Working at Height and High-Level Shelving Access: What the Regulations Require Beyond Steps

Buying a certified set of steps feels like the job is done. It isn't. The Work at Height Regulations 2005 don't start from "which steps should we buy," they start from a question most businesses skip entirely: should anyone be climbing to reach this shelf at all.

What the Work at Height Regulations Actually Require

The Work at Height Regulations 2005 place duties on employers wherever work is done in a place from which a person could fall a distance liable to cause injury, which includes routine picking from high-level shelving and racking, not just obvious tasks like roof work or scaffolding. The regulations require a proper risk assessment before anyone works at height, not a general assumption that steps make it safe.

The Hierarchy: Avoid, Prevent, Minimise

The regulations set out a clear order of preference, and it matters that it's an order. First, avoid work at height altogether where reasonably practicable. Second, where it can't be avoided, use equipment or measures that prevent a fall, collective protection like guard rails ahead of anything personal. Third, where a fall still can't be prevented, minimise the distance and consequences of a fall. Steps sit relatively late in that hierarchy, not at the start of it.

Why "Just Get Some Steps" Skips Two Steps

Reaching straight for steps as the solution to high-level picking quietly skips the first two parts of the hierarchy: could this item be stored lower down instead, and is there a way to prevent a fall entirely rather than just accessing the height safely. For genuinely rarely-picked stock, reorganising a layout so the top shelf holds only what's needed a few times a year can remove the need to climb at all, which is a stronger control than any piece of equipment.

When Steps Are the Right Answer

Once avoidance and prevention have genuinely been considered and picking from height is still necessary, the right equipment matters enormously, and this is where certification earns its keep. Our guide to BS EN 131-7 access steps covers what that certification actually means and why it matters for the specific case of mobile platform steps. That piece is about choosing the right product once steps are the appropriate control; this one is about establishing that they are.

Training and Assessing Who Can Access High-Level Storage

The regulations also expect that people working at height are competent to do so, which for warehouse and stockroom picking means proper training on the equipment provided, not an assumption that anyone can safely use a set of steps because the instructions look simple. Restricting high-level access to trained staff, rather than leaving it open to whoever's nearest, is a straightforward control that costs nothing beyond the training itself.

Layout Choices That Reduce the Need to Climb at All

The most effective long-term fix is often a layout decision rather than an equipment purchase: keeping frequently picked stock within normal reach, and genuinely rare or bulk stock at height where it's retrieved occasionally with proper equipment rather than climbed for daily. Adjustable shelving makes this kind of rebalancing straightforward to revisit as picking patterns change, rather than being locked into whatever configuration was installed originally.

Final Thoughts

Steps are part of the answer, not the starting point. Work through avoidance and prevention first, and the times anyone actually needs to climb should be fewer than they look at first glance, and properly controlled when they do happen.