038 Peter Ferguson/First Access

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

Complete and submit this form by5pm AEST Friday 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
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
General / The experience from recent incidents and in particular the deaths in Qld showed clearly that the industry in general, is not well versed in swing stage erection or use. It has become a lost skill set.
It became very clear that while there are specific “pockets” of industry (in various places around Australia), where the designers and installers and users (to a lesser extent) are fairly competent and experienced, there are very large issues with use of swings in broader industry.
Industry has been using swings so little for such a long time that many (most??) advanced rigging and scaffolding courses do not train operators well enough to understand the products. In fact, in many courses, there is not even some equipment available for users to actually see.
From this experience, we concluded that a transition course from advanced rigging/scaffolding to swing erection was NECESSARY in most cases. We also concluded that the users of swings were similarly untrained and inexperienced and that a user’s course is necessary.
In both cases some flexibility is required to take account of those who operate in pockets of high experience.
What was also very evident is that there are few engineers with suitable EXPERIENCE. From this we assembled guidance materials some of which is now being incorporated into the re-write of AS 1576.4.
The wording in the Safework COP draft is a very good attempt to address some of these issues. However some of the issues are outside the remit of this document. For example, addressing the skills shortage of installers and users cannot be fully carried out in this document. Some wording could be added to flag these issues up and the document could certainly say more about the need for EXPERIENCE and not just “skills” for both designers and installers.
5.8, design issues, second dot point / Change last sentence to A hoist with separate hoist rope and backup rope (or alternatively, twin hoist ropes) should be used.
5.8, method of fixing needles, first dot point / Suggest modifying wording to Chemical and friction anchors should not be used in axial tension, only shear
5.8, method of fixing needles, third dot point / Suggest change clause to – if the needle is to be attached to an anchorage point or part of an existing structure on the building, the design of the system should be carried out by a suitably experienced engineer.
5.8 fall arrest / The requirement (as distinct optional) of harness wear and use is very debatable. In the report following the Qld accident we had a lot to say on the issue. What is in the Safework draft is not too bad but would be better saying – (1st dot point) Persons located in swing stage cradles should wear a fall arrest harness and attach to a properly designed anchorage system when hoisting/lowering and at other times when required by the work process or site conditions.
This replaces the first sentence. The others can then remain.
Appendix D, 1 / Design and engineering - ….documented by a competent person with relevant experience, …..
Appendix D, 2 / Loading. Suggest adding final sentence – Note that on many long swing stages, the load capacity will be severely reduced and only minimal tools and equipment may be able to be carried.
Appendix D, 4 / Installation. Suggest adding to last sentence as follows:
Persons holding an advanced rigging or advanced scaffolder licence and who have relevant additional training or specific suspended scaffold experience must be engaged to install suspended scaffolds.
Appendix D, 6 / Fall arrest systems. See comments 5.8, above
Appendix D, swing stage advice / See comments in 5.8 above, in relation to hoist (twin rope) description
Appendix D, installation design advice, 5th dot point / Whilst raising the issue of voltage drop is a good idea, some hoist are far more sensitive to voltage drop than others and the 5% “allowance” is very narrow and not always necessary or practical. Would be better to keep the advice more general and not so specific.
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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