072 Telstra Corporation
Draft model WHS Third Set Codes of Practice - Public Comment Response Form
Complete and submit this form by 5PM AEST FRIDAY 22 JUNE 2012 to codes@safeworkaustralia.gov.au
1. Safe Design, Manufacture, Import and Supply of Plant
Section/page no.
Comment
3.7 providing
information
Some information that is important to downstream parties appears to be
missing in this section:
 The type of training and licences that may be needed to safely use the
plant
 No reference to providing dangerous goods details, as some items of
plant are dangerous goods The standards used to ensure the item
meets safety requirements
 List of hazards mitigated through the design process. This would help
designers demonstrate that safe design has been undertaken, and
would make purchasing decisions easier.
This section recommends use of symbols, but does not provide guidance on
how to find appropriate symbols.
3.7 providing
information
Many Australian and International Standards are useful in selecting symbols to
use, such as:
 AS 1319-1994 Safety signs for the occupational environment
 AS 2342-1992 Development, testing and implementation of information
and safety symbols and symbolic signs
 AS 2359.16-2005 Powered industrial trucks - Safety signs and hazard
pictorials - General principles
The Association of Equipment Manufacturers (AEM) provides a long list of
helpful standards (some are not appropriate as they relate to American signage
methodology).
5.4 information
about the safe
use of plant
Proposed New
Appendix
The AEM also provides an image database that uses hazard inputs to find the
best symbols.
This sections mentions use of visual information such as signs, symbols, or
diagrams. There is no reference to the most appropriate signs, symbols, or
diagrams. See comments on 3.7 providing information
A checklist to help ensure all necessary information is disclosed should be
added to the Code. The checklist could cover:
1. Identification of plant and the company/undertaking
2. Purpose and description of plant
3. Design features
4. Hazards identification
5. Emergency measures
6. Handling and storage
7. Installation and commissioning
8. Inspection, testing and maintenance
9. Operation of the plant
10. Exposure controls / personal protection
11. De-commissioning, disposal and dismantling considerations
12. Transport Information (including dangerous goods)
13. Regulatory information
14. Training
A separate guide may be required to ensure all required information is provided
to all duty holders.
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072 Telstra Corporation
In the telecommunications sector, a system consisting of various components
of plant is needed to create an effective network. If there is any missing
information it makes downstream (system) design more difficult.
Telstra created an optional plant template for our suppliers to capture the
information they need to disclose to enable Telstra to meet its duty as a builder
of networks.
Attached for your information.
Product Safety Data
Sheet PSDS Plant template form General-41492.doc
Telstra uses this document to help to identity better relevant information in
relation to hazards, emergency measures, training needs, regulatory actions,
etc.
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different
to current requirements in your jurisdiction? If so, what are they?
The draft Code is too generic and lacks the prescription and guidance generally expected of Codes
of Practice.
To overcome this lack of prescription it may be useful to reference industry specific design codes
such as those listed by the Communications Alliance.
The lack of clarity for creating good quality and comphreshensive information makes fulfilling
downstream duties more difficult, especially for system designers.
2. Working in the Vicinity of Overhead and Underground Electrical Lines
Section/page no.
Comment
Issue Paper – 3.2
In relation to approach distances, Telstra submits that the Code should apply
option 3, as the draft Code conflicts with telecommunications regulatory
requirements and current energy (electrical) safety regulatory requirements.
Consequently Telstra submits that approach distances
3.2
Working in the Vicinity of Overhead and Underground Electrical
Lines
Option 3:
The approach distances are removed so that the code only includes a
statement that local electricity supply authorities should be contacted for
information on approach distances.
Application
Scope and
Application,
Sections 2.3, 2.6,
2.7,
This Code’s use of approach distances, authorised person and safety observer
conflicts with the way the telecommunications industry works near powerlines,
and other metallic telecommunications networks.
A good practical example is to be found within the Electricity Safety
(Installations) Regulations [Victoria] reg 318
318Minimum distances between persons and aerial lines
(2) This regulation does not apply to—
(c) a telecommunications worker who holds a current certificate
specifying satisfactory completion of a training course in
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072 Telstra Corporation
power line awareness, approved by Energy Safe Victoria; or
Telecommunication networks are built to industry standards such as:
C524:2004 External Communication Cable Networks
(available from the
Communications Alliance)
Provides guidance on the basic principles of installation, maintenance and safety of
external communications networks; describes the minimum requirements for electrical,
structural and network reliability and employee/public safety. Revised to include "Dial
Before You Dig" awareness, safety requirements for working near electricity lines,
OH&S arrangements for facilities that emit electromagnetic radiation, road traffic
management to Australian standards, the marking of underground cables, the depth of
cover within road reserves and to clarify that the Code refers to other authorities and
property owners not just utility owners.
Some extracts on clearance from the code.
8.4.7 Clearances to Other Cable Systems
8.4.7.1 The Carrier must ensure the arrangement of, and clearances between,
its own Telecommunication Cables to that of Other Cable Systems, either
attached to a common Supporting Structure, unattached, in shared spans or
crossing, are designed for the environmental and electrical service conditions
likely to be experienced in service.
8.4.7.2 These clearances should be in accordance with the arrangements
agreed to between the Carrier of the Telecommunication Cables and that of the
respective owner of the Other Cable Systems involved.
Telstra has agreements in place with overhead power asset owners to support 8.4.7.2
2.3
“Table 2 provides approach distances for:
• authorised persons, with a safety observer, who are performing work in the
vicinity of overhead electric lines, including plant, hand tools, equipment or any
other material held by a person “
This implies that a safety observer is mandatory regardless of the risk or activity
within the authorised person zone.
In the Telecommunications industry, those ITC workers that mainly work on
customers’ information technology and communications (ITC) plant and
systems may need to connect to the appropriate network (optic fibre, telephony
(PSTN), pay-TV coaxial cable).
This activity is normally completed safely by a single operator on a ladder. A
safety observer would not provide any additional safety measure, as the worker
on the ladder would be a better position to identify electrical risks than an
observer on the ground.
2.6
Telstra suggests that an additional line or reference be included to clarify the
circumstances where an observer helps provide a safer system of work, for
example, when working with plant, blind spots, etc.
In relation to:
“Maintenance of competency
Authorised persons and safety observers should be either re-assessed or re-trained
annually to ensure their on-going competency to perform activities associated with
work in the vicinity of overhead electric lines.”
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072 Telstra Corporation
For the telecommunications industry the appropriate competency is
ICTOHS2153A - Work safely near power infrastructure.
To complete this annually is excessive when compared against the requirement
for assessment of those persons that hold high risk licences i.e. afive year
reassessment.
Telstra currently has an internal requirement to reassess all competencies for
our field work force every three years.
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different
to current requirements in your jurisdiction? If so, what are they?
There would be significant impact to the provision of essential telecommunication services in timely
manner. This would have significant negative impact to those in the community that are the most
vulnerable, i.e. those with a life threatening illness. The requirement for additional “observers”
required by the Code will have financial impact and could delay provision of services given
resources.
Unfortunately aspects of this Code may create conflicts with the aims of the Telecommunications
Act, where Telstra is obliged to provide an essential communications service.
3. Traffic Management in Workplaces
Section/page no.
Comment
No comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different
to current requirements in your jurisdiction? If so, what are they?
4. Scaffolding Work
Section/page no.
Comment
No comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different
to current requirements in your jurisdiction? If so, what are they?
5. Formwork and Falsework
Section/page no.
Comment
No comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different
to current requirements in your jurisdiction? If so, what are they?
Other comments
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