How to Actually Write a WAH Plan

Just a few weeks ago, I wrote about the importance of Work at Height (WAH) Certification and having a written WAH Plan for your facility. That article dove into the details of how the Climbing Wall Association’s WAH Certification Program trains workers to perform tasks in compliance with health and safety regulations. Each certification level aligns with the roles and responsibilities with the OSHA designations for authorized, competent, and qualified people.

That post sparked a flurry of questions in online forums: What exactly do I need to know to write a WAH Plan for my facility? Where can I learn more? Does CWA have any resources?

I asked CWA Routesetting Committee what they thought were the most important things to consider when designing a climbing facility WAH Plan. Here’s what they said… 

What is a WAH Plan, and why should I have one?

In today’s world of liability exposure, if you don’t document something, it doesn’t happen. You might have robust training on the most current industry practices, but if you don’t have those practices written down as policy, you might as well be training your staff with the trailer for Cliffhanger. 

So, what does documentation look like? A comprehensive WAH Plan often resembles a technical manual, including definitions, roles and responsibilities, and policies.  A one-stop-shop WAH Plan is not only convenient when training employees, but it can also be a lifesaver if an inspector ever walks into your facility asking about your WAH operations.

Maybe you’re thinking, “My gym is bouldering only, no ropes!” Anyone working on a ladder is, in fact, conducting work at height. The trigger height for OSHA work-at-height regulations is just four feet, so unless your bouldering walls are only ten feet tall, you still need a written WAH Plan to outline exactly how employees are conducting operations. 

Or maybe you’re thinking, we’ve been doing things the same way for decades, and things have worked fine so far? Why fix something that isn’t broken? The reality is that these systems aren’t working fine.

Most of us who’ve worked for a while in the climbing wall industry know somebody who, at best, has had a close call, if not a life-altering accident. The bigger the climbing wall industry gets, the more people will be working at height, and there is no excuse for sub-standard practices.

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The hard truth? The safety practices that are “new” to the climbing wall industry aren’t new at all; they have been standard practice for other work at height professionals for decades. Early climbing gym operators brought the skills they learned at the crag into the industry, but most of those practices didn’t meet the minimum standard expected for a workplace environment, even then. Work and sport are different.

What should your WAH Plan include?

At the very minimum, your WAH Plan must include a Written Hazard Assessment, a Hazard Protection Plan, a Fall Protection Plan, and a Rescue Plan. These should be written and maintained by a Qualified Climbing Wall Worker and should comply with the CWA WAH Standard, which you can download from www.cwapro.org. The WAH Standard is an invaluable resource, providing clear best practices for conducting WAH operations in an indoor climbing gym. 

Beyond the minimum components we just outlined, your WAH Plan should contain all the information employees need to know to do their job.

Definitions

The climbing wall industry is rife with jargon and colloquialisms, but when it comes to policy, we often need to be specific. What exactly do we mean by “low-elongation rope?” Should we define the diameter of that rope? The more clarity we can provide in the WAH Plan, the less guesswork we leave to employees. 

Guidelines and Policies

Do you permit a single employee to perform work at height by themselves in your facility? Are there age restrictions regarding certain tasks at specific heights? Who is allowed to use the lift, if you have one? Who is allowed to perform tasks behind the wall? Knowing who is allowed to do what is a critical part of any work environment.

Job Hazard Analyses

If you’re struggling to get your WAH Plan off the ground (pun absolutely intended), Job Hazard Analysis documents can be a great place to start. I’d personally recommend starting with the standard OSHA JHA form. It is extraordinarily comprehensive and includes many hazards that may not ever exist in your facility.

However, it will open your eyes to potential hazards and various controls you may want to consider. I personally have added a whistle to my kit because of the “noise hazards” section on that form. If the ambient noise is too loud for my coworkers to hear me in an emergency, now I have a whistle. 

Standard Operating Procedures

How are we performing and documenting PPE inspections? How do we set up our haul system for hold removal? Many tasks within climbing gyms can (and should!) be standardized for ease of training. Standard operating procedures, complete with equipment lists and diagrams, can provide any employees working at height with clear expectations about how their work is performed.

Think hold attachment, hold removal, stuck hold removal, approved ropes systems, hauling…and rescues.

Other Tips and Tricks from the CWA Routesetting Committee

 Writing a WAH Plan is no small task, and the CWA Routesetting Committee had a lot of thoughts about the best ways to go about it. Here are a few more things they thought were important for anyone designing a WAH Plan to consider:

• Don’t just write it, use it! One of the biggest mistakes you can make when creating your WAH Plan is not using it. If you have an inspection log but nobody fills it out, you don’t have an inspection log. Make sure the policies and procedures outlined in your WAH Plan are consistently followed.
• Document Trainings: As you train staff, document that training! Many online learning programs automatically record when users complete a module. Analogue signatures work too. If updates are made to the work at height plan, staff will need to be trained on those updates.
• Make it User Friendly: You’ll also want to make sure that your documentation isn’t easily broken by accidental user error. If you have an inspection spreadsheet that is editable by a dozen employees, it’s easy for formulas and links to get broken, resulting in chaos. Create forms that allow staff without editing privileges to contribute to documents without risking the structure and integrity of those documents.
• Keep an Analog Copy: Digitizing your documentation can provide an easy, searchable resource, but you should also have physical copies of everything. Physical copies can be easier to access and harder to accidentally delete or break. 
• Create a Durable System: Don’t tie critical documentation to a single person. Turnover of staff in climbing gyms can be high. If only one person has access to a document and they leave the company, you might be left in the lurch. Consider using a generic or easily transferable account to access important documents.

Lastly, get support if you need it! In addition to the CWA Work at Height Standard, the Climbing Wall Association has a plethora of educational resources. We host quarterly webinars for gym operators and routesetters where you can ask other industry professionals how they design their programs.

And of course, the CWA provides Work at Height (WAH) and Professional Routesetting (PRS) Certification Programs, which can ultimately teach workers the skills they need to become Qualified Persons, able to write a Work at Height plan that meets the needs of your facility.

About Foxman McCarthy-James

Foxman McCarthy-James is a freelance routesetter with over a decade of commercial and competition-setting experience. She has brought her background in education into her routesetting career, serving as the Routesetting Education Consultant for the Climbing Wall Association and contributing routesetting educational content for the Climbing Business Journal. She is passionate about continuing the conversation on how we can make our industry more welcoming and inclusive.