Individual / Organisation name: 001 Tim Greay
What state/territory are you from?
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
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. 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 Page 4.4 page 24 fall arrest systems
With the new guideline there is an opportunity to improve on the controls when
working at heights while carrying out scaffold work. It is not practical to employ
sequential erection techniques in a lot of circumstances as implied in the new
guideline and working in a harness using fall arrest is the common practice. The
extra scaffold required to build manner where a fall is not possible is best
practice but increases the risk of soft tissue injuries ( working above shoulder
height for longer periods, exposure at heights and also the increase probability
of dropped objects as the scaffold gear is double handled.
The opportunity exists to raise the bar and industry best practice by using fall
restraint techniques and limited free fall (fall arrested with in 600mm) to reduce
the risk of injury while working at heights. There are many types of fall arrestors
on the market now that can do this at a reasonable cost so there should be no
reason to work in fall arrest where the allowable fall can be up to and greater
that 2 meters (classed as a survivable fall but most likely to result in serious
injury).
I would like to also suggest that there is some guidance around rescue and
development of rescue plans while working at heights. (how will you rescue,
what with and who buy.) In the case of a fall the time spent in the harness
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Individual / Organisation name: 001 Tim Greay
What state/territory are you from?
suspended is reduced if there is a plan in plan for rescue and the people are
trained..
Going back to my previous comment this would not be such an issue if the fall
was arrested with in 600mm (limited free fall) and not the allowable fall that is
allowed when working in fall arrest of over 2 metres. Construction companies
will always work to the least path of resistance that is cost effective to them. By
not legislating maximum fall of 600mm, mandatory rescue plans etc legislation
is governing a survivable fall and not really improving controls around working
at heights.
I am currently a health and safety advisor (Graduate diploma ECU) on a major
oil and gas project with a major gas provider. I spent 14 years in the industry as
a rigger and scaffolder onshore and offshore and the last 3 years as a health
and safety advisor specialising in working at heights, lifting, rigging, and
scaffolding. I have a good grasp on what goes on and what is practical to
implement and have had a lot of buy in to how WAH is managed on our
facilities. The control of trying to eliminate exposure at height through build
methods in a lot of cases is not a practical option (Cost and Time, soft tissue
injury exposure, tube and clip scaffolding) and guidance on managing falls
quickly and making the allowable fall of 600mm would be of more benefit to
improving scaffolding practices at height and reducing the likely hood of
sustaining an injury as a result of a fall.
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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