072 Telstra Corporation

Draft model WHS Third Set Codes of Practice - Public Comment Response Form

Complete and submit this form by 5pm AEST Friday 22 June 2012 to

1.  Safe Design, Manufacture, Import and Supply of Plant
Section/page no. / Comment
3.7 providing information / Some information that is important to downstream parties appears to be missing in this section:
·  The type of training and licences that may be needed to safely use the plant
·  No reference to providing dangerous goods details, as some items of plant are dangerous goods The standards used to ensure the item meets safety requirements
·  List of hazards mitigated through the design process. This would help designers demonstrate that safe design has been undertaken, and would make purchasing decisions easier.
3.7 providing information / This section recommends use of symbols, but does not provide guidance on how to find appropriate symbols.
Many Australian and International Standards are useful in selecting symbols to use, such as:
·  AS 1319-1994 Safety signs for the occupational environment
·  AS 2342-1992 Development, testing and implementation of information and safety symbols and symbolic signs
·  AS 2359.16-2005 Powered industrial trucks - Safety signs and hazard pictorials - General principles
The Association of Equipment Manufacturers (AEM) provides a long list of helpful standards (some are not appropriate as they relate to American signage methodology).
The AEM also provides an image database that uses hazard inputs to find the best symbols.
5.4 information about the safe use of plant / This sections mentions use of visual information such as signs, symbols, or diagrams. There is no reference to the most appropriate signs, symbols, or diagrams. See comments on 3.7 providing information
Proposed New Appendix / A checklist to help ensure all necessary information is disclosed should be added to the Code. The checklist could cover:
1.  Identification of plant and the company/undertaking
2.  Purpose and description of plant
3.  Design features
4.  Hazards identification
5.  Emergency measures
6.  Handling and storage
7.  Installation and commissioning
8.  Inspection, testing and maintenance
9.  Operation of the plant
10.  Exposure controls / personal protection
11.  De-commissioning, disposal and dismantling considerations
12.  Transport Information (including dangerous goods)
13.  Regulatory information
14.  Training
A separate guide may be required to ensure all required information is provided to all duty holders.
In the telecommunications sector, a system consisting of various components of plant is needed to create an effective network. If there is any missing information it makes downstream (system) design more difficult.
Telstra created an optional plant template for our suppliers to capture the information they need to disclose to enable Telstra to meet its duty as a builder of networks.
Attached for your information.

Telstra uses this document to help to identity better relevant information in relation to hazards, emergency measures, training needs, regulatory actions, etc.
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?
The draft Code is too generic and lacks the prescription and guidance generally expected of Codes of Practice.
To overcome this lack of prescription it may be useful to reference industry specific design codes such as those listed by the Communications Alliance.
The lack of clarity for creating good quality and comphreshensive information makes fulfilling downstream duties more difficult, especially for system designers.
2.  Working in the Vicinity of Overhead and Underground Electrical Lines
Section/page no. / Comment
Issue Paper – 3.2 / In relation to approach distances, Telstra submits that the Code should apply option 3, as the draft Code conflicts with telecommunications regulatory requirements and current energy (electrical) safety regulatory requirements. Consequently Telstra submits that approach distances
3.2 Working in the Vicinity of Overhead and Underground Electrical Lines
Option 3:
The approach distances are removed so that the code only includes a statement that local electricity supply authorities should be contacted for information on approach distances.
Application
Scope and Application,
Sections 2.3, 2.6,
2.7, / This Code’s use of approach distances, authorised person and safety observer conflicts with the way the telecommunications industry works near powerlines, and other metallic telecommunications networks.
A good practical example is to be found within the Electricity Safety (Installations) Regulations [Victoria] reg 318
318 Minimum distances between persons and aerial lines
(2) This regulation does not apply to—
(c) a telecommunications worker who holds a current certificate specifying satisfactory completion of a training course in power line awareness, approved by Energy Safe Victoria; or
Telecommunication networks are built to industry standards such as:
C524:2004 External Communication Cable Networks (available from the Communications Alliance)
Provides guidance on the basic principles of installation, maintenance and safety of external communications networks; describes the minimum requirements for electrical, structural and network reliability and employee/public safety. Revised to include "Dial Before You Dig" awareness, safety requirements for working near electricity lines, OH&S arrangements for facilities that emit electromagnetic radiation, road traffic management to Australian standards, the marking of underground cables, the depth of cover within road reserves and to clarify that the Code refers to other authorities and property owners not just utility owners.
Some extracts on clearance from the code.
8.4.7 Clearances to Other Cable Systems
8.4.7.1 The Carrier must ensure the arrangement of, and clearances between, its own Telecommunication Cables to that of Other Cable Systems, either attached to a common Supporting Structure, unattached, in shared spans or crossing, are designed for the environmental and electrical service conditions likely to be experienced in service.
8.4.7.2 These clearances should be in accordance with the arrangements
agreed to between the Carrier of the Telecommunication Cables and that of the respective owner of the Other Cable Systems involved.
Telstra has agreements in place with overhead power asset owners to support 8.4.7.2
2.3 / “Table 2 provides approach distances for:
• authorised persons, with a safety observer, who are performing work in the vicinity of overhead electric lines, including plant, hand tools, equipment or any other material held by a person “
This implies that a safety observer is mandatory regardless of the risk or activity within the authorised person zone.
In the Telecommunications industry, those ITC workers that mainly work on customers’ information technology and communications (ITC) plant and systems may need to connect to the appropriate network (optic fibre, telephony (PSTN), pay-TV coaxial cable).
This activity is normally completed safely by a single operator on a ladder. A safety observer would not provide any additional safety measure, as the worker on the ladder would be a better position to identify electrical risks than an observer on the ground.
Telstra suggests that an additional line or reference be included to clarify the circumstances where an observer helps provide a safer system of work, for example, when working with plant, blind spots, etc.
2.6 / In relation to:
“Maintenance of competency
Authorised persons and safety observers should be either re-assessed or re-trained annually to ensure their on-going competency to perform activities associated with work in the vicinity of overhead electric lines.”
For the telecommunications industry the appropriate competency is ICTOHS2153A - Work safely near power infrastructure.
To complete this annually is excessive when compared against the requirement for assessment of those persons that hold high risk licences i.e. afive year reassessment.
Telstra currently has an internal requirement to reassess all competencies for our field work force every three years.
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?
There would be significant impact to the provision of essential telecommunication services in timely manner. This would have significant negative impact to those in the community that are the most vulnerable, i.e. those with a life threatening illness. The requirement for additional “observers” required by the Code will have financial impact and could delay provision of services given resources.
Unfortunately aspects of this Code may create conflicts with the aims of the Telecommunications Act, where Telstra is obliged to provide an essential communications service.
3.  Traffic Management in Workplaces
Section/page no. / Comment
No 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.  Scaffolding Work
Section/page no. / Comment
No 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?
5.  Formwork and Falsework
Section/page no. / Comment
No 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?
Other comments

Page 4 of 4