062 Workplace Standards Tasmania, Department of Justice Tasmania
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 codes@safeworkaustralia.gov.au
1. Safe Design, Manufacture, Import and Supply of Plant
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?
2. Working in the Vicinity of Overhead and Underground Electrical Lines
Section/page no.
Comment
Section 1.4
The section on ‘Safe work method statements’ merely restates the
circumstances under which they are required (by the WHS Regulations). We
suggest consideration be given to expanding this section by explaining their
purpose and role in the context of this type of work, and that safe work method
statements be presented as one of the suite of measures that can be
considered (together with an explanation of the circumstances under which they
are mandated).
Section 2.1 on
page 9
This section refers to the ‘National Guidelines for Safe Approach Distances to
Electrical Apparatus’. It may assist the reader if a cross reference is made to
Appendix E, where the full reference is listed.
Section 2.1, the
dot point between
the diagrams on
page 10
This dot point refers to ‘… and/or excessive electrical load current passing
through the conductors.’ We submit that the use of the word ‘excessive’ is
incorrect in this context, as the distribution network service provider (the
electricity supply authority) must operate the system within design constraints
and ‘excessive’ would be outside such constraints. Alternative wording is
suggested, for example, ‘… and/or excessive the changing electrical load
current passing through the conductors.’
Section 2.1 page
11
We recommend deletion of the text on ‘Increase to approach distances’. We
note that the question of approach distances was raised in the Issues Paper
and WST supports Option 1 or 4 (our comments on the options are provided
later in this document), neither of which would require this text.
Section 2.1 figure
3 page 11
For clarity and ease of application, we recommend pictorial differentiation
between poles and towers. Therefore an additional figure is needed to cover
towers. For example, see pages 2 and 3 of WST’s document called a Guide to
working safely near overhead power lines (GB 137) (available at
www.wst.tas.gov.au ) for depictions of poles and towers.
Section 2.2, 2.3
and 2.4
These sections should include reference to the 4.0 metre approach distance for
metal scaffolding near live electrical lines, as per section 5 and also Table 4 in
section 7 (on page 41).
We also suggest that Table 4 (where it mentions ‘scaffolding’) include a note
cross-referencing the COP on Scaffolding Work.
Section 2.4 on
pages 13 & 14
The text on ‘About no go zones’ needs to support the requirements in the
preceding paragraphs in 2.4. for the electricity supply authority’s written
approval. This might be easily covered by rewriting the 1st paragraph on page
14 as follows (changes marked):
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062 Workplace Standards Tasmania, Department of Justice Tasmania
‘In planning the work, Tto decide the correct no go zone in the circumstances,
you should consider contacting the electricity supply authority or owner, and:
 verify the voltage of the electric line, and
 verify if it is insulated or bare.’
Then the next line ‘ if you don’t know these facts, you …’ could be removed.
This puts preference to making contact with the electricity supply authority,
which adds to the safety aspects, as well as notifying electricity supply authority
so they can also make a judgement as to whether or not it is safe to perform the
work with the lines energised, even though the work may be outside the ‘no go
zone’.
Section 2.5
The current design envelope in Tasmania covers a 4.3 metre height, not the 4.6
metres as mentioned in this section. There are some exemptions to this under
the Vehicle and Traffic (Vehicle Operations) Regulations 2001 and the
associated Heavy vehicle general Access Mass and Dimension limits – vehicle
information bulletin. This comment is also relevant to the categories of
maximum transport height above road in section 8 of this COP, see category 1
page 45.
We submit that it is outside the scope of this code of practice to change
jurisdictional requirements, which are established by authorities other than
WHS Regulators. This need not preclude future consideration, in consultation
with appropriate agencies, of whether there are prospects for harmonising this
area.
Available options for this COP include:
 listing the requirements in each jurisdiction (perhaps as an appendix);
or
 making a general statement that the design envelope varies across
jurisdictions and is generally in the vicinity of 4.3 to 4.6 metres in height
(we note that there is more information in Appendix D, which is not
referred to in Section 2.5).
WST does not support the current approach of merely referring to 4.6 metres in
Section 2.5.
Section 2.6
We suggest that this section include text that explains that the requirement to ‘
… have successfully completed an appropriate course of training …’ is in
addition to the requirements under the Act and Regulations for plant operators
to be competent and, in the case of high risk plant, licensed. Similarly there are
requirements for safety observers under the Regulations that we recommend
be referenced.
Section 3
We suggest the number of terms used to refer to plant, especially mobile plant,
be rationalised. The COP variously uses ‘crane or operating plant’, ‘crane or
other operating plant’, ‘cranes and mobile plant’, ‘crane or other plant’, ‘crane or
plant’, ‘crane or item of mobile plant’, and ‘crane, mobile plant, machinery and
equipment’, all within the chapter dealing with cranes and mobile plant.
Section 3.2
We submit that the risk assessment should be documented and available on
site when the work is be performed.
Section 3.3 on
page 19
We submit that there should be reference to the earthing of the crane, or mobile
plant or load etc., when in the authorised person zone, and possibly even
outside the zones when working in the vicinity of energised electric lines,
whether overhead or underground. This would then link the earthing aspects in
the risk assessment to section 3.7 of this COP.
Section 4
We suggest the text of the second dot point of the second paragraph be
amended as follows (changes shown):
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
‘ a local government work crew (other than those who are authorised
persons for clearing of vegetation around electricity supply authority and
private owner distribution electric lines and assets) performing
vegetation clearing or planting or vegetation treatment’.
This emphasises that the owner of the electrical lines or asset has the role of
authorising the work around such assets.
Section 4.1
The text under ‘unauthorised persons carrying out tree and vegetation
management’ is only appropriate for the safe access to voltage up to 132kV,
say on poles. The text also needs to cover the safe access no go zone for
transmission lines. Additionally, there would need to be a figure showing the
work zones for towers (in addition to the diagram showing poles).
Section 4.1
Consistent with our response later in this submission to the question in the
issues paper on training, we submit that the ‘current competency’ under
‘Authorised persons carrying out tree and vegetation management’, on page
27, be spelt out as being (as a minimum) the UET20312 – Certificate II in ESI –
Powerline Vegetation Control, or a person enrolled in that cert II course of
training whilst being supervised by a competent person who holds that cert II
qualification.
Section 4.4
We submit that the text on ‘Minimise the risk’ section on page 29 should include
reference to the earthing of mobile plant (as we have also recommended in our
comments above on section 3.3).
Section 5
We submit that the introduction on page 31 should cross reference the COP on
Scaffolding Work for guidance on scaffolding work (in the same way that the
Scaffolding Work COP references this COP in section 4.5).
Additional examples for inclusion in the introduction to this section could include
transportable/movable structures such as grain silos.
Section 6 on
page 36
Section 7.1
We suggest you include ladders in the list of the examples of handling of metal
materials in table 4 on page 41.
Section 7.4
We suggest the inclusion of a note on figure 15 stating that insulated matting
and tiger tails are only to be installed/fitted by appropriately competent and
licensed (where appropriate) persons.
Section 8, pages
44, 45, 46 and 47
As mentioned in our comments on Section 2.5, references to a vehicle load
height of 4.6 metres does not line up with the 4.3 overall height dimension limits
in Tasmania. We acknowledge the note on page 47 that indicates the
information in Table 5 pertains to Queensland, and the reference to Appendix
D.
WST does not support basing Table 5 on a single jurisdiction. Pending any
work to harmonise these requirements, and given that the responsibility for
these limits does not rest with WHS Regulators, we suggest that, the COP
should include appendices detailing the requirements in all jurisdictions
(developed in consultation with the responsible agencies in each jurisdiction).
On a related issue, we are advised that the term ‘escort vehicle’ is defined in
each jurisdiction’s road and traffic legislation. To prevent confusion, we
suggest that similar terms of ‘escorting’ and ‘escort service providers’ not be
assigned different meanings. We suggest a cross reference to the relevant
laws be considered if the scope is sufficiently similar.
Section 9
We recommend you add the following examples to the examples of work on
page 48:
 A person drilling or nailing into a wall, where electrical cables are
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062 Workplace Standards Tasmania, Department of Justice Tasmania

installed behind the plaster board or masonry etc. (this is partly
covered in the 3rd dot point of the hazard examples of 9.1);
A plumber cutting a conductive water pipe that is part of the
site’s electrical installation’s earthing system.
Section 9
We suggest that consideration be given to including reference to safe approach
distances for cables, depending on their voltage, in a similar system to that for
overhead electric lines identified in section 2, with no go zones, authorised
person zones and unauthorised person zones. Many electricity supply
authorities do not allow mechanical excavations within 1 metre of their high
voltage cables. The safe approach distances to energised cables is heavily
reliant on the type of cable, its location and it’s condition etc. (in Tasmania, the
cables range from 110/240/415 volts up to 110kV AC and 400kV DC).
Section 9.2
As per our comment on section 3.2, we submit that the risk assessment should
be documented and available on site when the work is be performed.
Section 9.3
With respect to the reference to digging by hand in the second paragraph we
note that this may not be safe either, as crow bars, picks and shovels can cut
and expose electrical conductors. We suggest the following modified text to
cover this concern (changes shown): ‘… For example, if you cannot determine
exactly where an underground cable is, you should dig carefully to use ‘pot
holing’ to carefully identify the cable location and avoid accidental damage
contact with the cable. This may mean digging only by hand using insulated
hand digging tools (appropriate for the voltage concerned) when pot holing, or
the use of vacuum pumping in the pot holing process to locate the underground
cable/s. …’. Doing this could also remove need for the last sentence in this
paragraph, ‘This may mean using hands tools instead of power tools.’ The
introduction of the term ‘pot holing’ would be appropriate, as it is an industry
identifiable term (and it would be appropriate to add the definition of ‘pot holing’
to appendix A).
Appendix A
We suggest that a definition of ‘isolated’ be added in Appendix A, as the term is
used in 9.3 and elsewhere in the COP; and persons with no industry experience
may not understand that ‘isolated’ is not merely de-energised/switched off.
Appendix A
We have three matters to raise with the definition of ‘Electricity Supply
Authority’.
The first is that the definition as it stands does not appear to include the
transmission of electricity (predominantly on towers) between the Generator
and the Distributor (unless ‘distribution’ is read to include ‘transmission’). This
could be addressed by adding ‘or transmission’ after ‘distribution’.
Secondly we suggest that ‘or network service provider’ be added after ‘network
operator’.
Thirdly, we note that the definition of ‘electricity supply authority’ in the Model
WHS Regulations is subject to a jurisdictional note which requires jurisdictions
to insert the relevant person or body into the definition. This means that the
definition may possibly be different between the regulations and the COP, and
we consider this to be problematic. Cross-referencing to the definition in the
regulations may resolve the issue if the scope is the same. However, if it is not
(and noting our comment that ‘transmission’ needs to be included), another
option will be required.
A simple solution may be to use a different term in the code of practice (such as
the alternative of ‘network operator’) and include a definition along the lines of:
‘Network operator means a person or body engaged in the distribution or
transmission of electricity to the public or in the generation of electricity for
supply, directly or indirectly, to the public. An electricity supply authority as
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062 Workplace Standards Tasmania, Department of Justice Tasmania
defined in the Work Health and Safety Regulations is a network operator. A
network operator may also be known as a network service provider.’
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062 Workplace Standards Tasmania, Department of Justice Tasmania
Appendix C
Comment on
three options
posed on pages
8 and 9 of the
Issues Paper
We submit that the word ‘shall’ in the first sentence should be replaced with
‘should’ because it is not relating to a legislative requirement.
We submit that words to the effect of ‘only if it is safe to do so’ be added to the
beginning of the first dot point on page 56.
1. Option 1: WST conditionally supports this option, subject to Tasmania’s
electricity supply authorities raising no safety concerns regarding a
reduction of the distance applicable to lines greater than 132kV (and up
to 330kV) from 8 metres to 6.4 metres. This option is consistent with AS
2550.5 – 2002, and aligns the distances to voltages that are expressed
numerically.
By way of background, in Tasmania, a number of electricity supply
bodies utilise the ‘no go zones’ published by Workplace Standards
Tasmania (available at www.wst.tas.gov.au in publication no. GB137,
page 2 & 3) within which written authorisation to work is required.
GB137 accommodates and aligns with the dimensions in option 1,
however there are only two specifications:
 less than 132kV - 3 metres and
 greater than 132kV - 8 metres.
Please note, the maximum nominal operating voltage in Tasmania
currently is 220kV (with the exception of the Basslink line which
operates at 400kV DC).
2. Option 2. Not supported. Wherever possible, we should seek to have
consistency with other standards and codes.
3. Option 3. Not supported. Removal of the table does nothing to
advance national harmonisation.
4. Option 4. WST notes that the issues paper does not specify what
distances would apply. WST conditionally supports this option, subject
to the distances specified.
Comment on
question posed
on training on
page9 of the
Issues Paper
With regard to training and competence requirements for authorised persons to
work in the authorised person/no go zones; to provide harmonisation and
portability, we submit that this should be;
 Provided by registered training organisations;
 Involve the application of not only the ENA NENS 04 document –
Safe Approach Distance to Electrical and Mechanical Apparatus,
but also
i. ENA NENS 03 – National Guidelines for Safe Access to
Electrical and Mechanical Apparatus; and
ii. The Australian Energy Supply Industry (ESI) Skill
Passport, which was an ENA initiative, that is currently
being implemented with over 21,000 already issued
nationally.
 To nationally recognised units of competence for endorsed
training packages, where appropriate. This should include as a
minimum the;
i. appropriate high risk licences, as appropriate,
ii. appropriate national occupational licence (NOLA) for the
type of prescribed work, as appropriate e.g. Electrician,
Cable Jointer, Lineworker, Plumber, etc.
iii. competence requirements for the work activity, e.g.
UET20312 – Certificate II in ESI – Powerline Vegetation
Control, for vegetation management, Safety Observer
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062 Workplace Standards Tasmania, Department of Justice Tasmania
training and registration/authorisation,
iv. set of Refresher Training Units for the ESI as endorsed
under the Transmission, Distribution and Rail Training
Package UET11, and
v. competence in the application of ENA NENS 03 and ENA
NENS 04, as appropriate for the work activity.
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?
Depending on the distances proposed Option 4 may impose some additional cost on PCBUs in
changing existing work practices in working in the vicinity of overhead or electrical lines.
We also note the potential for costs if Tasmania were to align with the vehicle load heights specified
in Section 8.
3. Traffic Management in 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?
4. Scaffolding Work
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. Formwork and Falsework
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?
Other comments
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