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negligible risk of serious personal injury.
58 The risk of a fall will depend on various factors including:
1) procedures in place for opening aircraft doors.
2) the availability and adequacy of any existing fall protection measures including
guarding and personal fall protection systems.
3) the work that is being done, for instance whether it involves handling awkward or
heavy loads, the suitability of platform or step design.
4) the surface on which the person is standing whilst working, including its integrity,
angle, its level of slip resistance and the actual surface area available.
5) the duration of the work and the location in which it is carried out. If carried out
externally there may be impact from the weather conditions such as high winds.
Table 1: Risks of serious injury requiring immediate action, including consideration of a
Prohibition Notice
Scenario Remedial action
Access steps in use without guard
rails on steps or upper platform
Position existing guard rails or take steps out of
use until suitable guard rails are fitted
Ground handler reaching across
unguarded gap at height to open/
close aircraft door without suitable
guard rails or personal fall
protection
Adequately guarded access equipment or
personal fall protection to be provided and used,
with suitable training
Aircraft doors open and unguarded
when passengers or workers on
board aircraft
Door to be guarded/ protected or closed, or
ground support equipment to be positioned
outside aircraft to provide protection
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59 Inspectors are reminded of the possible implications of an immediate Prohibition Notice and
should consider the impact such a Notice might have on other workers around an aircraft, and
on overall air traffic control and flight safety at the airport. Where immediate prohibition could
cause significant health and safety or air safety risks, a deferred notice should be considered.
60 Consideration should be given to risk control systems for equipment procurement,
maintenance and thorough examination, as well as training in procedures, selection and use of
equipment, systems for maintaining edge protection and restricting access to unguarded
edges, and management control of contractors.
61 Given the potential for injury it is essential that a suitable and sufficient risk assessment is
carried out. To be suitable the assessment should consider the issues identified above. The
assessment should recognise the potential for serious injury arising from low falls as well as
high falls. The failure to undertake a risk assessment should be dealt with by reference to the
EMM.
62 Where inspectors find failings of management systems such as:
1) absence of suitable risk assessments; and/or
2) inadequate arrangements for planning, organising, control etc; and/or
3) lack of suitable training,
And there is evidence that:
4) employees are not following safe practices while opening/ closing aircraft doors; and/
or
5) there is a lack of suitably guarded access equipment; and/or
6) there are damage or defects to access equipment or fall protection equipment which
give rise to significant risks an Improvement Notice should be considered. Advice or
enforcement should be addressed to the parties best able to rectify an identified problem
that is airport and/or airline and/or ground handler.
63 The long term aim should be better designed access equipment, better guarding, and
improved design of aircraft doors and their opening mechanisms. Where current equipment
and guarding are obviously inadequate, we should be asking for immediate improvements.
This may mean modifying the equipment or using fall restraint equipment in the short term. In
the longer term we should be asking companies to come up with a programme and timetable
for replacement or improvement of equipment where necessary.
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STRATEGIC FACTORS
64 Falls from a height are currently a HSE industry reduction programme priority programme.
A failure by inspectors to take enforcement action where the EMM and local factors indicate
such action to be appropriate may have a negative impact upon employers' attitudes. This
should be considered as a strategic factor for the purposes of the EMM.
65 HSE has been working with the industry via the Revitalising Health & Safety in Air
　
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