Look Up Look Out

Industry guidance: safety expectations, product claims and transparency look up look out

Look Up Look Out National Safety Campaign — balanced industry guidance on telescopic pole safety claims, UK standards context, consumer protection, and transparency. General information, not legal advice.

If cables feel unsafe, stop work and call 105 (Great Britain). In an emergency, call 999.

Campaign position: The Look Up, Look Out National Safety Campaign is not positioned against consumers, manufacturers, retailers, distributors, or any individual product. The campaign aims to act as a fair referee between all parties: encouraging clear rules, clear claims, clear evidence, and safer decision-making. Consumers and industry users should understand what safety-related claims mean, and responsible suppliers should have a fair opportunity to explain the basis of those claims clearly. In short, this campaign is not here to take sides. It is here to help make sure everyone understands the risks, the responsibilities, and the information needed to make safer decisions.

Purpose of this guidance

This guidance has been prepared to support safer decision-making across the window cleaning, exterior cleaning, and telescopic pole industries.

It is intended to encourage clearer safety information, greater transparency around product claims, and a better shared understanding of what UK consumer protection principles may expect where products are marketed for use in environments where overhead electrical hazards may be present.

Telescopic and water-fed pole systems are widely used across the UK. Many are used professionally every day, often safely and responsibly. However, where a known hazard exists - especially one involving overhead electricity - the industry has a shared interest in ensuring that claims, warnings, testing information, and product descriptions are clear, accurate, and capable of being understood by ordinary users.

This guidance is general industry information. It is not legal advice, and it does not make findings about any individual company, product, manufacturer, distributor, or retailer.

Current position in the UK: no dedicated pole standard

At present, there is no dedicated UK testing standard specifically written for telescopic or water-fed pole systems in relation to electrical insulation, electrical contact, or use near overhead power lines.

BS 8020:2011 is an existing British Standard for tools for live working. It is described by BSI as a specification for insulating hand tools used for work on or near conductor rail systems operating at voltages up to 1000 V a.c. or 1500 V d.c. It was not written specifically for telescopic or water-fed cleaning pole systems.

The issue has also been raised in Parliament. In the House of Commons debate on window cleaning industry workplace safety on 17 December 2025, Dr Andrew Murrison, Jason's local MP who has been championing his cause highlighted the absence of a mandatory British standard governing the electrical insulation of telescopic cleaning poles and discussed whether BS 8020 should be amended or extended. In the Government response, Sir Stephen Timms noted that the relevant BSI committee had rejected the application to include water-fed poles in BS 8020 because it regarded that standard as intended for tools used by trained live-working personnel, not for water-fed cleaning work near live cables.

That context matters. BS 8020 may contain useful concepts, and parts of it may inform future thinking, but it should not currently be presented as a complete or settled UK standard for water-fed poles.

The absence of a dedicated water-fed pole standard creates a practical challenge for manufacturers, distributors, retailers, and users. It means there is currently no single agreed UK benchmark against which all electrical safety claims for these products can be measured.

However, the lack of a dedicated UK standard does not mean the industry should do nothing. Where a serious and foreseeable electrical hazard exists, responsible interim steps may include independent testing, clearer product information, safer design review, improved warning durability, transparent explanation of limitations, and continued engagement with standards bodies, regulators, and industry stakeholders.

In that gap, testing carried out in the UK or internationally may still provide useful supporting evidence that a manufacturer has actively considered electrical risk. The key point is transparency: users should be able to understand what was tested, how it was tested, what conditions applied, and what the test results do - and do not - prove.

The campaign does not rank one credible testing route as automatically better than another in the absence of a dedicated UK benchmark. Different methods may serve different purposes. What matters is that claims are not vague, exaggerated, or unsupported, and that users are not left to assume more protection than has actually been demonstrated.

Absence of a dedicated standard does not mean absence of responsibility

The absence of a dedicated UK standard may explain why companies are taking different approaches to testing, design, warnings, and product information. It should not be misunderstood as an absence of responsibility.

Under the General Product Safety Regulations 2005, producers are required to place only safe products on the market and to provide consumers with relevant information to help them assess risks where those risks are not immediately obvious.

Under Section 3 of the Consumer Protection Act 1987, a product may be considered defective if its safety is not such as persons generally are entitled to expect, taking all the circumstances into account. Those circumstances may include how the product is presented, marked, warned about, instructed for use, and what might reasonably be expected to be done with or in relation to the product.

Therefore, a company should be cautious about treating the absence of a dedicated water-fed pole standard as a reason for inaction. Where a known and foreseeable electrical hazard exists, it may be relevant to ask what reasonable steps were taken to reduce risk, improve product information, support safety claims, and review whether safer design approaches were available.

Equally, manufacturers and retailers should not be unfairly criticised simply because they use an interim or international testing route while the UK has no dedicated standard. If testing has been carried out, and if the scope, method, voltage, conditions, and limitations are clearly explained, that may help demonstrate that the risk has been actively considered.

The balanced position is this: until a dedicated UK standard is created, adopted, and widely recognised, the industry should not wait for perfection before taking reasonable steps to improve safety transparency and reduce foreseeable risk.

What "defective" means under the Consumer Protection Act 1987

In everyday language, people often think a "defective" product means something that is broken, badly made, cracked, faulty, or not working.

In legal terms, the meaning is broader.

Under Section 3 of the Consumer Protection Act 1987, a product may be considered defective if its safety is not such as persons generally are entitled to expect. This means the question is not only whether the product functions as intended. The question is whether, taking all the circumstances into account, the product provides the level of safety the public are reasonably entitled to expect.

Those circumstances can include how the product is marketed, how it is described, the warnings and instructions supplied with it, the way it is likely to be used, whether risks are obvious or hidden, what level of knowledge an ordinary user is likely to have, and whether safer design approaches or clearer information are available.

So, in plain English, a product does not have to "fail" mechanically to raise a product safety concern.

A product might work exactly as designed, but still raise questions if the level of safety, warnings, design, or information provided does not match what users are entitled to expect in the real-world circumstances in which the product is likely to be used.

For telescopic and water-fed poles, the issue is not simply whether the pole extends, collapses, cleans windows, or performs its normal function. The wider issue is whether the product, its claims, its warnings, and its supporting information properly reflect the seriousness of the known electrical hazard.

Warnings are important, but they may not be the whole answer

Warnings, labels, instructions, and training are all important. No responsible campaign would suggest otherwise.

However, warnings should not be treated as the only possible safety measure where a serious and foreseeable risk is known.

If a product is likely to be used outdoors, at height, around buildings, near service cables, or in environments where overhead electricity may be present, then the risk is not remote or imaginary. It is part of the real-world working environment.

A warning label saying "do not use near overhead power lines" may be necessary. But the wider safety question is whether the warning, the design, the marketing, and the supporting information together give users a fair and realistic understanding of the risk.

Good safety practice does not rely only on perfect human behaviour. It considers foreseeable human error, poor visibility, weather, fatigue, distraction, site layout, trees, building angles, and lack of experience. In real life, people do not always see every hazard in time. Safety systems should recognize that reality.

Durability of safety warnings

Under the General Product Safety Regulations 2005, producers are required to place only safe products on the market and to provide consumers with relevant information to help them assess risks where those risks are not immediately obvious. Official product safety guidance also refers to consumers being able to assess risks throughout the normal or reasonably foreseeable period of use of the product.

For telescopic and water-fed poles, safety warnings are therefore not only important when the product is new. Where a warning is relied upon to communicate a serious risk, including the risk of contact with overhead electrical lines, manufacturers, distributors and retailers should consider whether that warning remains visible, legible and understandable during normal and reasonably foreseeable use.

These products are often handled daily, used in wet conditions, extended and collapsed repeatedly, exposed to dirt, cleaning chemicals, sunlight, vehicle storage, friction and general wear. If a warning is applied only by surface printing, transfer, sticker or similar method, there is a risk that the warning may become faded, damaged, peeled away or illegible over time.

Where that happens, a later user may no longer see the safety message at the point of use. This may be particularly important where the product is used by employees, temporary workers, new starters, second-hand users, or anyone unfamiliar with the original instructions.

This may also be relevant under Section 3 of the Consumer Protection Act 1987, which considers whether the safety of a product is such as persons generally are entitled to expect, taking all the circumstances into account. Those circumstances may include the way the product is presented, marked, labelled, warned about, and instructed for use.

The campaign does not suggest that any particular labelling method is automatically unsuitable. However, where safety warnings form part of the product's risk-control approach, manufacturers and suppliers are encouraged to review whether those warnings are durable enough for the expected working life of the product, or at least for any guarantee period or period of normal expected use.

Possible approaches may include protected labels, embedded warnings, repeated warnings, more durable marking methods, clear protective layers, replacement warning-label guidance, or other methods that help ensure the warning remains available to the user.

This is a practical product safety issue. A warning can only help prevent harm if it remains present, visible and readable when the product is actually being used.

Consumer protection and misleading information

The Consumer Protection from Unfair Trading Regulations 2008 are relevant where products are marketed or sold to consumers and trade users.

In simple terms, traders should not give misleading information, hide important information, or present information in a way that is likely to deceive the average consumer.

This does not mean every technical detail must be published in full. Companies may have legitimate commercial reasons for protecting detailed test reports, proprietary designs, or confidential development work.

However, where a company makes a safety-related or performance-related claim, users should be given enough information to understand the basis and limits of that claim.

A short claim may look impressive in marketing, but without context it may not tell the user enough to make an informed decision. The stronger the safety impression created by the wording, the stronger the need for clear supporting explanation.

Online listings and point-of-sale safety information

Where telescopic or high-reach pole systems are marketed or sold online, clear safety information at the point of sale is important. A buyer should not have to purchase a product first before discovering a serious and foreseeable electrical risk.

Where a conductive pole is marketed for outdoor high-reach use, the absence of clear information about overhead electricity, power lines, electric shock, arcing, or flashover may raise questions about whether users are being given enough information to make an informed decision before purchase or use.

This may be particularly relevant where products are sold through online marketplaces, third-party sellers, or listings that provide limited technical information. Clear wording in the listing, product description, images, instructions, and product labelling can help reduce misunderstanding.

The campaign does not suggest that every listing must contain every technical detail. However, where a serious non-obvious electrical risk exists, safety information should be visible early enough for the buyer to understand the risk before deciding whether to buy or use the product.

General Product Safety Regulations 2005

The General Product Safety Regulations 2005 require producers to place only safe products on the market.

They also require producers to provide consumers with relevant information to assess risks where those risks are not immediately obvious, and to allow consumers to take precautions against those risks.

This is particularly important where a product may be used in a hazardous environment. Electrical hazards are not always obvious. Overhead service cables may be difficult to see. Weather, poor visibility, fatigue, distraction, site layout, trees, building angles, or lack of experience can all affect whether a user spots a danger in time.

For this reason, product safety should not rely only on ideal use. It should take into account normal and reasonably foreseeable use, including the possibility that a user may make a mistake.

Advertising and substantiation of claims

UK advertising rules are also relevant. Under the CAP Code, objective marketing claims must be capable of substantiation. In plain English, if a company makes a claim that sounds factual and measurable, it should hold evidence to support it before making that claim.

This is especially important for safety-related claims.

Words such as "insulated", "non-conductive", "anti-conductive", "voltage tested", "electrically safer", or "tested to X volts" may create expectations in the mind of the user.

Some of those phrases may mean different things depending on context. That is why supporting explanation matters. If the evidence only relates to a handle section, a material sample, a dry laboratory condition, or a particular voltage test, that limitation should be clear enough for users to understand.

Testing in the absence of a dedicated UK benchmark

Independent testing may help manufacturers, distributors, retailers, and users better understand product behaviour. It may also show that a company is actively considering known risks rather than simply relying on historic practice.

However, testing should be presented carefully. Different tests may not be directly comparable. A test on a material sample is not the same as a test on a full assembled pole. A dry laboratory test is not the same as real-world wet outdoor use. A voltage-withstand test is not necessarily the same as proof of safety near overhead lines.

For that reason, the campaign does not ask users to assume that the biggest voltage figure is automatically the safest option, or that any one non-dedicated test is automatically the final answer. The better question is: what exactly was tested, against what method, under what conditions, and with what limitations?

Testing should therefore be treated as one part of a broader safety approach, alongside clear warnings, honest marketing, product design review, user education, transparent limitations, durable warning information, and ongoing monitoring of incidents, near misses, and industry developments.

Transparency over assumption

The campaign encourages manufacturers, distributors, and retailers to provide clear, meaningful information where safety or performance claims are made.

This is not about forcing companies to publish confidential technical data. It is about giving users enough information to understand the claim being made.

Good transparency protects users. It also protects responsible companies from misunderstanding, exaggerated assumptions, and unfair comparison.

The best position for both sides is simple: if a safety claim is made, the basis of that claim should be clear enough to be understood without guesswork.

Two sides of the same safety coin

This guidance is deliberately balanced. It reminds consumers and industry users that they may ask fair questions about safety-related claims. It also reminds manufacturers, distributors, and retailers that they should be given a fair opportunity to explain what has been tested, what has been improved, and what limits apply.

For users, the message is: do not assume. If a product is described as insulated, voltage tested, non-conductive, anti-conductive, or electrically safer, it is reasonable to ask what evidence supports that description and what the limits are.

For suppliers, the message is: clear evidence and clear explanation help protect everyone. If a product has been improved, tested, labelled, or reviewed, explaining that work properly can help users make informed choices and can help prevent unfair comparison with products making vague or unsupported claims.

The campaign does not direct users to choose one product over another. That choice remains with the individual user or business. The campaign's role is to encourage a fairer conversation, where rights and responsibilities are understood on both sides.

Helping users and suppliers understand safety claims

Where safety-related claims are made, manufacturers, distributors, and retailers are encouraged to provide enough information for users to understand the basis and limits of those claims.

This may include explaining whether a claim relates to a full product, a specific section, a material sample, or a particular test condition. Clear explanation helps users make informed decisions and helps responsible suppliers avoid misunderstanding.

The campaign encourages respectful questions and clear answers. That is how trust is built. The purpose is not to place one side against another, but to make sure the rules of the game are clear to everyone.

Independent testing directory

A global directory of organisations offering potentially relevant testing services is available separately on this website: Independent electrical testing and certification centres directory.

Inclusion in that directory does not represent endorsement by the Look Up, Look Out National Safety Campaign.

The directory is intended as a practical resource for manufacturers, suppliers, and others who may wish to explore testing options in the absence of a single defined UK standard for these products.

Ongoing development

This guidance will be reviewed and updated as UK standards, legal interpretations, testing methods, and industry practices develop.

The campaign welcomes constructive engagement from manufacturers, distributors, retailers, trade bodies, safety professionals, and industry users.

The aim is simple: clearer information, safer decision-making, and fewer preventable incidents involving telescopic poles and overhead electricity.

Questions that may fairly be asked about safety claims

Where a product is described using safety-related terms, the following questions may help both users and suppliers have a clearer conversation:

  • What part of the product was tested?
  • Was the complete pole assembly tested, or only a section, handle, material sample, or component?
  • What voltage, duration, and conditions were used?
  • Was the testing independent?
  • Was the test carried out in dry conditions only, or were wet, dirty, worn, aged, or contaminated conditions considered?
  • Does the claim relate to accidental contact, flashover risk, insulation resistance, material behaviour, or something else?
  • What does the test prove?
  • What does the test not prove?
  • Are there any limitations users should know about?
  • Is a certificate, test summary, technical note, or clear explanation available?

Relevant UK frameworks referred to in this guidance

  • Consumer Protection Act 1987, particularly Section 3, which defines a defective product by reference to whether its safety is such as persons generally are entitled to expect, taking all the circumstances into account.
  • Consumer Protection from Unfair Trading Regulations 2008, including rules relating to misleading actions and misleading omissions in commercial practices, including where important safety information is omitted, hidden, or presented in a way that could affect a buyer's decision to purchase or use a product.
  • General Product Safety Regulations 2005, including the obligation to place only safe products on the market and to provide consumers with relevant information to assess non-obvious risks throughout the normal or reasonably foreseeable period of use, not only when the product is first supplied.
  • Health and Safety at Work etc. Act 1974, including duties on designers, manufacturers, importers, and suppliers of articles for use at work to ensure, so far as reasonably practicable, that equipment is designed and constructed to be safe when being set, used, cleaned or maintained, and to provide adequate information about safe use.
  • UK Advertising Codes/CAP Code principles, including the requirement that objective marketing claims capable of substantiation should be supported by documentary evidence before they are made.
  • British Standards context, including the current absence of a dedicated UK electrical-insulation standard specifically written for telescopic or water-fed cleaning poles, and the ongoing public discussion about whether existing standards such as BS 8020 or other standards should be amended, extended, or supplemented.

Note: This guidance is intended to help explain safety transparency principles in plain English. It should not be treated as formal legal advice.

The following official or recognised references support the legal framework and standards context discussed in this guidance: