What Is It?
A working at height risk assessment is a structured document that examines work carried out anywhere a person could fall a distance liable to cause injury, identifies the hazards, evaluates the risk, and records the control measures used to make the work safe. For window cleaners it focuses on the core access methods — water-fed poles used from the ground, ladders, and mobile access towers — and the hazards around them: falls, overhead power lines, fragile surfaces, ground conditions, weather and the public. It follows the HSE's recognised five-step approach and the legal hierarchy set out in the Work at Height Regulations 2005: avoid working at height where reasonably practicable, prevent falls where it cannot be avoided, and minimise the consequences of any fall that does occur.
About This Template
Working at height is the single biggest cause of serious injury and death for window cleaners, and a recognised hazard for many other trades. The Work at Height Regulations 2005 require that any work at height is properly planned, supervised and carried out by competent people, with the risks assessed in advance. A working at height risk assessment is how that duty is met — it identifies where and how someone could fall, applies the legal hierarchy of avoid, prevent and minimise, and records the control measures that will keep the work safe. It is essential for window cleaners and useful for any trade that uses ladders, towers or other access equipment.
When to Use
- Before any window cleaning or other work where a person could fall a distance liable to cause injury
- When using ladders, stepladders, mobile access towers, or any equipment to reach height
- When deciding whether work at height can be avoided altogether, for example by using a water-fed pole from the ground
- Before commercial or contract work, where a written risk assessment and method statement are routinely required by the client
- When site conditions present specific hazards — overhead power lines, fragile roofs or skylights, uneven or sloping ground, restricted access or busy public areas
- As a regular review of your standard working methods, and whenever conditions, equipment or the type of work changes
What to Include
- Job details — location, description of the work, date of assessment, and the name of the competent person carrying it out
- The access methods to be used — water-fed pole from the ground, ladder, stepladder, or mobile access tower — and why each was chosen
- Hazard identification — falls from height, falling objects, overhead power lines, fragile surfaces and skylights, unstable or sloping ground, adverse weather, and risk to the public and other site users
- Who is at risk — the window cleaner, employees, other contractors, the customer and household, and members of the public passing below
- A risk rating for each hazard — likelihood multiplied by severity — recorded both before and after control measures are applied
- Control measures applied through the hierarchy — avoid working at height where reasonably practicable, prevent falls with suitable work equipment, and minimise the consequences of a fall
- Ladder controls — pre-use checks, correct angle (the 1 in 4 rule, approximately 75 degrees), firm and level footing, securing or footing the ladder, three points of contact, and limiting the duration of work from a ladder
- Water-fed pole controls — checking overhead power lines before extending the pole, managing hoses as a trip hazard, and water and electrical safety
- Mobile tower controls — erection by a trained person, level ground, outriggers or stabilisers fitted, wheels locked, and a tower inspection record
- Weather assessment — wind, rain, ice and storms, and the conditions under which work at height will be stopped
- Emergency and rescue arrangements — first aid provision, what to do if someone falls, and how a person could be reached and recovered
- Sign-off by the person carrying out the assessment, a review date, and the conditions that would trigger reassessment
Tips
Apply the hierarchy in order, every time — first ask whether the work at height can be avoided entirely (a water-fed pole worked from the ground removes the fall risk), only then consider equipment that prevents a fall, and only then equipment that reduces the consequences. The Work at Height Regulations 2005 require this sequence, not a free choice
Treat ladders as a considered decision, not a default — under the regulations a ladder may be used for low-risk, short-duration work where its use can be justified, but the assessment must show why a safer method was not reasonably practicable
Carry out a pre-use check on ladders and access equipment every working day and before each use — look for damaged stiles, rungs, feet and locking mechanisms; HSE guidance is that a ladder with a visible defect must not be used
Always check for overhead power lines before raising a water-fed pole or a ladder — contact with overhead lines is a known cause of fatal accidents, and modern poles are long enough to reach them
Stop work at height in unsafe weather — high winds, ice, lightning or storms — and record in the assessment the conditions under which you will stop; do not let a customer's expectations override a genuine safety decision
The Work at Height Regulations 2005
The Work at Height Regulations 2005 are the primary piece of UK law governing work at height. The stated purpose of the regulations, in the words of the Health and Safety Executive (HSE), is to prevent death and injury caused by a fall from height.
The regulations place duties on employers, the self-employed, and any person who controls the work of others — including, for example, facilities managers or building owners who contract others to carry out work at height. A self-employed window cleaner therefore carries these duties personally.
The core requirement is that all work at height is properly planned, supervised, and carried out by competent people. Planning includes carrying out a risk assessment, choosing the right equipment for the job, and putting emergency and rescue arrangements in place. The regulations recognise that the level of planning should be proportionate to the risk: a low-risk, short task needs less rigorous planning than complex or high-risk work.
The regulations also require that the equipment used for work at height is suitable for the task, is inspected and maintained, and that the people using it are competent — meaning they have the training, knowledge and experience to do the work safely. Workers in turn have a duty to take reasonable care of themselves and others, to use equipment properly, and to report any safety hazard they become aware of.
It is worth noting what the regulations do not say. There is no blanket ban on ladders, and no "two-metre rule" — the regulations apply to any work at height where a person could fall a distance liable to cause injury, regardless of the height. // VERIFY: the Work at Height Regulations 2005 do not set a minimum height threshold; older guidance referencing a fixed two-metre rule predates these regulations and should not be relied on.
The Hierarchy: Avoid, Prevent, Minimise
The Work at Height Regulations 2005 require risk to be managed through a hierarchy. The duty holder must work through the steps in order — it is not a menu to pick from freely.
Avoid. The first duty is to avoid work at height altogether where it is reasonably practicable to do so. For window cleaners this is exactly why water-fed pole systems have become standard: a telescopic pole fed with purified water lets most domestic and many commercial windows be cleaned from the ground, removing the fall risk entirely. Cleaning accessible windows from the inside is another way of avoiding height. The assessment should always start by asking whether the work at height is necessary at all.
Prevent. Where work at height cannot reasonably be avoided, the next duty is to use work equipment or other measures to prevent a fall. This means selecting suitable, stable equipment for the task — a properly erected mobile access tower, a podium step, or, for low-risk and short-duration tasks where it can be justified, a ladder used correctly and, where possible, secured.
Minimise. Where the risk of a fall cannot be eliminated by the measures above, the final duty is to minimise the distance and consequences of a fall — for example through collective measures such as soft landing systems where appropriate, or personal fall protection where the work genuinely requires it.
For most window cleaning, the assessment should resolve at the first or second step: avoid height with a water-fed pole wherever possible, and where a ladder or tower is genuinely needed, use it correctly. Recording how the hierarchy was applied — and why a lower step was reached — is the heart of a working at height risk assessment.
Safe Use of Ladders for Window Cleaning
Ladders remain part of window cleaning, particularly for windows a pole cannot reach or where pole access is obstructed. The Work at Height Regulations 2005 do not ban ladders, but they require their use to be justified: a ladder is appropriate for low-risk, short-duration work where the risk assessment shows that a safer method is not reasonably practicable.
Where a ladder is used, the following controls should be recorded in the assessment and applied on site.
Pre-use checks. Inspect the ladder before each use, and carry out a more thorough check at the start of each working day. Look for bent or damaged stiles, missing or worn rungs, damaged or missing feet, and faulty locking mechanisms on extension or step ladders. HSE guidance is clear that a ladder with a visible defect should not be used.
Footing and angle. The ladder must stand on firm, level, dry and non-slippery ground. A leaning ladder should be set at the correct angle — the 1 in 4 rule, one unit out for every four units up, which gives an angle of approximately 75 degrees from the horizontal.
Stability and securing. The single most important factor in preventing falls from ladders is stability. Wherever possible the ladder should be tied to a suitable secure point near the top. Where tying is not practical, an effective alternative such as a stability device or a second person footing the ladder should be used, and the assessment should record which method applies.
Working from the ladder. Maintain three points of contact with the ladder while working, do not overreach beyond the stiles, and do not carry loads that prevent a secure grip. Work from a ladder should be of short duration; for longer tasks a tower or other platform is more appropriate.
Overhead hazards. Before raising any ladder, check for overhead power lines and other obstructions. Never position a ladder where it could contact, or be brought into contact with, a live overhead line.
Water-Fed Poles, Towers and Other Access Equipment
Window cleaners use a range of access methods, and the risk assessment should cover whichever ones the work requires.
Water-fed pole systems are the standard way of avoiding work at height. A telescopic pole fed with purified water cleans windows from the ground, which removes the fall risk and satisfies the first step of the hierarchy. They are not, however, hazard-free. The most serious risk is contact with overhead power lines — poles are long, conductive when wet, and easily raised into lines without thought, so checking for overhead lines before extending the pole is essential. Other hazards include hoses creating a trip risk on the ground and around the public, water and electrical safety where pumps and batteries are used, and manual handling of poles, hoses and water tanks. These should be assessed even though the method removes the fall hazard.
Mobile access towers are used where a stable working platform at height is needed. A tower should be erected, altered and dismantled only by a person trained and competent to do so, stood on firm and level ground, fitted with outriggers or stabilisers as specified by the manufacturer, and have its wheels locked before anyone climbs it. Towers should be inspected before use and at intervals, and a tower inspection record kept. Guard rails and toe boards should be in place at the working platform.
Stepladders and podium steps may be used for lower-level access, again as a considered choice for short-duration, low-risk work, set up on firm level ground and used within their safe working limits.
Whatever the equipment, the principle is the same: it must be suitable for the task, in good condition, used by a competent person, and chosen because the hierarchy of avoid, prevent and minimise pointed to it — not simply because it was to hand.
Key Hazards and How to Control Them
A working at height risk assessment should identify the hazards specific to the job and record a control measure for each. The following are the hazards most relevant to window cleaners and other trades working at height.
Falls from height are the central hazard and the reason the assessment exists. Control them by applying the hierarchy: avoid height with a water-fed pole, use stable equipment where height cannot be avoided, and ensure ladders are checked, correctly angled, footed and secured.
Falling objects — tools, buckets, equipment — can injure people below. Control them by securing tools, keeping the ground area clear, and cordoning off the area beneath the work where the public could pass.
Overhead power lines are a recognised cause of fatal accidents. Both ladders and water-fed poles can reach them. Control by checking for overhead lines before raising any equipment and keeping well clear.
Fragile surfaces and skylights — older conservatory roofs, rooflights, and asbestos cement sheeting — can give way under a person's weight. Control by never standing or leaning on a surface that cannot be confirmed as load-bearing, and treating any uncertain roof surface as fragile.
Ground conditions — soft, uneven, sloping, wet or icy ground, drain covers, and loose paving — undermine the stability of ladders and towers. Control by inspecting the ground before setting up and choosing a firm, level position, or a different method.
Weather — high wind, rain, ice and storms — sharply increases the risk of working at height. Control by setting clear limits in the assessment for when work at height will stop, and by stopping when those limits are reached regardless of the schedule.
The public — pedestrians, customers, children and pets — may be near the work, particularly on commercial premises and busy streets. Control by managing the area below the work, using signage or barriers where needed, and timing higher-risk work to avoid the busiest periods.
