Individual/Organisational name: Civil Contractors Federation

What state/ territory are you from? Across Australia

Model Work Health and Safety Codes of Practice - Public Comment Response Form

1)First Aid in the Workplace
Comments due by Friday, 18 November 2011
Comments:(Please include section/page numbers).
Foreword
Page 3 Para 2
An approved code of practice is a practical guide to achieving the standards of health, safety and welfare required under the WHS Act and the Work Health and Safety Regulations (the WHS Regulations Part 3.2 Division 3 First Aid - include
1.2What is required in providing first aid?
Page 4 last para
Identifying all reasonably foreseeable hazards and understanding the level of risk associated with those hazards will help you decide what first aid equipment, facilities and services.....
What is the definition of foreseeable?
2.2Size and location of the workplace
Page 7 para 4
The distance of the workplace from ambulance services, hospital and medicalcentres should be taken into account when determining your first aid requirements. For example, if life-threatening injuries or illnesses could occur and timely access to emergency services cannot be assured, a person trained in more advanced first aid techniques (including the use of defibrillators and oxygen provision) may be needed.
Comment - What is timely access? Ambulance allocation is not always from the closest station
3.4 First aid facilities
Page 10 para 1
The following items should be provided in the room:
  • ......
  • the names and contact details of first aiders and emergency organisations
  • clock with second hand
  • automatic defibrillator– include
3.5Trained first aiders
Page 12 Number of trained first aiders
There is room to provide greater guidance on the number and type of First-aiders required for each type of worksite rather than the generic statements in this section.It is also interesting that as the workplace numbers increase the number of first-aiders recommended on average decreases.
A suggestion would be to make it simple by saying :
Low Risk Workplaces – 1 first aider for every 50 workers
High Risk Workplaces – 1 first aider for every 25 workers.
Page 12 Step 3
In determining whether a workplace is remote or not why not set a standard time from medical services (say 25 minutes) rather than “do not have timely access to medical or ambulance services”.

APPENDIX B – Example of contents for first aid kits

For most workplaces, a first aid kit should include the following items:
Item / Standard or High Risk
Workplace
Kit / Small or Low Risk
Workplace
Kit
Quantity
Include risk level
Also a definite definition of what is considered a Standard Workplace and what is considered a Small Workplace.
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different to current requirements in your jurisdiction? If so what are they?
2)Managing Risks in Construction Work
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
Page 7

1.2Who has duties relating to construction work?

Person conducting a business or undertaking
A person conducting a business or undertaking has the primary duty under the WHS Act to ensure, so far as is reasonably practicable, that workers and other persons are not exposed to health and safety risks arising from the business or undertaking.
The WHS Regulations also require a person conducting a business or undertaking to carry out specific duties for high risk construction work which include:
  • before the work commences, ensuring a Safe Work Method Statement (SWMS) for the proposed work is prepared, or that it has already been prepared by another person, in accordance with the WHS Regulations
  • putting in place arrangements to ensure that work is carried out in accordance with the SWMSi.e. monitoring/verification - include
  • stopping the work immediately (or as soon as it is safe to do so) if it is not carried out in accordance with the SWMS and only resumed as per the details in the SWMS
  • if the work is in connection with a construction project, a SWMS must be given to the principal contractor before the work commences
  • ensuring ......
Page 7 last para
A person with management or control of a workplace at which construction workis being carried out - include
A person with management or control of a workplace at which construction work is being carried out must ensure so far as is reasonably practicable that the workplace is secure from unauthorised access and must have regard to matters including:
  • risks to health and safety arising from unauthorised access to the......
Page 9 para 3
There are a number of duties the principal contractor has under the WHS Regulations. These are:
  • For WHS management plans, the principal contractor must:
  • prepare a written WHS management plan for the workplace before work on the project commences
  • ensure, so far as reasonably practicable, that each person who is to carry out construction on the project is made aware of the WHS management plan and their right to inspect it before commencing work
  • review and revise the WHS management plan to ensure it remains up-to-date
  • ensure so far as is reasonably practicable, each person carrying out construction work in connection with the project is made aware of any revision to the WHS management plan, and
  • ensure a copy of the WHS management plan for the project is kept until completion and is made available as specified in the WHS Regulations.
Define completion – is completion when the maintenance period has expired and a final completion certificate has been issued by the client.
Page 12 para 1 dot point 8

2.1Identify the hazards

When identifying hazards, particular attention should be paid to hazards arising from:
  • manual handling, including the potential for occupational overuse injuries, and (comment the regulations refer to manual tasks and handling should be replaced)
page 21 para 2

4.1What is a WHS management plan?

A WHS management plan is required when the value of a project exceeds $250,000. The plan sets out the arrangements to manage work health and safety on a construction project where there can be many contractors and subcontractors involved and where the circumstances can change quickly from day-to-day. In larger organisations, the WHS management plan may form part of a larger documented management system used by a principal contractor to manage the construction project. – Include
page 29 para 2
The table in Appendix Iprovide examples of some common construction workplaces and the facilities that might be suitable for these workplaces.
Should be Appendix H
page 36 para 2
Prior to commencement of any excavation that affects roads or traffic movement, traffic management planning should be completed to include, where necessary, a traffic controller, traffic signals (portable or permanent), barricades and any road closures. Traffic management planning should be in written form and available at the workplace at all times.
Comment - Permanent lights cannot be used for traffic management on construction sites.
page 44 last para
When carrying out construction work, it is possible that asbestos may be found in the workplace or in materials being used at the workplace, for example:
  • asbestos cement products such as roof and wall cladding, bath panels, boiler and incinerator flues, gutters, rainwater pipes, and water tanks
  • textiles – asbestos felts, ropes, fire blankets and woven asbestos cable sheathing
  • sprayed insulation materials used for fire-proofing, thermal protection, insulation and soundproofing
  • lagging and other loosely bound insulation materials used in a wide range of electrical, thermal and acoustic applications
  • sprayed ('impet') asbestos on structural beams and girders
  • lagging on pipework, boilers, calorifiers, and heat exchangers, and
  • asbestos insulating board - ceiling tiles, partition walls, service duct covers, fire breaks, heater cupboards, door panels, lift shaft lining, fire surrounds, and soffits.
  • telecommunications pipes, conduits and pits
  • water and wastewater pipes - (include)

Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different to current requirements in your jurisdiction? If so what are they?
3)Preventing Falls in Housing Construction
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
Nil Comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different to current requirements in your jurisdiction? If so what are they?
4)Managing Electrical Risks in the Workplace
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
Section 2 and Section 4 “How to manage the risks”. Part A and Part B, both sections state the same risk management processes. Sections 2 and 4 should be combined and examples be provided for both of Part A and B in the one section to save confusion
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different to current requirements in your jurisdiction? If so what are they?
5)Managing Risks of Hazardous Chemicals
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
Nil Comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different to current requirements in your jurisdiction? If so what are they?
6)Managing Risks of Plant in the Workplace
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
General comment
Code has very limited reference to any item of plant that is not fixed within a workshop. Minimal references to earthmoving plant throughout the document.Amusement structures are also limited. Diagrams for other items of plant should be included within the code.
Page 5 Part 1.1 – The meaning of key terms
Definition of plant is very broad considering the content of the document is limited in detail for anything other than fixed plant. Some items of mobile powered plant are referenced in examples however particular control measure for mobile powered plant are not addressed – pedestrian segregation, traffic management etc. (except for half a line reference in the last dot point on page 11
Page 10 Clause 2.1 “Identifying Hazards” – Inspect the Plant, Condition
Need to be more prescriptive how to evidence how much the plant has been used (if it is relevant), i.e. Log book, Verbally? Service and maintenance records?Makes it extremely interesting how to trace “manufacturers intended use for plant”. Most of the time, this will not be an issue, but could present logistic concerns for lower tier plant users or when entering the “grey” area where not 100% intended use for plant.
Page 14Part 3.1 – Other persons with duties in relation to plant
Last set of dot points should include dot point to check that the plant has adequate protective structures installed.
Page 17 Clause 3.4
What is the definition of “industrial lift truck”?
Consulting with plant manufacturers and designers prior to any modifications to plant will be difficult. What are the boundaries here? E.g. – After market safety elements? Additional guarding? Arrow boards for mobile plant? ROPS? Attachments for Integrated Tool Carriers or similar?
Page 26 Clause 4.4 Warning devices - Motion sensors
This could prove to be a difficult inclusion to the civil construction industry. Reversing (or travelling) beepers for mobile plant is ok, but for example, motion sensors for excavators may be difficult. (Especially when not being used for lifting.
Page 29 Clause 5.2 Item registration
For the registration of plant items, with the implementation of the new Code of Practice, will all items require registration?
Page 31Clause 6 Keeping Records
Would there be any obligation for anyone selling plant to transfer service/maintenance records? Also, relating to clause 6, records for plant it should include instructions on use, training provided to workers and operator competencies. This may be a conflict with the organizations systems and procedures and training and personnel records.
Appendix B
This should be useful. In our experience, an issue that has previously caused injury is debris (mud etc) trapped in footholds on plant, making getting on and off machines hazardous. This could be included as a checklist item in the “Slipping, Tripping and Falling” section of the Hazard Checklist.
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different to current requirements in your jurisdiction? If so what are they?