Individual/Organisational name: 188 Veolia Environmental Services

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Model Work Health and Safety Codes of Practice - Public Comment Response Form

1)  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?
2)  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?
3)  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?
4)  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?
5)  Abrasive Blasting
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
Veolia Environmental Services conducts ultra high and high pressure water jetting activities and abrasive blasting throughout Australia. Veolia Environmental Services disputes the relevance of the water jetting activities contained within the Abrasive Blasting Code of Practice and as such would like to see the removal of all water jetting references from that Code of Practice.
High pressure water jetting operations are covered by the following:
AS/NZS 4233.1-1999 High Pressure Water (hydro) Jetting Systems – Guidelines for Safe Operation and Maintenance.
AS/NZS 4233.2-1999 High Pressure Water (hydro) Jetting Systems – Construction and Performance.
WA Industry Code of Practice Code of Practice for the Safe Use and Application of High Pressure Water Jetting Equipment 2001. (currently being revised)
4.3  Using a less hazardous surface preparation method. Page 10.
The hazards, associated risks, controls and consequences when conducting high pressure water jetting operations are radically different to abrasive blasting operations. High pressure water jetting operations is a more hazardous method of surface preparation. Therefore water jetting activities should not be included in the Abrasive Blasting Code of Practice.
Definition of high pressure water jetting.
The Abrasive Blasting Code of practice definition for high pressure water jetting is not in line with high pressure water jetting industry standards, or code of practice. It states:
High pressure water jetting
High pressure water jetting (greater than 20,500 kPa but less than 172,500 kPa, 3,000 to 25,000 psi) uses a pressure pump, a large volume of water, a specialised lance and nozzle assembly, and in some cases, an inhibitor to prevent flash rusting. High pressure water can remove loose paint and rust but will not efficiently remove tight paint, tight rust, or mill scale.
Ultra high pressure water jetting
This uses pressurised water from 172,500 kPa to 257,800 kPa, 25,000 to 40,000 psi (or higher). Ultra high pressure water jetting is similar to high pressure water jetting (see above) except that higher pressures clean much more efficiently and are better able to remove tight rust and paint.
AS/NZS 4233 not differentiate between High Pressure and Ultra high pressure, but defines controls around the high pressure water jetting unit’s output capacity in bar litres per minute. All pressures are measured in bar.
The high pressure water jetting industry uses the following pressures as a guideline. This is also identified by the style of pressure hose fitting and connection.
High Pressure- Up to and including 1500 bar or 20,000 psi
Ultra High Pressure – above 1500 bar or 20,000psi. Pressure can be up to 4000 bar 56000psi
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?
AS/NZS 4233.1-1999 High Pressure Water (hydro) Jetting Systems – Guidelines for Safe Operation and Maintenance and AS/NZS 4233.2-1999 High Pressure Water (hydro) Jetting Systems – Construction and Performance, as well as the WA Industry Code of Practice Code of Practice for the Safe Use and Application of High Pressure Water Jetting Equipment 2001 outline minimum standards that apply to the water jetting industry and provide comprehensive controls to manage risks.
High Pressure Water Jetting operations have inherent hazards and associated risks with working pressures up to 3000bar.
One of the major risks associated with high pressure water jetting is a person being hit by a jet of high pressure water. Death or severe high pressure water injection may result. Any injection injury can lead to hospitalisation, multiple operations followed by long periods of hospital care. The consequences of incidents involving high pressure water jetting operations by far out way those associated with abrasive blasting.
To that extent trained high pressure operators carry a medical alert card stating. “This person has been working with water jetting at pressures to 55,000 psi (374 MPa, 3740 bar, 3867kg.cm2) with a jet velocity of 3000 fps (914 mps). This should be taken into account during diagnosis. Unusual infections with microaerophilic organism occurring at lower temperatures have been reported. These may be gram-negative pathogens such as are found in sewage. Bacterial swabs and blood cultures may therefore be helpful”
Reaction forces generated by the stream of water although limited to 22.5kgs can also result in health and safety risks in particular situations.
The level of information included in the Abrasive Blasting Code of Practice in regard to water jetting is extremely low and does not include any of the above.
The Abrasive Blasting Code of Practice states controls that mainly relate to abrasive blasting activities and are not relevant or specific to high pressure water jetting operations.
Training
There is no mention of training or competency levels for persons carrying out high pressure water jetting operations. AS/NZS standards as well as the WA Industry Code of Practice Code of Practice for the Safe Use and Application of High Pressure Water Jetting Equipment 2001 state the minimum levels of training. This is an important function with in preventing incidents within the High pressure water jetting industry.
Personal Protective Equipment
The Abrasive Blasting Code of Practice does not address Personal Protective Equipment requirements for high pressure water jetting operations. There is a marked difference from abrasive blasting PPE to high pressure water jetting PPE. Examples are the body armour and hose shrouds to protect the operator from injury in the case of a hose or fitting failure.
6)  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?
7)  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?
8)  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?
9)  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