Individual/Organisational name: Cancer Council Western Australia
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Model Work Health and Safety Code of Practice Managing Risks in Stevedoring
Public Comment Response Form
Model Code of Practice – Stevedoring
Chapter 1: Introduction
Comments: (Please include section/page numbers).
1.2 Who has health and safety duties in relation to stevedoring? (page 7)
Cancer Council Western Australia (WA) recommends that protection from over-exposure to ultraviolet
(UV) radiation be added to the list of other requirements under the Work Health and Safety (WHS)
Regulations that may apply to stevedoring activities along with noise, hazardous manual tasks, falls,
hazardous chemicals and plant.
As stated in the Guide on Exposure to Solar Ultraviolet Radiation (UVR), “under the model Work Health
and Safety (WHS) laws a person conducting a business or undertaking (PCBU) must manage risks to
health and safety. This includes the risk of workers being exposed to solar UVR” 1 (page 3).
Chapter 2: Risk Management
Comments: (Please include section/page numbers).
2.1 Identifying the hazards
Table 1: Hazards associated with stevedoring activities (page 10)
Cancer Council WA recommends that “working outside when the UV Index is 3 or above” be listed as a
separate task in the ‘examples of tasks’ column next to ‘working environment’ and the associated
potential harm of ‘sunburn/skin cancer’. The current listing places sunburn/skin cancer against an
‘extreme weather’ category. This is misleading as sunburn/skin cancer is an everyday risk.
UV radiation is classified as a ‘Class 1 Carcinogen’ by the International Agency for Research on Cancer
(IARC)2. Over-exposure to UV radiation can lead to skin cancer and other conditions such as eye
damage, sunburn and visible aging3. The World Health Organization (WHO) currently recommends the
use of sun protection by all people when the UV radiation level reaches three or above on the UV Index,
the level at which exposure to UV radiation is known to cause skin damage and increase a person’s risk
of skin cancer4.
2.3 Controlling the risks (page 11-12)
Where it has been identified by a risk assessment Cancer Council WA recommends that engineering,
administrative and PPE control measures be provided to protect stevedoring workers from over-exposure
to UV radiation. Examples of control measures include:

Engineering controls can include the provision of shade, modifying reflective surfaces and
window tinting in work vehicles.

Administration controls can include re-scheduling work programs around high UV times and
rotating workers.

In regard to sun protection the use of PPE includes:
o provision of sun protective work clothing (long pants and shirts with a collar);
o provision and use of sun protective hats (not caps);
o provision and use of sunglasses; and
o provision and use of sunscreen.
Chapter 3: Planning
Comments: (Please include section/page numbers).
3.1 Pre-arrival planning (page 14)
Cancer Council WA recommends adding “the max UV Index and sun protection times” to the list of points
the person(s) conducting the business or undertaking should consider in the planning stage.
The World Health Organization (WHO) currently recommends the use of sun protection by all people
when the UV radiation level reaches three or above on the UV Index, the level at which exposure to UV
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Individual/Organisational name: Cancer Council Western Australia
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radiation is known to cause skin damage and increase a person’s risk of skin cancer4.
Chapter 4: Inspections
Comments: (Please include section/page numbers).
Chapter 5: Working Environment
Comments: (Please include section/page numbers).
5.5 Weather conditions (page 24-25)
Cancer Council WA recommends adding “when the UV Index is 3 or above” to the list of weather
conditions which may impact safe working practices. Control measures may include: 1) engineering
controls including provision of shade and window tinting in work vehicles; 2) administration controls
including rescheduling work tasks outside of peak UV times and rotating workers; and 3) sun protective
PPE including clothing, hats, sunscreen and sunglasses.
Alongside the point “The Code of Practice: Managing the Work Environment and Facilities provides
further information about managing the risks associated with working in extremes of heat and cold”
Cancer Council WA recommends adding exposure to UV radiation as a separate point and include the
guidance note Guide on exposure to solar ultraviolet radiation (UVR) for further information about
managing the associated risks1. This should be changed if a Code of Practice on exposure to UV
radiation is developed.
Chapter 6: Handling Loads and Cargo
Comments: (Please include section/page numbers).
Chapter 7: Plant and Equipment
Comments: (Please include section/page numbers).
Chapter 8: Mooring and Unmooring
Comments: (Please include section/page numbers).
General Comments
Cancer Council WA believes in its current format the draft model Code of Practice for Managing Risks in
Stevedoring does not contain adequate information relating to workplace UV radiation exposure and
guidance for PCUBs on how to comply with their duty of care to protect stevedoring workers. UV
radiation is not directly associated with heat and expecting that a policy that covers extreme heat will also
address over-exposure to UV radiation is a mistake. UV radiation is an everyday hazard. UV radiation
is classified as a ‘Class 1 Carcinogen’ by the International Agency for Research on Cancer (IARC) 2.
Over-exposure to UV radiation can lead to skin cancer and other conditions such as eye damage,
sunburn and visible aging3. Australia experiences some of the highest levels of UV radiation in the world
due to our close proximity to the equator, high sun elevation and our generally clear atmospheric
conditions5 6. This means that Australia experiences some of the highest rates of skin cancer in the
world. Outdoor workers are thought to receive five to 10 times more UV exposure in a year than indoor
workers. This increased exposure means outdoor workers have a higher risk of developing skin cancer 7.
It is estimated that around 200 melanomas and 34,000 non-melanoma skin cancers in Australia are
caused by occupational exposures each year 8.
The issue of occupational exposure to UV radiation is becoming increasingly recognised in Australia.
Between 2000 and 2009 at total of 1,360 * workers compensation claims were made in Australia for sun
related injury/disease resulting in a total cost of $38.4 million. These claimants proved their skin cancers
*
This number must be viewed with some caution as they are rounded to the nearest five claims for confidentiality
purposes and have some limitations in terms of inclusions (full information available at www.safeworkaustralia.com.au).
Regardless, the data shows that the issue of occupational sun exposure is becoming increasingly recognised, and the
number and cost of claims is increasing.
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Individual/Organisational name: Cancer Council Western Australia
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were caused by occupational sun exposure and successfully claimed against their employers or former
employers for breach of duties. These cases firmly establish the legal recognition of sun exposure as an
occupational hazard causing injury/disease and of breach of employers’ duties to provide safe
workplaces in this context. These types of claims and associated costs are preventable by the
establishment and enforcement of proper sun protection policies and practices 9.
Please refer to Cancer Council WA’s Occupational exposure to ultraviolet (UV) radiation: Compensation
claims
paid
in
Australia,
2000-2009
for
further
information.
Available
from:
http://www.cancerwa.asn.au/resources/2011-12-05-ccupational-exposure-to-ultraviolet-radiation.pdf9.
Cancer Council Australia has also developed a comprehensive guide for workplaces looking to
implement a comprehensive sun protection program called Skin cancer and outdoor work: A guide for
employers. The guide explores the relationship between UV exposure and skin cancer and provides
PCBUs with information and advice to understand and confidently address sun protection in the
workplace. Available from: http://www.cancerwa.asn.au/resources/2013-02-12-skin-cancer-and-outdoorworker-a%20guide-for-employers-A4-book.pdf10.
The current guidelines, Guide on Exposure to Solar Ultraviolet Radiation (UVR) updated in August 2013,
provides practical guidance for employers looking to protect workers from over-exposure to UV radiation,
however this has no regulatory force1.
Cancer Council WA recommends that the current guidelines be upgraded into a Code of Practice
therefore having regulatory force and providing credible guidance for PCBUs on how to comply with their
duty of care to protect workers.
Comments on specific issues – specific questions can be found in the draft model Code.
Code of Practice or Guide:
Interaction with Marine Orders:
Guidance on mooring and unmooring:
1
Safe Work Australia, Guide on exposure to solar ultraviolet radiation (UVR). 2013 [cited 2013; Available
from: http://www.safeworkaustralia.gov.au/sites/SWA/about/Publications/Documents/788/Guide-ExposureSolar-Ultraviolet-Radiation.pdf].
2
International Agency for Research on Cancer, Agents Classified by the IARC Monographs. Last updated
July 2013.
3
Australian Radiation and Protection and Nuclear Safety Agency, Radiation Protection Standard for
Occupational Exposure to Ultraviolet Radiation. 2006, ARPANSA.
4
World Health Organisation, et al., Global Solar UV Index: a practical guide. 2002: Geneva.
5
Liley, J.B. and R.L. McKenzie, Where on earth has the highest UV? UV radiation and its effects - an update
2006. 2006, National Institute of Water and Atmospheric Research: Dunedin.
6
Gies, P., et al., Global Solar UV Index: Australian measurements, forecasts and comparison with the UK.
Photochemistry and Photobiology, 2004. 79(1): p. 32-9.
7
Australian Radiation Protection and Nuclear Safety Agency, Resource guide for UV protective products.
2003, Commonwealth of Australia: Yallambie.
8
Fritschi, L. and T. Driscoll, Cancer due to occupation in Australia. Australian and New Zealand Journal of
Public Health, 2006. 30(3): p. 213-219.
Cancer Council Western Australia. Occupational exposure to ultraviolet (UV) radiation: Workers’
compensation claims paid in Australia 2000-2009. 2011, Perth: Cancer Council Western Australia.
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Individual/Organisational name: Cancer Council Western Australia
Office Use Only
011
Cancer Council Australia’s Skin Cancer Committee, Skin cancer and outdoor work: A guide for employers.
2012, Melbourne: Cancer Council Victoria.
10
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