4.2 Risk Assessment, Method Statements, Height and PPE

4.2 Risk Assessment, Method Statements, Height and PPE

A 2922-34 installer does not turn up and see how it looks. Before anyone steps on a roof or opens a DC isolator, a risk assessment (RA) and a method statement must describe how the system will be installed or maintained. The RA identifies who could be harmed and how. The method statement sets the logical sequence, the personal protective equipment (PPE), and the safety procedures that keep those people out of harm. Both documents must be specific to the site. Copy-pasting a generic RAMS pack that never mentions this terrace, this occupied dwelling, or this school-run pavement is not planning. Independent study for 2922-34 treats RAMS as part of competence, not paperwork to be filled after the job.

Producing a risk assessment for install and maintain

Handbook 2.1.1 expects an RA that covers, as a minimum, PPE, manual handling, work at height, control of access, and adverse weather. On real PV jobs those headings interact. A wind hold is also a manual-handling control. A scaffold gate is also an electrical control, because it stops a householder reaching an open DC connector at the eaves.

PPE. Specify equipment against the task, not a single all-day uniform. Hard hat or bump cap where there is a struck-by risk from above or from module corners. Footwear with grip on wet membranes and frost. Gloves that allow connector work without sacrificing cut protection on glass and rail. Eye protection when drilling, cutting rail, or working near possible DC arcs. Hearing protection for SDS drilling into masonry. A harness only as part of a planned work-at-height system with identified anchors and a rescue plan, not as a substitute for edge protection. High-visibility clothing matters when the pavement is a school entrance. Jewellery, uninsulated watches, and loose drawcords are snag and shock hazards around live DC.

Manual handling. A modern module is often around 20 kg, awkward, glass-faced, and a sail in the wind. Rails, inverters, batteries, and ballast add more. Plan the route from van to roof. Loft hatches are not a default path for a 1.8 m laminate. Use two-person lifts, lifting aids, and staging. Do not carry modules up an unsecured ladder. On a terrace, the handling route may be through a neighbour's airspace or over a shared valley; the RA must name that route rather than hoping it appears on the day.

Work at height. The Work at Height Regulations 2005 require a hierarchy: avoid height if you can; then prevent falls with scaffolds, towers, or mobile elevating work platforms (MEWPs) and edge protection; then minimise consequences. Fragile coverings — old asbestos-cement sheets, rooflights, fibre-cement, badly fixed tiles, degraded felt — are a PV classic. Never assume a roof is a platform. Crawl boards, roof ladders, and designated walkways exist because people have gone through coverings. Edge protection must be in place before modules become a trip and a sail at the eaves. Lone work at an open eaves with no exclusion below is not a competent plan.

Control of access. Occupied homes contain children, pets, delivery drivers, and visiting relatives who will use the loft. Terrace roofs share party walls, neighbouring windows, and sometimes a continuous valley. A school next door means safeguarding, pavement congestion at drop-off, and people who will walk under a ladder if you let them. Barriers, signage, a defined exclusion zone under the eaves, locked loft hatches, and a named person controlling the scaffold gate are controls, not niceties. Temporary 110 V tools still need residual current protection and leads that do not create a trip on the only fire escape.

Adverse weather. Wind turns every module into a kite and every sheet of covering into a projectile; it also loads unfinished arrays and scaffolding. Wet roofs are slip and shock together. Ice hides fragility and kills grip. Lightning means get off the roof and stay off until the storm has passed — an array is a collection of conductors on the highest part of the building. Heat adds dehydration and burns from module backs. The RA should state hold points: what wind speed stops lifting, what rainfall stops electrical making-off, who has authority to call the job. A method statement that says use common sense is not a hold point.

Asbestos awareness and waste equipment

Handbook extra material includes asbestos awareness and waste equipment transport and disposal. Many UK roofs that look like ideal PV are pre-2000 coverings, soffits, flue cement, or textured coatings that may contain asbestos. You are not an analyst, but you must not drill, cut, or walk through suspect material. If the RA cannot confirm the covering is non-asbestos, stop and get a competent asbestos survey before disturbing it. Walking a cement sheet because the modules have to sit there is how PV jobs become asbestos incidents.

Waste is part of the job, not an afterthought. Damaged modules, replaced inverters, old generation meters, cable off-cuts, and packaging are waste. PV panels and inverters fall under waste electrical and electronic equipment (WEEE) duties. Plan how failed equipment leaves site: suitable wrapping for broken glass, no unsecured modules on a van roof, no fly-tipping of silicon and aluminium, and a documented route to an authorised handler. Battery waste on hybrid jobs is a separate chemical and fire hazard and must not ride loose in a mixed scrap bag.

Where the work is construction under the Construction (Design and Management) Regulations 2015, the RA sits inside a wider duty to plan, manage, and coordinate. A domestic retrofit is still work at height and still electrical work. Calling it a small job does not delete those duties.

Method statement: sequence, PPE, procedures

Handbook 2.1.2 wants a method statement with a logical sequence, appropriate PPE, and safety procedures. Sequence is where PV jobs go wrong electrically. The statement must not allow DC connectors to be unmated under load. That means the written order is: set up access and exclusion; verify weather hold points; shut the inverter down using its internal control; isolate DC at devices that are suitable for switching on load, or confirm no load; isolate inverter AC input and output and other AC sources; prove dead; lock off and label; then mechanical or connector work; then reverse the sequence to re-energise.

If the sequence says unplug the string so the inverter stops, it is wrong. Unplugging under load is an arc. If the sequence says the scaffolder will sort height and we just do electrics, it is wrong. You cannot make off DC at the eaves over a public pavement without owning the access control. PPE in the method statement should match the RA task by task: harness specification and anchor points for the roof; gloves for connector work; residual-current protection for temporary 110 V tools; and a rule that uninsulated tools stay off live DC.

Rescue from height belongs in the statement, not in a toolbox-talk after someone is hanging. Who calls the emergency services, how a casualty is reached on a terrace with a narrow pavement, and how DC is left isolated during a rescue are planning items.

Scenario: terrace roof, occupied dwelling, school hours

A three-storey terrace, family in occupation, primary school opposite, install during term time. The RA should record: fragile or unconfirmed coverings; falls from the front eaves onto the pavement; objects dropped onto parents at pick-up; children attracted to scaffold; neighbours' roof access; party-wall noise and dust; DC connectors at the eaves within reach of a determined climber; asbestos uncertainty in soffits; module handling up a narrow stair if the loft is used; and weather funnelling along the terrace.

Typical controls: independent scaffold with ladder gates, debris netting, and a pavement licence if required; work windows that avoid drop-off and pick-up, or a banksman and full exclusion; occupant briefing — no loft access, pets in, windows on the elevation closed; neighbour notice; asbestos check before drilling soffits; two-person module lifts from the scaffold, not through the house if stairs are tight; DC isolation and prove-dead before any connector work; no unattended open DC at the eaves; WEEE plan for the old inverter if this is a replacement. School hours are not a reason to rush isolation. Relying on the householder to keep children off the scaffold because it is a private dwelling is not a control. Leaving connectors accessible at gutter level so a teacher can see work in progress is an invitation to interference.