Individual/Organisational name: 236 Select Utility Solutions
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Model Work Health and Safety Codes of Practice - Public Comment Response Form
1) Safe Design Of Building and StructuresComments 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).
Introduction & General Comment:
Select Solutions are a division of the Victorian Electricity Distributer, SP AusNet. We are one of the largest employers of tree cutters in the state and have in excess of 300 contract personnel responsible for keeping vegetation clear of electrical lines. Where the term ‘We’ is used in this response it is intended to mean Select Solutions.
We fully support the process of harmonisation and the development of a nationwide Code of Practice for amenity tree industry activities. We encourage ongoing work on this document to bring it to a standard that can be wholly endorsed by a broad cross-section of our industry. We would be happy to participate in further development of this Code.
We recommend that the existing Victorian Tree Industry Organisation Draft Climbing Guidelines, or the NSW Amenity Tree Industry Code of Practice (under review), be considered to form the basis of the current Draft Model Work Health and Safety Code of Practice for Safe Access in Tree Trimming and Arboriculture.
Specific Comment:
o Timeline for public comment:
We strongly recommend that the period for public comment be extended and that the current draft Code of Practice is extensively re-written in consultation with a panel of industry experts prior to being re-released for further public comment.
o Page 3 – scope – “methods of access”:
This is a fairly narrow scope given the hazards in amenity tree work. We would suggest it is more appropriate to address all major hazards within the industry and give a more balanced consideration to those hazards. E.g. working within the canopy (after accessing), EWP’s, large machinery, rigging in trees and felling.
o Page 7 – Hazard identification – Equipment:
It would be appropriate to broaden the risk assessment process to include equipment (not just the tree and the site) particularly the most problematic gear such as karabiners, ropes, brakes, push bars on chippers, guards on stump grinders, chain breaks and clutch springs on chainsaws.
o Page 9 – Accessing the tree – Industrial rope access:
Industrial rope access as it is described in the Australian Standard is not applicable to the amenity tree industry. In Arboriculture a work positioning system is used with equipment and systems now developed and accepted worldwide.
We recommend replacing the term ‘should’ with “shall” in the statement “Climbers not specifically trained in utility work (working near power lines) should not be allowed to engage in work within exclusion zones adjacent to overhead lines”.
o Page 10 – Temporary work platform – leaning out:
Most tree work done from an EWP involves leaning out of the bucket. Therefore we recommend that the statement “Temporary work platforms are not suitable for activities that require the worker to lean outside the structure of the platform” be removed from the document as it is standard practice to lean out of the EWP Platform when completing works.
o Page 12 – Industrial rope access qualifications:
Qualifications applicable to the Amenity tree industry are contained within the nationally recognized Horticulture (arboriculture) training package. We would suggest the COP has a specific section allocated to required qualifications and that the appropriate training is required for all activities including but not limited to:
§ Tree access / climbing / rescue
§ Rigging in trees
§ Felling
§ EWP operation
§ Pruning
§ Chippers and stump grinders
§ Chainsaw use above ground
§ Etc
o Page 13 – Crane use:
We would suggest a review of the crane section; this review should include some consideration to the use of new equipment such as remote controlled cranes which allow the operator to supervise unhooking of chains. Also the appropriate training for those rigging within trees which is quite different from rigging on the ground.
o Page 14 – “must be anchored to the tree”:
In some circumstances the crane facilitates separation from a potentially unstable tree and being anchored to the crane rather than the tree would be safer, tree sections could then be cut and dropped.
o Page 14 (and 15) – “two independent anchor points”:
Industry standard within arboriculture is that other than when cutting, a single point of life support attachment is acceptable. The reason for this is that when moving through the tree 2 points is not practicable, adds to fatigue and becomes unworkable with equipment entanglement. This need to be changed to 1 point of attachment at all times and when cutting in a tree, maintain at least two life support attachments.
o Page 14 – Rope type and diameter:
New technology is producing thin strong ropes; specifying a minimum diameter may not be appropriate. The tree industry most commonly uses what are technically ‘static’ ropes rather than ‘dynamic’ ropes as specified in the draft.
o Page 17 – Fall arrest system:
In arboriculture it is unusual to use fall arrest systems other than perhaps in EWP’s. All climbing work is performed with a work positioning system. This also relates to the section on suspension trauma (page 22) as many tree harnesses are not ‘sit type’ harnesses.
o Page 24 – Electrical Safety:
We recommend that in States or Territories where a Code of Practice for Electrical Safety exists, the relevant documents are referenced in this section. For example, in Victoria, the ‘Blue Book’ and ‘Green Book’ should be referenced.
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 explained above, this COP fails, by a large extent, to address the current work practices and equipment used in the amenity tree industry. The associated reduction in safety is immeasurable and the reaction from workers is expected to be extremely negative and would significantly detract from any safety benefits that the document attempts to achieve. In the section that deals with tree climbing, many technical and fundamental errors are included in the document, some of which would adversely affect tree climber safety if observed.
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