Risk analysis for aerial work platforms under the Code on Well-being at Work: the guide for site managers

Before the first scissor lift or articulating boom lift stands on a site, a document must exist that many contractors underestimate: the risk analysis. It is not a formality but, under the Code on Well-being at Work, Book IV (work equipment), the precondition for using work equipment such as an aerial work platform or a telehandler at all. Anyone who carries it out incorrectly or not at all runs a personal liability risk in the event of damage – regardless of whether the rented machine itself was technically flawless.

For site managers and prevention advisers, a question therefore arises before every enquiry to Luibl Rental that starts well before machine selection: what hazards does the specific job location present, and which measures must be in place before the operator first gets on? This guide takes you step by step through the process and shows how the analysis concretely affects the choice of the right access equipment.

Belgian well-being at work legislation (Act of 4 August 1996 and the Code on Well-being at Work) requires the employer, or the site manager responsible on site, to identify and assess all associated hazards before using a piece of work equipment for the first time. This expressly also applies to rented machines: responsibility for assessing the specific job location remains with the operator, i.e. the renting company – not with the rental company. Luibl Rental supplies a technically inspected machine, but whether that machine is suitable for the site, the ground and the weather conditions must be assessed and documented by the operator.

This responsibility cannot be delegated without being transferred in writing. If a foreman or charge hand is tasked with carrying it out, this assignment must be documented just like the analysis itself. If the document is missing during an inspection by the Well-being at Work Inspectorate (FPS Employment), the risk analysis is considered not to have been carried out – even if work on the site was in fact safe.

The procedure follows a fixed scheme that can be made concrete for the use of aerial work platforms and telehandlers. First, all hazards that may occur at the planned job location are identified: the load-bearing capacity of the ground, possible wind loads outdoors, the proximity of overhead lines, traffic areas nearby and any fall edges or floor openings. Only when this list is complete does the assessment follow – that is, estimating how likely a damaging event is and how serious the possible consequences would be.

Based on this assessment, specific measures are defined in the third step. This is where the so-called TOP principle applies, which sets the order of permissible protective measures: technical measures before organisational measures before personal protective equipment. For an aerial work platform this means in practice: first check whether a technical solution such as outrigger pads for load distribution or an automatic wind sensor cut-off can eliminate the hazard. Only if that is not enough do organisational measures follow, such as barriers and time windows for the work, and finally personal fall protection as the last level of safety for the operator.

In the fourth step, the defined measures are actually implemented and communicated to everyone involved – in particular the operator of the aerial work platform. The fifth and often neglected step is checking effectiveness: the process is only complete once it has been verified that the measures actually work in everyday site practice. If conditions change – for example because a second construction phase begins or the ground changes due to the weather – the analysis must be updated.

The specific hazards differ considerably depending on the machine used, which is why a general analysis without reference to the machine is usually inadequate in practice. With scissor lifts indoors, the focus is mainly on the floor load from the point loads of the wheels and the ceiling height, while with diesel scissor lifts outdoors, wind load, uneven ground and the need for outrigger pads also become relevant. Articulating boom lifts, with their ability to reach sideways over obstacles, bring a different hazard category: here the analysis must cover the entire slewing range of the boom, including possible collisions with facade elements or lines.

Spider lifts are used specifically on difficult or sensitive terrain, for example in green areas or on historic floors – here the risk analysis shifts more towards ground pressure and surface load. With truck-mounted platforms, a traffic-law component is added, because a set-up position on or next to public roads entails additional safeguarding obligations under the Belgian Highway Code. If you are unsure which hazard category applies to your project, the Luibl Rental aerial work platform category overview provides the key technical data of all platform types as a starting point for your own analysis.

The risk analysis does not stand alone, but forms the basis for two further obligations that are closely linked in practice. It directly determines which qualification the operator must have: if the analysis shows that an articulating boom lift with high slewing dynamics will be used, you must ensure that the assigned operator holds the appropriate IPAF category. Details on the individual categories and designation by the employer are summarised in the guide to the IPAF operator licence.

The risk analysis is likewise related to the technical inspection of the machine, but does not replace it: the periodic inspection establishes that the machine itself is safe, while the risk analysis assesses whether its use at the specific location under the specific conditions is safe. Both documents are required independently of each other during an inspection. The guide to the periodic inspection of lifting equipment explains in detail how inspection documentation is organised at Luibl Rental and which records must be kept with the machine.

A risk analysis carried out only verbally has no evidential value in court or during inspections by the Well-being at Work Inspectorate. The report must contain the job location and period, the hazards identified, the measures defined according to the TOP principle, the responsible person and the date of the effectiveness check. The document is signed by the person who carried out the analysis, usually the site manager or a specialist appointed by them in writing.

Keep the report at least for as long as the work equipment is in use and in any case until the end of the works concerned. For recurring, comparable deployments – for example when the same scissor lift is regularly used in the same factory hall – an existing analysis can serve as a template, but it must be reviewed and updated whenever the conditions change significantly.

To help site managers get started, Luibl Rental provides a compact checklist that summarises all relevant check points for using aerial work platforms and telehandlers in the right order – from assessing the ground and wind limits to the documentation template according to the TOP principle. The checklist does not replace an individual on-site analysis, but it provides a solid structure so that even site managers without a daily safety routine do not overlook any relevant check point.

Once the risk analysis is complete, it is usually also clear which machine category meets the requirements: an electric scissor lift for dust-free work in a hall, an articulating boom lift for work over obstacles or a spider lift for sensitive outdoor surfaces. Luibl Rental delivers the right machine throughout Belgium with a valid inspection sticker and helps with questions on machine selection, so that the technical measures defined in the analysis can actually be implemented. At handover, the operator receives an operator briefing on site.

Do I really have to draw up a risk analysis myself for a rented machine? Yes. Responsibility for the risk analysis lies with the operator, i.e. the renting company, regardless of whether the machine was bought or rented. Luibl Rental provides a technically inspected machine; assessing the specific job location remains the task of the site manager.

Is one general risk analysis enough for all sites? No. Because ground, weather and surroundings differ from one job location to the next, the analysis must be reviewed for every new location and adapted in case of significant differences.

What happens if no risk analysis is available during an inspection? If the document is missing, the analysis is considered not to have been carried out. This can lead to penalties, an immediate ban on use and, in the event of damage, personal liability of the person responsible.

How does the risk analysis differ from the periodic inspection? The periodic inspection confirms that the machine itself is technically safe. The risk analysis assesses whether using this machine at the specific location under the specific conditions is safe. Both records are required independently of each other.

Who may carry out the risk analysis? In principle the employer or a competent person appointed in writing, such as a site manager or a prevention adviser. The appointment must be documented.

The Luibl Rental team answers questions about the right machine category for your assessed job during service hours, Mon–Fri, 08:00–17:00.

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