Draft model WHS Codes of Practice and guidance - Public Comment Response Form

Complete and submit this form by5pmAEST Friday 24 AUGUST 2012to

  1. Cranes

Section/page no. / Comment
General / Why was this Code of practice developed without consultation with the Standards Australia committee who recently published AS2550.1? There are a number of requirements and methodologies listed in AS2550 which have not been covered by this draft.
The AS2550 series of Safe Use Standards have few peers on the international stage. The ME-005 committee members felt the AS2550 series of Safe Use standards were more relevant to industry than the AS1418 series of design standards which have become outdated and not relevant to industry practice.
Foreword/Page 6/Para 6 / Need to define the right of appeal if an owner disagrees with the determination of an Inspector in relation to an Improvement Notice?
2.1 page 9 / Other key hazards are :
Operating Environment
Crane type and suitability for the lift
Maintenance/Serviceability of the crane
Operator controls
3.2 page 14 / Second hand cranes must be assessed to determine their classification and remaining design life. AS2550.1 outlines what is to be done and by whom in order to determine available design life based on what information is available about the crane.
4 Page 21 / Sections 4.1 thru 4.5 are primarily written around Mobile or Tower Cranes. There are many different variants of cranes with the biggest population of cranes being Bridge cranes. There is little or no details of crane use that is targeting this crane type.
4.4 Page 24 / Information should be given in relation to operating cranes in the vicinity of Overhead Electric Lines, not just a reference to another Code of Practice.
4.7 page 27 / Other types of load handling devices such frictionless devices have not been included eg. Magnet or vacuum operated devices
4.7 page 27 / Limiting and Indicating Devices. The statement that load limiting devices should not be relied on in place of load charts, is incorrect. Most cranes such as Bridge cranes do not have load charts. Load limiting devices are provided to ensure a crane motion does not exceed it’s operating limits. There are a number of mandatory load limiting devices called up in both AS and overseas design standards.
4.7 page 27 / Lifting gear. The statement that lifting gear ‘should’ be checked, reduces the significance of this point. In fact lifting gear ‘must’ be checked prior to use as it is critical to the Safe Use of a Crane/Hoist.
4.9 page 30 / This section is primarily written around mobile cranes lifting workboxes. Bridge cranes, travelling hoists and fixed hoists are also used to lift work boxes or lift platforms. Where cranes are to lift personnel and/or hazardous substances, there are a number of design requirements which need to be implemented before such a lift can take place.
4.10 page 31 / Communication. Diagrams explaining the standardised hand signals and audible signals should be included in this document.
4.12 page 32 / There is no mention of providing clear access ways for pendant operated cranes.
5 page 34 / All crane/hoist types must be subject to a major inspection, not just registrable mobile or tower cranes.
5.1 page 34 / A critical record that has been omitted is the results of an assessment of consumed design life.
5.1 page 35 / Major Inspections. The first assessment to be carried out at a major inspection is that of determining consumed design life, along with reviewing the service and repair records of the crane. It is only after this assessment has been carried and reviewed by a competent person, that an inspection regime be determined by the competent person.
AS2550.1 has dedicated an entire section on assessing a crane for continued safe use or changed operation. This section was a key achievement of the recently published standard and laid out practical methods on how to determine remaining design life and the importance of load spectrum recording equipment.
5.1 page 35 / The reliance on the dismantling of equipment to assess wear and deformation, or by carrying out NDT of critical elements, does not given a true indication of stress cycles of load bearing parts of a machine, or indication of consumed design life. Design life assessment has to be carried out by assessing the load spectrum the crane has undergone, reviewing the service and repair history and then making a recommendation of what inspections and testing is required.
5.1 page 35 / The qualifications of a competent person carrying out testing and inspection of welding , needs to be stated.
5.1 page 35 / The requirement that a licensed/registered electrician based on the potential of the control system, is not adequate to make an assessment of the electrical system of a crane. What is required is a competent person familiar with control systems, motor control, safety systems and crane technical standards to make this assessment, most electricians do not have this knowledge.
5.1 page 37 / Annual Inspection. An assessment of remaining (or consumed) design life should also be calculated in order to determine if the crane is being operated within or outside classification and what that will mean for future inspections.
5.1 / There is no mention of commissioning requirements in relation to the load testing of the crane or hoist, their mechanisms or structure. eg 110% load test of hoist , deflection of bridge and/or support structure.
Section 6 / There is no mention or guidance on Engineering Lifts’
6.9 page 49 / A common bridge crane configuration is two hoists that can be operated in Tandem or individual mode. Please clarify the licensing requirements for this type of crane.
6.9 page 49 / All bridge and Gantry cranes that have been designed to lift personnel, will need to be registered.
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?
Yes, a reduction in safety benefits by not following all the requirements of AS2550.1_2011

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