033 OHS Branch, The Australian National University

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

Complete and submit this form by5pmAESTFriday 22 June 2012to

  1. Safe Design, Manufacture, Import and Supply of Plant

Section/page no. / Comment
Sections
1.2
1.3 / The shift in responsibility
The ‘Managing Risks of Plant in the Workplace’ Code of Practice does not make clear to the reader the shift in responsibilities a PCBU/workertakes on when deciding to acquire/purchase Plant (Equipment) directly from an overseas supplier for their organisation.
This should be clarified/considered for inclusion into:
Section 1.2 ‘Who has health and safety duties in relation to plant at the workplace’.
Definition of Officer and Worker in 1.2 including Designers, manufacturers, suppliers, importers and installers of 1.3 other persons with duties related to plant.
For Example:
Duties as an Importer– Note that the PCBU holds obligations as an ‘importer’ if the designer/ manufacturer of the plant is located overseas. To avoid this situation, it is preferable that the PCBU purchases plant from Australian based sources or those with local agents, where possible.
An importer must ensure that plant used in the PCBU’s workplace is assessed for hazards to health and safety. These hazards should be eliminated or the risks controlled as far as is reasonably practicable.
An importer is responsible to provide information about the particular plant. This information should allow the user to determine compliance to relevant legislation or standards to achieve safe use of the plant in the workplace.
7.10 / Consider re-writing the sentence “Plant should be designed so external radiation does not interfere with its operations or with people working on or in the vicinity of the plant.” To something that considers personal exposure and limits.
For example:
Plant should be designed to minimise personal exposure to radiation or achieves levels below recognised exposure limits. The radiation should not prevent the safe operation of the plant, even during emergency situations.
Under Lasers
Please refer to the current Australian Standard AS/NZS 2211.1:2004. (not 1997)
Radiofrequency radiation
Radiofrequency (RF) radiation is the correct presentation, not RFR
Although RF fields of 10 MHz and above interact with human tissue, it is incorrect to state just the frequency. Power must also be included. That paragraph is in need of rewriting.
Ultraviolet radiation
Two issues need to be teased out. UV radiation containment from the plant or associated process and protection of the operator from UV radiation present. In the example, the mobile plant (eg a tractor) is not the likely source, the sun is. The canopy and glass windows should be UV resistant or absorbing.
Readers should be directed to relevant exposure standards and guidance material, such as that supplied by ARPANSA.
7.11 / This is a confusing paragraph. Some points belong in the confined spaces section, while plant structural integrity should be elsewhere. Not sure what this paragraph is about.
7.17 / Lighting
This section tends to cover general lighting. Specific information about task lighting and lighting of control panels needs to be included/emphasised.
Appendix C / Consider the inclusion of AS 4343Pressure equipment – hazard levels into ‘Appendix C Examples of Technical Standards (Pressure Equipment)’ as reference.
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?
  1. Working in the Vicinity of Overhead and Underground Electrical Lines

Section/page 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?
  1. Traffic Management in Workplaces

Section/page 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?
  1. Scaffolding Work

Section/page 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?
  1. Formwork and Falsework

Section/page 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
The Plant series of COPs should be linked with an explanatory document or flowchart to help people navigate the information available and processes to be followed.

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