098 Parkside Group

Individual / Organisation name: Parkside Group

What state/territory are you from?Queensland

Draft model WHS Codes of Practice and guidance - Public Comment Response Form

Complete and submit this form by5pm AEST Friday 24 AUGUST 2012to

General Comments

Parkside Group makes the following general comments on the Draft Code of Practice for Managing Risks in Forestry Operations.

Parkside Group are native forest harvesters and sawmillers based in South East and Western Queensland. We have a range of contractors involved in the native Forest harvesting, who have been consulted along with our own internal staff.

We make the following recommendations on the Draft Code of Practice for Managing Risks in Forest Operations:

  1. the code should avoid being overly prescriptive, unless as a prescription is based on a legislative or regulatory requirement, as such wording of must, ensure and should needs to be reconsidered;
  2. the code should be based on performance outcomes, rather than specific methodology, this would deliver a more consistent outcome across a wide and differing landscapes and forest types this code is addressing;
  3. driving of trees should be allowed as a last resort and not prohibited;
  4. the location of the truck driver when loading should be communicated between the loader operator and the truck driver. The truck driver should be allowed to remain in their cabin.
  5. A list of recommended competencies should be included;
  6. the inclusion of Australian Standards should be for a reference only;
  7. where safety signage has been ignored, the health and safety responsibility lies with the unauthorised visitor;
  8. the use of leg protection should be based on a risk assessment and should not be considered a mandatory piece of PPE for chainsaw operators.

General Comments on Issues Listed in the Public Comment Document

  1. Guidance on ‘driving trees’

Driving trees should be used only as a last resort when all other methods of felling the tree have failed. By prohibiting the use of driving trees, the alternative is often to leave the tree hung up, creating a (potentially unknown) hazard for future harvesting operations.

  1. Use of holding wedges with trees that are manually felled with a chainsaw

Where a tree already has an obvious lean in a given direction, the use of wedges has little benefit. However the use of wedges for general falling is common practice for hand falling in the native forest industry and is it a preferred method for hand falling.

  1. Location of the log truck driver when loading and unloading

Preventing a truck driver from remaining in his cabin whilst logs are being loaded is highly impractical and raises safety concerns. Truck driver location while loading should be based on an agreement between the truck driver and the loader operator. Concerns at this point are:

  • truck drivers in the cabin can be in constant radio communication with the loader operator, providing feedback on load limits
  • logs are placed onto the truck using a laser with either a grapple or forks, logs are never thrown all rolled onto the truck
  • logs are not lifted over the cabin of the truck
  • remaining in the loader operator's line of sight is not always practical to achieve at all times

Parkside has recorded no incidents from truck drivers remaining in their cabins during loading

  1. Inclusion of required competencies

Inclusion of recommended competencies would be helpful, as long as the competency is relevant to the specific task.

5. Reference to Australian Standards

The inclusion of Australian Standards should be on a reference basis only, they should not be prescriptive.

Specific Comments

  1. Safety Signage

Where safety signage has been ignored or not adhered to by visitors, the responsibility for the health and safety of the visitors lies entirely with the (unauthorised) visitors.

  1. Leg protection

Appendix D - Personal Protective Equipment (PPE) states that leg protection use is mandatory for chainsaw operators when supplied. Leg protection is a valid form of PPE for a chainsaw operator, however it is not practical in all situations. In Queensland temperatures in the shade can easily exceed 30°C and humidity exceed 60% for months on end during the wet season. While workers often start early to avoid the heat of the day, the use of leg protection can greatly increase the amount of sweating, increasing dehydration risk and increases fatigue. Another problem faced is dense understory where leg protection decreases the speed at which a chainsaw operator can escape. Mechanical scrubbing around the base of a tree is not practical, as often the skidder operator is not on site at the same time as the chainsaw operator. The only "scrubbing" that occurs is clearing a small track as an escape route with a chainsaw. Scrubbing further than this is likely to create further issues in relation to environmental impacts, particularly with highly erodible soils. It is not just the vegetation directly surrounding the tree to be felled, but also the vegetation the chainsaw operator is walking through to get to the next tree.

It is recommended that a documented risk assessment be an appropriate tool to determine whether the use of leg protection will create a higher risk than not wearing it.

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