Draft model WHS Codes of Practice and guidance - Public Comment Response Form
Complete and submit this form by 5pm AEST Friday 24 AUGUST 2012 to
1. CranesSection/page no. / Comment
P2 / 1. In response to the question regarding reference to technical standards-
Our view is that the AS2550 suite of standards should be referenced as a source of information on crane safety. It contains a vast amount of useful info on safe use of the various types of cranes which has been compiled over years by industry experts and should not be ignored.
Also noted is the following comment –
Where does this document fit in an order of hierarchy or precedence with the AS1418.1, Cranes, Hoists and Winches – General Requirements, AS 2550 Cranes, hoists and winches Safe Use including Parts 1 to 20.
This document appears in many areas to duplicate information that is in AS2550 in many areas. This will lead to the future problem of maintaining accuracy when documents are updated.
An explanation and reference to the standards would clarify things somewhat and I think be beneficial to end users despite the concerns raised on page 2.
P2 / 2. Page 2 In response to the question regarding the structure of the material-
We found the information somewhat jumbled. Our specific area of interest is mainly with regards to Bridge and Gantry cranes and it is quite difficult to pick out the relevant material so separate documents on specific types of cranes would be a better option from our perspective.
In support of this is the following comment –
The document is very heavily biased towards Mobile cranes, Tower cranes and the construction industry. Many of the issues discussed throughout the document are irrelevant to operators of Bridge and Gantry cranes.
In fact the only detailed reference to Bridge and Gantry cranes is on the last page of the main body of the document.
I would think any small manufacturer with overhead workshop cranes would find this a very confusing document to interpret. It is not particularly user friendly.
There is also has lots of detail in the body of the document that is duplicated in the appendices. The document could be much more beneficial to end users with the use of more diagrams tables etc.
Foreword P6 / 3. Page 6 Paragraph 4
” Code of practice are admissible…” Will the CoP take precedence over the Australian safe Use code suite, AS2550?
Where there are discrepancies between the CoP & AS2550 or safety improvements to the AS2550, which of the 2 documents will take precedence?
Scope and Application P6 / 4. Page 6 Scope and Application
Suggest the following words are added in the Scope and Application section after “This Code should be read…..and Supply of Plant”
Further information regarding the safe use of cranes may be sourced from the suite of Australian Standards, AS2550. (as per comment 1.)
Design Registration P15 / 5. Page 15 Last point “you significantly change the crane design..”
Further information would be useful on what constitutes a “significant” design change.
We do not wish to go through this process unnecessarily on our huge number of bridge and gantry cranes. Would for example replacing a hoist drum brake with a modern disc brake be deemed significant?
Design Registration P16 / 6. Page 16 Paragraph 3 “If a registered crane design is altered or modified…”
Does the requirement for notification of crane alterations to the WHS regulator apply to registrable crane designs that predate this legislation but do no not have design registration numbers?
Design Registration P16 / 7. Following on comment 6, the CoP should clarify what is to be done about cranes that are reused for a different duty cycle or task than their original design.
Suggested wording: “Where cranes are reused and have had the rated capacity (including load) increased from original design or are reused for a different task than original , those cranes will be subjected to a thorough engineering review and inspection by a competent person. The crane, in its new configuration may require design registration”.
Emergency Plan P20 / 8. Page 20 Paragraph 2
Rescue should only be undertaken by trained personnel and competent personnel. The intent of this paragraph should be to highlight the need for a rescue plan. Therefore we suggest rewording to “Where required, a detailed rescue plan will be developed for the work, which will include a communication system to contact the appropriate professional rescue services, should the need arise.”
Lifting People P30 / 9. 4.9 Lifting people- Work Boxes, 1st bullet point “have at least two brakes..”
Very few commercial cranes have 2 brakes or an emergency brake attached to drum. This point is impracticable and will never be met. The remaining provisions of the clause will adequately cover the safe use of workboxes. Suggest removal.
Lifting People P31 / 10. Page 31 Safety of Persons in crane-lifted work boxes point 2.
Is this requiring a person holding a doggers license to be present in a workbox? This is a bit unclear and in our view unnecessary.
Major inspection P35 / 11. Major Inspection, page 35 R235 b) is determined by the WHS regulator to be a competent person.
How will this clause be implemented?
Pre-OP Inspection P38 / 12. Page 38 Pre-operational inspections
‘Visual inspection of the crane’ for some cranes, due to the configuration, height of crane or operating environment, this is not recommended for safety reason or impracticable as the crane structure may not be readily accessible. Suggest add an additional sentence. “Where access to the crane structure has been deemed impracticable due to safety or other reasons, a regular inspection of the crane structure will be implemented to ensure the structural integrity remains intact”
Last paragraph, “Where issues are identified these should be recorded…” Is this sentence referring to issues identified in the pre-operational inspection? If so, the requirement to rectify before operation should be reworded. “Where issues are identified these should be recorded, reported before the crane is used. Equipment integrity or safety issues must be assessed by a competent person prior to using the crane”
Bridge and Gantry Cranes P49 / 13. Page 49 6.9 Bridge and Gantry Cranes
With regards to design registration –
We are assuming that these design registration requirements apply only to new equipment and that existing equipment which has been managed under previous legislation does not require any further action unless subject to a “significant” design change.
Please advise if this is not the intent.
Bridge and Gantry Cranes P49 / 14. Page 49 Licenses.
We seek clarification as to whether a high risk work license is required for a remotely controlled bridge or gantry crane with more than one hoist and possibly more than one cross travel trolleys but only hoisting , traversing and travelling motions.
Comment on this would be appreciated.
Bridge and Gantry Cranes P50 / 15. Page 50 Licences: Final dot point, page 50- “any person who directs a bridge and gantry crane in the movement of the load”
Does this apply to personnel conducting a lift with predetermined lifting equipment and have been trained to a specific operating procedure to conduct the lift? or can an exemption from this point be granted?
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?
There are potentially significant cost related to items 5,9,10,13,& 15. Our major concerns would be with 14 & 15.
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