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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).
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?
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).
Below are just someareas we believe should be considered for the Draft Code of Practice for Safe Access in Tree Trimming and Arboriculture
Page 5
Suggested inclusion:
Utilise a more widely accepted example for consultation process
Using the hierarchy of controls to ensure that all risks are eliminated or minimised as far as reasonably practicable.
I think an example of a more widely used method of accessing for a tree. Ie. reference industry/business hiring Work Platforms and induction into that equipment required instead of below
For example:
  • If you are a business owner who is carrying out tree trimming work with the use of a contracted mobile crane, you will need to co-operate and co-ordinate work activities with the person responsible for the mobile crane
Page 6
Suggested inclusion:
Managing Risk
No Reference to Manual Handling – vibration form equipment and/or lifting techniques/job rotation
Tree issues to consider include:
  • Is the tree suitable to be climbed?
Has a risk analysis been conducted for the most appropriate method for accessing the tree been considered. .ie. Work Platform, Climbing, Crane
  • Is the tree considered high value? For example, does it have heritage value?
Is this meant that therefore could attract aggressive public reaction?
Page 10 – 3.2
Reference
AS 2550.10 Cranes, hoists and winches - Safe use - Mobile elevating work platformsis AS 2550.10-1994 Cranes - Safe use - Elevating work platforms
Suggested inclusion:
The safety considerations include that:
  • Prestart check of equipment i.e. checks for hydraulic leaks, electrical/weight testing has been conducted.
  • All workers hold a High Risk Licence when operating elevating work platforms regardless of boom length
  • Groundsperson/Spotter has the same competency ie. High Risk Licence – WP, Aerial Rescue and at L2 First Aid in the event of emergency situation
  • Operators are aware of step potential when working around powerlines
This section seems to omit criteria that Elevated Work Platform should met as outline following page for Crane-lifted workboxes. Ie SWL
Page 11
Remove - Only use fall arrest rated equipment compliant with AS/NZS 1891.4 Industrial fall-arrest systems and devices—Selection, use and maintenance
Page 12
Section 3.3. Remove entire section and all other sections commenting on rope access. Current industry standard techniques can vary significantly from the majority of the proposed section.
Page 21
7.1 Emergency procedures
Ascertain the appropriate course of action for the emergency.
Can a rescue take place without any additional risks being presented to the rescuer/s – ie. Powerlines and step potential
Page 24
8.1 Electrical safety
In addition to the above, other means of addressing risks associated with working near electric lines include:
Suggested inclusion:
  • Tree section being cut or plant/equipment can accidentally infringe on the ‘Safe Approach Distance’
  • Safety observer/spotter must hold the same qualifications, competency of persons undertaking the works and hold a current L2 First Aid Certificate with CPR refreshed annually
8.2 Plant
We believe this area should be further developed to ensure that it is relevant and a useful tool.
Chippers
Suggested inclusion:
Safety considerations;
  • Consideration to tipping loads
  • Evenly distribute woodchips to prevent unbalanced loads when tipping
Remove– Torque settings – These are checked at time of service not during routine maintenance.
Chainsaws
Suggested inclusion:
Safety considerations - PPE;
  • Anti-Vibration gloves to prevent white finger syndrome
Stump grinders
Suggested inclusion:
Before using stump grinders or root pruners ensure:
  • Erection of safety screens/barriers when stump grinding
Suggested inclusion:
  • Health Surveillance for employees working within the Arboricultural Industry ie.
  • Audiometric Testing
Checklist/s
Can be improved.
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
Citywide similarly supports the collective industry thought process that a “Code of Practice” for the Arboricultural industry is welcome. However, to ensure that information contained within is consistent with industry best practices (throughout Australia) and is an accurate, reliable tool. We believe the current Code of Practice should be postponed from release until appropriate consultation has taken place from industry experts, organisations and Arboricultural associations from all states and territories.