Pest Work on Roofs and Ladders: What HSE’s Working at Height Guidance Says About Fragile Roofs, Ladder Use and Who Must Plan the Job in Great Britain

Wasp nests under eaves, pigeons on a roof edge, squirrels in a chimney or gulls on a flat roof all mean a pest controller working above ground level. For a business, landlord or facilities manager who books that work, the Health and Safety Executive (HSE) says the rules on working at height matter: falls from ladders and through fragile roofs are among the biggest causes of workplace death and serious injury. This article summarises HSE’s guidance on work at height, mainly its leaflet INDG401 “Working at height: A brief guide” (a web version of a January 2014 revision) and its web pages on ladders and common myths. HSE is Great Britain’s workplace health and safety regulator, so this covers Great Britain. It is general information and not a substitute for HSE’s own guidance or professional advice.

What counts as work at height

HSE’s FAQ says work at height means work in any place where, if precautions were not taken, a person could fall a distance liable to cause personal injury. It gives examples: working above ground or floor level, working where a person could fall from an edge, through an opening or fragile surface, or into an opening in a floor or a hole in the ground. Walking up and down a permanent staircase in a building is not work at height. Working on a ladder or a flat roof counts, as does anywhere a person could fall through a fragile surface.

Who the Work at Height Regulations 2005 apply to

HSE says the Regulations apply to employers and to those who control any work at height activity, giving contractors and factory owners as examples. Its FAQ adds that duties can fall on facilities managers or building owners who contract others to work at height. Employers and those in control must ensure work is properly planned, supervised and carried out by competent people, using the right equipment. HSE says the Regulations require that all work at height is properly planned and organised, that those involved are competent, that risks are assessed, that the risks of working near fragile surfaces are managed, and that equipment is inspected and maintained. Low-risk, relatively straightforward tasks need less planning effort.

The three-step hierarchy

HSE’s brief guide sets out a sequence to follow before anyone works at height:

  • Avoid work at height where it is reasonably practicable to do so, by doing as much work as possible from the ground. Its examples include extendable tools used from ground level so no one has to climb a ladder.
  • Prevent falls where work at height cannot be avoided, using an existing safe place of work or the right type of equipment.
  • Minimise the distance and consequences of a fall where the risk cannot be eliminated.

The guide says collective protection, such as a guard rail, that works without the person doing anything should be considered before personal protection such as a harness, which depends on the individual using it correctly.

Ladders

HSE says ladders are not banned. It describes them as a sensible option for low-risk, short-duration tasks, and its FAQ gives 30 minutes at a time as a guide: if a task needs more than that on a leaning ladder or stepladder, consider alternative equipment. On the “myths” page it says a ladder user needs to be competent, not formally qualified. It says ladders should be used only where they can be level and stable and, where reasonably practicable, secured. When both hands are needed briefly on a stepladder, HSE says to keep three points of contact at the working position, which can be two feet and the body supported by the stepladder. A ladder used to reach another level should extend at least one metre above the landing point so there is a secure handhold, be of a suitable industrial grade and be tied.

Roofs and fragile surfaces

The leaflet says roof work is high risk and that falls from roofs, and through fragile roofs and roof lights, are among the most common causes of workplace death and serious injury. It says these accidents occur on roofs of factories, warehouses and farm buildings as well as in construction, when repair or cleaning is under way. HSE lists as likely to be fragile: roof lights, liner panels on built-up sheeted roofs, non-reinforced fibre cement sheets, corroded metal sheets, glass including wired glass, rotted chipboard, and slates and tiles. It says the place where work will be done must be checked every time before use, that weather conditions that could compromise safety must be taken into account, and that emergency and rescue plans should not rely entirely on the emergency services.

What this means when booking a pest job

  • Ask whether the contractor has assessed the access route and method, and whether ground-level options such as extendable tools or non-roof solutions can do the job.
  • For commercial buildings, warehouses or farms, tell the contractor about fragile roof lights or sheeting before the visit.
  • Expect a contractor to use suitable equipment and to be competent, since HSE says the Regulations require it. The site’s piece on asbestos and roof void access covers a separate check that may apply before roof-space work.

These are practical questions drawn from HSE’s duties on planning and competence; they are not a legal test of any particular contract. For choosing a contractor more generally, see the site’s guide to choosing a pest controller.

Common questions

Does HSE ban ladders for roof or gutter work?

No. HSE says ladders and stepladders are not banned and can be used for low-risk, short-duration tasks or where existing features cannot be altered.

Must a ladder user hold a formal qualification?

HSE says no: the requirement is competence, meaning the skills, knowledge and experience to use the ladder properly, or working under competent supervision.

The bottom line

HSE’s position is that height work should be avoided if reasonably practicable, that fall prevention comes before fall protection, and that ladders remain acceptable for low-risk, short jobs when used competently. Fragile roofs are the standout hazard. For anyone booking a pest job that involves roofs or lofts in Great Britain, the practical takeaway is to expect planning, competence and suitable equipment from the contractor.

Sources

  • HSE, “Working at height: A brief guide” (INDG401) (hse.gov.uk)
  • HSE, “Work at height: Frequently asked questions” (hse.gov.uk)
  • HSE, “Common work at height myths” (hse.gov.uk)
  • HSE, “Safe use of ladders and stepladders” (hse.gov.uk)