122 - NASH Inc - Safe Work Australia Public Submissions

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122
Individual/Organisational name: National Association of Steel-Framed Housing
What state/ territory are you from? Victoria
Model Work Health and Safety Codes of Practice - Public Comment Response Form
1) First Aid in the Workplace
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
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) Managing Risks in Construction Work
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
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) Preventing Falls in Housing Construction
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
General:
Whilst the Code is generally based on the current National Code of Practice, significant changes have
been made which affect the economics and safety of workers. It is recommended that the existing Code
be adopted. The existing code was developed by industry, unions and government regulators over a long
period of time
Scope and Application page 3
This covers all types of construction, but the document does not cover double brick or masonry
construction.
Introduction 1.1 page 5
A 2m height limit of given in this clause. However it is not clear whether a 2 m threshold is application to
the whole document. In fact NASH would recommend a 3m threshold for domestic construction as this
has proved to be a safe and practical limit. A minimum height threshold is required in this Code
External Wall used as edge protection page 11
Where the wall frame is used as edge protection, guardrails are not required to the floor.
Loading wall frames with trusses/roof framing page 11
Office Use Only
122
Individual/Organisational name: National Association of Steel-Framed Housing
What state/ territory are you from? Victoria
The comment in the introduction that some of this guidance may apply to metal trusses is very open
ended and will lead to confusion. The sections with trusses at 600mm centres, bracing requirements,
standing of trusses is purely related to timber trusses and should be identified as such. Steel trusses are
significantly lighter than timber trusses and have consistent properties.
Erect first and second standard trusses page 15
A 450mm wide plank or ladder are safe ways to connect the trusses where the people are working below
the threshold height
Use of crane to lift and position domestic trusses
A 450mm wide plank or ladder are safe ways to connect the trusses where the people are working below
the threshold height
Trusses spacings of greater than 600mm centres page 17
A threshold of preferably 3m should be given in this clause unless a general threshold is given in the
document as previously commented on.
2.11 Fixing of roof battens to trusses /rafter page 17
The requirement for all roof work to have physical fall protection mitigates against the first control
measures under the hierarchy of control. Where the trusses are assembled on the ground, there is no
need for fall protection.
Similarly there is no need to limit batten spacing where the trusses are assembled on the ground.
2
.12 Fixing fascias and gutters page 18
Where the site is cut into the ground, there may be no need for guardrailing.
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 current draft will add significantly to cost of construction when compared to the current code
without providing a higher level of safety.
4) Managing Electrical Risks in the Workplace
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
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 Risks of Hazardous Chemicals
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
Office Use Only
122
Individual/Organisational name: National Association of Steel-Framed Housing
What state/ territory are you from? Victoria
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 of Plant in the Workplace
Comments due by Friday, 18 November 2011
Comments: (Please include section/page numbers).
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?
Office Use Only
122
Individual/Organisational name: National Association of Steel-Framed Housing
What state/ territory are you from? Victoria
7) Safe Design Of Building and Structures
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
8) Excavation Work
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
9) Demolition Work
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
10) Spray Painting and Powder Coating
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
11) Abrasive Blasting
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
12) Welding and Allied Processes
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
Office Use Only
122
Individual/Organisational name: National Association of Steel-Framed Housing
What state/ territory are you from? Victoria
13) Safe Access in Tree Trimming and Arboriculture
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
14) Preventing and Managing Fatigue in the Workplace
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
15) Preventing and Responding to Workplace Bullying
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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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