APAC Service Operations HSE
Health & Safety Management System
Title:
Working at Height
Group Document:
Group Reference Standard – Work at Height –
Fall Protection
Document Reference:
APC-HSE-HSMS-00539
Date of Issue:
12 Jul 2019
Process Owner:
APAC Service Operations HSE
Process Writer:
Ashwin Bhosale & Nisar Shaikh
Process Approver:
Sian Petigny
1.0 Objective
Sodexo is committed to protect Sodexo employees (including contractors, visitors, and
clients that may be affected by our performed maintenance work activities) wherever Work
at Height (WaH) activities are identified in order to minimise the risk of potential injury to
persons or potential impact and damage to the surrounding environment.
This document describes the process for working safely at heights (at or above 1.8m) where
there is a risk of an individual(s) falling from one level to another, when conducting work on
machinery, equipment or other installations, or where individuals are working within 1.8m of
a live edge or brittle surface; including any potential for dropped objects impacting personnel
below.
Examples of work at height include; roof work, working from cradles, accessing ceilings and
lighting fitments, and access to other high areas inside and outside buildings. Work at
height considerations also apply where a worker could fall into dangerous machinery or
materials, regardless of the height of the work being performed. Work at ground level can
also be hazardous where there is the potential to fall below ground, for example into
excavations, inspection chambers and pits.
2.0 Scope
This process applies to all APAC sites and compliance with its requirements is mandatory
for all scope of services rendered by Sodexo and its contracted services.
This process shall also be applied in accordance with applicable local legal requirements.
If Sodexo is required to adopt and/or use (by contractual agreement) client’s
methodology and/or form (e.g. Risk Assessment, Job Safety Analysis, Job Hazard
Analysis), this is to be agreed upon and documented in the HSE Interface Document
(APC-HSE-FORM-00550b). When required, Local Operating Process (LOP) is to be
developed. Regardless, client is responsible to provide related training with refresher
frequency arranged for Sodexo affected team.
Where there is a more stringent height limit, i.e. less than 1.8m (e.g. this process against
client or applicable national, state, and local legal requirements), the more stringent
requirement shall be followed. Such cases shall also be defined in the LOP to be developed.
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3.0 Responsibilities
Regional and Local Management Team
Regional and local management team are responsible for ensuring that this process is
followed on site and that there is access to a competent operational resource allocated to
each site/ contract in order to meet and implement the requirements in this document, as
well as applicable local or international legal requirements.
APAC Regional HSE Team



Supporting the management team in the implementation of this process within the
organisation
To promote and cascade this process across the region through the respective Territory
Team(s)
Ensure that this process is reviewed at regular interval, kept current and all references
are relevant/valid, including all related documents
Territory HSE Team (Includes In-Contract & Site HSE)




Will facilitate the deployment of this process including relevant guidelines, tools and
forms at site
Allocate / provide training in accordance with the training needs analysis and/or training
matrix for the appointed resources to be able to carry out work
Conduct random checks during announced or unannounced site visits, inspections or
audits to ensure that this process is being followed by the site(s) and to confirm
compliance
Ensure that this process is in compliance with applicable local requirements
Regional and Local FM Team



Provide technical knowledge and support to the local / site team, across all territory or
business activities (e.g. FM services or food services) in the development of risk
assessments (RA), Safe System of Work (SSW), etc. associated with WaH tasks to be
done onsite
Conduct review of contractor method statements, qualifications, etc. to ensure that
subcontracted work will be carried out in accordance with this process and Sodexo’s
Permit to Work (PTW) process
Prescribe additional control measures necessary to ensure the WaH task shall be
carried out and completed safely in accordance with this process
Site Manager / Lead





Ensure that a detailed RA is completed for all WaH tasks in order to identify appropriate
controls to mitigate or reduce the risk, in consultation with Qualified Authorized
Person(s), and appropriate SMEs
Making sure that any WaH equipment (e.g. mechanical aids or PPE) identified in the RA
are used and implemented as required
Ensure that the appointed operational competent resource (i.e. Qualified Authorized
Person) trains the affected employees in accordance to the WaH SSW
Ensure that the PTW Process (in accordance with APC-HSE-HSMS-00532) is
implemented for WaH tasks
Ensure that all employees who are required to carry out WaH as part of their tasks are
provided with the necessary training, which may include but not limited to: general
awareness, Sodexo internal WaH training, training from supplier of WaH equipment, etc.
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If a Qualified Authorized Person for WaH is not available on site, reach out to Local FM
Team for appropriate support
In the event of the Qualified Authorized Persons (responsible person) Site Manager will
take on the role of Permit Issuer – in accordance with PTW process
Ensure that this process is implemented and enforced on contractors who perform WaH
tasks
Ensure that any HSE concerns regarding a client appointed contractor is brought to the
attention of the client at the earliest possible opportunity
Qualified Authorized Person1 for WaH (includes Supervisor, Team Lead, etc. leading the
work team)




Understand Sodexo RA, PTW and WaH processes
Support the Site Manager (if not the same person) to issue WaH permits and ensure
requirements of this process is implemented on site
Attend the required internal and external trainings
Train Qualified Person/s in the SSW of a specific WaH activity
Qualified Person2 (includes Workers and Standby Person)



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Attend WAH related training (internal or external)
Comply with the SSW and RA of affected WAH activity
Perform pre-checks of WaH equipment and WaH control measures when appointed by
Qualified Authorized Person
Understand the SSW as trained by the Qualified Authorized Person and comply with the
SSW requirements while performing the work.
4.0 What you need to do
4.1
Requirements before performing Working at Height
4.1.1
Ensure Appropriate Risk Assessment is in Place and Implemented
All potential WaH activity shall have detailed risk assessments. Control measures to protect
against fall hazards will be selected in accordance with the hierarchy of controls. The most
protective control measures will be used wherever feasible to eliminate potential fall
exposure.
The RA shall be carried out considering these potentials:
 Wherever practicable, the need to eliminate the need to WaH shall be identified as part
of the risk assessment process. This could include carrying out the work on the ground
or from a solid structure such as a work platform which is secured by hard barricading
(e.g. platform with guard rails, toe boards etc.)
1
A Qualified Authorised Person is a Qualified Person with additional training and experience, and has a good understanding
of the plant, equipment, building or site in order to understand the process or task being undertaken and associated controls,
and verify the required precautions have been effectively applied. This individual is responsible for developing and
implementing safe work processes; preparing or approving work permits; approving the selection and use of work equipment
and clothing; and verifying that safety equipment chosen by the Qualified Person for specific tasks is appropriate.
2
Person or persons that are locally qualified and registered in accordance with the local legislation as appropriate, and have
been assessed by the Authorizing Engineer as sufficiently competent. They are responsible for adhering to all the
requirements detailed in the Group Standard as well as the local safe work process.
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If applicable, minimize the distance or impact of a potential fall
Minimize risk by providing information, instruction or training to applicable workers
Use fall prevention, fall protection or fall arrest equipment (whichever is applicable)
Regardless of the height where work is being done, Point-of-Work Risk Assessment (i.e. 3
Checks for Safety, Working at Height Safety Nets Card, or Dynamic Risk Assessment) shall
be completed and the appropriate SSW followed.
The table below provides examples of possible hazards and risk factors associated with a
WaH activity and control measures that may be implemented to manage such hazards and
risks. This list is not exhaustive and only provided to serve as reference in conducting WaH
RAs.
Hazards
 On fragile roofing
 While
using
access
equipment
 On unstable or uneven
surfaces
 Near an unprotected edge or
opening
 In adverse weather
or
environmental
conditions
(e.g. low visibility, extreme
temperatures etc.)
 With tools or objects that may
fall
 Near overhead power lines or
sources of hazardous energy
4.1.2
Risk Factors
 Medical and physical
fitness of the person
conducting the task
 Work area condition (e.g.
quality of
the work
surface, lighting and/or
ventilation
conditions,
etc.)
 Adverse
weather
conditions
 Number of personnel who
may be at risk
 Location of the work area,
including locations of
access/egress routes
 Type of work to be carried
out
 Work practices in use
 Scheduling
of
work,
including
time
and
duration of work
 Type of plant, machinery
or equipment to be used
 Competence, training and
experience of the people
carrying out the work
 Being struck by a moving
or falling object, tools or
equipment during the
work
 Simultaneous operations
within the vicinity of the
work at height
Control Measures
 Eliminating the hazard i.e.
working on the ground where
possible
 If
work
at
heights
is
unavoidable,
secure
the
elevated work area with a
passive fall prevention barrier
system, such as guardrails
 Being medically and physically
fit for the task
 Substituting a work method or
process
with
one
less
hazardous i.e. using walkways
for access instead of a ladder
 Modifying the system of work
or equipment i.e. using
scaffolding
 Adopting work positioning
systems such as scissor lifts
or MEWPs
 Providing additional controls
i.e. adopting administrative
controls such as permit to
work, SSW, so the time or
conditions of exposure to the
risk is reduced
 Using personal protective
equipment i.e. fall-arrest or fall
restraint equipment
Safe Systems of Work (SSW) In Place
SSWs shall be developed in consultation with Qualified Authorized Person(s) who shall be
supported by relevant SMEs (e.g. HSE and FM). The SSWs shall be based on good
industry practice, local requirements, or manufacturer recommendations.
The SSW shall be developed based on the following recommendations and using a riskbased approach [e.g. based on Risk Assessment process] and include consideration of:
 The situation under which the SSW is to be developed
 The means and sequence by which the safe access will be achieved
 The checks that are to be performed prior to the commencement of work
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The specific fall protection and personal protective equipment (PPE) required
Whether or not a Permit to Work (Working at height) is required, based on the results of
the risk assessment
The title/positions of persons authorised to perform work and issue permits (if required)
in relation to the work to be done
Any other special requirements.
SSW should usually come and be issued in the form of a proper operations document
format, however, if unavailable, site team could also make use of the SSW section as
available in the detailed risk assessment for the same purpose.
All controls identified in the SSW shall be in place before work commences.
The Qualified Authorized Person for WaH in each territory will jointly develop, together with
other SMEs, the local procedures (SOP) and conduct the necessary relevant training to
employees who will carry out the work.
A register of WaH SSWs (Refer to APC-HSE-FORM-00539a), including the names of the
Qualified Authorized Person(s) who have undergone training, shall be maintained by the
Site Manager in accordance with appropriate FM SME recommendations.
4.2
Performing the Work at Height under an Approved WaH PTW
Upon completion of the requirements of the PTW, Responsible Person shall apply a WaH
PTW from the Permit Issuer (Sample permit provided in Appendix).
Note that in some situations, the Qualified Authorized Person(s) conducting the work may
also be the Permit Holder. In such cases, the Site Manager shall take on the role of the
Permit Issuer. For the case of Sodexo direct contractors, Qualified Authorized Person (if
appointed) shall take on the role of the Permit Issuer.
The approved Working at Height Permit shall be displayed in the area where the work is
being undertaken.
All working at height shall be conducted in strict accordance to the SSW and/or Risk
Assessment and (if applicable) the Working at Height Permit conditions.
If a Working at Height Permit is required and has been issued, the Responsible Person (i.e.
the Permit Holder) must also monitor the work to ensure that all the controls and other
precautions described in the Permit are being followed.
If any breaches to the conditions or controls required under the Working at Height Permit
occur, the Permit Holder must immediately stop the work and notify the authorised Permit
Issuer. Work can only recommence upon formal approval of the Permit Issuer, including reissuing the Working at Height Permit.
4.3
Completion and Cancellation of Permit
After completing the WaH activity or task, the Permit Holder shall conduct an inspection
before closing-down (securing) and leaving the work site.
This inspection shall include a check that all the work has been satisfactorily completed and
all persons, equipment, tools and instruments have been withdrawn.
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The post work inspection shall also ensure that the work area is in a condition that will allow
it to be safely secured before any associated plant or equipment can be reinstated or
brought back into service e.g. all barricades and signs have been removed, temporary road
closures or deviations removed, isolations removed, etc.
Consequently the Permit Issuer, after agreeing with the Permit Holder on the completion of
work, shall cancel the WaH PTW to confirm that the work area/equipment is returned to a
safe status with no hazards remaining in respect of these works; and that all personnel,
work equipment and materials have been withdrawn as appropriate.
5.0 Training and Competence
WaH Permit Issuer shall be appointed by the Site Manager (in consultation with the
Regional SMEs as necessary) to issue WaH Permits. Such appointment shall be
documented in the APC-HSE-FORM-00532d - Authorised Permit Issuer Appointment Form.
WaH Permit Issuers shall undergo related internal and external WaH training.
Alternatively if specialised work is required at a height of 1.8m or more, a suitably trained
and competent contractor shall be engaged to conduct work at heights providing they hold
the appropriate competencies and/or licences. In such cases, the Site Manager shall ensure
that contractors are supervised at all times while WaH is being performed.
Site Manager shall ensure related internal and external training is provided to Qualified
Persons to make sure they are capable and competent to perform the WAH activity.
Qualified Person(s) shall be trained and assessed to ensure that:
 They have sufficient skills and knowledge to apply safe working practices when working
at height
 They have demonstrated a responsible attitude towards safe work practices
 They understand applicable site SSWs relating to the working at height they are
authorised to conduct
 They have demonstrated an understanding and have sufficient skill to identify work
requirements, assess and install equipment, perform work at height and clean work
area(s)
Prior to their appointment, the following personnel involved in WaH task shall undergo the
required initial and appropriate refresher trainings as defined below. Refresher trainings are
recommended to be at least every two years unless local requirements require more
frequent.
Trainees
Trainer
Training Method
Training Records
Site Employees, Site manager,
Qualified Authorized Person,
Qualified Person, Permit Issuer,
SME, etc. and all other
employees involved in the
performance and implementation
of WaH activities, including the
use of WaH PTW
Internal – to
introduce the
Sodexo WaH
process and WaH
PTW System
Induction
(Refer WAH
Training guidance)
Maintained at site
Permit Issuer, SMEs, Qualified
Authorized Person; Qualified
Person doing WaH
External - Suitably
recognised training
organisation – as
required based on
client or local legal
Induction &
Practical
Maintained at site
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Trainees
Trainer
Training Method
Training Records
requirements
Where WaH activities are to be performed by contractors, the contractor company shall
provide records of personnel qualification, competency and appropriate training to the Site
Manager as part of the approval process for WaH permit.
6.0 Record Keeping
Site Manager/Lead (or his/ her appointed person) is responsible to ensure the following are
kept up to date, relevant and available at their site:
 Work at height Risk Assessments and Safe Systems of Work
 Work at height Permit to work
 Relevant internal and external training.
 Applicable certifications, operation manuals, service logs and any other documents /
records related for WaH equipment
 Applicable licenses / certifications of relevant personnel
7.0 Revision Table
Version No
Revision Date
1
12 Jul 2019
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Revision Description
New Document
Appendix
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