Working at Height in the Marine Environment: A WHS Priority
Working at height is a critical safety challenge in the marine industry, where tasks often require elevated access on vessels, docks, cranes, and other structures. The unique conditions of the marine environment, such as slippery surfaces, strong winds, and constant motion, amplify the risks associated with height-related tasks. Falls from height are among the leading causes of workplace injuries and fatalities, making this a key focus under Work Health and Safety (WHS) laws.
Employers in the marine sector must ensure that all height-related risks are systematically assessed and controlled to comply with legal obligations and protect workers.
The WHS Context: Understanding Height Risks in the Marine Industry
Under the Work Health and Safety Act 2011 (Cth), employers, or Persons Conducting a Business or Undertaking (PCBUs), must take reasonably practicable steps to eliminate or minimise risks. This duty includes addressing working-at-height hazards, particularly in challenging marine environments.
Height-Specific Risks in the Marine Sector
- Slippery and Unstable Surfaces: Sea spray, algae, and water create slippery decks and ladders.
- Confined and Elevated Spaces: Tasks on masts, cranes, or high platforms are common in marine work.
- Dynamic Environments: The constant motion of vessels or platforms increases the likelihood of slips and falls.
- Weather Conditions: Wind, rain, and waves complicate safety measures for elevated work.
WHS Obligations for Working at Height
Risk Assessment
A thorough risk assessment must identify all hazards associated with working at height. In the marine environment, this includes accounting for motion, weather, and surface conditions.
Implementing Controls
Using the Hierarchy of Controls, employers can mitigate risks:
- Elimination: Where possible, use remote equipment or technology to eliminate the need to work at height.
- Substitution: Replace hazardous equipment or systems with safer alternatives, such as drone inspections instead of manual checks.
- Engineering Controls: Install guardrails, anchor points, or netting to prevent falls.
- Administrative Controls: Develop and enforce safe work procedures, factoring in marine-specific conditions such as vessel stability.
- Personal Protective Equipment (PPE): Provide harnesses, fall arrest systems, and helmets compliant with AS/NZS 1891.4:2009, designed to withstand marine conditions.
Training and Supervision
Workers must be trained in height safety practices and the use of marine-specific safety equipment. Supervisors should ensure compliance with safety procedures and adapt them to changing conditions on vessels or platforms.
Case Law Spotlight: Lessons from the Marine Industry
The case of WorkSafe NSW v Gantry Crane Operations Pty Ltd (2020) highlights the risks of working at height in maritime operations. In this case, a worker conducting maintenance on a dockside crane fell after the company failed to provide a fall arrest system.
Key Failures in the Case
- Lack of Planning: No risk assessment was conducted for the task, despite the known height hazards.
- Inadequate Equipment: The worker was not provided with a harness or fall arrest system.
- Poor Supervision: The employer failed to monitor the task or enforce safety protocols.
Court Findings
The company was found to have breached its duty of care under the WHS Act, resulting in significant penalties. The case underscores the importance of robust planning, equipment, and supervision in height-related tasks, particularly in dynamic environments like docks and vessels.
Practical Steps for Marine Employers
Employers in the marine sector should adopt industry-specific measures to manage height-related risks effectively:
- Develop a Height Safety Policy: Include procedures tailored to marine operations, addressing risks such as unstable surfaces and vessel motion.
- Invest in Marine-Specific Equipment: Use corrosion-resistant anchor points, harnesses, and PPE designed for saltwater environments.
- Conduct Regular Training: Train workers on the unique challenges of working at height in the marine industry, including adapting to dynamic conditions.
- Schedule Inspections and Maintenance: Ensure ladders, guardrails, and safety systems are inspected regularly for wear and corrosion.
- Incorporate Technology: Use drones or remote-controlled cameras for inspections in hard-to-reach areas, reducing the need for manual access.
Resources for Marine Employers
Employers can access the following resources to enhance their approach to height safety in the marine sector:
Code of Practice:
Managing the Risk of Falls at Workplaces - Provides guidance on height safety, including industry-specific scenarios.Managing-the-risk-of-falls-at-workplaces-COP.pdf
Further Reading
- AMSA’s Maritime Safety Awareness Bulletin Issue 1 provides more information on height safety including identifying common safety factors.
- AMSA’s Maritime Safety Awareness Bulletin Issue 6 provides guidance on tools and methods you can adopt to support risk identification and control.
- AMSA’s Fatigue guidelines – managing and reducing the risk of fatigue at sea, provides more information on reducing fatigue as a factor in workplace accidents.
- ATSB’s investigation report MO-2018-001 Serious injury on board Berge Daisetsu, Portland, Victoria on 11 January 2018 provides an analysis of a fall from height incident.
- ATSB’s investigation report MO-2017-001 Fall from height and serious injuries to crewmembers on board Shanghai Spirit near Port Alma, Queensland, on 29 January 2017 provides an analysis of a fall from height incident.
A Shared Responsibility in the Marine Sector
Working at height in the marine industry presents unique challenges that require tailored safety measures. By implementing effective controls, providing marine-specific training, and fostering a culture of safety, employers can mitigate risks and ensure compliance with WHS obligations. Proactively addressing these hazards protects workers and strengthens the industry's commitment to safe and sustainable operations.