060 PF Olsen Australia
Suite 2, 1 st Floor, 120 Upper Heidelberg Rd | Ivanhoe |
Victoria 3079
ACN 117 085 373
T: 03 9497 2007 | www.pfolsen.com

060 PF Olsen Australia
Table of Contents ........................................................................................................................ 2
Introduction ................................................................................................................................. 3
General Comments...................................................................................................................... 5
Specific Comments ..................................................................................................................... 7
Cost Impacts ............................................................................................................................. 16
Questions in respect to this submission should be directed to
David Bennett – Manager Forest Systems via email david.bennett@pfolsen.com
© PF Olsen (Aus) Pty Ltd
All rights reserved.
All rights of copying, publication, storage, transmission and retrieval in whole or part by any means and for all purposes except for bona fide copying by the entity that commissioned this report, as set out on the title page, are reserved.
August 2012 Table of Contents Page 2 of 16

060 PF Olsen Australia
Overview
PF Olsen
Australia
PF Olsen Australia is pleased to have the opportunity to submit these comments to the public draft of Safe Work Australia, draft Code of
Practice – Managing Risks in Forestry Operations.
PF Olsen (Aus) Pty Ltd (PF Olsen Australia) is a specialist forest management services and consulting company. The company is a wholly owned subsidiary of the PF Olsen Group Ltd, the leading independent forest management services group in Australia and New Zealand.
The PF Olsen Group manages approximately 400,000 hectares of land and forests and about 4 million tonnes harvest per annum on behalf of some 400 clients throughout New Zealand and Australia.
PF Olsen Australia has been operating since 2005 and has established a presence in all Australian mainland States. It maintains offices in
Melbourne, Hamilton, Traralgon, Coffs Harbour, Tumburumba and
Albany.
PF Olsen Australia has current contracts for the provision of OH&S
Audit services with VicForests, HVP Plantations, Midway Plantations and Forestry Plantations Queensland.
We have specialist expertise in:
1.
OH&S systems for forestry operations
2.
OH&S Compliance Audits
3.
OH&S Performance Standard specification
4.
Operational safety management
David Bennett,
Manager –
Forestry Systems
PF Olsen
Australia
David specialises in the development and implementation of costeffective systems for forest managers, contractors and timber processors, aimed at reducing risk and improving compliance. He is responsible for
PF Olsen Australia’s ForestSmart® Online Contractor Management
Systems. Currently more than 60 contractors throughout Australia use these systems. He is an experienced forester with qualifications in law.
He is a member of the Institute of Forests of Australia and the Law
Institute of Victoria.
Prior to joining PF Olsen Australia, David was Principal Consultant with
STEM Services Pty Ltd, a company which David co-founded, and which specialised in safety and environmental management systems and due diligence audits for the Victorian forest industries. PF Olsen Australia purchased STEM Services in 2010.
Continued on next page…
August 2012 Introduction Page 3 of 16

060 PF Olsen Australia
…continued
Key Concerns
Prior to founding STEM Services, David was responsible for the development and implementation of Australia’s only SafetyMap certified SMS for a forest management organisation, at APM Forests Pty
Ltd.
He has worked closely with forestry contractors and was lead consultant for the development of WorkSafe Victoria’s Industry Standard for
Safety in Forest Operations (Harvest and Haulage).
He has conducted OH&S System Audits for the past 15 years in organisations throughout Australia’s timber industry.
Following a detailed review of the document the following matters are of concern:

Failure to explicitly allow truck driver to remain in cabin of truck during loading operations. We understand that this is common practice in all mainland states.

Section 9.1 provides very explicit but poorly researched or justified requirements for log load restraints. The section must be generalised and limit the information to list of available options and matters to be considered when designing a load restraint system.

The inconsistent use of language especially with regards to the use of the word “must” and other prescriptive terms such as
“ensure”.

The document format is inconsistent and therefore hard to follow. Sections with detailed step by step instructions are inappropriate in this document.

Code should include specific advice to duty holders about the means of developing alternative suitable controls to those specified in this document. This could be done by way of example dealing with issues such as driving tree or the use of cut-resistant leg protection in tropical regions of Australia.
August 2012 Introduction Page 4 of 16

ISSUE 1
Driving trees
ISSUE 2
Holding wedges
Holding wedges should be used where there is a risk of a tree sitting back during the falling operations. We support VAFI and the VFCA submission that “the prescriptive requirement should not be more than a faller is required to carry two wedges, and should use them if they determine it is the safest way to bring down a tree.”
ISSUE 3
Location of Truck
Driver when loading
Drivers should specifically be allowed to stay inside cabin during loading.
Precluding drivers from staying inside cabin is a great concern. Several drivers have been killed because they have wanted to begin lashing their load while the remainder of the load was being loaded. In one such event in Victoria, the conditions were extremely cold, as the coupe was above the snow line. The driver who was killed was highly experienced.
Making a driver stand outside in inclement weather conditions or extremely warm weather conditions increases the likelihood that this administrative rule will be broken.
Drivers who drive trucks that are load with wood chips from onsite chippers must also be allowed to remain inside cabin of their truck.
Exclusion zones around infield chippers are generally 100 metre and it is unreasonable to ask drivers to walk this distance from their truck.
The cabin of a truck is generally air-conditioned. It is possible to supervise load weights and communicate with the loader operator while in the cabin of the truck.
If a driver is required to stand outside the cabin the location should be risk assessed for hazards from other activities like chain-shot in log making operations and it may be appropriate for shelter from the weather to be provided.
Truck drivers should remain outside the cabin of the truck during all unloading operations.
Driving trees should be strongly discouraged. This could be used as an example of how documented hazard assessment can be used to develop alternate controls to those specified in this document and to identify which duty holders should be involved in authorising the alternate controls.
August 2012
060 PF Olsen Australia
General Comments Page 5 of 16

ISSUE 4
Inclusion of required competencies
ISSUE 5
Reference to
Australian
Standards
060 PF Olsen Australia
The document should refer to the list of national competency standards for high risk job functions and recommend that workers hold a
Statement of Attainment issued by a Registered Training Organisation as evidence of competency to conduct high risk forestry operations.
Refer p72 of Victorian Industry Standard – Safety in Forest Operations for a possible list of prescribed training.
The document should include a list of technical standards identified on p71 of Victorian Industry Standard – Safety in Forest Operations. The
Code could include advice as to the evidential weight of Australian
Standards. Our view is that if an Australian Standard is listed in this ti provides an easy reference for duty holders to check whether items like
PPE and operator protective structures are fit for purpose. If a duty holder checks an item is labelled to be compliant with a listed standard then this should be sufficient to demonstrate diligence in respect to ensuring appropriated controls.
We believe the Code should include specific advice that it is unnecessary for duty holders to own copies of the listed standards.
August 2012 General Comments Page 6 of 16

060 PF Olsen Australia
1.
Managing Risks in Forestry Operations
Section/page no.
FOREWORD 7
SCOPE AND
APPLICATION 7
Comment
OK, although consideration should be given to the document being released as
Guidance Material rather than as a Code of Practice, given the complexity of the forest environment and the difficulty in writing rules with a general application throughout Australia.
The scope of the document could be presented more clearly.
Our suggestion is to indicate that sections 2,3,4,5,11 and 12 are applicable to all forestry operations including silviculture and fire fighting, but specific hazards and controls have not been developed for these activities
It may make sense to make the above sections into a Code of Practice and then put all the operational specific hazards and controls into more fully documented guidance material that is developed by industry based experts in a similar manner to
New Zealand’s Best Practice Guidelines. These are developed and updated by
FITEC (www.fitec.org.nz)
The words “should” and “must” are not used throughout the document in a manner that is consistent with the guidance in this section.
1. INTRODUCTION 8
1.1 What are forest operations? 8
1.2 Who has health and safety duties in relation to forestry operations? 8
Suggest change of sentence as follows “ Forest operations may also involve multiple business operators and contractors working simultaneously at the one site.”
Suggest change as follows “ Persons conducting a business or undertaking may include land owners, forest managers, timber processing business owners and contractors.”
Suggest changes as follows
Table 1: Examples of typical responsibilities in forestry operations
Controllers of land
NB: This duty flows from s20 WH&S Model
Bill
Land owners or forest managers, timber processing business owners, principal contractors

Ensure roads are appropriately built and maintained.

Provide information on known hazards.

Enable safe access to work area.

Select competent contractors

Pass on information about known hazards

Conduct a job safety analysis in consultation with contractors

Ensure contractors conduct appropriate hazard assessments and implement necessary risk mitigation strategies.

Decide on the appropriate harvesting method

Allocate coupe/harvesting operational sites and schedules according to contractor skill and equipment

Ensure work can be safely conducted in the allocated time

Establish emergency procedures

Ensure traffic management plans are in place
August 2012 Specific Comments Page 7 of 16

060 PF Olsen Australia as required.

Establish consultation arrangements

Ensure compatible communications equipment for all contractors

Monitor and supervise contractors to ensure safe system of work
Contractors
Designers, manufacturers, suppliers
Workers

Select competent sub- contractors

Provide suitably maintained plant

Obtain licences and authorisations

Ensure only trained and competent workers are used

Supervise work practices

Check safety information about coupe/harvesting site/work area

Confirm communication and emergency procedures

Implement safe work procedures

Provide suitable PPE

Ensure first aid is available

Coupe and task assessment

Supply plant with proper operator protective structures and other necessary guarding suitable for forestry operations.

Provide users with information about safe hazards and controls for use of plant or substances

Follow safe work procedures

Not put themselves or others at risk

Report incidents

Comply with any reasonable instruction

Undertake training as required

Correctly use PPE that is provided for job tasks
1.3 What is involved in managing risks associated with forestry operations? 10
Please indicate specifically that regular toolbox meetings are an appropriate means for consulting with workers where other more formal arrangements have not been established.
2. THE RISK
MANAGEMENT
PROCESS13
2.1 Identifying the hazards 13 Review use of term hazard and ensure it is consistent within this section.
2.2 Assessing the risks 13 No comment
2.3 Controlling the risks 14 No comment
No comment 2.4 Reviewing control measures 15
August 2012 Specific Comments Page 8 of 16

060 PF Olsen Australia
3. PLANNING,
COORDINATION and
PREPARATION16
3.1 Longer term harvest plans
16
3.2 Annual plans 16
No comment
No comment
4.2 Safe work areas 20
3.3 Operational plans (Forest coupe/harvesting site plan/timber harvesting plan)
16
3.4 Building WHS into the next harvesting cycle 18
4. WORK HEALTH AND
SAFETY PRACTICES and PROCEDURES 19
4.1 Information, training, instruction and supervision
19
No comment
No comment
Refer to list of national competency standards for high risk job functions and recommend that workers hold a Statement of Attainment issued by a Registered
Training Organisation as evidence of competency to conduct high risk forestry operations. Refer p72 of Victorian Industry Standard – Safety in Forest Operations.
First dot point should be Work environment hazards. To be consistent with section
2.1 terminology.
Change Terminology to “Controlled Work Areas” – the whole point is that the zones being determined are NOT safe for unprotected workers and formal controls need to be established and enforced.
Make terminology more relevant to plantation based operations for example include additional boxes, as below:
Activity
Log extraction
Operator (s)
Faller / Harvester operator / skidder / forwarder / log processing operations
Infield processing Skidder, forwarder, truck driver
Typical safe work area

Separation distance of two tree lengths
(distance)

Machine canopy
(physical)

Separation by work scheduling (time)

Entry by either operator into controlled work are only by agreed protocol such as radio communication.

Separation distance of
100 metres (distance)

Machine canopy
(physical)

Separation by work scheduling (time)

Entry by either operator into controlled work are only by agreed protocol such as radio communication.
August 2012 Specific Comments Page 9 of 16

060 PF Olsen Australia
4.2 Safe work areas 20
(continued)
Include as an explicit example in “Loading of trucks”

Truck driver in cabin (physical)
Justification:
Precluding drivers from staying inside cab is a great concern.
The issues are:

Exposure to inclement weather and risks from other operations (intersecting work sites, chain shot)

Inability to read truck scales and hence safe loading of truck

Reduces monitoring of work site radio communications

Although cabins are not specifically engineered to withstand large logs being dropped on the roof, in a situation where the logs are small, the risks are much lower than for a driver outside the cabin.

Lighting inadequacy

Being in always feasible due to configuration the ‘loader’s line of sight’ is not of machines and it is difficult for loader driver to continually monitor where the driver is standing given the complexity of the loading operation.
Move to Section 2 4.3 Risk assessment of ground conditions 21
4.4 Communications 21 No Comment
4.5 Emergency procedures 21 Provide specific advice about appropriate means of “testing” emergency procedures, including discussing plans and checking emergency equipment during toolbox meetings or running mock emergency in conjunction with principal contractor.
4.6 Personal protective equipment (PPE) 22
4.7 Workplace facilities 22
4.8 First aid.22
4.9 Incident reporting 23
Appendix D table is incorrect.
Hearing protection is not required by everyone or ground workers where there is no chainsaw use involved.
Machine operators only require hearing protection where noise levels exceed prescribed levels.
Machine operators do not require eye protections and it should be based on risk assessment for ground workers.
It should be noted that there are different types of safety gloves and the gloves need to be matched to the hazard type “handling fuels and oils” or “cuts and abrasions”
Anti-vibration gloves should not be required for chainsaw operators if the chainsaw is fitted with anti-vibration damping mounts.
Guidance should provide specific guidance about required toilet facilities in bush operations. Current Victorian practice is to require toilet facilities only where crews are camping out. In circumstances where portable toilets have been provided, workers are very reluctant to use them. To require anything extra would be a significant cost.
Reference to “remote first aid training” needs to be removed as it is already covered in First Aid Code of Practice.
Should recommend reporting of incidents to principal contractor.
Need to advise duty holders where to find definitions of incidents that are reportable under s38.
Needs to clarify which PCBU has the duty to report.
Needs to ensure duty holders understand the importance of preserving the site until cleared by relevant regulator.
August 2012 Specific Comments Page 10 of 16

060 PF Olsen Australia
5.
COUPE/HARVESTING
SITE ACCESS AND
PREPARATION 24
5.1 Roads.24 Recommend that Code recognise an authorised Harvesting Plan as per Appendix B to be a suitable alternative for a SMWS under High Risk Construction Work
Regulations.
Recommend that the National Competency Standard FPICOR2205B - Follow OHS policies and procedures should be preferred standard for Induction Training in High
Risk Construction Work associated with Forestry Operations.
No Comment 5.2 Bridges 25
5.3 Log Landings 25
5.4 Safety signage 25
5.5 Visitor control 26
5.6 Unauthorised entry to coupe/harvesting site 26
6. TIMBER
HARVESTING 27
6.1 Hazardous trees 27
Generalise title to “Log Loading Areas” – Landings have a specific and narrow meaning in native forest operations. The hazards addressed here are hazards in all forestry operations regardless of whether a formal log landing area has been established.
First dot point – remove “to allow water run off.”
Ninth dot point – add “log processing and grading” as another major activity.
Add a new dot point – “safe area for securing load.”
2 nd paragraph bracketed example should be (such as a log loading area).
No Comment
Highlight that there are duties under s29 of other persons in a workplace to “comply with reasonable instructions” such as not entering exclusion areas signposted in accordance with section 5.4
6.2 Manual felling 29
6.3 Machine-assisted manual tree felling 32
Listed hazards apply to felling any tree – not just hazardous ones.
Section 4 inconsistent use of should and must.
Restrictions on driving trees should apply generally to all trees not just hazardous ones.
Remove “Specific fire salvage risks” This is not relevant to a national code. Other states issues such as cyclone damage are more significant. The emphasis should be on having people able to identify extra-ordinary circumstances and developing relevant plans to deal with such circumstances. Move to Section 3 planning.
Recommend “mechanical falling” as the preferred method especially for thinning operations.
Change “wedge must be inserted” to “wedge should be inserted”
Inappropriate use of word “must”. What does “relevant training and experience” mean?
Requirement to “have sufficient height reach, and is able to control the felling direction of the tree in a safe manner” is not practical in all circumstances. This requirement should be removed.
Detailed requirements after heading “The felling operation” are inappropriate for a
Code of Practice, better suited to Guidance Material.
August 2012 Specific Comments Page 11 of 16

060 PF Olsen Australia
6.4 Mechanical felling 33
7. LOG EXTRACTION
36
7.1 Delimbing 38
8. LOG LANDINGS 39
8.1 Log preparation 39
8.2 Log Measurement 39
No Comment
What is the definition of steep?
In appropriate use of “must”
No Comment
No Comment
Fifth dot point – replace word “under” with word “below”
Inappropriate use of word “must”
Add additional risk control for log marking – “select non-hazardous log marking paint”
Common Hazards of Workers Outside a Machine Canopy should be given more
Priority. This is a general issue for all forestry operations. Should be moved to
Section 12.
9. LOADING,
TRANSPORT and
UNLOADING of LOGS
42
9.1 Loading and unloading of logs 42
First dot point in Section 1 of Risk Controls should be “The driver should remain in a pre-arranged and agreed exclusion zone. An exclusion zone may be the truck cabin or a location outside the Controlled Work Area of the loading machine (refer section
4.2).” The term “exclusion zone” is used in other transport Codes of Practice.
Precluding drivers from staying inside cab is a great concern.
The issues are:

Exposure to inclement weather and risks from other operations (intersecting work sites, chain shot)

Inability to read truck scales and hence safe loading of truck

Reduces monitoring of work site radio communications

Although cabins are not specifically engineered to withstand large logs being dropped on the roof, in a situation where the logs are small, the risks are much lower than for a driver outside the cabin.

Lighting inadequacy

Being in the ‘loader’s line of sight’ is not always feasible due to configuration of machines and it is difficult for loader driver to continually monitor where the driver is standing given the complexity of the loading operation.
Truck suspensions are now built to a standard where cabin vibration during loading is unlikely to cause injuries.
Inappropriate use of the word “must”
August 2012 Specific Comments Page 12 of 16

060 PF Olsen Australia
9.1 Loading and unloading of logs 42
(continued)
Replace figure 9.1 with the following diagram. More appropriate to plantation operations which are more than 70% of the industry.
9.2 Transport and load restraint 46
August 2012
Figure 9.2 - It is highly unlikely that the loading operator could see truck driver as cabin on a forwarder is facing towards rear of the truck. More important that driver has 2-way radio communications.
This entire section is potentially ultra-vires. We remain extremely concerned about the load restraint requirements placed into this document because of the clear misinterpretation of the relevant load restraint regulations. These regulations are performance based standards and therefore it is clearly inappropriate for another regulator to mandate requirements such of rear load guards. The furthest this document should go is to identify potential load restraint techniques that may be used to meet the legislated load restraint regulations
Further, there is no evidence that the specifications for cab guards and load restraint guards in this document have been developed by engineers or the safety factors assumed in the performance outcomes that are expected to be achieved.
In many instances front load block may be more appropriate to meet load restraint performance standards than rear load blocks where logs have low static frictions.
Section should be limited to general comments about key issues and the types of load restraint devices that may be appropriate and potentially a “traffic light” approach for appropriate controls. The section should be written so that it is consistent in format with the other sections.
Logs are harvested down to 30mm small end diameter, so any guards need to be appropriate to product being carted.
Self-loading trucks have never been classified as cranes in Victoria. Licencing requirements of crane operations is likely to be an additional compliance expense.
Sections on “load configuration” and “load security” are not logically presented and not appropriate considering the large variety of log types harvested and hauled.
Specific Comments Page 13 of 16

060 PF Olsen Australia
9.2 Transport and load restraint 46
(continued)
10. INFIELD
PROCESSING 52
10.1 Infield chipping52
10.2 Firewood, post or sleeper cutting and portable sawmilling 53
11. PLANT AND
MACHINERY55
11.1 Plant and machinery selection 55
11.2 Safe use of plant and machinery 55
11.3 Modification of plant and machinery 57
11.4 Inspection and maintenance 58
Load unloading section
Too much detail for a Code of Practice – more appropriate for this detail to live in guidance documents. Haulage operators have resisted the introduction of “detwitching stations”.
Requirement for unloading machine to secure load prior to removal of restraints is introducing a new hazard associated with the close interaction of the unloading machine and truck driver. Best control is to limit the height of logs to below height of stanchion.
Log restraining equipment
There is no “non-rebounding” tensioner on the market suitable for securing a belly chain as the line of pull is not straight.
Figure 9.5 – Consider representing the preferred solutions such that load is crowned and no log is above the outer pin or stanchion end.
There is no information included about haulage of wood chips from infield chipping operations.
Should include “poles” in heading.
The requirement to carry out a “risk management approach” should not be limited to firewood cutting.
No comment
Requirement to where a seat belt in Victoria is limited to operations where there is a
“tip-over” risk. Therefore an excavator operator grading and loading logs on a flat landing is not required to wear a seat belt even if it is fitted to the machine. This is because it is likely he will climb in an out of the machine many times each day.
Therefore second sentence should be “All operators should wear a seat belt in all operations where there is a risk of machine tip over”. This provides a positive onus to get a seat belt fitted to all machines used in locations with the risk of a tip over.
Examples of objects penetrating the cabin should include “tree limbs and logs”.
Last paragraph starting “Windows should….” needs to be generalised to include machines without windows.
Inappropriate use of word “must”.
Needs more emphasis on requirement to inspect and maintain “hand held powered equipment like chainsaws and brush cutters.”
The sentence beginning “Wooden handles…” is out of context and may narrow the way a reader interprets the application of this section.
Recommend that “in-field maintenance” operations should be supported with a documented SWMS or JSA.
Risk Controls – No. 2. Checking fluid levels and refuelling – Remove sentence beginning “ The recommended process….”
August 2012 Specific Comments Page 14 of 16

060 PF Olsen Australia
12. OTHER COMMON
HAZARDS IN
FORESTRY
OPERATIONS 60
12.1 Hazardous manual tasks
60
12.2 Noise.62
No comment
Statement “that hearing protection will usually be necessary for workers in forestry operations” is untrue. Experience over the past 10 years measuring noise levels in forestry machinery has shown that only chainsaw operators and operators driving older open cabin dozers and skidders are working in an environment with noise levels in excess of prescribed levels.
No comment 12.3 UV exposure 62
12.4 Fatigue 63
12.5 Working alone 63
12.6 Working at night 64
12.7 Slips, trips and falls 65
No comment
No comment
No comment
Inappropriate use of the word “must”.
Should be generalised to apply to all “forest workers” and a couple of examples like
“tree-planters and forestry supervisors” also included.
Wind should also be identified as a weather condition that may trigger a requirement to “cease work”.
12.8 Extreme weather conditions 66
12.9 Working near powerlines 67
No comment
APPENDIX A – THE
MEANING OF KEY
TERMS 68
APPENDIX B – SAMPLE
HARVESTING PLAN 70
APPENDIX C – SAMPLE
FOREST OPERATIONS
RISK MANAGEMENT
PLAN 72
APPENDIX D –
PERSONAL
PROTECTIVE
EQUIPMENT 75
Recommend inclusion of additional section in respect to “Handling Hazardous
Substances” – key focus should be handling of fuel and oils.
No comment
No comment
No comment
Hearing protection is not required by everyone or ground workers where there is no chainsaw use involved.
Machine operators only require hearing protection where noise levels exceed prescribed levels.
Machine operators do not require eye protections and it should be based on risk assessment for ground workers.
It should be noted that there are different types of safety gloves and the gloves need to be matched to the hazard type “handling fuels and oils” or “cuts and abrasions”
Anti-vibration gloves should not be required for chainsaw operators if the chainsaw is fitted with anti-vibration damping mounts.
August 2012 Specific Comments Page 15 of 16

060 PF Olsen Australia
APPENDIX E –
PROCEDURES FOR
BRINGING DOWN
TREES THAT SIT BACK
DURING FELLING 76
Remove – unnecessary detail for Code of Practice. Put into Guidance material.
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?
Yes:
- Workplace facilities requirements section 4.7 – Provision of toilets and hot running water.
- Load restraint requirements specified in section 9.1 especially Rear load guards.
- Requiring operators loading trucks with truck mounted cranes to hold formal crane licences in section 9.2.
August 2012 Cost Impacts Page 16 of 16