Individual / Organisation name: 016 Essential Energy
What state/territory are you from? NSW (& Queensland)
Draft model WHS Third Set Codes of Practice - Public Comment Response Form
Complete and submit this form by 5pm AEST Friday 22 June 2012 to
1. Safe Design, Manufacture, Import and Supply of PlantSection/page no. / Comment
Page 4 Foreword
Last sentence. / (Draft code sent out without this sentence being completed).
- A draft of this Code of Practice was released for public consultation on 2 April 2012 and was endorsed by the Select Council for Workplace Relations on [to be completed].
Page 7
Providing and obtaining information / Designers, manufacturers, importers and suppliers all have obligations to provide information about the plant to enable other duty holders to fulfil the responsibilities they have in managing the associated risks. (Suggest to remove the last 3 words .. associated with it. As it is already implied and grammatically not to end a sentence with a preposition).
Page 10
2.2 Assessing the risks – Dot point 2 / Comment: In spite of the preliminary statement - A risk assessment is unnecessary if you already know the risk and how to control it. To arrive at this conclusion, a risk assessment needed to occur.
• how many people would be exposed to the potential hazard at the same time (this affects the consequence or risk?
Page 14
Knowledge and capability / In addition to core design capabilities, the following skills and knowledge should be demonstrated by a designer: Remove the words … or acquired by…
Page 14 3.4 Pre-design and concept development phase. / · Conducting research and consultation to assist in identifying hazards, assessing and controlling risks (see section 2.3).
- The document actually states …see section 2.5. - but it should read 2.3
Page 15 Fig. 1 Diagram on A systematic approach to integrating design and risk management / Redesign to reduce risks within the ……………… Text missing / been cut off from this box at the bottom in the diagram –
Page 18
Installation and commissioning (bottom of page) / · Environmental factors affecting installation and commissioning.
· Operating procedures. Extra point added
Page 19
3.8 Registering plant design / Schedule 5 of the WHS Regulations requires certain plant designs and items of plant to be registered (registrable plant). Schedule 5 (Part 1) is reproduced in Appendix B. – (Part 1) is missing.
Page 22
4.4 Minimising human error / Human error is not always the result of carelessness or negligence.
Same paragraph
Workers may use unsafe practices to overcome poor plant design or become bored and distracted with repetitious work, which may cause loss of concentration. – Suggest to shorten the sentence to this.
Page 24 Fig. 2: Examples of guards on a press brake / If guarding is used, the designer must ensure that:
• the guarding will prevent access to the danger area of the plant
Remove the words ….danger point …
Page 31
6.3 Compatibility of Plant / A manufacturer using components from a variety of sources should provide the importer or supplier an assurance of compatibility of components and that the plant is safe and without risk to health when used properly.
Comment: How will this occur?
Page 32
6.5 Design registration / 2nd Paragraph
If the importer or supplier makes modifications to the plant, for example to ensure compliance with Australian standards, they should take all reasonable steps to advise both the designer and manufacturer. Remove the words …of this…
Page 32
6.6 Hire of Plant / A supplier must ensure the hired plant is accompanied by information about the way the plant must be used to ensure health and safety.
The words … if the information is available… should be removed. The equipment should not be hired if does not have accompanying H & S information.
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. Working in the Vicinity of Overhead and Underground Electrical Lines
Section/page no. / Comment
Title / Possibly consider changing the title to or adding to the title to include electrical apparatus. This is then inclusive of all electrical equipment e.g., substations, etc. Change the reference throughout the document from electric line to Electrical Apparatus.
Also adding this definition into the appendix.
Electrical Apparatus: any electrical equipment (including overhead lines) associated with the supply of electricity at high or low voltage, the conductors of which are live or can be made live. [This is the definition used in all National Energy association documentation].
Section 3.6
p.24 / Authorised person
In order to authorise a worker, the person conducting a business or undertaking should first gain approval from the person with management or control of the electrical line to do the work that involves being near it. The person conducting a business or undertaking would need to ensure that the worker has enough technical skill and knowledge to perform the work.
Does this mean that PCBU has to gain approval from the controller of the line (ESA) each time they wish to authorise a worker? Is this approval in writing or just notification? Either way this would be an unnecessary burden on the ESA for no real gain to either party. Section 2.6 has no mention of notifying the ESA. Section 2.3 states that notification to the ESA is determined by a risk assessment.
Section 3.6 p.24
Authorised person, 2nd para / In many instances, approval would need to be sought from an electricity supply authority. However, if it is a private electric line, the owner would need to approve the person to work near the electric line. For example, if the private electric line is on a farm, the person conducting a business or undertaking would need to seek approval from the farm owner before the worker can be authorised.
The example given should not imply that the farmer is the owner of the line. In the majority of cases this is not correct. A farmer would not necessarily have the knowledge to authorise the worker. We believe this statement should only be to seek advice from the electricity Network Distributor. If a network is in private hands, then the owner should have a nominated person to operate and maintain their system, and as such, they should be the person consulted.
Section 4.1
p.26 - first dot point / An unauthorised person should not:
· climb a tree (replace than with - which is ) closer than 3 metres to energised overhead electric lines, or cut any branch that may come closer than 3 metres to energised overhead electric lines as a result of the work.
Section 4.1
p.26 – 2nd dot point / An unauthorised person should not:
· allow any part of their body or anything they are holding or that is attached to their body, or anything they are using, to come closer than the approach distances specified in Table 1 of this Code when carrying out the work in the vicinity of energised overhead electric lines. The only exception is if the person is handling an insulated device which has been tested and found to be safe for use on and near the electrical part.
- An Unauthorised Person should not take anything inside the 3 metre zone.
Section 5 – Last sentence – 1st para. / Construction work carried out on or out on or near energised electrical installations or services is defined as ‘high risk construction work’ and requires the preparation of a safe work method statement (SWMS). – Typo – double up on wording.
Sect 5.3 p.32
Administrative Controls (dot point 3) / · using approved visual indicators, to make the hazard visible by arranging for the electricity supply authority to effectively identify exposed energised low voltage conductors (up to and including 1000 volts a.c.), for example ‘tiger tails’ shown in Figure 15 of this code.
This section should state that the installation of tiger tails does not allow any closer approach. It is not insulation – only indication.
Sect 5.3 p.32
Use PPE / Appropriate PPE includes the use of electrically tested insulating gloves by anyone who may be at risk of coming closer than the 4 metre approach distance.
Insulating gloves is not a control for non-qualified workers. Non-Qualified workers must maintain their safety clearances.
Section 5.4 Specific Control measures – p.33 1st para / …..tiger tails’ should be provided and installed by the electricity supply authority for the full length of the scaffolding plus a minimum distance beyond each end of the scaffolding of 5 metres.
This is worded to say that the supply authority will provide and install. Maybe we need to indicate that the electricity supply authority should be ‘engaged or consulted’ for the installation of tiger tails. Consultation will confirm if they are private or Electricity distributor’s lines. Secondly, it should be mentioned that there should be costs associated with the installation and application of tiger tails.
Section 6 p.36 / Add and Underground to the title of Agricultural work
Add new dot point to examples
· ploughing and excavation work
Last paragraph Add and section 9
Section 6.1 p.36
Identify hazards / 1st sentence after overhead add or underground electric lines
2nd sentence after overhead add or underground electric lines
2nd Paragraph 3rd sentence after overhead add or underground electric lines
Last sentence after overhead add or damaged underground cables when ploughing or excavating
Hazards dot point add when ploughing or excavating
Last paragraph – last sentence add Operators must also be aware of underground assets installed in the area to be ploughed or excavated.
Section 6.2 p.37 Assess risks
/ Section dot point add or underground and after height of add or depthAdd new 3rd dot point location of underground assets
p.38
/ Bottom of page add danger sign keep clear of underground power linesSection 7.1 p.41 / Table 4 - Handling of non-conductive materials (e.g. timber, plywood, PVC pipes and guttering, etc) regarded as conductive unless knowledge to the contrary.
Section 8.1 p.44 / Qualified person is a person who has successfully completed a high load transportation scoping course or its equivalent provided or authorised by an electricity supply authority. The evaluation of the person’s qualification will be made by the relevant electricity supply authority.
There is no such course or authorisation process that covers this within the Electricity Supply Industry. ‘Qualified’ has a very specific meaning in the Electricity Supply Industry which means those with electrical knowledge and within the scope of their qualification and authorisation, are allowed to come closer to Electrical Apparatus than Ordinary Persons. The statement which exists in 8.1 in this document may be misconstrued and implied that individuals can obtain such an authorisation, which does not exist in NSW.
Section 8.3
p.46 / Escort service provider – electrical safety
Responsibilities regarding the transport of high loads are to:
· use only specialised equipment, especially where the equipment may and can come into contact with exposed energised parts
Are we going to allow transport companies to contact the line to lift it etc? The transport companies need to contact the Electricity Distributor after risk assessment and co-operatively decide a strategy and plan of action.
Section 8.3 p.47 / Note: The categories and requirements for the transportation of high loads are based on Queensland requirements. For specific requirements in other jurisdictions contact the relevant Transport/Traffic Authority and the Electricity Supply Authority in your state or territory. For further information see Appendix D.
This Statement should be at the start of section 8. Several of our readers found
it a daunting challenge to change from the successful processes we currently
employ. It wasn’t until they got to the very end of the chapter that it was noticed
it particularly pertained to Queensland. Placing it at the beginning will alleviate
any of these issues.
Section 9 p.48
Electrical risks
Section 9.1 p.48
Identify hazards
/ 2nd sentence in text box within an unsafe distance What is a safe distance?2nd paragraph end of sentence after must be managed - by the use a safety observer
Also, Insert DBYD Promo
Section 9.2 p.49
Assess Risks / Add Once cables have been identified in the excavation area, contact the network operator for safe approach distances to cables. Pot-holing shall take place to ensure positive location of cables by non-evasive methods such as hand digging or hydro vacuum excavationAdd reference table for close approach distances
Section 9.3 p.50 Control risks
/ Last sentence after practical by carrying out excavation using an Authorised Person safety observer to prevent excavation machinery from making contact with cables. Add definition Authorised PersonPage 51 Eliminate the hazard and associated risks
/ 1st paragraph after this means digging by hand add Or hydro - vacuuming excavationLast sentence after arrange. Add To De-Energise electrical assets contact the Network Operator or asset owner