The information on this web page is aimed at window cleaning businesses. It will help you to plan and organise your window cleaning activities and manage the associated risks.
What the law says
The Health and Safety at Work etc. Act 1974 (HSW Act) requires employers to ensure, so far as is reasonably practicable, the health, safety and welfare of their employees and to ensure that those affected by their activities are not exposed to risk. Health and safety law also applies to self-employed window cleaners if their work exposes others to risk.
The Work at Height Regulations 2005 require employers and those in control of any work at height activity to ensure that the work is properly planned, supervised and carried out by competent people. This includes using the right type of equipment for working at height. When planning and organising window cleaning you must avoid work at height where it is reasonably practicable to do so, for example by using telescopic water fed poles or cleaning windows from the inside.
Best practice guidance 'Window Cleaning with Water Fed Poles – How to do it and look after your body' was produced jointly by HSE and industry is available from the Federation of Window Cleaners website.
Where window cleaning at height cannot be avoided, you must first consider using an existing place of work that is already safe for example, cleaning from inside windows or from a balcony. If you cannot find an existing safe place, to work from, you must provide suitable access equipment. Where the risk of falling is not eliminated by either of these means, you must take additional measures to minimise the distance and consequences of any fall by using the right type of fall arrest equipment.
It is important to discuss all window cleaning activities with the client as they will know their business well. Working together to develop an agreed co-ordinated approach is essential for reducing the risks e.g. your client will be aware if window/building design allows for safe cleaning of windows from the inside effectively eliminating the risk of falling.
All those working at height must have the right skills, knowledge and experience. The requirements for specific competences will depend on the work being done, e.g. a window cleaner involved in abseiling will require different skills, knowledge and experience from someone only involved in cleaning ground floor windows.
If working at height is unavoidable, you must plan and organise the task in advance. You will need to consider the following areas:
Working conditions
Working conditions will vary from site to site. It is important, before beginning any window cleaning task, to consider how these variations will impact on actions you need to take to control the risk.
These include:
- Height – How high is the job from the ground?
- Access – How can workers get safely to and from where they work at height e.g. cradle operators must not have to climb over the edge of a building into a cradle. Consider the presence of fragile surfaces, obstructions and the proximity of overheard power lines.
- Location – Buildings in busy town or city locations can present different risks to those on industrial estates and domestic properties. Consideration should be given to the time of cleaning, traffic conditions and preventing public access to areas directly below the working area to minimise the risk of them being struck by any falling object.
- Weather conditions – Are there procedures in place to stop work in the event of adverse weather conditions that could endanger those working at height e.g. high winds when using access equipment?
- Surface – What surface will the access equipment rest on? Is this surface strong enough to take the weight of the workers and their equipment?
- Ground – What is the ground condition under the area where access equipment might need to be set up - for example, is it sloping, muddy or uneven? The access equipment you use must be suitable for the ground conditions - stable, level and not liable to fall or collapse.
- Tools/materials – What tools or materials will you need for window cleaning? How will you get them up and down safely? How will you secure tools to avoid them being accidentally dropped?
Selecting the right access equipment
For every window cleaning job your choice of access equipment will be determined by the height to be negotiated, site conditions, duration and extent of work and frequency of access. Access equipment including anchorages etc, must be suitable for the task and must be properly maintained, regularly inspected and, where applicable, thoroughly examined in accordance with the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER).
Safe methods of work must be implemented for all activities where there is a risk of injury, particularly where higher risk window cleaning activities are carried out e.g. those requiring powered access or rope access. Operatives carrying out this work must be fully aware (and their understanding checked) of the safe working method statement.
Fall prevention equipment must also be suitable for the task and should be subject to the same maintenance and inspection regime as access equipment. You should also complete pre-use checks of your equipment ensuring any damage is identified before use. Any damage likely to compromise the integrity of equipment should be reported to the appropriate person and the equipment repaired/replaced before next use if necessary.
Regardless of the equipment to be used you must ensure you/your employees/contractors are fully trained and competent to use the work equipment provided.
Considering the risks associated with work at height and putting in place sensible and proportionate measures to manage them is an important part of working safely. Follow this simple step-by-step guide to help you control risks when working at height.
Portable Ladders
Portable ladders have traditionally been used mainly for cleaning domestic premise windows on ground, first and second floors. Whilst use of a ladder should not be your automatic choice, it can be the most sensible and practical option for low-risk, short duration tasks.
Before beginning work you should ensure that any ladder is both suitable for the work ie it is strong/robust and long enough for the job and is in a safe condition ie. without any visible defects.
Almost all falls from ladders happen because the ladder moves unexpectedly. The key factor in preventing falls from ladders is to ensure your ladder is stable whilst being used, through careful consideration of the working conditions and whenever possible tying the ladder to a suitable point to prevent movement.
For windows that are more difficult to reach the use of specialist access equipment will be necessary.
Protective Equipment
You should always consider measures that protect everyone who is at risk (collective protection) before measures that protect only the individual (personal protection).
Fall Arrest Equipment
Cleaning windows at height will often require the use of appropriate fall arrest equipment. This is normally a safety harness suitable for fall arrest, connected via an energy-absorbing lanyard, to a suitable anchor point. Harnesses must be adjusted properly to fit the wearer.
Fall arrest equipment must be maintained in good repair, periodically inspected and replaced when appropriate. Equipment which is exposed to conditions causing deterioration which is liable to result in dangerous situations should be inspected regularly and each time exceptional circumstances which might jeopardise safety have occurred.
Anchor points for fall arrest purposes require periodic inspection and testing by a competent person.
Detailed guidance on inspecting fall arrest equipment made from webbing.
Personal protective equipment (PPE)
You must provide appropriate personal protective equipment (PPE) and training in its usage to your employees wherever there is a risk to health and safety that cannot be adequately controlled by other means. Common PPE in the window cleaning industry includes items such as safety helmets and hard hats, gloves, protective footwear and clothing, high visibility clothing.
Emergency evacuation and rescue procedures
Emergency evacuation and rescue procedures must be in place before the work starts. For example, how will you rescue a person who has fallen while using a fall arrest system? It is not acceptable just to rely on the emergency services. Rescue procedures need to be covered in the risk assessment and planned prior to the work activity being carried out.
This will require cooperation and communication between all parties including property owners and managing agents, window cleaning contractors and sub-contractors and their workers.
It is important not only to have these in place but also to check employee understanding of these procedures before beginning the work.