products on the market that meet this BS EN and at a much elevated price beyond that of a standard hard hat.

Going to the bottom of the hierarchy of control measures is NOT the solution for risks such as glancing blows from scaffold tubes. Just as likely to hit you below the helmet as the side of the helmet. Either way, likely to exacerbate other risks, e.g. making it more likely for you to fall from a ladder.

mickfinney 4 months ago   Reply

 

It's the ridiculous over the top blanket rules like this that make health and safety such a joke for so many of us.

Incidently my wife questioned some of these policies on one of her may HSE courses and was told by the HSE instructor running the course that in his opinion it did far more harm than good.

thank god I've managed to avoid the need to work on these sites for the last five years and avoid the little Hitlers that are unwilling to discuss the reasons for these rules, probably because they cant sensibly defend them