Regulations & Compliance Matters

Regulations & Compliance Matters #

Lowering bell

During a bell project, various regulations, standards, policies and practices will be encountered. Some of these will be managed by suppliers and contractors but ringers and tower authorities should be aware of the implications as failure to observe them can have serious repercussions.

Requirements related to towers within the Church of England and other jurisdictions are given in a companion document and further requirements related to Health & Safety, Construction Design & Management and Insurance are covered below.

Church Policies and Practices #

Each church will have its own policies and practices but these are unlikely to encompass all the circumstances that will be encountered during a major programme of work in the tower. These should therefore be reviewed during planning and suitable arrangements made that will be applicable for the various stages of the project proposed. It is likely that specific risk assessments will be required for the project. The tower authorities remain responsible for ensuring that appropriate practices are adopted. Contractors will have their own practices for complying with regulations, and specific arrangements must be made for volunteers who may assist.

General Considerations #

Emergency arrangements #

  • While work is underway, there must always be at least 1 volunteer on site who knows the tower and church well
  • At the start of work, and when different people arrive, every individual must be briefed fully
  • A record of who is on site during the work must be maintained, with time and date of arrival and departure for each person
  • Access to basic first aid equipment and accident record book must be available at all times
  • Battery powered lighting should be available in case of power failure
  • Contractors and volunteers must know how to contact emergency services and be able to advise them clearly of the building location
  • A reliable means of communication should be maintained between individuals working on site and those who may need to contact them. Mobile phones may not be adequate if signal strength is poor

CDM (Construction Design and Management) Regulations 2015 #

This section has been prepared in conjunction with Safe Projects Ltd.

The Construction (Design & Management) Regulations 2015 (known as CDM 2015) are the main set of regulations for managing the health, safety and welfare of construction projects. CDM is a UK law that applies to all building and construction work and includes new build, demolition, refurbishment, extensions, conversions, repair and maintenance. The full text of the law may be seen here.

Work for churches is governed by these Regulations and work to bells, whether major rehangs or minor maintenance work by contractors, comes within its remit.

The great majority of ringers will not encounter CDM, but those that are involved with bell restoration work should be aware this law exists; and if the PCC for which the work is being undertaken knows nothing about it, they should be informed, as they too, are involved.

The Regulations assign responsibilities to various duty holders, which are: Client, Designer, Principal Designer and Principal Contractor. The PCC will be the Client in most cases, the Designer will be the person or company who formulates the design of the work (for example, replacement bell frames, new floors, etc), and where there is more than one contractor, the Principal Contractor will, in most cases, be the bell hanging company that is to undertake the work.

These roles have lawful responsibilities, each duty holder having responsibility for co-ordinating the work of other duty holders (for example, sub-contractors) undertaking similar but lesser roles in the project. PCCs are normally advised by the professional designer (for example, the Church Architect), who is managing the project for them - but this is rarely the case for bell-related projects, as most do not include the Architect. This might imply CDM does not apply to bell projects – it does – but many projects are short term on site and therefore do not come within the requirement to notify the project to the Health & Safety Executive (HSE).

The requirement to notify the HSE of a project becomes necessary if the construction work on site is scheduled to:

  • last longer than 30 working days and have more than 20 workers working simultaneously at any point in the project or
  • exceed 500 person days.

It is only major bell projects that exceed these parameters (but such projects do exist).

However, while this might seem like a get-out clause for doing nothing, this is not the case. The Regulations demand, regardless of whether a project is notifiable or non-notifiable, that the Client produces a Pre-Construction Information (PCI) document for a project before the site work starts, and in turn the Principal Contractor must provide a Construction Phase Plan (CPP), which is reviewed by the Principal Designer on behalf of the Client. The Regulations require the PCI to be compiled in a way that is appropriate to the scale and complexity of the work being undertaken, in terms of relevant information being passed between the parties prior to the work starting, and thus non-notifiable work will generally include basic information rather than that needed for larger projects.

Relevant HSE Documents #

The United Kingdom Health & Safety Executive produces a wide range of relevant documents which are grouped here for convenience. While the documents have no legal standing outside the UK, the information provided may be useful in other jurisdictions.

Health and Safety in Construction #

This free-to-download version of a printed edition is aimed at the small contractor but also applies to everyone involved in construction. It provides help and assistance on how to work safely on most tasks you will encounter. It will also help to identify the main causes of accidents and ill health and explains how to eliminate hazards and control risks. The guidance is simple but comprehensive. The solutions are straightforward and easy to adopt.

Personal Protective Equipment #

Regulations covering the use of personal protective equipment (PPE) at work first came into force in 1992 (PPER 1992). These were amended in 2022 (PPER 2022). A free pdf download provides practical advice on how you can comply with the requirements of PPER 1992 as amended by PPER 2022. See also the relevant section in Belfry Upkeep.

Lifting Operations & Lifting Equipment #

This document describes the Lifting Operations and Lifting Equipment Regulations 1998 (often abbreviated to LOLER). These place duties on people and companies who own, operate or have control over lifting equipment. This includes all businesses and organisations whose employees use lifting equipment, whether owned by them or not.

Provision and Use of Work Equipment Regulations 1998 #

This document describes regulations placing duties on people and companies who own, operate or have control over work equipment. The scope of work equipment is extremely wide, covering any machinery, appliance, apparatus, tool or installation for use at work (whether exclusively or not). This includes equipment which employees provide for their own use at work.

Control of Noise at Work Regulations 2005 #

Guidance on these regulations is available as a free PDF download. In general, workers on an installation project will not be subject to damaging noises, except when bells, with clappers present, are swung as part of testing. Any workers present during this must be equipped with suitable ear defenders or earplugs.

Even though bellringing may be suspended during the work, it is helpful for neighbours to be alerted that unusual noises from equipment and machinery may disturb them.

Work at Height Regulations 2005 #

The purpose of the work at height regulations is to prevent death and injury caused by a fall from height.

Control of Substances Hazardous to Health Regulations 2002 #

These regulations (usually abbreviated to COSSH) require employers to control substances that are hazardous to health. There may be hazardous substances in towers, for example asbestos was often used as pipe insulation. Bat and bird droppings are highly likely in towers and pose risks to health. Further information is given here.

Any materials used in the course of the work must be disposed of appropriately. See here.

Reporting of Diseases and Dangerous Occurrences Regulations 2013 #

These regulations (usually abbreviated to RIDDOR) put duties on employers, the self-employed and people in control of work premises (the Responsible Person) to report certain serious workplace accidents, occupational diseases and specified dangerous occurrences (near misses).

The Church should already have an accident reporting system.

Fire protection #

Use of tools and certain materials can increase the risk of fire. Will fire exits be blocked necessarily during the work? If so, what alternative arrangements can be made and how are they to be notified to building users? Advice is provided here.

Electrical supplies #

Contractors will usually make use of the church electrical supplies so these need to be checked that they are adequate for power tools. Fuse boxes and electrical mains connections should be made known to contractors so that they can isolate circuits if required. Contractors may need to bring their own generators and lighting equipment. Safety guidance on the use of electrically powered equipment is given here.

Access During the Project #

The usual tower access may not be appropriate for work during a project so there may be a need for the permanent installation of walkways and steps. Temporary scaffolding or a scaffold tower may also be hired. Flooring will need to be strong enough to support the scaffold and suitable protection for fragile surfaces such as tiles may be essential. Note that scaffolding has to be inspected periodically during work and tagged. Ladders, gantries and platforms must all comply with legislation.

Scaffolding and ladders erected will make access easier to parts of the building that are not normally accessible. Additional security precautions may be necessary along with checks of insurance policies. One insurer provides a questionnaire for completion with their requirements for scaffold security.

Remember that scaffolding is expensive so minimise the period during which it will be installed.

Welfare Facilities #

Adequate washing, changing and eating facilities should be provided for contractors and volunteers. If not available in the church or adjacent building then it may be necessary for suitable facilities to be hired during the project. Local ringers will be able to suggest convenient and suitably priced overnight accommodation for contractors.

Insurance #

Information about insurance and ringing is available here. For bell projects more specifically, the church policy may need extension to cover bell projects and insurers should be informed of the work being undertaken.

Local volunteers are often used (with agreement of the bell hanger) to reduce the cost. Such volunteers working with the authority of the church may be covered by the church but this must be confirmed, particularly if the volunteers are under 18 or of more mature years.

Additional insurance cover may be required at certain stages, for example when the bells are at ground level in the church and hence more at risk of theft.

Security #

During a project, additional people may be loaned keys or given key codes. Ensure that there are arrangements made to enable access, but that security will be maintained, with keys returned on completion of the project or combination codes changed.

Lightning Protection #

Lightning protection may be disrupted or altered during the work. For example, a metal bell frame will need to be bonded to a lightning conductor. Specialist contractors will advise on temporary or permanent arrangements. More detailed information is provided here.

Safeguarding #

If young people (under 18) participate in events or act as volunteers in any way during the project then the church safeguarding policy must be followed.

GDPR (General Data Protection Regulations) #

The church should have a defined process for managing personal data and information. Specific arrangements must be made for how project data will be managed during and after the project.

Related to this is filing systems and record keeping. A project will amass a lot of correspondence and documents. Much of this will be electronic but there will also be some that is still paper based. The project team will need to establish and adopt systems, that can be understood by not just the primary user but also other agreed users. Some information, for example, contract quotes, funds donated, may be marked as confidential so must be managed appropriately.

Protected Wildlife #

Church towers may be home to various forms of wildlife, some benign, some damaging. Some are protected – bats certainly, and some species of birds. Advice on this is given here.

Other Issues to Consider #

  • Depending on the location of the tower and the surrounding road infrastructure, special arrangements may be required with highways authorities and neighbours to enable vehicle access sometimes several at one time, manoeuvring and parking, including for larger cranes and lifting gear.
  • Churches will normally expect to continue their normal activities as much as possible while work is underway. Contractors will plan for equipment and tools to be cleared at appropriate times, or alternative arrangements made. Narrow doorways, monuments, timberwork and other objects that cannot be removed during the work, will need careful protection.
  • Inevitably, any work in the tower will generate dust and debris. An organ, for example, will be particularly vulnerable and may need to be protected; organ builders are accustomed to providing this service. Protective sheeting, flooring and “tack mats” will be required, and extra cleaning support will help with keeping dust levels down throughout the work. Bell hangers are familiar with the likely risks and should advise.
  • Some contractors will include specific requirements in their contract documents so these need to be noted and adhered to.

Image Credits #

TitleBell project at Great Malvern Priory © Simon Mellor

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Disclaimer #

Whilst every effort has been made to ensure the accuracy of this information, neither contributors nor the Central Council of Church Bell Ringers can accept responsibility for any inaccuracies or for any activities undertaken based on the information provided.

Version 1.1, August 2023

© 2023 Central Council of Church Bell Ringers