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

General comments

Farmsafe Queensland Ltd supports the introduction of the Managing Risks of Plant in Rural Workplaces, given that there has been a similar Code in place in Queensland for a number of years. While there may be some overlap with other codes it is believed that rural workplaces have some relatively unique characteristics, in that a wide variety of tasks may be undertaken in the workplace some of which only occur infrequently.

Rural workplaces also differ from many other workplaces in that people also live there which imposes and additional set of risks and obligations not normally found in other workplaces. Farmsafe Queensland Ltd supports the use of the generic term “Rural Workplace” as opposed to using farm, property, station etc.

Comment on referencing technical standards

Given that Australian Standards are owned by a private company becomes quite important that where details from the standard needs to be referenced this detail should be included in the Code of Practice. If there is simply a reference to a standard in regard to a piece of equipment e.g. rollover protection structure or helmets then this may be included but there should be no reliance on any further detail. The cost of purchasing relevant standards can be prohibitive for any small business including farmers.

Comment on inclusion of guidance for two wheeled motorcycles

Two wheeled motorcycles still account for a number of deaths and injuries on farms. Thus there should be guidance material in this Code of Practice relating to their safe use.

This could be included in a new subsection in Section 4 - Farm Vehicles. This section could also contain some guidance material on the use of farm utes particularly with regard to carrying unrestrained passages both in the cabin and the tray of the ute.

1.  Managing Risks of Plant used in Rural Workplaces
Section/page no. / Comment
1.1/page 6
1.2/page 6
2.1/page 9
2.2/page10
2.2/page page 10
2.2/page 11
2.2/page 11
2.2/ page 11
2.4/page 12
2.4/page 12
2.4/page 12
3.7/page 16
4.1/page 18
4.1/page 18
4.1/page 19
4.5/page 31
4.5/page 31
4.5/ page 31
4.5/page 32
4.5/page 32
4.5/page32 / change flour or vegetable market gardens to horticulture and amenity horticulture
Quad bikes should be a separate dot point and also include farm vehicles eg farm utes.
The major risk from mobile plant is run over.
Contact will most likely be with the PTO shaft, PIC or POC and slasher blades or objects propelled from the slasher during operation.
This statement should be emphasised – “A risk assessment is unnecessary if you are already aware of the risk and there is a known solution of how to control it”.
The phrase “on uneven terrain” should be removed as rollovers can occur on level terrain.
Insert “or moving” in the phrase rotating parts.
Would suggest that motorcycle helmets be included in PPE. If helmets are required to be worn then there will need to recognition of equivalence for standards including US and European standards (road use) for helmet. Given that quad bikes can be used at low speeds the NZ standard for helmets for low speed use (below 30 kph ) should also be recognised. Road type helmets may present some risks particularly in hot weather and limited air flow.
This would appear to be a commercial logging operation rather than farming.
There may be some confusion as to what type of saw is being referred to i.e. chain saw or circular saw.
Some examples of high- risk plant may be useful.
Would be helpful to include the actual distances from the electrical code.
It would be useful to introduce a new sub-section on Farm vehicles including farm utes in relation to carrying unrestrained passengers.
In the sentence relating to round bales add “a hay spike or grab should be used”
It is essential that there be no requirements to use a ROPS in sheds or orchards however it would be appropriate to recommend the use of fold down ROPS on such tractors so they can also be used for other purpose around the farm.
Consideration should be given to including a section on the selection of the most appropriate vehicles for the job task, whether it be a quad bike, side-by-side vehicle or farm ute etc.
It is recommended that the statement about endorsed and tested attachments be removed, as there are no guidelines for such assessments. Many farmers make and fit their own designs for attachments. To try to design register such devices would be virtually impossible to enforce.
The fitment of CPD’s to quad bikes is a very contentious issue which does require more research before there is any consideration of making them mandatory. There needs to be changes made to the structural engineering of bikes and after market CPD’s so that there are no unintended consequences associated with their fitment.
We would support the view that two seater bikes should be used where it is necessary to carry a passenger although there is little evidence of them being used on farm.
Farmsafe Queensland Ltd does not support the statement that children under 16 should not be allowed to ride a quad bike. This is simply too simplistic. Humans for any give age or sex will differ enormously in physical characteristics and levels of maturity (mental). The decision making process should be based on a risk assessment and ensuring that the rider has the skill level and physical and mental capacity necessary to ride the bike safely.
Farmsafe Queensland Ltd supports the current manufacturers recommendations that persons under the age of 16 should not be allowed to operate adult sized Quad-bikes above 90cc capacity. Children above the age of 12 should be educated to safely operate Quad-bikes using appropriate sized machines in the range of 60-90 cc engine capacities.
Regarding the statement about adequate training Farmsafe Queensland Ltd believes that the whole issue of education about operating and purchasing appropriate models, who should ride them and what accessories can be fitted needs to be looked at in a lot more depth.
Farmsafe Queensland Ltd further contends that there is a lack of forensic examination of incidents involving Quad Bikes in Australia and that a forensic crash investigation unit should be established to investigate these incidents. This information gained from such a unit could then be used to further enhance the education of Quad-bike users generally.
Farmsafe Queensland Ltd would prefer to see the term education rather than just training which implies a more formal process involving competencies.
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?
While there is an expectation that compliance with the code will assist in making workplaces safer there are probably many workplaces, which already have a culture of safe work practices.
Codes should make it easier for PCBU’s to meet their obligations, as the Code should make it easier for the PCBU to understand those obligations and provide some practical advice about doing so.
There will undoubtedly be some costs associated with compliance particularly with regard to such things as the increasing use of helmets and the future fitment of CPD’s where appropriate.

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