Safe Design, Manufacture, Import and Supply of Plant

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DRAFT
SAFE DESIGN, MANUFACTURE,
IMPORT AND SUPPLY OF PLANT
Code of Practice
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of Practice
under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
DRAFT
TABLE OF CONTENTS
FOREWORD ................................................................................................................................ 4
SCOPE AND APPLICATION ....................................................................................................... 4
1
INTRODUCTION................................................................................................................... 6
1.1
Who has health and safety duties in relation to plant?.................................................... 6
1.2
What is involved in managing risks associated with plant? ............................................. 7
2
THE RISK MANAGEMENT PROCESS ................................................................................ 9
2.1
Identifying the hazards ................................................................................................... 9
2.2
Assessing the risks ...................................................................................................... 10
2.3
Controlling the risks ..................................................................................................... 10
2.4
Maintaining and reviewing control measures................................................................ 11
2.5
Information sources ..................................................................................................... 12
3
SAFE DESIGN .....................................................................................................................13
3.1
What is safe design? .................................................................................................... 13
3.2
The role of designers ................................................................................................... 13
3.3
Integrating safe design and risk management .............................................................. 14
3.4
Pre-design and concept development phase ............................................................... 14
3.5
Design phase ............................................................................................................... 17
3.6
Providing information ................................................................................................... 17
3.7
Registering plant designs ............................................................................................. 20
4
DESIGN CONSIDERATIONS ..............................................................................................22
4.1
Physical and cognitive characteristics of users ............................................................ 22
4.2
Designing plant which is safe to use ............................................................................ 22
4.3
Reasonably foreseeable misuse .................................................................................. 23
4.4
Minimising human error................................................................................................ 23
4.5
Environmental conditions ............................................................................................. 23
4.6
Erecting and installing plant ......................................................................................... 24
4.7
Maintenance ................................................................................................................ 24
4.8
Guarding ...................................................................................................................... 24
4.9
Operator control devices .............................................................................................. 27
4.10 Emergency stops ......................................................................................................... 27
4.11 Control circuit failure .................................................................................................... 28
4.12 Warning devices .......................................................................................................... 28
5
MANUFACTURING PLANT .................................................................................................30
5.1
The role of manufacturers ............................................................................................ 30
5.2
Manufacturing plant ..................................................................................................... 30
5.3
Testing and examining plant ........................................................................................ 31
5.4
Information about using plant safely ............................................................................. 32
5.5
Registering plant designs ............................................................................................. 33
5.6
Item registration ........................................................................................................... 33
6
IMPORTING AND SUPPLYING PLANT ..............................................................................34
6.1
Testing and examining plant ........................................................................................ 34
6.2
Information about using plant safely ............................................................................. 35
6.3
Compatibility of components ........................................................................................ 35
6.4
Importing plant ............................................................................................................. 35
6.5
Design registration ....................................................................................................... 36
6.6
Hiring plant................................................................................................................... 36
6.7
Second-hand plant ....................................................................................................... 37
PAGE 2 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of Practice
under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
DRAFT
7
SPECIFIC HAZARDS AND CONTROL MEASURES ..........................................................39
7.1
Confined spaces .......................................................................................................... 39
7.2
Manual tasks................................................................................................................ 39
7.3
Noise ........................................................................................................................... 40
7.4
Energy sources ............................................................................................................ 40
7.5
Static electricity ............................................................................................................ 41
7.6
Lightning ...................................................................................................................... 41
7.7
Fire and explosion........................................................................................................ 41
7.8
Plant capable of entangling a user ............................................................................... 41
7.9
Vibration ...................................................................................................................... 42
7.10 Exposure to radiation ................................................................................................... 42
7.11 Risk of being trapped ................................................................................................... 44
7.12 Hazardous chemicals ................................................................................................... 44
7.13 Combined plant ............................................................................................................ 44
7.14 Stability ........................................................................................................................ 45
7.15 Mechanical or structural failure during use ................................................................... 45
7.16 Software ...................................................................................................................... 45
7.17 Lighting ........................................................................................................................ 46
APPENDIX A – DEFINITIONS.....................................................................................................47
APPENDIX B – REGISTRABLE PLANT .....................................................................................48
APPENDIX C – DESIGN SOURCES OF HUMAN ERROR .........................................................50
PAGE 3 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of Practice
under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
DRAFT
FOREWORD
This Code of Practice on the safe design, manufacture, import and supply of plant is an
approved code of practice under section 274 of the Work Health and Safety Act (the WHS Act).
An approved code of practice is a practical guide to achieving the standards of health, safety
and welfare required under the WHS Act and the Work Health and Safety Regulations (the
WHS Regulations).
A code of practice applies to anyone who has a duty of care in the circumstances described in
the code. In most cases, following an approved code of practice would achieve compliance with
the health and safety duties in the WHS Act, in relation to the subject matter of the code. Like
regulations, codes of practice deal with particular issues and do not cover all hazards or risks
which may arise. The health and safety duties require duty holders to consider all risks
associated with work, not only those for which regulations and codes of practice exist.
Codes of practice are admissible in court proceedings under the WHS Act and Regulations.
Courts may regard a code of practice as evidence of what is known about a hazard, risk or
control and may rely on the code in determining what is reasonably practicable in the
circumstances to which the code relates.
Compliance with the WHS Act and Regulations may be achieved by following another method,
such as a technical or an industry standard, if it provides an equivalent or higher standard of
work health and safety than the code.
An inspector may refer to an approved code of practice when issuing an improvement or
prohibition notice.
This Code of Practice has been developed by Safe Work Australia as a model code of practice
under the Council of Australian Governments’ Inter-Governmental Agreement for Regulatory
and Operational Reform in Occupational Health and Safety for adoption by the Commonwealth,
state and territory governments.
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].
SCOPE AND APPLICATION
This Code provides practical guidance for persons conducting a business or undertaking who
design, manufacture, import or supply plant that is used, or could reasonably be expected to be
used, at a workplace on how to meet the requirements under the WHS Act and Regulations.
Design includes redesign and modification.
The Code of Practice: Managing Risks of Plant in the Workplace provides guidance on how to
manage health and safety risks of plant once it is in the workplace – from installing,
commissioning and using plant through to decommissioning and dismantling.
This Code does not apply to structures unless the items of plant form a structural component or
are assembled to form a structure, for example scaffolding. A structure is anything that is
constructed, whether fixed or moveable, temporary or permanent.
Further guidance on the design of structures is available in the Code of Practice: Safe Design of
Structures.
PAGE 4 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the
Select Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of
Practice under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is
approved by the Ministerial Council.
DRAFT
How to use this Code of Practice
In providing guidance, the word ‘should’ is used in this Code to indicate a recommended course
of action, while ‘may’ is used to indicate an optional course of action.
This Code also includes various references to sections of the WHS Act and Regulations which
set out the legal requirements. These references are not exhaustive. The words ‘must’,
‘requires’ or ‘mandatory’ indicate a legal requirement exists and must be complied with.
PAGE 5 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the
Select Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of
Practice under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is
approved by the Ministerial Council.
DRAFT
1
INTRODUCTION
Plant is a major cause of workplace death and injury in Australian workplaces. There are
significant risks associated with using plant and severe injuries can result from unsafe
design, manufacture and use of plant, including:





limbs amputated by unguarded moving parts of machines
being crushed by mobile plant
fractures from falls while accessing, using or maintaining plant
electric shock from plant that is not protected or isolated
burns or scalds from contact with hot surfaces or exposure to flames or hot fluids.
Other risks include hearing loss from noisy plant and musculoskeletal disorders caused by
manually handling or using plant which is poorly designed.
Risks to health and safety exist throughout the lifecycle of the plant from manufacturing
through to installing, commissioning, using, maintaining, repairing, decommissioning and
disposing of the plant.
Designers, manufacturers, importers and suppliers have an important role in ensuring, so far
as is reasonably practicable, the plant they design, manufacture, import or supply is safe
before it is introduced and used in the workplace.
Plant includes machinery, equipment, appliances, containers, implements and tools, and
components or anything fitted or connected to those things. Plant includes lifts, cranes,
computers, machinery, scaffolding components, conveyors, forklifts, vehicles, power tools
and amusement devices.
Plant which relies exclusively on manual power for its use and is designed to be primarily
supported by hand, for example a screw driver, is not covered by Chapter 5 of the WHS
Regulations. The general duty of care under the WHS Act applies to this type of plant.
1.1 Who has health and safety duties in relation to plant?
A person conducting a business or undertaking has the primary duty to ensure, so far as
is reasonably practicable, workers and other people are not exposed to health and safety
risks arising from the business or undertaking.
This duty requires the person to manage risks by eliminating health and safety risks so far as
is reasonably practicable, and if it is not reasonably practicable to eliminate the risks, by
minimising those risks so far as is reasonably practicable. It also includes ensuring, so far as
is reasonably practicable:


the provision and maintenance of safe plant
the safe use, handling, storage and transport of plant.
A persons who conduct a business or undertaking who manages or controls fixtures,
fittings or plant at a workplace must ensure, so far as is reasonably practicable, that the
fixtures, fittings and plant are without risks to the health and safety of a person.
Designers, manufacturers, importers, suppliers and installers of plant must ensure, so
far as is reasonably practicable, the plant they design, manufacture, import or supply is
without risks to health and safety. This duty includes carrying out testing and analysis as well
as providing specific information about the plant.
A designer, manufacturer, importer, supplier or installer of plant is the person conducting the
business or undertaking that carries out that activity. For example the designer is the person
conducting a business or undertaking that designs plant.
Where the person with management or control of plant in the workplace gets plant directly
from overseas, they also take on the duties of an importer and supplier. If they modify plant
they take on the duties of a designer or manufacturer. There are more requirements to
PAGE 6 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the
Select Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code
of Practice under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when
it is approved by the Ministerial Council.
DRAFT
manage risks under the WHS Regulations, including from fatigue, hazardous chemicals,
remote and isolated work, noise, hazardous manual tasks and plant.
There are often a number of people involved with plant during its lifecycle. A person
conducting a business or undertaking can have more than one duty and more than one
person can have the same duty at the same time. For example sometimes a manufacturer,
importer or supplier of plant will also have the duties of a designer.
Officers, such as company directors, have a duty to exercise due diligence to ensure the
business or undertaking complies with the WHS Act and Regulations. This includes taking
reasonable steps to ensure the business or undertaking has and uses appropriate resources
and processes to eliminate or minimise risks plant.
Workers have a duty to take reasonable care for their own health and safety and to not
adversely affect other people’s health and safety. Workers must co-operate with reasonable
policies or procedures relating to health and safety at the workplace and comply, so far as
they are reasonably able, with reasonable instructions.
1.2
What is involved in managing risks associated with plant?
Chapter 2 of this Code provides guidance on how to manage the risks associated with plant
in the workplace by following a systematic process which involves:




identify hazards – find out what could cause harm from using the plant
assess risks if necessary – understand the nature of the harm that could be caused by
the hazard, how serious the harm could be and the likelihood of it happening
control risks – implement the most effective control measures that are reasonably
practicable in the circumstances
review control measures to ensure they are working as planned.
Designers, manufacturers, importers, suppliers and installers of plant should use this
process as a way of making plant as safe as reasonably practicable before it is used in the
workplace.
Further guidance on the risk management process is available in the Code of Practice: How
to Manage Work Health and Safety Risks and the Code of Practice: Managing Risks of Plant
in the Workplace.
Providing and obtaining information
Designers, manufacturers, importers and suppliers have obligations to obtain and provide
information about plant so other duty holders can fulfil their responsibility to manage risks.
This information must be given to each person to whom the plant or its design is provided.
Information must be passed on from the designer through to the manufacturer, importer,
supplier and the end user. This information includes:




the purpose for which plant was designed or manufactured
the results of calculations, analysis, testing or examination necessary to use, inspect,
commission and maintain plant safely
information about plant design registration, if applicable
conditions necessary for the plant to be used safely.
It is also helpful for designers, manufacturers and other duty holders to provide a statement
about relevant technical standards used in the plant’s design and manufacture so the plant
can be manufactured, installed and used in accordance with those standards.
PAGE 7 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the
Select Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code
of Practice under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when
it is approved by the Ministerial Council.
DRAFT
Consulting your workers
S.47: The person conducting a business or undertaking must, so far as is reasonably
practicable, consult with workers who carry out work for the business or undertaking who
are, or are likely to be, directly affected by a matter relating to work health or safety.
S.48: If the workers are represented by a health and safety representative, the consultation
must involve that representative.
Consultation involves sharing information, giving workers a reasonable opportunity to
express views and taking those views into account before making decisions on health and
safety matters.
Consultation with workers and their health and safety representatives is required at each
step of the risk management process. By drawing on the experience, knowledge and ideas
of your workers you are more likely to identify all hazards and choose effective control
measures. If you are designing or modifying plant for use in your workplace, you must
consult your workers, so far as is reasonably practicable, as the plant and the way it is used
may affect their health and safety.
You should encourage your workers to report hazards and health and safety problems
immediately so the risks can be managed before an incident occurs.
Consulting, co-operating and co-ordinating activities with other duty holders
S.46: If more than one person has a duty in relation to the same matter under this Act, each
person with the duty must, so far as is reasonably practicable, consult, co-operate and coordinate activities with all other persons who have a duty in relation to the same matter.
Many different businesses are often involved in designing, manufacturing, importing,
supplying and installing plant and their decisions may affect the safety of the product. Each
has responsibility for health and safety to the extent they influence and control aspects
health and safety with the plant. These people should consult with the each other about the
risks and work together in a co-operative and co-ordinated way to effectively eliminate or
minimise them so far as is reasonably practicable.
Further guidance on consultation requirements is available in the Code of Practice: Work
Health and Safety Consultation, Co-operation and Co-ordination.
PAGE 8 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the
Select Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code
of Practice under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when
it is approved by the Ministerial Council.
DRAFT
2
THE RISK MANAGEMENT PROCESS
2.1 Identifying the hazards
Identifying hazards involves finding all the things and situations that could potentially cause harm
to people. Hazards associated with plant often arise from:

The plant: hazards associated with a forklift could include the plant’s mobility, electrical,
hydraulic and mechanical power sources, moving parts, load-carrying capacity and user
protection.

How and where the plant is used: forklift hazards may arise from the load being lifted, the
size of the area where it is used and the slope or evenness of the ground.
Table 1 Things to consider when looking for hazards
Hazards
Suitability
Access
Location
Systems
of work
Unusual
situations
 Can the plant cause injury from entanglement, crushing, trapping, cutting,
stabbing, puncturing, shearing, abrasion, tearing or stretching?
 Can the plant create hazardous conditions from pressurised content,
electricity, noise, radiation, friction, vibration, fire, explosion, temperature,
moisture, vapour, gases, dust, ice, hot or cold parts?
 Can the plant cause injury from lack of guarding of moving parts?
 Can the plant cause injury as a result of unexpected start-up?
 Can the plant cause injury or ill health from poor ergonomic design?
 Is the plant suitable for its intended purpose? What is likely to happen if it is
used for a purpose other than the intended purpose?
 Are the materials used to make the plant suitable?
 Are accessories to the plant suitable?
 Is the plant stable? Could it roll over?
 If the plant is intended to lift and move people, equipment or materials, is it
capable of doing this?
 Is access to the plant necessary when installing, using and maintaining the
plant or in an emergency?
 Can workers access the plant safely without being injured by the plant or the
risk of slips, trips and falls, for example a walkway, gantry, elevated work
platform or fixed ladder?
 Does the plant affect the safety of the area where it will be located, for
example what is its impact on the design and layout of the workplace?
 Does the location affect the safety of the plant, for example environmental
conditions, terrain and work area?
 Will there be people or other plant nearby? What effect would this have?
 Do the systems of work for the plant create hazards?
 Does the plant’s safety depend on the competency of its users?
 Have users and others working near the plant been given training,
information, instruction and supervision needed to ensure they are safe?
 What unusual situations, misuse or changes to how the plant is used could
occur?
 What would happen if the plant failed? Would it result in loss of contents, loss
of load, unintended ejection of work pieces, explosion, fragmentation or
collapse of parts?
 Is it possible for the plant to move or be operated accidently?
PAGE 9 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of Practice
under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
DRAFT
2.2 Assessing the risks
A risk assessment involves considering what could happen if someone is exposed to a hazard
and the likelihood of it happening
Many hazards and their associated risks are well known and have well established and accepted
control measures. In these situations, the second step to formally assess the risk is unnecessary.
If, after identifying a hazard, you already know the risk and how to control it effectively, you may
simply implement the controls.
A risk assessment can be done with varying degrees of detail, depending on the complexity of the
plant and the type of information available. Specific risk analysis tools and techniques may be
needed to assess the different types of plant used at the workplace.
To assess the risks consider:




how often and for how long people would be exposed to each of the potentially hazardous
situations you have identified –the longer and more frequent the exposure to a potential
hazard, the more likely it is to cause harm
how many people could be exposed to the potential hazard at the same time – this affects
the consequence
environmental factors influencing the design and use of the plant, e.g. available space,
temperature, contaminants and moisture
technical and human factors, including a person’s ability to change behaviour to
compensate for design changes.
2.3 Controlling the risks
Some control measures are more effective than others. Control measures can be ranked from the
highest level of protection and reliability to the lowest. This ranking is known as the hierarchy of
control.
Eliminating the risk
This means removing the hazard or hazardous work practice from the workplace. This is the
most effective control measure and must always be considered before anything else. Many
hazards can be addressed at the design, manufacture, supply and installation stages. For
example designing machinery to produce low noise levels is more effective than providing
workers with personal hearing protection. This also avoids costly changes to plant after you
buy it.
If eliminating the risk is not reasonably practicable, you must consider using substitution, isolation
or engineering controls, or a combination of these control measures, to minimise the risk.
Minimising the risk
Substitution
Minimise the risk by substituting or replacing a hazard or hazardous work practice with a safer
one. For example a person who designs plant operator controls for a machine substitutes controls
powered by 240 volt alternating current power supply with a 24 volt direct current power supply
which lowers the risk of electrical shock. However, this is likely to introduce a greater risk of fire.
PAGE 10 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of Practice
under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
DRAFT
Isolation
Minimise the risk by isolating or separating the hazard or hazardous work practice from people.
Examples include:
 separating the hazardous part of the plant from people by using physical barriers like
guarding
 fitting an air conditioned bulldozer cabin with a dust filter to isolate the operator from a
dusty environment outside the cabin
Engineering Controls
Engineering controls are physical control measures to minimise risk. Examples include:



an importer retrofitting a roll over protective structure on a tractor
a designer including load sensors to prevent overloading machinery
installing moment limiters on mobile plant to prevent the plant from tipping over.
If a risk then remains, the duty holder must minimise the remaining risk, so far as is reasonably
practicable, by using:
Administrative controls
Administrative controls should only be considered when other higher order control measures are
not reasonably practicable, or to increase protection from the hazard. These are work methods or
procedures designed to minimise exposure to a hazard. For example using a sign-on process for
entering a plant room, providing training and supervision, using warning signs or arranging work
to minimise the time spent near noisy machinery.
Any remaining risk must be minimised, as far as is reasonably practicable, by providing and
ensuring the use of:
Personal protective equipment
Personal protective equipment (PPE) is the lowest order control measure in the hierarchy of
controls. PPE should also only be considered when other higher order control measures are not
reasonably practicable or to increase protection from the hazard. Examples of PPE include
respiratory protection, hard hats, gloves, aprons or protective eyewear.
Administrative control measures and PPE rely on human behaviour and supervision. For
example, a lock-out system of work should be used rather than a sign-in sign-out procedure so
the plant is physically isolated from its power source while the plants being maintained or cleaned.
Combining control measures
In most cases, a combination of the controls measures will provide the best solution to minimise
the risk to the lowest level reasonably practicable. For example, protecting workers from flying
debris when using a concrete cutting saw may involve guarding the blade (engineering), isolating
the work area by using barriers (isolation), signs (administrative) and providing PPE like face
shields and hearing protection. You should check your chosen control measures do not introduce
new hazards.
2.4
Maintaining and reviewing control measures
The control measures that are implemented must be reviewed and if necessary revised to make
sure they work as planned and that no new hazards have been introduced by the control
measures.
Designers, manufacturers, importers and suppliers of plant may use quality assurance processes
to check that the plant effectively minimises health and safety risks. Feedback from users of the
plant is useful to determine whether improvements can be made to make it safer.
PAGE 11 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of Practice
under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
DRAFT
2.5
Information sources
There are a range of sources that may assist in managing risks associated with the plant and the
systems of work used in connection with the plant.
Researching information
 WHS Act and Regulations, codes of practice and technical standards about designing,
manufacturing, testing and using plant.
 Injury, faults, incident reports and plant failure data kept by manufacturers and users of the
same or similar types of plant.
 Statistics, hazard alerts or other reports from regulators, unions, employer associations,
specialists, professional bodies representing designers, manufacturers, or engineers.
 Information and documentation supplied by designers or manufacturers on safety and
health issues, for example test reports on previous designs or similar plant.
 Reports or articles from work health and safety journals, technical references or data
bases.
Inspecting and testing
 Inspect plant that has failed and been returned by users.
 Develop prototypes and inspect and test their design and manufacture.
 Conduct ‘walk-through’ surveys of the workplace where the plant will be used before
beginning the design process and while the plant is being installed or erected – the latter
to look for hazards which may be introduced during installation.
Consulting
Where possible, talk to other plant designers, manufacturers, installers and users. People working
with the same or similar plant are often well aware of what can go wrong and why and how the
work environment can change. It also enables issues to be discussed, for example whether it is
possible to use alternative design materials for a safer design.
PAGE 12 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of Practice
under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
DRAFT
3
3.1
SAFE DESIGN
What is safe design?
Safe design means integrating control measures early in the design process to eliminate or, if this
is not reasonable practicable, minimise risks to health and safety throughout the life of the plant
being designed.
The safe design of plant will always be part of a wider set of design objectives, including
practicability, aesthetics, cost and functionality. These sometimes competing objectives need to
be balanced to not compromise the health and safety of those potentially affected by the plant
over its life.
Safe design begins at the concept development phase when choices are made about design,
materials used and methods of manufacture. In these early phases there is more chance to
design-out hazards or incorporate risk control measures that are compatible with the original
design concept and functional requirements of the product.
3.2
The role of designers
A designer is a person conducting a business or undertaking whose profession, trade or business
involves them in:
 preparing sketches, plans, drawings or models, including prototypes, for plant that is to
be used or could reasonably be expected to be used at a workplace, including variations
to a plan or changes to the plant
 making decisions for incorporation into a design that may affect the health or safety of
people who manufacture, use or carry out other activities with the plant.
Designers include design professionals such as engineers, industrial designers and designers of
plant systems like software and electrical systems. Designers should consult with people who use
the plant.
A person will also have the duties of a designer if they change the design during manufacture, or
change existing plant, so that new measures for controlling risk are needed. For example, if the
maximum working radius of a mobile crane is increased by fitting a longer boom, a new load chart
should be prepared to control the increased risk of the crane overturning. The person designing
the boom extension should contact the original designer to check the new boom extension does
not compromise the existing design criteria or safety factors.
Consider the lifecycle
Safe design applies to every stage in the lifecycle, from conception to disposal.
S.22: A person (the designer) who conducts a business or undertaking that designs plant that is
to be used, or could reasonably be expected to be used, as, or at, a workplace must ensure, so
far as is reasonably practicable, that the plant is designed to be without risks to the health and
safety of persons who:
 use the plant at a workplace for a purpose for which it was designed
 store the plant
 carry out any reasonably foreseeable activity at a workplace in relation to the manufacture,
assembly or use of the plant for a purpose for which it was designed, or the proper
storage, decommissioning, dismantling or disposal of the plant, or
 are at or in the vicinity of a workplace and who are exposed to the plant at the workplace
or whose health or safety may be affected by one of the above uses or activities.
This means thinking about potential hazards and design solutions as the plant is manufactured,
transported, installed, commissioned, used, maintained, repaired, de-commissioned, dismantled,
disposed of or recycled.
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Knowledge and capability
In addition to core design capabilities, the following skills and knowledge should be demonstrated
by a person who carries out work for the designer or is part of the design team:
 knowledge of the WHS Act and Regulations, codes of practice and other regulatory
requirements
 understanding the intended use of the plant throughout its lifecycle
 knowledge of hazard identification, risk assessment and control methods
 knowledge of technical design standards
 the ability to find and apply relevant data on human dimensions, capacities and
behaviours and using relevant expertise where required
 knowledge of the environment where the plant is to be used and possible impact on the
plant’s operation.
Many design projects are too complex to be fully understood by one person. Often a range of
people are involved in or consulted before a design is finalised. This can include the designers,
their workers and people with specific skills and expertise to fill any knowledge gaps. It may also
include ergonomists, engineers, occupational hygienists and plant users.
3.3
Integrating safe design and risk management
The design brief should include a requirement to apply a risk management process in the design.
The safe design of plant is usually a repetitive process. After the initial control measures are
incorporated into the design, the design is reviewed to determine whether there are remaining
risks and whether redesign can eliminate or minimise these risks (see Figure 1).
3.4
Pre-design and concept development phase
This stage of the process involves:




establishing the design context for the purpose of the plant, its functions and limitations
identifying the roles and responsibilities of various parties for the project and establishing
collaborative relationships with clients, manufacturers and users of the plant including
those who maintain and repair the plant
researching and consulting to assist in identifying hazards, assessing and controlling risks
conducting hazard identification.
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Figure 1 A systematic approach to integrating design and risk management
Conduct research and
consultation
Establish the design
context
Pre-design phase
Get information including:
• Purpose of the plant, its
functions and limitations
• Data from similar types of plant,
test reports
• Workplace health and safety
legislation, codes of practice,
published technical standards.
Identify hazards associated with the plant
Develop prototype or initial design
Determine how hazards will be eliminated or
minimised through:
(a) implementing solutions from published
technical Standards
(b) conduct a risk assessment process.
(a) Implement solutions from
published technical standards.
Identify hazards that can be
adequately addressed by applying
solutions/guidance from existing
standards if appropriate
Conceptual and schematic
design phase
Hazard identification (technical
and human factors):
• Hazardous conditions
• High consequence hazards
• Systems of work
• Plant access and location
• Abnormal situations.
Design development phase
(b) Conduct a risk assessment process
for hazards which have no suitable
solutions in published technical
standards or there is poor safety
experience with this type of hazard.
Design risk controls
Final design
Yes
Test, trial or evaluate the design
Determine information needs
for safety during the lifecycle
Redesign to reduce
risks within the
designers control.
Have risks been eliminated or
minimised so far as is
reasonably practicable?
NO
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Plant functions and limitations
Identify the functions of the plant and its limitations, for example:








the specifications, e.g. what is produced and materials to be used
expected place of use, e.g. environment, supporting surface
planned service life
intended functions and operating modes
expected malfunctions and faults
the people interacting with the plant
the products related to the plant
how the plant can be used safely, as well as reasonably foreseeable misuse.
Table 2 Examples of plant functions and limits
Plant limitations
Examples
Use limits
Intended use, production rates, cycle times, working load
limits
Space limits
Range of movement, access for maintenance
Time limits
Wear and tear of materials, use of fluids
Environmental limits
Temperature, humidity, noise, location
Interface limits
Other plant, energy sources, user interface
Technology limits
Intuitive decision making, visual stimulus overload
Identifying the hazards
Hazard identification should take place as early as possible in the concept development and
design stages. It involves identifying activities the plant will be subjected to throughout its life and
the reasonably foreseeable hazards associated with each activity.
Table 3 Examples of plant hazards
Potential hazards
 mechanical, e.g. crushing, cutting, trapping,
shearing, high pressure fluids
 electrical
 thermal
 noise
 vibration
 radiation
 hazardous chemicals
 slipping, tripping and falling
 manual handling
 confined spaces
 environmental conditions
 hazards resulting from a combination of the
above
Phases of the plant lifecycle

















manufacture
storage
packing and transportation
unloading and unpacking
assembly
installing
commissioning
using
cleaning
adjustment
inspection
planned and unplanned maintenance
repair
decommissioning
dismantling
disposal
recycling.
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3.5
Design phase
The design phase may involve:
 developing a prototype or initial design
 testing, trialling or evaluating the prototype or design
 redesigning to control any remaining risks so far as is reasonably practicable
 finalising the design and preparing risk control plans for the lifecycle of the product.
Some hazards may be adequately addressed by applying existing solutions in published technical
standards. Alternatively a risk management process should be used to develop and select the
most effective control measure. Proven engineering best practice may also be applied if there are
no relevant standards.
Technical standards
Where the design meets regulatory requirements, including under the WHS Act and Regulations,
a plant designer may use technical standards or a combination of standards and engineering
principles relevant to the design requirements to design plant. Engineering principles include, for
example, mathematical or scientific procedures outlined in an engineering reference or standard.
Testing and examining plant
S.22(3): The designer must carry out, or arrange the carrying out of, any calculations, analysis,
testing or examination that may be necessary to ensure, so far as is reasonably practicable, that
the plant is designed to be without risks to the health and safety of persons.
Analysis, testing or examination can be carried out when developing a prototype and during the
manufacturing stage. Consider:
 simulating the normal range of operational capabilities
 testing design features to ensure ‘fail safe’ operation
 measuring imposed stresses on critical components to ensure maximum design stresses
are not exceeded
 testing critical safety features like over-speed and over-pressure devices under both
normal and adverse operational conditions
 developing overload testing procedures to ensure plant safety when plant is misused.
Records of tests and examinations must be maintained by the designer. The designer must
provide information necessary for the manufacture of plant and for the future safe use and
maintenance of that plant by the end user.
3.6
Providing information
S.22(4): The designer must give adequate information to each person who is provided with the
design for the purpose of giving effect to it concerning:
 each purpose for which the plant was designed
 the results of any calculations, analysis, testing or examination
 any conditions necessary to ensure that the plant is without risks to health and safety to a
person using the plant for a purpose for which it was designed or when carrying out a
reasonably foreseeable activity using the plant.
S.22(5): The designer, on request, must, so far as is reasonably practicable, give current relevant
information on:
 each purpose for which the plant was designed
 the results of any calculations, analysis, testing or examination
 any conditions necessary to ensure that the plant is without risks to health and safety to a
person using the plant for a purpose for which it was designed or when carrying out a
reasonably foreseeable activity using the plant.
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to a person using the plant for a purpose for which it was designed or when carrying out a
reasonably foreseeable activity using the plant.
For example, if plant is to be located a specific distance from other plant, written instructions must
be provided for the manufacturer, supplier, installer, owner and end user.
If the manufacturer tells the designer there are safety issues with the design, the designer must
revise the information to take account these concerns, or tell the manufacturer in writing the
reasons why revisions are not necessary.
Information provided to the manufacturer should include details of risks which may remain.
The information provided should be easily understood by the person receiving it. Information may
be a combination of writing or visual information like signs, symbols or diagrams. Where visual
information is provided it should meet the relevant standard.
The designer should record details of testing and examination carried out and must ensure they
are made available to the design verifier if plant design registration is required.
Type of information to provide
Under the WHS Regulations designers must provide specific information to the manufacturer to
enable the plant to be manufactured in accordance with the design specifications. If relevant,
information must be provided on:





the installing, commissioning, using, handling, storing, decommissioning and dismantling
the plant
hazards and risks associated with using the plant
testing or inspections to be carried out
systems of work and competency of users necessary for the plant to be used safely
emergency procedures if there is a malfunction.
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Table 4 Other information which can be provided to the manufacturer
Manufacturing plant
Transport, handling
and storage of plant
Installing and
commissioning
 specific conditions relating to the method of manufacture
 instructions for fitting or refitting plant parts and their location on other
components of the plant or their housings where errors could be made
when installing the plant
 instruction where hot or cold parts or material may create a hazard
 specifications of material
 wiring diagrams
 specifications for proprietary items, e.g. electric motors
 component specifications including drawings and tolerances
 assembly drawings
 assembly procedures including specific tools or equipment to be used
 manufacturing processes, e.g. requirements for welding
 details of hazards presented by materials during manufacturing
 safety outcomes for programming.
















Using, inspecting
and testing plant









dimensions and weight
indications for handling, e.g. application points for lifting equipment
conditions for storage
exposure to dangerous parts before installing guards
lifting procedures
plant interacting with people
plant interacting with other plant, e.g. connected services and
installations
stability during installation
the proposed method for installing and commissioning, including tests
that should be carried out
using special tools, jigs, fixtures and appliances necessary to
minimise the risk of injury during installation
concealed installations, e.g. gas or fuel lines
environmental factors affecting installation and commissioning.
intended uses for the plant, including prohibited uses
operating procedures
safe entry and exit
requirements for maintenance and repair, e.g. nature and frequency
of maintenance, disposal of hazardous by-product and consumables
emergency situations, e.g. types of fire fighting equipment
exposure to hazardous substances
how environmental conditions effect using the plant
the results or documentation of tests and examinations carried out on
the plant and design
de-commissioning, dismantling and disposing of plant
known residual risks i.e. those that cannot be eliminated or sufficiently
minimised by design
details of control measures like personal protective equipment that
should be used to further minimise the risks associated with plant
guidance on administrative control measures
requirements for special tools needed to use or maintain plant.
For registrable plant, the information provided by the designer to the manufacturer should include
the plant design registration number to provide evidence the plant design has been registered
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under the WHS Regulations. The plant design registration number is not necessary where the
manufacturing process relates to the development of a prototype to test the design.
Documenting details of critical components1 means the specifications and applicable standards to
which the plant complies are readily available. This includes test reports and third party
certificates. In maintenance and repair, critical components should only be replaced by
equivalents.
3.7
Registering plant designs
S.42: A person who conducts a business or undertaking must not direct or allow a worker to use
plant at a workplace if the regulations require the plant or its design to be authorised and they are
not authorised in accordance with the regulations.
R.231-233: A manufacturer, importer or supplier must not supply plant specified in Part 1 of
Schedule 5 unless the design of that plant is registered under Part 5.3.
Part 1 of Schedule 5 to the WHS Regulations lists the plant for which the design must be
registered with the regulator before the plant can be supplied. Schedule 5 is reproduced in
Appendix B.
Plant design registration involves registering a design from which a number of individual items can
be manufactured to that same design.
How to register a plant design
To register a plant design, the design must be verified by a design verifier who must provide a
statement that the design has been produced in accordance with published technical standards or
engineering principles nominated by the designer.
Drawings or other documents provided with the application must be capable of being kept in
electronic form.
Design verification
The design verification statement is prepared by a design verifier stating the design has been
produced in accordance with the technical standards or engineering principles specified in the
statement. It must be in writing and signed by the design verifier. The statement must include the
design verifier’s name and business address. If applicable it must also include their qualifications
and the name and business address of the organisation for which the design verifier works.
Design verifier
R.253: A design verifier of the design of an item of plant specified in Part 1 of Schedule 5 must
document the design verification process carried out by that person and the results of that
process.
A design can only be verified by a person who is eligible to be a design verifier under the WHS
Regulations. People who are competent to verify the design of plant include those who:
 have educational or vocational qualifications in an engineering discipline relevant to the
design to be verified, or

have knowledge of the technical standards relevant to the design to be verified, or

have the skills necessary to independently verify that the design was produced in
accordance with the published technical standards and engineering principles used in the
design, or
‘Critical components are components or sub-assemblies which in the event of a failure will leave the plant in a condition that exposes
operators or others to a high level of risk.
1
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
is certified by a body that is accredited or approved by the Joint Accreditation System—
Australia and New Zealand or an equivalent overseas body to carry out conformity
assessments of the design against the relevant technical standards.
For example, a person accredited by a third party certifier may have the qualifications and
experience to be a design verifier for a particular type of plant.
Similarly, a design verifier could also be someone who is:


registered on the National Professional Engineers Register administered by the Institution
of Engineers Australia and is determined by that institution as competent to design the
structure, verify the design or inspect the plant or structure, or
is a member of the Institution of Engineers Australia with the status of Chartered
Professional Engineer.
The design verifier must not have been involved in the plant design process. A business or
undertaking may however engage a design verifier to verify more than one design at the same
time as long as the verifier was not involved in the plant design process. For example, a company
designs tractors and forklifts – once the tractor design is finalised the company engages a design
verifier to verify the tractor design. Part way through verifying the tractor design, a new forklift
design is finalised and the company asks the design verifier to also verify the new forklift design.
This is allowed because the design verifier was not involved in either design process - the verifier
is simply in the business of verifying plant designs already developed.
Where the design verifier was engaged by the same organisation that produced the design the
organisation must have a quality system in place that has been certified by a body accredited or
approved by the Joint Accreditation System – Australia and New Zealand.
Once the design is registered
When a plant design is registered the regulator will issue a plant design registration document
containing the registration number for the plant design and the date on which registration starts.
This document must be kept and made available for inspection under the WHS Act.
If it is lost, stolen or destroyed, the registration holder must give written notice to the regulator as
soon as practicable. The registration holder may then apply to the regulator for a replacement
document outlining the reasons for needing a replacement.
The regulator may impose conditions it considers appropriate on registering the plant design,
including conditions for record keeping or providing information to the regulator.
The design registration number must be given to the manufacturer, importer or supplier of the
plant. These duty holders must ensure that the design registration number is provided to the
person with management or control of the plant at a workplace. The person with management or
control of the plant must ensure the design registration number is readily accessible in the vicinity
of the plant at all times, for example printed in instruction manuals, stamped on identification
plates or labelled on the plant.
Changes to design registration
If the design of registered plant is changed and needs new risk control measures, the altered
design must be registered.
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4
4.1
DESIGN CONSIDERATIONS
Physical and cognitive characteristics of users
Plant should be designed to take into account the range of physical characteristics and cognitive
ability of likely users. You should take into account information about the range of human
dimensions and capabilities, for example height, reach and weight, to provide an optimum match
between plant and users. Consider using relevant anthropometry (human body measurement)
data.
Designers should consider the varying anthropometrics of cultural groups that are likely to use the
plant.
If information is available for a piece of plant and who will be using it, the designer might also
tailor the plant design to meet the needs of specific people.
A designer should apply ergonomic design principles so that when the plant is being used
properly, the user’s discomfort, fatigue and psychological stress are minimised, so far as is
reasonably practicable.
The designer should also take into account the cognitive ability of workers, for example if people
with disabilities will use the plant.
A designer should consider whether the plant could be misused or how uncontrolled physical
movements could impact the plant’s operation.
4.2
Designing plant which is safe to use
A designer should address the following:
 assess the required skill levels to use or maintain the plant
 the complexity of functions a user can be expected to perform
 the need for and the location of items to ensure proper use and prevent user errors, e.g.
aids, guides, indicators, guards, mounted instruction, signs, symbols and name plates
 ensuring plant design is fail safe at least to the category, performance level and safety
integrity level as determined by the plant risk assessment
 layout of work stations, e.g. the view of work being performed and the position of the
worker in relation to plant controls
 instrumentation needed at each work station or cabin and the layout of the instrumentation
 the devices, tools or controls the user and support people need to carry out their jobs
safely
 the options available to allow quick recovery or to maintain the safety and integrity of the
system if the user makes an error or the plant fails
 the user being able to be accessed if help is needed
 environmental conditions that may impair user performance, e.g. long periods where the
user carries out physical or repetitive activity or inactivity in a hot or cold environment
 separating people, including the user, from entrapment when using plant, e.g. being
caught between the plant and other objects in use.
Designers should also take into account predictable human behaviour and never presume those
who use or maintain plant have a full or continuous appreciation of essential safety features.
Where user error is likely, higher order control measures should be incorporated into the design.
For example:
 A driver used a tractor to haul a hydraulically operated tilt-up trailer loaded with grain. The
gear lever of the tractor was positioned close to the control lever which operated the tip-up
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mechanism of the trailer. While underway, the driver’s arm moved the control lever slightly
so the trailer tray began to lift. The trailer rose and eventually overturned. If the possibility
of this type of incident occurring had been anticipated at the design phase these levers
would have been located far enough away from each other so that the operator did not
accidentally activate the wrong mechanism.
On power operated plant with a seat belt there can be a risk that operators who get on and off
regularly might not bother to wear seatbelts. If the plant is designed so that the seat belt, seat
pressure sensing and engine are interlocked on a sequence then the operator has no choice but
to use the seat belt.
4.3
Reasonably foreseeable misuse
Sometimes plant may be used for applications other than those for which it was designed and
originally intended, for example where an excavator is used to lift and transport concrete pipes or
when a front end loader is used as a crane. When designing plant it is helpful for the risk of
reasonably foreseeable misuse to be assessed and appropriate control measures incorporated in
the design. This can be achieved by reviewing incident reports for the specific type of plant.
4.4
Minimising human error
Human or worker error is not always the result of carelessness or negligence. Sometimes the
need for extra speed, increased production and making tasks easier mean guards are bypassed
or removed. Workers may become bored and distracted with repetitious work or use unsafe
practices to overcome poor plant design. For example, locating two important controls close
together which are of similar shape or size may lead to the user mistakenly operating the wrong
control.
Workers have a responsibility to take reasonable care for their own health and safety and must
not adversely affect the health and safety of others. Workers must comply with any reasonable
instruction and co-operate with any reasonable policy or procedure. Workers should never use
unsafe practices or deliberately bypass guarding on plant.
In designing plant, designers should be aware of the factors contributing to human error,
including:
 forgetfulness
 workers’ diligence to ‘get the job done’ or to ‘find a better way’
 capacity to understand information
 psychological or cultural environment
 habit
 accepted customer practice
 fatigue
 level of training.
Further information on human error is included in Appendix C.
4.5
Environmental conditions
A designer should consider the hazards created by physical, environmental and operational
conditions to which plant will be exposed during its life. For example, where moving parts are
exposed to dust which could cause the plant to malfunction, a designer should incorporate
effective dust covers into the design. A designer can contribute to minimising these types of
hazards, for example by providing instructions to erectors and installers of plant about positioning
of the plant.
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If a user is physically uncomfortable using the plant this may lead to inattention, carelessness or
fatigue which may result in an incident. For example a poorly designed workstation or cabin which
does not provide adequate sun and heat protection for the user could lead to heat exhaustion or
dehydration.
4.6
Erecting and installing plant
A designer must, so far as is reasonably practicable, ensure hazards from erecting and installing
plant are eliminated or minimised so far as is reasonably practicable. For example, poor access to
fasteners such as clips and bolt holes may mean an erector or installer needs to stretch or bend
at an unnatural angle. This could result in musculoskeletal injury to the erector or installer.
Designers can refer to the Code of Practice: Hazardous Manual Tasks for further guidance.
Designers should also consider the stability of plant when it is erected or installed and whether
special supports are needed if a partly complete structure is unstable.
4.7
Maintenance
R.190(2): If the need for plant to be operated during maintenance or cleaning cannot be
eliminated, the designer of the plant must ensure that the design provides for operator's controls
that:
 permit operation of the plant while a person is undertaking the maintenance or cleaning of the
plant
 while the plant is being maintained or cleaned, cannot be operated by any person other than
the person who is carrying out the maintenance or cleaning of the plant, and
 will allow operation of the plant in such a way that any risk associated with the activities in
relation to any person who is carrying out the maintenance or cleaning is eliminated, so far as
is reasonably practicable. If it is not reasonably practicable to eliminate the risk, it is
minimised, so far as reasonably practicable.
A designer’s responsibility extends to eliminating or minimising the risks, so far as is reasonably
practicable, associated with maintaining the plant. Any reasonably foreseeable hazards with
future plant maintenance and repair should be identified and designed out so far as is reasonably
practicable.
Where a worker is required to maintain plant, a designer should:
 Design places for adjusting, lubricating and maintaining the plant are outside danger
zones. This may be achieved, for example, by placing clearly labelled lubrication points
away from moving parts.
 Incorporate interlocks into the design so the plant cannot be activated while maintenance
work is carried out in the danger zones.
 Design safe entry points, for example walkways and guardrails for maintaining and
inspecting cooling towers or storage silos.
 Pass on relevant information to the manufacturer for inclusion in the manufacturer’s
instructions for maintenance
 Design parts of the plant where workers move or stand to eliminate or minimise the risk of
slips, trips and falls.
 Design the plant to eliminate or minimise the risk of accidently touching hot, sharp or
moving parts.
4.8
Guarding
A guard is a physical or other barrier that can perform several functions, including:
 preventing contact with moving parts or controlling access to dangerous areas of plant
 screening harmful emissions like radiation
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

minimising noise by applying sound-absorbing materials
preventing ejected parts or off-cuts from striking people.
Guards may include:
 permanently fixed or interlocked physical barriers
 self-adjusting guards
 presence-sensing systems.
Figure 2 Examples of guards on a press brake
R.189: The designer must ensure, so far as is reasonably practicable, that the guarding designed
will prevent access to the danger point or danger area of the plant.
If guarding is used, the designer must ensure that:
 if access to the area of plant requiring guarding is not necessary during operation,
maintenance or cleaning, the guarding is a permanently fixed barrier, or
 if access to guarded areas is necessary during operation, maintenance or cleaning—the
guarding is an interlocked physical barrier that allows access to the area being guarded at
times when that area does not present a risk and prevents access to that area at any other
time, or
 if it is not reasonably practicable to use a permanently fixed barrier or an interlocked physical
barrier, the guarding is a physical barrier that can only be altered or removed using a tool, or
 if it is not reasonably practicable to use a permanently fixed barrier, an interlocked physical
barrier or a physical barrier fixed in position, the guarding includes a presence-sensing
safeguarding system, and
 if the guarding is of a kind that can be removed to allow maintenance and cleaning of the plant
it can be removed at any time that the plant is not in normal operation, and
 if the guarding is removed, that, so far as is reasonably practicable, the plant cannot be
restarted unless the guarding is replaced.
Guarding must:
 be of solid construction and securely mounted so as to resist impact or shock
 make bypassing or disabling the guard, whether deliberate or accidental, as difficult as is
reasonably practicable
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DRAFT
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not create a risk in itself
be properly maintained
control any risk from broken or ejected parts and workpieces, and
be able to be removed when the plant is not in normal operation to allow for maintenance and
cleaning but when the guarding is removed the plant must not be able to be restarted unless
the guard is replaced.
Guard design
The mechanisms and controls forming part of a machine guard should be of fail safe design. The
guarding should not weaken the structure of the plant, cause discomfort to the people using the
plant or introduce new hazards, for example pinch points, rough edges or sharp corners. The
designer should review the regulatory requirements for guarding at each phase of the design
development.
Where some form of physical barrier is provided to prevent access to dangerous parts, the size
and position of the barrier should take into account the range in height and build of people using
the plant.
The guard should be designed taking into account, where appropriate:
 the placement of the guard, e.g. to allow the user to observe the operation
 removal or ejection of work pieces
 lubrication
 inspection
 adjustment
 repair of machine parts.
Guarding should be designed so a person can use the plant safely.
When selecting a guard you should consider the environment in which it will be used. Some
examples of guards which should not be selected include where the guard can be electrically
charged on high frequency welders, the guard is heated in hot processes or wire mesh guards on
machines which produce splashes.
Physical barrier guarding should be constructed of material strong enough to resist normal wear
and shock from reasonably expected failure of the parts or processes being guarded, and to
withstand long use with a minimum of maintenance. If a guard is likely to be exposed to corrosion,
corrosion-resistant materials or surface coatings should be used.
When an enclosure is used to prevent access to mechanical, chemical and electrical hazards,
there may be an opportunity to control other risks. For example, risks associated with exposure to
dust may be controlled by substituting a sheet metal guard for a mesh guard, provided the
accumulation of dust within the guard does not create another hazard.
Where there is a risk of jamming or blocking moving parts, the designer should document the
work procedures, devices and tools to clear the plant in a way that minimises the risk. This
information must be passed on to the manufacturer and supplier.
The designer should carry out safety integrity testing for presence-sensing safeguarding systems
to test the likelihood of a safety function performing as intended. A risk assessment determines
the safety integrity requirements - the higher the level of safety integrity, the lower the likelihood of
failure which can cause harm. If applicable, the designer should specify the safe systems of work
for using and maintaining the guarding and the maintenance of the components being guarded in
the information provided to the manufacturer.
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This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
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the Ministerial Council.
DRAFT
4.9
Operator control devices
R.190: A designer of plant must ensure that the design provides for any operator's controls for the
plant to be:
 identified on the plant so as to indicate their nature and function and direction of operation
 located so as to be readily and conveniently operated by each person using the plant
 located or guarded to prevent unintentional activation, and
 able to be locked into the "off" position to enable the disconnection of all motive power.
Badly designed operator controls can lead to plant being unintentionally used unsafely. For
example, a control for setting the speed for a cutting device like a saw or guillotine should not be a
simple slider or rotary control. It should be graduated in fixed lockable steps so the speed does
not suddenly change if someone bumps the control.
Control devices should be designed:
 So the plant is fail safe to the category, performance level and safety integrity level
determined by risk assessment.
 Within easy access of the user.
 With extra emergency stops which can be used from other parts of the plant. A risk
assessment would assist in their location.
 So they are clearly visible, identifiable and appropriately marked, for example signs or
markings to indicate on and off.
 To clearly indicate the function of the control and that the control operates as indicated, for
example moving a control to the right should move the plant to the right.
 Using symbols and written instructions where appropriate.
 So they can be easily read and understood, including dials and gauges.
 So the control moves consistent with established convention, for example anticlockwise to
open, clockwise to close.
 So the desired effect can only occur by intentionally operating a control, for example
providing a starting control.
 To withstand normal use, undue forces and environmental conditions.
 To be outside danger zones.
 To be located or guarded to prevent unintentional activation.
 So they can be locked in the ‘off’ position to isolate the power.
 To be readily accessible for maintenance.
It should only be possible to start plant by deliberately moving or operating a control provided for
that purpose, including after a stoppage. Each item of plant should be designed to include a
control which completely stops the plant or its relevant components safely.
4.10 Emergency stops
R.191: If plant is designed to be operated or attended by more than 1 person and more than 1
emergency stop control is fitted, the designer of the plant must ensure that the design provides for
the multiple emergency stop controls to be of the "stop and lock-off" type so that the plant cannot
be restarted after an emergency stop control has been used unless that emergency stop control is
reset.
If the design of the plant includes an emergency stop control for the plant, the designer of the
plant must ensure that the design provides:
 for the stop control to be prominent, clearly and durably marked and immediately accessible to
each operator of the plant
 for any handle, bar or push button associated with the stop control to be coloured red, and
 that the stop control cannot be adversely affected by electrical or electronic circuit malfunction.
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DRAFT
An emergency stop is a device installed on or adjacent to an item of plant to bring the plant to a
stop when other control measures fail or cannot be used in an emergency situation. It could be a
button, grab wire or foot pedal.
Emergency stop devices should not be the only method of controlling risks. They should be
designed as a backup to other control measures. The number of emergency stops, aspects of the
plant operation and the location and number of operators should be considered during the risk
assessment.
The emergency stop system should be compatible with the operational characteristics of plant.
Emergency stops do not remove the need for adequate guarding.
The type of emergency stop design should be chosen in accordance with the requirements of the
category/performance level/safety integrity level determined by risk assessment.
The emergency stop control must be prominent, clearly and durably marked and immediately
accessible to each plant user, for example accompanied by a sign ‘EMERGENCY STOP –
PRESS’
Once engaged, the emergency stop controls should remain in place until a risk assessment is
made. It should be possible to disengage the emergency stop controls only by a deliberate action.
Disengaging the emergency stop control should not restart the plant. It should only permit the
normal starting sequence to be activated.
In the case of plant or parts of plant designed to work together, stop controls, including the
emergency stop, should be capable of stopping the plant itself, as well as the equipment
interrelated to its operation where continued operation of this interrelated equipment may be
dangerous.
Examples of ways to reduce the impact of the stop control being adversely impacted by electrical
or electronic circuit malfunction can include the use of:




pure mechanical stop controls which have no electrical or electronic circuit interaction and
cannot malfunction, but are not always a practical solution
risk assessment and safety integrity testing
having a level of electrical or electronic reliability that is larger than other malfunctions or
errors in the system
having electrical or electronic integrity to the maximum extent in order to have an
extremely high level of protection from circuit malfunction.
4.11 Control circuit failure
A control circuit used to control the plant should be designed in accordance with the requirements
of the category/performance level/safety integrity level determined by the risk assessment. In
particular:
 the plant should not start unexpectedly
 the plant should not be prevented from stopping if such a command has already been
given
 no moving part of the plant or work piece being held by the plant should fall or be ejected
 automatic or manual stopping of moving parts should not be impeded
 the protection device should remain fully effective or fail to a condition that does not create
a risk.
4.12 Warning devices
R.192: If the design of plant includes an emergency warning device or it is necessary to include
an emergency warning device to minimise risk, the designer of the plant must ensure that the
design provides for the device to be positioned on the plant to ensure the device will work to best
effect.
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This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
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under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
DRAFT
Warning devices can include:
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audible alarms
motion sensors
lights
rotary flashing lights
air horns
percussion alarms
radio sensing devices.
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the Ministerial Council.
DRAFT
5
MANUFACTURING PLANT
5.1
The role of manufacturers
S.23: A person (the manufacturer) who conducts a business or undertaking that manufactures
plant that is to be used, or could reasonably be expected to be used, as, or at, a workplace must
ensure, so far as is reasonably practicable, that the plant is manufactured to be without risks to
the health and safety of persons who:
 use the plant at a workplace, for a purpose for which it was designed or manufactured
 store the plant at a workplace
 carry out any reasonably foreseeable activity at a workplace in relation to the assembly or
use of the plant for a purpose for which it was designed or manufactured or the proper
storage, decommissioning, dismantling or disposal of the plant, or
 are at or in the vicinity of a workplace and who are exposed to the plant at the workplace
or whose health or safety may be affected by a use or activity in the dot points above.
The manufacturer must use the design specifications provided by the designer. If the
manufacturer identifies a hazard in the design for which the designer did not provide a control
measure, the manufacturer must:



not incorporate that hazard into the plant during manufacture
give the designer written notice of the hazard as soon as practicable
take all reasonable steps to consult with the designer of the plant on altering the design to
rectify the hazard.
Where it is not possible for the manufacturer to tell the designer about the hazard, the
manufacturer must ensure the risk is eliminated or minimised so far as is reasonably practicable.
If a manufacturer or any other person modifies the design of plant without consulting the original
designer, that person will have the duties of a designer. All modifications should be approved by
the original designer or by a competent person, for example, substitution of metals in a
manufacturing process should be approved by the original designer or a person with relevant
expertise before the substitute material is incorporated. A competent person is a person who has
acquired through training, qualification or experience the knowledge and skills to carry out the
task.
The manufacturer must ensure the plant is supplied with appropriate information on safe use and
other aspects of the plant as outlined in section 5.4.
5.2
Manufacturing plant
R.193: A manufacturer of plant must ensure the following:
 that the plant is manufactured and inspected having regard to the information provided to the
manufacturer by the designer of the plant under the Act and these Regulations
 if the information provided to the manufacturer by the designer of the plant under the Act and
these Regulations requires the plant to be tested—that the plant is tested in accordance with
that information
 if, during the manufacturing process, any hazard is identified in the design of the plant for
which the designer has not provided a control measure
o
that the hazard is not incorporated into the manufacture of the plant
o
that the designer of the plant is given written notice of the hazard as soon as practicable
o
that all reasonable steps are taken to consult with the designer of the plant in relation to
the alteration of the design to rectify the hazard.
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DRAFT
A manufacturer of plant must ensure that, if it is not possible to inform the designer about the
hazard identified the risk is eliminated, so far as is reasonably practicable. If it is not reasonably
practicable to eliminate the risk, the risk is minimised so far as is reasonably practicable
If a hazard is identified in plant a manufacturer must not manufacture the plant until the designer
gives the manufacturer the revised information or written instruction, or the manufacturer
eliminates or minimises the risk so far as is reasonably practicable.
The manufacturer must ensure that the plant is manufactured, inspected and if required tested in
accordance with the information provided by the designer.
Connected, fabricated or machined materials are likely to be required in the construction of plant.
Manufacturing processes require that design specifications are followed, for example crane
booms of a particular lifting capacity should have the particular grade of steel specified.
The manufacturer may choose to consider other published technical standards for guidance on
the materials used for the plant, the method of construction and testing to achieve safety of the
plant.
Guarding
R.194: A manufacturer of plant must ensure that guarding used as a control measure is of solid
construction and securely mounted so as to resist impact or shock.
A manufacturer of plant must ensure:
 that any guarding used as a control measure in relation to plant is of a kind that can be
removed to allow maintenance and cleaning of the plant at any time that the plant is not in
normal operation, and
 if the guarding is removed—that, so far as is reasonably practicable, the plant cannot be
restarted unless the guarding is replaced.
Selecting material from which guards can be constructed is determined by four main
considerations:
 strength and durability, e.g. use of non-metallic materials in corrosive environments
 effects on machine reliability, e.g. a solid guard may cause the machine to overheat while
a mesh guard may allow dust into the working environment
 visibility, e.g. there may be operational and safety reasons for needing a clear view of the
danger area
 the control of other hazards, e.g. the use of a material that will not permit the ejection of
molten metal.
5.3 Testing and examining plant
S.23(3): The manufacturer must carry out, or arrange the carrying out of, any calculations,
analysis, testing or examination that may be necessary to ensure, so far as is reasonably
practicable, that the plant is manufactured to be without risks to the health and safety of persons.
Details of the testing and examination carried out should be documented and must be provided to
each person to whom the manufacturer provides the plant. Typical testing nominated by the
designer may include but is not limited to:
 electrical testing, e.g. input current, safety contactor current, leakage current, protective
earth continuity, dielectric strength test and insulation resistance
 safety function testing, e.g. safety circuit operation times, appropriate installation
distances, use of appropriate components and reliability design
 temperature rise tests, e.g. for exposed temperature hazards and to confirm components
are used within their specification
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DRAFT
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
pressure, stability, mechanical or structural testing to the levels required by the design
specification
abnormal condition tests, e.g. foreseeable component failures, unexpected start up,
hazards following interruption and restoring power sources like electricity and air.
Tests and examinations should include:
 all critical components
 the suitability of selected components
 mechanical devices
 pneumatic devices
 hydraulic devices
 sources of emissions, e.g. lasers, noise
 guarding and interlocking arrangements
 structural integrity
 material types and properties
 review safety circuits to ensure the requirements of the category/performance level/safety
integrity level have been met.
There are both visual and non-visual techniques for checking the integrity of plant manufacture.
For example, checking welded joints may require non-visual, non-destructive testing (NDT)
techniques.
For high risk plant where welding is used as a joining technique, NDT techniques like ultrasonic
and x-ray procedures should be used to ensure the welds are defect free and fit for the intended
purpose.
To ensure an accurate assessment of operational stresses is made, consideration should be
given to the use of techniques, for example strain gauging or photo-elastic. Stresses should be
measured dynamically under a range of operational conditions.
5.4 Information about using plant safely
S.23(4): The manufacturer must give adequate information to each person to whom the
manufacturer provides the plant concerning:
 each purpose for which the plant was designed or manufactured
 the results of any calculations, analysis, testing or examination
 any conditions necessary to ensure that the plant is without risks to health and safety to a
person using the plant for a purpose for which it was designed or manufactured or when
carrying out a reasonably foreseeable activity using the plant.
S.23(5): The manufacturer, on request, must, so far as is reasonably practicable, give current
relevant information on:
 each purpose for which the plant was designed or manufactured
 the results of any calculations, analysis, testing or examination, and
 any conditions necessary to ensure that the plant is without risks to health and safety to a
person using the plant for a purpose for which it was designed or manufactured or when
carrying out a reasonably foreseeable activity using the plant
to a person using the plant for a purpose for which it was designed or manufactured or when
carrying out a reasonably foreseeable activity using the plant.
A manufacturer must take reasonable steps to get the information from the designer of the plant
and pass it on to the person to whom the manufacturer supplies the plant. See section 3.6 for the
type of information that should be provided.
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DRAFT
Instructions should be trialled to ensure the intent of the instructions is achieved and that carrying
out the instructions does not pose a risk to health and safety. Information may be provided in the
form of written text or visual information like signs, symbols or diagrams.
5.5 Registering plant designs
Part 1 of Schedule 5 to the WHS Regulations lists plant for which the design must be registered
with the regulator. Schedule 5 is reproduced at Appendix B. If the designer has registered the
design, the designer must provide the design registration number to the manufacturer. The
manufacturer must pass on the design registration number to the person being supplied with the
plant.
R.231: A manufacturer must not supply plant specified in Part 1 of Schedule 5 unless the design
of that plant is registered under Part 5.3.
If the designer has not registered the plant design then the manufacturer must register the plant
design before it is supplied to a person. If the manufacturing process has involved modifying an
already registered plant design in such a way that it requires new risk control measures, the
altered design must be registered. See section 3.7 for information about design registration.
5.6 Item registration
Part 2 of Schedule 5 to the WHS Regulations lists items of plant which must be registered with the
regulator. Schedule 5 is reproduced at Appendix B. A manufacturer who produces a number of
the same items of plant may apply for the item registration, noting that once it is sold to someone
else, the manufacturer must notify the regulator that they no longer have management or control
of that item of plant.
Marking registered items of plant
In the case of an item of plant that requires registration, the plant registration number provided by
the regulator must be marked on the item of plant where it can be easily seen. It will generally be
a simple task to mark large items of plant with the plant registration number by either etching the
number in place or by fixing the number in place in a position that will not lead to damage or
removal over time
On some items, for example a tower crane that may comprise many parts and is often assembled
in a configuration to suit a particular workplace/task, it may not be feasible to mark each
component. In such cases the item registration number should be marked on those components
that are readily accessible and able to be seen when the crane is fully assembled.
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DRAFT
6
IMPORTING AND SUPPLYING PLANT
S.24 and S.25: a person (the importer) who conducts a business or undertaking that imports
plant and a person (the supplier) who conducts a business or undertaking that supplies plant
must ensure, so far as is reasonably practicable, that the plant is without risks to the health and
safety of persons who:
 use the plant at a workplace, for a purpose for which it was designed or manufactured
 store the plant at a workplace
 carry out any reasonably foreseeable activity at a workplace in relation to the assembly or
use of the plant for a purpose for which it was designed or manufactured or the proper
storage, decommissioning, dismantling or disposal of the plant, or
 are at or in the vicinity of a workplace and who are exposed to the plant at the workplace
or whose health or safety may be affected by a use or activity in the dot points above.
Importers and suppliers must, so far as is reasonably practicable, eliminate or minimise risks to
health and safety with regard to the plant being supplied, where the manufacturer has not already
done so. This may be necessary where the importer has no direct connection to an overseas
designer or manufacturer.
For example, an importer starts importing a new model of tractor into Australia. When checking
the tractor against requirements of the WHS Regulations and relevant standards, the importer
finds that it requires roll-over protection and this has not been installed. For those tractors already
imported, the importer must install adequate roll-over protection before selling the tractors. They
should consult with the manufacturer or the designer about how best to do this. The importer
should negotiate with the manufacturer to ensure that tractors supplied in future have roll-over
protection that meets Australian requirements.
6.1 Testing and examining plant
S.24(3) and S.25(3): The importer and supplier must:
 carry out, or arrange the carrying out of, any calculations, analysis, testing or examination
that may be necessary to ensure, so far as is reasonably practicable that the plant is without
risk to the health and safety of persons
 ensure that the calculations, analysis, testing or examination have been carried out.
Importers or suppliers must take reasonable steps to get this information from the manufacturer of
the plant and pass the information on to the person to whom the plant is supplied. If this
information is not available, the importer or supplier must carry out the necessary testing and
examination required under the WHS Act.
For example, an importer receives a consignment of lathes from overseas but finds the safety and
operating instructions are not delivered. When the importer contacts the manufacturer to get the
safety and operating information they are told the company has closed down. In this case the
importer must carry out the testing and examination to compile safety and operating instructions
to pass on when the importer supplies the goods.
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6.2 Information about using plant safely
S.24(4) and S25(4): The importer and supplier must give adequate information to each person to
whom the importer or supplier provides the plant concerning:
 each purpose for which the plant was designed or manufactured
 the results of any calculations, analysis, testing or examination
 any conditions necessary to ensure that the plant is without risks to health and safety to a
person using the plant for a purpose for which it was designed or manufactured or when
carrying out a reasonably foreseeable activity using the plant.
S.24(5) and S25(5): The importer and supplier, on request, must, so far as is reasonably
practicable, give current relevant information on:
 each purpose for which the plant was designed or manufactured
 the results of any calculations, analysis, testing or examination
 any conditions necessary to ensure that the plant is without risks to health and safety to a
person using the plant for a purpose for which it was designed or manufactured or when
carrying out a reasonably foreseeable activity using the plant
to a person using the plant for a purpose for which it was designed or manufactured or when
carrying out a reasonably foreseeable activity using the plant.
The information may be provided in user manuals and manufacturers' instructions.
The information should, wherever possible, be in plain English and include pictures or drawings
where possible, while at the same time maintaining the accuracy and quality of the technical
information.
6.3 Compatibility of components
Some plant may be assembled from components from a variety of sources. The assembly of
these by a manufacturer could present a risk to health and safety. A manufacturer using
components from a variety of sources should provide the importer or supplier an assurance of
compatibility of components, for example by listing the specifications required in relevant technical
standards. The manufacturer must also, so far as is reasonably practicable, ensure the
components are without risk to health and safety when used properly or for a reasonably
foreseeable activity.
The importer or supplier should in turn pass this information on to the end user. If this information
is not available then you must carry out the relevant testing to ensure that risks to health and
safety are eliminated or minimised, so far as is reasonably practicable.
6.4 Importing plant
Importers of plant must take reasonable steps to get information from the manufacturer about the
purpose for which the plant has been designed and the conditions necessary to ensure it is
without risks to health and safety.
If the health and safety information is not provided to the importer by the original designer or
manufacturer, the importer assumes responsibility for supplying the information normally provided
and must ensure the necessary testing is done to get the information (see sections 3.6, 3.7, 5.3
and 6.2 of this Code).
The importer or supplier must inspect the plant in conjunction with information provided by the
manufacturer and carry out testing specified by the manufacturer. Risks identified during
inspection and testing must be eliminated or minimised so far as is reasonably practicable. The
person to whom the plant is supplied must, so far as is reasonably practicable, be told of the
residual risks.
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The importer must take reasonable steps to ensure that the designer and manufacturer are
consulted on alterations made to the plant to control risk.
6.5 Design registration
R.232: An importer must not supply plant specified in Part 1 of Schedule 5 unless the design of
that plant is registered under Part 5.3.
If the item of plant to be imported requires design registration under Schedule 5 of the WHS
Regulations, the importer must apply for and receive design registration before supplying the plant
to anyone within Australia (see section 3.8). This will require the importer to conduct testing and
develop the information required for design registration if it is not available. The design
registration number must be provided to people who the plant is supplied to.
If the importer or supplier makes modifications to the plant, for example to ensure compliance with
Australian standards, they should take reasonable steps to tell both the designer and
manufacturer. When the importer or supplier modifies the design they also take on the duties of a
designer.
When importing second-hand plant, the importer must ensure that the plant has been
manufactured in accordance with the original design (based on which the plant design was
registered). If the design is not the same or if the plant (as imported) has been modified to the
extent that the safety has been changed, the original plant design registration number must not be
used. The duty holders must engage a competent person to verify the new or modified design and
if necessary, register the new design. A competent person for design verification is a person who
has the skills, qualifications, competence and experience to design the plant or verify the design.
6.6 Hiring plant
If you supply hired or leased plant (the ‘hirer’ or ‘lessor’) to someone you have the same
obligations as a supplier of new plant and ensure, so far as is reasonably practicable, that hired
plant is safe and without risk to health and safety when used properly. A supplier must ensure the
hired plant is accompanied by information about how to use the plant safely.
The hirer of plant should ensure the plant is inspected between hiring and that maintenance and
repairs are carried out to minimise risks to health and safety. In the context of hired plant,
‘between’ means every time the plant is hired or leased, but does not include an extension to the
hiring or leasing period for the same user, that is, hiree or lessee.
Where a lease or hiring period is extended the supplier should put in place processes to ensure
the plant is continued to be inspected and maintained properly.
Excessive wear or damage to the plant must be identified and fixed by the supplier in accordance
with the designer's or manufacturer's specifications for inspection and maintenance.
A regular testing program should be implemented. Testing should consider factors like how often
the plant is used and the operating and environmental conditions during the period.
Where plant is to be transferred between hirees or lessees without being returned to the supplier's
depot, the supplier must ensure the plant is inspected and maintained before transfer. For
example, this may be done ’on-site’ without returning the plant to the depot.
Where the plant is hired or leased for an extended period of time, the supplier should make
arrangements with the hiree or lessee to have the plant inspected and maintained in accordance
with the designer's or manufacturer's specifications for inspection and maintenance.
For plant that is hired or leased with an operator, the supplier may fulfil their duty by preparing a
comprehensive set of checks and authorising the operator to carry out these checks between
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hiring and leasing. If this option is used the supplier should ensure that the operator is competent
to apply the checks and carry out, or arrange to carry out, the maintenance identified by the
checks.
Records must be kept by the supplier of inspections and maintenance carried out on the plant.
The maintenance schedule should be monitored so necessary maintenance is not required during
a period of hire.
If agreement is reached that the hiree or lessee will carry out the necessary inspections and
maintenance, the supplier should ensure that either during the hire or lease of the plant or at the
conclusion of the hire or lease, records associated with inspections and maintenance of the plant
are obtained from the hiree or lessee.
6.7 Second-hand plant
S.25: A person who conducts a business or undertaking that supplies plant that is to be used, or
could reasonably be expected to be used, as, or at, a workplace must ensure, so far as is
reasonably practicable, that the plant is without risks to the health and safety.
R.198: A supplier of plant must:
 take all reasonable steps to obtain the information required to be provided by the
manufacturer under section 23(4)(a) and (c) of the Act and these Regulations, and
 when the plant is supplied, ensure the person to whom the plant is supplied is given the
information obtained by the supplier.
R.199: A supplier of second-hand plant must ensure, so far as is reasonably practicable, that any
faults in the plant are identified.
Before plant is supplied, the supplier of second-hand plant must ensure that the person to whom
the plant is supplied is given written notice of:
 the condition of the plant
 any faults identified, and
 if appropriate, that the plant should not be used until the faults are rectified.
R.8: A supply of a thing does not include the supply of a thing by a person who does not control
the supply and has no authority to make decisions about the supply, for example an auctioneer
without possession of the thing or a real estate agent acting in their capacity as a real estate
agent.
Who is a supplier?
A person is a supplier of second hand plant if they conduct a business or undertaking that
supplies second hand plant. This includes selling the plant or even if they give the plant away.
Supplier to identify faults
A person conducting a business or undertaking that supplies second-hand plant must ensure, so
far as is reasonably practicable, that faults which may cause a risk to health and safety are
identified. This can include faults or defects from excessive wear for example the tyres will need
replacing soon, or there are damaged or removed safety features such as an emergency stop
control.
If the supplier is not competent to identity the faults they should get a person with the knowledge,
skills and experience relevant to the plant to identify them, for example a mechanic.
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Supplier to make plant safe
Where the supplier intends or it is reasonable for the supplier to expect the plant will be used at a
workplace, the supplier must ensure, so far as is reasonably practicable, the plant is without risks
to health and safety before it is used.
Supplier and agent to pass on information
A supplier must provide the buyer or person receiving the plant with information about using the
plant properly and safely and anything about the plant which would create a risk to health and
safety. The supplier must give the following type of information to the person buying the plant in
writing before they buy it:
 what condition the plant is in, e.g. is it working properly or can it only be used for scrap
 identified faults that were not reasonably practicable for the supplier to fix, e.g. from
excessive wear or, damage or where legally required safety features are not installed such
as an emergency stop control
 where it was not reasonably practicable for the supplier to fix a fault, information about the
faults which must be fixed before using the plant, e.g. if a tractor is being sold without a
rollover protective structure, the supplier must point out this and that such a structure must
be fitted before the tractor can be used.
When the plant is supplied, the supplier must also ensure the person buying or receiving the plant
is given relevant information from the designer, manufacturer and past owners which the supplier
has obtained. This includes information about:
 purpose for which the plant is designed
 correct and proper use
 installing, commissioning and maintaining etc. from the designer and manufacturer, e.g.
data sheets, test certificates, operations and service manuals, reports and safety manual
 records of the plant kept by previous owners.
Supplying scrap or spare parts
R.200: A supplier of plant to be used for scrap or spare parts must, before the plant is supplied,
inform the person to whom the plant is supplied, either in writing or by marking the plant, that the
plant is being supplied for scrap or spare parts and that the plant in its current form is not to be
used as plant.
Where second-hand plant is to be used for scrap or spare parts, the supplier must:

Tell the person buying or receiving the plant that it is being supplied as scrap or spare
parts and that the plant in its current state is not to be used as plant. This must be done in
writing or by marking the item of plant. An auctioneer with possession of the second hand
plant also has this duty.
Once plant is supplied as scrap or spare parts it cannot be used in its current form as plant so no
further information about defects needs to be provided by the supplier.
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7
7.1
SPECIFIC HAZARDS AND CONTROL MEASURES
Confined spaces
The design, manufacture or modification of a plant or structure that includes a confined space is
critical. Thoughtful design can eliminate the need to enter a confined space or eliminate the risk of
inadvertent entry.
R.64: A designer, manufacturer, importer or supplier of the plant or structure, and a person who
installs or constructs the plant or structure, must ensure that the need for any person to enter the
space and the risk of a person inadvertently entering the space are eliminated, so far as is
reasonably practicable.
If this is not reasonably practicable, then:
 the need for any person enter the space must be minimised so far as is reasonably practicable
 the space is designed with a safe means of entry and exit, and
 the risk to the health and safety of any person who enters the space is eliminated so far as is
reasonably practicable or, if it is not reasonably practicable to eliminate the risk, the risk is
minimised so far as is reasonably practicable.
The following features should be incorporated in the design and manufacturing stages:
 use of lining materials that are durable, require minimal cleaning and do not react with
materials contained in the confined space
 design of mechanical parts to provide for safe and easy maintenance to reduce the need
for people to enter
 access points, including those within the confined space, through divisions, partitions or
obstructions, should be large enough to allow people wearing the necessary protective
clothing and equipment to pass through and to permit the rescue of people who may enter
the confined space.
Further guidance on confined spaces is available in the Code of Practice: Confined Spaces.
7.2
Manual tasks
R.61: A designer and manufacturer of plant must:
 ensure that the plant is designed so as to eliminate the need for any hazardous manual
task to be carried out in connection with the plant
 if it is not reasonably practicable to do this, the designer must ensure that the plant is
designed so that the need for any hazardous manual task to be carried out in connection
with the plant is minimised so far as is reasonably practicable
 give to each person who is provided with the design for the purpose of giving effect to it
adequate information about the features of the plant that eliminate or minimise the need
for any hazardous manual task to be carried out in connection with the plant.
The importer or supplier of plant must take reasonable steps to get the information and provide it
to any people who the plant is supplied to.
Designers and manufacturers should consider:
 Characteristics for example the weight, size, shape, surface characteristics and stability of
plant or its various component parts. Where these characteristics present a risk to users,
plant should be equipped with items like hand-grips to enable it to be picked up and
moved safely.
 Vertical and horizontal reach distances of people who may use or manually handle plant.
 Conditions in which the plant will be used, serviced, maintained and repaired. For
example, in some situations it may not be possible to make use of mechanical lifting
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devices and so items of plant or their components should be designed to eliminate risk to
the user.
Methods designers and manufacturers may consider to minimise risks associated with manual
tasks include:
 modular components designed to dismantle so that they can easily be carried or repaired
 attachments like handles or designated lifting points to make lifting easier or wheels to
make moving easier
 using lightweight materials
Further guidance is available in the Code of Practice: Hazardous Manual Tasks.
7.3
Noise
R.59: A designer and manufacturer of plant must:
 ensure that the plant is designed so that its noise emission is as low as is reasonably
practicable
 give to each person who is provided with the design for the purpose of giving effect to it
adequate information about:
o the noise emission values of the plant
o the operating conditions of the plant when noise emission is to be measured, and
o the methods the designer has used to measure the noise emission of the plant.
A designer and manufacturer of plant must also provide information on the conditions required to
use the plant safely.
The importer or supplier of plant must take reasonable steps to get the information and provide it
to people who the plant is supplied to.
In eliminating or minimising the risks associated with noise, consider:

preventing or reducing the impact between machine parts

replacing metal parts with quieter plastic parts

combining machine guards with acoustic treatment

enclosing particularly noisy machine parts

selecting power transmission which permits the quietest speed regulation, e.g. rotationspeed-controlled electric motors

isolating vibration-related noise sources within machines

good seals for machine doors

machines with effective cooling flanges which reduce the need for air jet cooling

quieter types of fans or placing mufflers in the ducts of ventilation systems

quiet electric motors and transmissions

pipelines for low flow speeds (maximum 5m/sec.)

ventilation ducts with fan inlet mufflers and other mufflers to prevent noise transfer in the
duct between noisy and quiet rooms.
Further guidance is available in the Code of Practice: Managing Noise and Preventing Hearing
Loss at Work
7.4
Energy sources
The design of plant should accommodate the possibility of a dangerous situation occurring where
the energy source to the plant fluctuates or the energy source is discontinued and then resumes.
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In particular:
 the plant should default to the ‘off position’
 the plant should not be able to restart automatically after power fluctuations – if there is a
risk of injury due to the plant restarting when the power resumes, the plant should remain
in a de-energised state until the start sequence is started,
 protective devices should remain fully effective before, during and after a change to the
status of the energy source.
Where electrical equipment has been designed for use within certain voltage limits, only those
specific requirements, for example electrical standards and statutory requirements, that address
the design requirement should apply.
Where plant is powered by an energy source other than electricity, for example hydraulic,
pneumatic, thermal or stored kinetic energy, it should be designed to allow the plant to be
constructed and equipped to eliminate or minimise so far as is reasonably practicable potential
hazards associated with these types of energy.
7.5
Static electricity
Static electricity may cause an electric shock to a person. As a consequence the person may fall
or drop an object. Static electricity may also cause unintended combustion where flammable
fumes are present. Where the build-up of potentially dangerous electrostatic charges creates a
risk to health and safety, plant should be designed to prevent or limit the discharge or be fitted
with a discharging system. For example, spark detection and suppression systems can be
incorporated into dust extraction systems to minimise the risk of explosion or fire.
7.6
Lightning
The design of plant that is likely to be exposed to lightning while being used should incorporate a
system for conducting resultant electrical charges to earth.
7.7
Fire and explosion
Certain types of plant have the potential to be a fire or explosion risk. A designer should eliminate
or minimise risk of fire, overheating or explosion posed by the plant itself or by gases, liquids,
dusts, vapours or other substances produced or used by the plant or other plant nearby.
7.8
Plant capable of entangling a user
Designers should make certain that moving parts of machines are designed in a way that
prevents user contact that may cause injury. In some instances this may be difficult to achieve as
there may be a need to have rotating elements exposed during normal use.
Older plant like radial drills, surface planers and milling machines commonly operate with the
rotating tool unguarded and this presents a real risk of entanglement should the user or their
clothing contact the rotating part. The most likely causes of contact are where the user applies
cutting lubricant to the interface between the tool and the part being machined, removing swarf
from around the part, or where the tool is not brought to a complete stop during re-setting of the
work piece.
Modern metal-working machine tools often incorporate protective guards that surround the cutter
and provide lubricant and swarf removal that can eliminate the need for user intervention and in
doing so, eliminate the risk of entanglement. Where plant is computer controlled, the need for
user interaction is further reduced. Older style machines however should be protected, for
example by the use of physical barriers, pressure sensitive mats or presence sensing devices.
Lubricant application and swarf removal can also be achieved by the retro-fitting extra devices
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dedicated to these purposes and which allow the user to remain outside the danger zone while
the plant is being used.
Woodworking machinery can also expose a user to a risk of entanglement, especially when work
pieces are being fed into machines. Such risks can be eliminated by the use of powered feed
equipment that provides a safe distance between the user from revolving cutters or blades. Plant
like grain augers or tree-limb mulchers also require special attention to prevent users becoming
entangled in the plant, such as fitting barriers like mesh guards or tunnel guards.
Controls for plant capable of entanglement should be able to bring the plant quickly to a complete
stop. The braking system on the plant should, so far as is reasonably practicable, prevent further
movement once the plant has stopped.
7.9
Vibration
Plant should be designed to avoid risks resulting from vibration. Vibration may be transmitted to
the whole body and through the hands and arms when using plant. There are two approaches to
control vibration:


preventing vibration happening in the first place
separating the vibration from the person using the plant.
Examples of prevention are substituting an internal combustion engine fitted to plant with an
electric drive.
Examples of separation include:
 suspended cabs used on some commercial vehicles
 use of vibration isolation, e.g. the use of rubber blocks or mounts on an engine to reduce
(isolate) the vibration
 tool design that isolates the handles from the percussive action.
7.10 Exposure to radiation
Radiation hazards are produced by a variety of sources and may be generated by non-ionising or
ionising radiations. Information on non-ionising and ionising radiation for particular items of plant
can be found in relevant Australian Standards. Plant should be designed so external radiation
does not interfere with its use or with people working on or in the vicinity of the plant.
Plant should be designed to eliminate or minimise, so far as is reasonably practicable, personal
exposure to radiation. Some examples of engineering control measures to minimise exposure to
radio frequency radiation include shielding, interlocking doors on industrial microwave ovens or
installing remote operator controls when stray radiation could be produced from an induction or
dielectric heater.
Radiation levels should not exceed relevant exposure limits set by the Australian Radiation
Protection and Nuclear Safety Agency.
The radiation emitted should also not be higher than what is necessary to use the plant, even in
an emergency. The effects of radiation exposure are cumulative. Where necessary, instructions
should be included stating the need for regular personal monitoring for radiation build-up.
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Lasers
R. 223: The person with management or control, at a workplace, of laser equipment that may
create a risk to health and safety must ensure that:
 laser equipment intended for use on plant is designed, constructed and installed so as to
prevent accidental irradiation of any person
 laser equipment on plant is protected so that any operator of the plant or other person is
not exposed to direct radiation, radiation produced by reflection or diffusion or secondary
radiation
 the visual equipment used for the observation or adjustment of laser equipment on plant
does not create a risk to health or safety from laser rays.
Lasers are devices that produce optical radiation with unique properties. They have varying power
and applications. High power laser devices can present a hazard over considerable distances
from the source. While exposure to some higher powered laser products may cause skin burns,
most laser injuries are to the eyes. For example, some laser pointers available on the market are
of sufficient power to cause eye injury.
Laser products may consist of a single laser with or without its own power supply or multiple
lasers in a complex system.
Designers can design out some of the health and safety risks which are explained in regulation
223. Designers should consult with manufacturers, suppliers, owners and end users to ensure
that the correct strength of laser is used and the housing of the laser unit is designed according to
safe design principles. The designer should ensure that complete written information on how to
use laser products safely is provided to manufacturers, erectors, installers, suppliers, owners and
end users.
All laser devices must be sold with information about how to use them safely. This generally takes
the form of a label with both the classification details and the warnings-for-use that are
appropriate to that classification. The warning labels appropriate to the class should be
permanently affixed to the housing in a highly visible position.
Laser devices sold in Australia should be classified in accordance with AS/NZS IEC 60825:
Safety of laser products
Radio frequency radiation
Radio frequency (RF) radiation is electromagnetic energy (wave) that is transmitted at frequencies
between 3 kHz and 300 GHz. Radio frequency (RF) generating plant may be used at workplaces
that perform forging, annealing, tempering, brazing or soldering, sealing of plastics, glue drying,
curing particle boards and panels, heating fabrics and paper, or cooking by means of a microwave
oven.
Workers in industrial workplaces that use RF generating plant are at risk of exposure to levels of
RF fields where radiation may cause adverse health effects. Usually those workers using the plant
are the most likely to be exposed. However, workers who do not use RF generating plant but are
situated within its vicinity and people coming into the workplace can also be at risk from the
generated radiation. For guidance on maximum exposure levels for RF radiation refer to Radiation
Protection Standard No 3 produced by the Australian Radiation Protection and Nuclear Safety
Agency.
Pregnant women and people with metallic implants or cardiac pacemakers may be at particular
risk from RF radiation.
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Ultraviolet radiation
Excessive exposure to ultraviolet radiation can cause not only sunburn but also lasting skin
damage, premature skin aging and an increased risk of developing skin cancer. Ultraviolet
exposure also increases the risk of ultraviolet induced damage to the lens and cornea of the eye.
Ultraviolet radiation exposure can also result from artificial sources like germicidal lamps and
quartz-halogen lights.
Designers should consider ultraviolet risks associated with the plant they are designing, for
example a designer of mobile plant used externally should safeguard the driver from exposure to
ultraviolet radiation from the sun by incorporating an effective canopy into the design to eliminate
or minimise the risk.
Other radiation
Static electric and magnetic fields should be taken into account by duty holders. Static electric
fields are widely used in industries like chemicals, textile, aviation, paper, rubber and
transportation. Plant related sources of static magnetic fields include devices, appliances and
equipment containing wires carrying direct current. Some examples of technologies that involve
the use of large static magnetic fields include aluminium production, electrolytic processes,
producing magnets and nuclear magnetic resonance imaging and spectroscopy. For guidance on
exposure limits refer to International Commission on Non-Ionising Radiation Protection Guidelines
on limits of exposure to static magnetic fields - 2009.
Low Frequency radiation is man-made, extremely low frequency electromagnetic fields at
frequencies of 50 and 60 Hz which come predominantly from electric energy generation
transmission, distribution and use. For guidance on exposure limits for low frequency radiation
refer to Australian Radiation Protection and Nuclear Safety Agency Radiation Health Series 30:
Interim guidelines on Limits of Exposure to 50/60 Hz electric and Magnetic Fields (1989)
7.11 Risk of being trapped
Where there is a risk of a person becoming trapped or enclosed within the plant, measures should
be included in the design to allow the plant to come to an immediate stop or prevent the plant
being activated while a person is in that position, for example presence sensing systems used
together with control systems that de-energise the plant.
For mobile plant the risk of the user being trapped if the plant overturns can be minimised with
rollover protective structures.
7.12 Hazardous chemicals
Plant should be designed and manufactured to eliminate or minimise the release of substances
which are hazardous. This extends to controlling hazardous waste.
7.13 Combined plant
Where plant is arranged to work in combination with other plant or parts of other plant, it should
be designed so that the stop controls, including the emergency stop control, can not only stop the
plant but also stop other plant related to the use if the continued use of the plant creates a risk to
the user or others.
Where production lines are separated into zones, it should be made clear to the users that the
controls will only work for that zone. Demarcating zones should be clear and intrusions into
adjoining zones should be made as difficult as practicable.
Designers must provide information about combined plant to the manufacturer and ensure that
the instructions for using the plant provide guidance for end users.
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7.14 Stability
Unstable plant is a hazard. It can topple, parts can fall off or it can unexpectedly move and result
in workers or others in the workplace suffering crushing or impact injuries.
Designers should ensure that plant is designed to be stable and without risk of overturning, falling
or unexpected movement during erection or installation and under all operating conditions. It may
be necessary for designers to consult with other stakeholders including manufacturers, erectors,
installers and end users.
Detailed erection, modification and dismantling procedures should be provided by the designer in
writing to prevent unstable plant at the workplace. Stability testing requirements for the plant can
be developed and specified at the design stage and verified after manufacture.
7.15 Mechanical or structural failure during use
The various parts of plant and their linkages must be able to withstand the stresses to which they
are subjected during intended use and reasonably foreseeable misuse. The durability of materials
used to construct the plant must be adequate for the nature of the specified working environment.
When nominating the type of materials to be used, you must consider the possible effects of
fatigue, ageing, corrosion and abrasion.
The design specification must indicate the type and frequency of inspection and maintenance
required to keep the plant in a safe condition. The design specification must, where appropriate,
also indicate the parts subjected to wear and the criteria for determining replacement.
Where a risk of rupture or disintegration of component parts remains after measures are taken,
the parts must be designed, so far as is reasonably practicable, to be mounted, positioned or
guarded so if they rupture their fragments will not put the user or others at risk.
Rigid and flexible hoses and pipes carrying fluids like gases or solids, particularly those under
high pressure, must be able to withstand the foreseen internal and external stresses and must be
firmly attached and protected against those stresses. Precautions must be taken to make sure
that there is no risk posed by rupture.
Where material to be processed is automatically fed to moving parts of the plant, the design must
include a way to avoid risks to the user and others which may arise from the material being
ejected or being blocked in the moving parts of the plant. This may include:


allowing the moving parts to attain normal working condition before material comes into
contact with the moving parts
co-ordinating the feed movement of the material and the moving parts of the plant at all
times including on start-up and shut-down, regardless of whether the use is intentional or
unintentional.
7.16 Software
Designers considering the use of interactive software to be used by the user to command or
control the use of the plant should make sure that the software is as intuitive as possible and does
not require complex manipulation that could be affected by repetition or fatigue.
Software used for safety functions should be referenced against the relevant Australian
Standards.
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7.17 Lighting
Lighting should be provided to enable safe use and use of plant. Poor lighting can lead to poor
visibility, user fatigue, wrong decisions and incidents. For example if a user is unable to clearly
see a hopper capacity indicator, he or she may not empty it at the right time thus creating a
dangerous situation.
Emergency lighting should use its own power supply and not be subject to cuts in power. Lighting
may be internally or externally installed.
If external lighting needs to be provided in the workplace to ensure the safety of workers at or
near the plant, the designer should ensure that written information is provided to the
erector/installer and end user. Adequate lighting of control panels should also be taken into
consideration when designing plant.
Technical standards cover lighting requirements for plant use and maintenance, including:
 the direction and intensity of lighting
 the contrast between background and local illumination
 the colour of the light source
 reflection, glare and shadows.
Technical standards describe some specific situations where lighting design for use in industrial
settings must meet electrical safety standards. Standards also detail design requirements to
prevent lighting interactions causing a stroboscopic effect, particularly fluorescent lighting on
moving plant which makes moving parts of machinery look as if they are stopped, or rotating
beacons in mobile plant in the internal environment.
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APPENDIX A – DEFINITIONS
Fail safe2 means a state or condition where, if a component or function of the plant fails, a system
exists to prevent an increase in the risks.
The reliability and safety integrity of the fail safe system should be adequate to meet the level of
risk, for example by using the Category 1 to Category 4 Safety Integrity Level (SIL) system
applied in AS 4024: Safety of Machinery.
Examples of fail safe systems include:
 Passenger lifts –where lift cars are suspended using wire ropes, safety brakes are fitted
under the car and are automatically engaged to stop the car when a predetermined speed
of the falling car is reached for example when the wire ropes fail.
 Materials hoist – a switch automatically operates to stop the hoist, that is return it to
neutral, if the operator lets go of certain controls, for example because they are
incapacitated.
 Hydraulic powered elevating work platform (EWP) – valves are installed to prevent the
EWP from collapsing if a hydraulic hose bursts. This also prevents the normal lowering of
the platform so in an emergency the EWP must be lowered manually.
As defined in Public Discussion Paper- Safety Requirements for the Design, Manufacture and Conformity
Assessment of Plant February 2009, Australian Safety and Compensation Council
2
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APPENDIX B – REGISTRABLE PLANT
List of Plant requiring registration of design as outlined in Schedule 5 (Part 1) of the WHS
Regulations















Pressure equipment, other than pressure piping, and categorised as hazard level A, B, C
or D according to the criteria in Section 2.1 of AS 4343 Pressure equipment – hazard
levels
Gas cylinders covered by Part 1.1 of AS 2030.1 Gas cylinders - General Requirements
Tower cranes including self-erecting tower cranes
Lifts, including escalators and moving walkways
Building maintenance units
Hoists with a platform movement exceeding 2.4 metres, designed to lift people
Work boxes designed to be suspended from cranes
Amusement devices covered by Section 2.1 of AS 3533.1:2009 - Amusement Rides and
Devices, except Class 1 structures (see below)
Concrete placement units with delivery booms
Prefabricated scaffolding and prefabricated formwork
Boom-type elevating work platforms
Gantry cranes with a safe working load greater than 5 tonnes or bridge cranes with a safe
working load of greater than 10 tonnes, and any gantry crane or bridge crane which is
designed to handle molten metal or Schedule 10 hazardous chemicals
Vehicle hoists
Mast climbing work platforms
Mobile cranes with a rated capacity of greater than 10 tonnes
Note The plant listed as requiring design registration does not include:





a heritage boiler
a crane or hoist that is manually powered
an elevating work platform that is a scissor lift or a vertically moving platform
a tow truck
certain Class 1 structures including:
o playground structures
o water slides where water facilitates patrons to slide easily, predominantly under
gravity, along a static structure
o wave generators where patrons do not come into contact with the parts of machinery
used for generating water waves
o inflatable devices that are sealed
o inflatable devices that do not use a non-return valve.
List of Plant items requiring registration as outlined in Schedule 5 (Part 2) of the WHS
Regulations





Boilers categorised as hazard level A, B or C according to criteria in Section 2.1 of AS
4343 - Pressure equipment - hazard levels.
Pressure vessels categorised as hazard level A, B or C according to the criteria in Section
2.1 of AS 4343 - Pressure equipment - hazard levels, except for gas cylinders; LP Gas fuel
vessels for automotive use, and serially produced vessels.
Tower cranes including self-erecting tower cranes.
Lifts, including escalators and moving walkways.
Building maintenance units.
PAGE 48 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of Practice
under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
DRAFT



Amusement devices covered by Section 2.1 of AS 3533.1:2009 - Amusement Rides and
Devices, except for certain Class 1 structures (see below).
Concrete placement units with delivery booms.
Mobile cranes with a rated capacity of greater than 10 tonnes.
Note The plant listed as requiring item registration does not include:


a crane or hoist that is manually powered
certain Class 1 structures:
o playground structures
o water slides where water facilitates patrons to slide easily, predominantly under
gravity, along a static structure
o wave generators where patrons do not come into contact with the parts of machinery
used for generating water waves
o inflatable devices that are sealed
o inflatable devices that do not use a non-return valve.
PAGE 49 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of Practice
under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
DRAFT
APPENDIX C – DESIGN SOURCES OF HUMAN ERROR
The following table lists some human errors that may be associated with the use of plant and the
possible causes due to poor design of the plant or systems of work associated with the plant.
Unintended outcome
Inadvertent activation of plant.
Errors of judgement, particularly
during periods of stress or high
job demand.
Critical components installed
incorrectly.
Inappropriate use or delay in use
of controls.
Inadvertent activation of controls.
Critical instruments and displays
not read or information
misunderstood because of clutter.
Failure to notice critical signal.
Plant use results in unexpected
direction or response.
Lack of understanding of
procedures.
Following prescribed procedures
results in error or incident.
Lack of correct or timely actions.
Exceeding prescribed limitations
on load or speed.
Possible causes due to poor design
 Lack of interlocks or time lockouts.
 Lack of warning sign against activating equipment under specified
damaging conditions.

 Several critical displays of information are too similar or too close
together.
 Job requires user to make hurried judgements at critical times,
without programmed back-up measures.
 Design and instructions are ambiguous on installing components.
 Lack of asymmetrical configurations or guides on connectors or
equipment.
 Critical controls are too close, similar in design, awkwardly
located.
 Readout instrument blocked by arm when making adjustment.
 Labels on controls are confusing.
 Information is too small to see from user's position.
 Controls easy to activate by brushing past or too close to other
controls.
 Controls can be easily activated accidentally.
 Lack of guards over critical controls.
 Critical instruments or displays not in most prominent area.
 Design of many displays similar.
 Lack of suitable auditory and visual warning to attract user's
attention to information.
 Direction of controls conflicts with population norms or
expectancies.
 Instructions are difficult to understand.
 Written prescribed procedures not checked for accurate use.
 Available information incomplete, incorrect or not available in
time.
 Response time of system or plant too slow for making next
appropriate action.
 Lack of automatic corrective devices on system with fast
fluctuations.
 Lack of governors and other parameter limiters.
 Lack of warnings on exceeding parameters.
PAGE 50 OF 50
This DRAFT Code has been approved by Safe Work Australia Members and is ready for approval by the Select
Council on Workplace Relations (Ministerial Council). This Code will become a model WHS Code of Practice
under the Inter- Governmental Agreement for Regulatory and Operational reform in OHS when it is approved by
the Ministerial Council.
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