Individual / Organisation name: 021 Department of Infrastructure, Energy and Resources. Land Transport Safety Division, Vehicle Operations

What state/territory are you from? TAS

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
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
Section 8, pages 45, 46 & 47 / The following comments relate to section 8 of the code which pertains to the Transportation of High Loads and are provided by the Vehicle Operations Branch from an operational perspective.
1)- Table 5 on page 45 sets out the notification, route assessment and “escorting” requirements for special purpose vehicles and vehicles transporting indivisible loads that exceed 4.6 metres in height. There is a note on page 47 that indicates that the information in table 5 pertains to the requirements in Queensland only and to obtain the requirements for other jurisdictions to contact the relevant jurisdiction.
The requirements set out in Table 5 vary considerably from what is currently required in Tasmania. The Tasmanian requirements were set by the Aurora Energy who is the major power provider in Tasmania in consultation with Vehicle Operations Branch which is the section of the Department of Infrastructure, Energy and Resources that administers exemptions for vehicles that exceed the regulatory dimension limits.
For the COP to be effective on a national basis we are of the opinion that it should either;
  • specify the requirements for each jurisdiction separately; or
  • work with each jurisdictions power providers to harmonise the current requirements to one nationally consistent requirement.
2)- The COP uses and defines the terms “escorting” and “escort service providers”, the term “Escort Vehicle” is defined in each jurisdictions current road and traffic legislation and is already known by the transport industry as having that current meaning. To use these terms with a different meaning in this COP is likely to cause confusion to vehicle operators which in turn has the potential to lead to unintentional diminished compliance with the road vehicle legislation.
3)- It is proposed that in mid 2013 that the regulations pertaining to the operation of heavy vehicles on roads in Australian (with exception to Western Australia at this stage) will be administered by a National Heavy Vehicle Regulator (NHVR) based in Brisbane. As this COP contains information that relates to the operation of heavy vehicles on roads the NHVR is likely to be a major stake holder in relation to this matter in the future and therefore possibly should be directly consulted with as part of this project.
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?
Costs:-If the requirements set out in Table 5 are implemented in Tasmania it will require the implementation of a change management process which will require resources. Additionally it is likely to cause considerable delays to the current time frames for the transport industry to obtain exemptions for the movement of loads between 4.6 and 5 metres in height. These delays will have financial implications to the Transport Industry and their clients.
  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

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