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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).
Nil
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?
NIL
2)  Managing Risks in Construction Work
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
P13; Administrative Controls
These are work practices that minimise the risk, such as ensuring there is no unauthorised entry of a person to a work area thus preventing them from being exposed to a particular hazard. For example:
Add the word “organisational” between “are” and ““work” so that it reads:
These are organisational work practices that minimise the risk, such as ensuring there is no unauthorised entry of a person to a work area thus preventing them from being exposed to a particular hazard. For example:
Currently the dot points only deal with safety issues. Add a dot point for the effective management of unnecessary exposure to general hazards so workers, who don’t need to be near a hazard such as noise, dust or mist, are contained outside the hazardous area.
P14; PPE
Second dot point example; add ‘risk of’ between the words “the” and “excessive” so that it reads;
Provide workers with ear plugs, ear muffs or other PPE when they are near or operating noisy machinery and powered tools to minimise the risk of exposure to excessive noise.
P14; Combination of control measures
The section contains a dot point on “reversing cameras and audible warning”. Despite the word “should” this section is too prescriptive as it indicates that both should be installed. Many configurations of vehicles are used in the construction industry, i.e. with large and small cabins, and reversing camera technology may not be appropriate. There should be flexibility in installing the optimum collision prevention equipment in a vehicle. Combinations such as visual and proximity sensors, reversing cameras, or other forms of collision avoidance technology could be installed depending on the vehicle configuration.
P16; Safe Method Work Statements
It states that:
A safe work method statement (SWMS) must be prepared for any and all high risk construction work to be undertaken prior to the work commencing.
In my experience of reviewing many SWMSs, they contain mostly generic statements enabling them to be taken from one site to the next. SWMSs should be site specific as each site has its unique H&S problems and this should be reflected in the SWMS.
Suggest adding the word “site specific” to the sentence: “A SWMS must be clearly set out, easy to understand and readily accessible so the risk control measures can be implemented and monitored”; e.g. as per example below;
“A SWMS must be site specific, clearly set out, easy to understand and readily accessible so the risk control measures can be implemented and monitored”
P26; Workplace specific training
The list of dot points deal with either safety or amenity issues. There is nothing in there that deals with health issues such as UV radiation, noise induced hearing loss, dermatitis or respiratory issues, all of which are significant risks on construction sites.
P50; 8.11 Noise
The term “over exposure” is ambiguous and has no place in the sentence in its current form. One over exposure is not very likely to result in permanent hearing loss as is evident from people going to rock concerts. However, regular exposures to noise at LAeq,8h 85dB(A) or more will result in noise induced hearing loss.
Better to state:
A person conducting a business or undertaking must prevent workers from being exposed to noise levels that exceed the exposure standard to reduce the risk of permanent loss of hearing and tinnitus (ringing in the ears).”
P51; Examples of noise control measures include:
The last two dot points are not noise control measures, particularly the last dot point about hearing protectors. They do not control workplace noise but if, and it is a big if, they are worn correctly they reduce noise entering into the ear canal of the wearer.
P51; last sentence; add reference to Aust Standard on Construction Noise so the sentence reads:
Further guidance about managing risks associated with noise is available in the Code of Practice: Managing Noise and Preventing Hearing Loss at Work and AS 2436: Guide to noise and vibration control on construction, demolition and maintenance sites
Appendix B Technical standards add
AS/NZS 1269 Occupational Noise Management
AS 2436: Guide to noise and vibration control on construction, demolition and maintenance sites
AS 2670.1, Vibration and Shock - Guide to the Evaluation of Human Exposure to Whole Body Vibration
AS 2763, Vibration and Shock - Hand Transmitted Vibration, Guidelines for Measurement of Human Exposure
ISO 7731, Ergonomics — Danger signals for public and work areas — Auditory danger signals
ISO 9533, Earth-moving machinery — Machine-mounted audible travel alarms — Test methods and performance criteria
Both hand arm and whole body are barely mentioned in the code of practice even though both are significant factors in demolition and construction work. Some examples of good practice should be included, e.g. vibration isolating handles on power tools and vibration dampened seating in vehicles
Audible warning devices for reversing were mentioned (albeit only once) in this Code of Practice and are common in vehicles on construction sites. Suggest including some guidance advising that to prevent the warning device itself becoming a hazard the sound should not be louder than necessary to be heard and restricted to the hazardous area in which the reversing vehicle operates. There should also be mention made to the newer types of reversing signals that produce a broad band sound which is perceived less annoying and a hazardous signal than a tonal alarm. This is particularly helpful with night time operations in noise sensitive neighbouring areas.
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?
NIL
3)  Preventing Falls in Housing Construction
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
NIL
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?
NIL
4)  Managing Electrical Risks in the Workplace
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
NIL
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?
NIL
5)  Managing Risks of Hazardous Chemicals
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
This Code of Practice needs to include a section on ototoxic chemicals as indicated in the Noise Code of Practice. The reader should be referred to the noise code of practice for more details
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?
NIL
6)  Managing Risks of Plant in the Workplace
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
P10; Identifying hazards
In this section an example of a forklift is used. The second point in the example should include a reference to the atmospheric conditions in which the forklift is used as explosions and fires have occurred simply by using an LPGas operated forklift in cold room conditions for instance instead of an electric operated forklift.
P11; What is the potential impact of the hazard?
Current sentence: How severe could an injury or illness be? For example, lacerations, amputation, serious or fatal crushing injury, burns
Add; and noise induced hearing loss to the above sentence after “burns” so that it reads:
How severe could an injury or illness be? For example, lacerations, amputation, serious or fatal crushing injury, burns and noise induced hearing loss.
P11; How likely is the hazard to cause harm?
Current paragraph:
·  Could it happen at any time or would it be a rare event?
·  How frequently are workers exposed to the hazard? For example if plant is used constantly with five operators per shift and three 8-hour shifts and there is a lack of high level control measures, the risk will increase.
The harm can be caused by a single exposure e.g. operating an explosive powered nail gun without hearing protection will result in a degree of immediate hearing loss as the noise exposure level is similar to that of firing a firearm and is made worse if it happens in a highly reverberant environment such as a stairwell or lift shaft. It is suggested that a reference to this hazard be included as a third dot point above.
P14; Sect 3.1 Purchasing and hiring plant
Again the sentence is safety driven and does not take into account that many plant processes can cause occupational derived illnesses. Suggest to change the first sentence to read:
Many injuries and illnesses associated with plant occur due to a failure to select the right equipment for the job.
The second sentence only takes into consideration the fact that the plant can do the work in a given environment. It does not consider the people required to use it. Suggest to change the sentence to read:
To do this you should plan the work to be carried out using the plant and identify whether the plant design and construction is suited to the work, the environment it will be used in and the people using it.
Third dot point;
·  any conditions necessary for the safe use of the plant.
Add to this dot point things like; lowest noise emission and lowest vibration emission e.g.
·  any conditions necessary for the safe use of the plant, e.g. have operating conditions been considered that give low noise and vibration emissions.
P14 Sect 3.1 last dot point in the third set of dot points
• It does not introduce other hazards (for example, manual handling problems) into your workplace.
Add excessive noise and vibration to the sentence so that it reads:
• It does not introduce other hazards (for example, manual handling problems, excessive noise, and/or excessive vibration) into your 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?
7)  Safe Design Of Building and Structures
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
8)  Excavation Work
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
9)  Demolition Work
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
10)  Spray Painting and Powder Coating
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
11)  Abrasive Blasting
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
12)  Welding and Allied Processes
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
13)  Safe Access in Tree Trimming and Arboriculture
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
14)  Preventing and Managing Fatigue in the Workplace
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
15)  Preventing and Responding to Workplace Bullying
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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