105 ACTU
Draft model WHS Codes of Practice and guidance - Public Comment Response Form
Complete and submit this form by 5PM AEST FRIDAY 24 AUGUST 2012 to
codes@safeworkaustralia.gov.au
1. Cranes
Section/page no.
Comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different
to current requirements in your jurisdiction? If so, what are they?
2. Amusement Devices
Section/page no.
Comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different
to current requirements in your jurisdiction? If so, what are they?
3. Industrial Lift Trucks
Section/page no.
Comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different
to current requirements in your jurisdiction? If so, what are they?
4. Managing Risks of Plant used in Rural Workplaces
Section/page no.
Comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are different
to current requirements in your jurisdiction? If so, what are they?
5. Managing Security Risks in the Cash-in-transit Industry
Section/page no.
Comment
The draft Code represents the current state of knowledge and will cover the
safety aspects required for the protection of workers and the general public.
However there are a number of drafting issues in the draft Code.
The draft Code would benefit from clarity between its scope, title and content.
Is the Code about the CIT 'industry' or CIT 'activities'?
The inclusion of 'security' in the title seems to lead to crucial information being
omitted eg the draft refers to 'safety and security assessments' (3.6) but there is
no specific information on 'security assessments' . It appears that the factors for
security assessment are included in 2.2. This means that it is unclear what is a
Scope and
application page
6
1.1, page 8
1.1, page 8 third
dot point
2.3, page 12
3.2 page 15
Third dot point
3.6, page 17
4 Incidents, page
21
Appendix A, page
24 - 26
'security assessment' for example and who is competent to do it. See 3.6
comment.
Is it intended that 'security risks' mean just the risk of 'robbery' and 'armed holdups'.
The first sentence would be better expressed as :
This Code provides practical guidance for persons conducting a business or
undertaking on how to manage the risks involved in the carrying or transporting
of money and other valuables including managing the risks of robbery and
armed hold-ups.
'Industry' is in the title but is not defined, rather the content of the draft code at
1.1 defines the 'activities' and the draft code uses 'activities' throughout.
It isn't clear what 'management, secretarial and administrative tasks' related to
these CIT activities refers to or how these roles are covered by the hazards
listed in 2.1.
Are they these positions in the 'operator' or the 'client'?
Under 'substitute with something safe' delete 'load shifting equipment'
Delete words after 'maintained regularly.'
Under provisions of information to workers, first dot point are 'safety and
security risk assessments' different from the risk assessment. Intent and
wording should be clarified.
Under 'who should receive training', 4th dot point - links to above comment who are 'safety and security assessors'?
NSW, Vic, Comcare for example include advice: all site assessors, engaged for
the purpose of site safety and security risk assessment for CIT operations, meet
the requirement of competent person, hold qualifications in Security Risk
Management and have CIT industry experience.
There are also references in current Codes to other legislative requirements
and licensing. How will/should these other legislative requirements be referred
to?
Last para - include the definition of 'competent person'
This is a mostly advice for victims about what to do in the event of a robbery or
armed hold-up which is not suitable for a Code. The information which should
be included is the need for the development of procedures. The information on
incidents from the NSW Code (Part 4) or Victorian document (Part 4) should be
used.
Refers to internal and external hazards - but the content of the draft does not
refer to hazards in that way.
There are references to 'security consultant', 'safety officer' and 'security officer'
who are not mentioned in the text of the Code.
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?
6. Managing Risks in Forestry Operations
Section/page no.
Comment
This Code represents the current state of knowledge for managing risks in
forestry operations.
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?
7. Guide for Tunnelling
Section/page no.
Comment
Page 2 of 3
Impacts: Do you anticipate any potential costs or safety benefits of complying with this guidance material that
are different to current requirements in your jurisdiction? If so, what are they?
8. Guide for Managing Risk in Cable logging
Section/page no.
Comment
Impacts: Do you anticipate any potential costs or safety benefits of complying with this guidance material that
are different to current requirements in your jurisdiction? If so, what are they?
Page 3 of 3