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.  Cranes
Section/page no. / Comment
General / Arrium is an ASX listed international mining and materials company with sales revenue for the 2011 financial year of $7.13 billion, and approximately 11,000 employees. Arrium operates approx. 2400 cranes across Australia. The majority of these are bridge cranes.
General / The intended scope of this Code of Practice applies to cranes in the workplace. The subject matter throughout the code appears to have a much narrower focus on tower and mobile cranes predominantly with only a small amount of guidance on bridge cranes.
The amount of guidance given for bridge cranes is minimal when compare to tower and mobile cranes and therefore would be of little assistance and may create further confusion as PCBUs will need to reference other sources. Some sections of the Code appear to be silent on Bridge Crane requirements. Examples are:
Page 61 gives detail for NDT inspections on tower cranes however there is no guidance on NDT inspections for bridge cranes.
Appendix E has sections for Mobile Cranes, Tower Cranes and Vehicle Loading cranes but not Bridge Cranes.
General / Feedback from practitioners was that the structure of the material appeared hard to follow when trying to understand requirements for specific cranes. This could be alleviated if separated out into types of cranes (or separate documents).
Greater clarity is required for the crossover between the Code of Practice and Standards. There are a wide range of Australian Standards that apply to cranes and without greater clarity a new document such as this Code of Practice can create confusion, particularly where there is either a disparity between the Code of Practice and current Australian Standards, or where there is still a need to reference Australian Standards when the Code of Practice is either silent or wanting in detail.
4.7/27 / Limiting devices are discussed, but there is no guidance for their application.
4.7/28 / It is unclear if all hooks must/should have a hook latch. Arrium handles certain product where lifts must be made without a hook latch as a hook latch would increase the risk. Suggested wording “ Where fitted, safety hook latches are operable”
5.1/34 -37 / The requirements for major inspection required for registrable mobile and tower cranes is specified however bridge and gantry cranes are not mentioned until within the Major Inspection paragraph on page 35.
This section appears to contradict AS 2550.1 2011 especially on major inspections and end of life. If this is the intent then there should be further clarification to avoid confusion.
There are separate paragraphs for inspecting a mobile crane and inspecting a tower crane however no similar paragraphs for bridge and gantry cranes.
5.1/37 / The annual inspection section does not clarify which types of cranes are included. There should be clarity on what is included and whether it aligns with the current annual inspection referenced in AS2550.1. If there are differences then there should be some explanation or guidance for PCBUs.
6.9/49,50 / Dogging Licence
The interpretation of when a dogging licence is required varies between States and was not clarified as part of the Regulations, meaning that some States have needed to develop guidance notes that still have different interpretations between States. The key point of contention is the term “exercise judgment”.
The Dogging Licence was originally introduced for the construction industry, where loads may be variable and asymmetric and not always within view of the crane or hoist operator. In many other industries the loads to be lifted are regular and repetitive and do not require the exercise of the vast majority of the competencies associated with a Dogging High Risk Licence.
Any requirement for a Dogging High Risk Licence for low risk activities adds a significant and unwarranted burden on the businesses and employees involved. Affected employees will be required to acquire competencies far broader than are needed for performing their job role (for example splicing ropes, hand signals to crane operator, calculating sling diameter) and may be challenged by the complexity of the training and assessment. If they are successful in achieving the required competencies they may move out of the industry in which they are currently employed to another role where the full scope of dogging is used.
Arrium proposes that the definition is further clarified by explaining when work is low risk and therefore a dogging licence is not required. A suggested addition would be:
A person who carries out low risk work with a crane or hoist is not required to be licensed in dogging or rigging if
(a) the work involves basic lifting tasks – slinging of common and repetitive loads; and
(b) the person carrying out the work is complying with a written procedure approved by a person with a dogging licence; and
(c) the person carrying out the work is licensed as a crane operator for the type of crane being used; and
(d) the load remains in the view of the crane or hoist operator
Three powered motions.
The licence requirement to operate a bridge and gantry crane requires further clarity to eliminate the different interpretations across States. The term “more than three powered motions’ should be updated to specifically exclude operation of a magnet attachment as this is not considered a powered motion. If this is not specifically excluded then State differences in interpretation will continue to create a needless increase in the amount of licences required in some States.
Appendix C /72 / The reference to “if certain conditions apply” in the table would be of greater benefit if it referenced the appropriate section 6.9 in the Code of Practice or a summary of the conditions.
Under “Bridge Crane”, the top running and underslung bridge cranes items could be combined as the requirements are the same. Side-loaded bridge cranes are not 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 highlighted in yellow
There is an opportunity for greater clarity and cost benefits if the interrelationship between the Code of Practice and the Australian Standards is better defined.
There is an opportunity for greater harmonisation between States if there is better clarity in the definition of when a Dogging Licence is and is not required. Remaining silent on this matter places a significant unwarranted burden on business and unnecessary licensing of operators performing low risk tasks.
There is an opportunity for greater harmonisation between States if there is better clarity in the definition of “three powered motions” of a crane. Remaining silent extends the current State differences in interpretation and means the unnecessary licensing in some States of crane operators who are using cranes with only three powered motions but that also include magnet attachments.
2.  Amusement Devices
Section/page no. / Comment
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.  Industrial Lift Trucks
Section/page no. / Comment
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.  Managing Risks of Plant used in Rural Workplaces
Section/page no. / Comment
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.  Managing Security Risks in the Cash-in-transit Industry
Section/page no. / Comment
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.  Managing Risks in Forestry Operations
Section/page no. / Comment
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.  Guide for Tunnelling
Section/page no. / Comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this guidance material that are different to current requirements in your jurisdiction? If so, what are they?
8.  Guide for Managing Risk in Cable logging
Section/page no. / Comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this guidance material that are different to current requirements in your jurisdiction? If so, what are they?

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