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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).
Please note that suggested changes are included in blue text.
Page 7 - 1.1
What is stevedoring?
It is considered that the definition of ‘Terminal’ should include that ‘…a secured gatehouse to control
entry and exit of vehicles, containers and other cargo’.
Page 7 - 1.2
Who has health and safety duties in relation to stevedoring? – refer to General
Comments section below, regarding use of term ‘hazardous chemicals’.
Page 8 - 1.3
What is required to manage risks associated with stevedoring activities?
Consulting, co-operating and co-ordinating activities with other duty holders
When referring to the Master of a vessel, it is suggested that the reference is to the Master or his
nominated representative.
Reasoning: This is considered necessary, as it is common practice for the Master to assign control of the
vessel to his 2nd Officer or Chief Engineer, particularly when moored.
Page 8 – please refer to General Comments section below, regarding use of term ‘hazardous chemicals’.
Chapter 2: Risk Management
Comments: (Please include section/page numbers).
Page 11 - Table 1 : Hazards associated with stevedoring activities
It is considered that the entries shown in blue text be included in Table 1, as below;
Hazard
Working Environment
Examples of tasks
 Working in holds and on
deck
Stored energy


Hazardous chemicals, including
dangerous goods **
Potential harm
 Possible flammable, corrosive,
or oxygen depleted asphyxiant,
including dust laden
,atmospheres
Pressurised liquids and
gases
Tensioned cable or ropes

Possible cargo spills or leaks
** Please refer to General Comments section below, regarding use of term ‘hazardous chemicals’.
Chapter 3: Planning
Comments: (Please include section/page numbers).
Page 14 – It is considered that 3.1 - Pre-arrival planning, should include reference to planning and
checking the type of cargo gear that may be needed to undertake work tasks. This would also support
the dot point provided on Page 20 under Training Topics relating to - operation of vehicles, other types of
plant and associated equipment.
Page 19 – Who should receive training? – What kind of training is considered acceptable? In house,
watching video, Cert III/IV, an approved course? How would this be articulated?
Chapter 4: Inspections
Comments: (Please include section/page numbers).
Page 22 – 4.1 – Vessel inspections
While the first paragraph refers to ‘equipment and gear’ this section only covers plant inspections and
does not include any advice about ensuring that cargo gear inspections are also carried out prior to their
use. This is considered to be an information gap, the previous Identifying hazards and Assessing risks
sections of Chapter 2, includes reference to cargo gear.
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4.1 – Vessel inspections
While it is understood that contemporary WHS legislation uses the term ‘person in charge’, this section
includes the terms: ‘person in charge’ and ‘designated responsible person’; with no definition or guidance
explaining the meaning of these terms. These terms are also inconsistent with the terminology in
common use in the stevedoring industry and in MO 32. MO 32 includes the terms ‘competent person’ and
‘responsible person’ and defines what those terms mean for the purposes of the order.
To avoid confusion, it is considered that this code should include how the terms ‘person in charge’ and
‘designated responsible person’ relate to the terms, ‘competent person’ and ‘responsible person’, defined
in MO 32.
If the code does not include definitions or guidance explaining the meaning of the terms ‘person in
charge’ and ‘designated responsible person’, AMSA considers that the code would need to define or
provide further guidance on the expectations of the delegated person, relevant to the assigned task or
tasks. Without such clarity, the person in charge has no guidance as to the scope, qualifications or
suitability to be considered of the person they delegate responsibilities to.
Chapter 5: Working Environment
Comments: (Please include section/page numbers).
Page 23 – With regard to the footnote 2: in section 5.1, as below;
5.1
Access and egress
5th dot-point…safe access and egress…where work is in a cargo compartment, that there are two means
of access.2
Editorial change required - the text needs to be amended so that the 2 is shown as superscript to reflect
the reference included at the bottom of the page
The 5th dot-point also includes the term ‘cargo compartment’ whereas MO 32 uses the term ‘cargo
space’. It is considered this inconsistency would create confusion for readers/users.
**Please refer to General Comments section below, regarding references to specific provisions of MO 32.
Chapter 6: Handling Loads and Cargo
Comments: (Please include section/page numbers).
Page 27 – Pre Slung Loads - third dot point, includes the term ‘qualified personnel’ ; whereas
Page 28 – During lashing and unlashing - under Control measures for lashing and unlashing activities
may include:…first dot point, includes the term ‘qualified person’;
It is considered these terms need to be consistent and either defined, or guidance included, to explain
the meaning of the selected term.
Page 30 – 6.3 Working in ship’s holds
Hatches and openings
For hatches and openings that provide access to holds, ensure:
 (third dot point) means of access include a ladder which is clear of the hatchway through which cargo
is loaded or unloaded3
3 Note Marine Order 32, issue 3 - Cargo handling equipment (Schedule 2 Clause 7) sets out the requirement for two means of access for each cargo
compartment in ships built on or after 1 August 1998 (except ships used exclusively as bulk carriers or as cellular container ships).
With regard to the footnote 3, please note that quoting specific references in MO 32 may not be
advisable as these could be subject to change.
Then, under the subheading Ladders;
The dot-points included in the section commencing - When using portable ladders in holds ensure:..
It is considered that these dot-points need to be consistent with the same requirements set out in MO 32.
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Page 32 – The first line includes references to Marine Orders, but there is also a reference to Marine
Orders 35, which appears to be a misprint and should possibly be a reference to Marine Order 32?
Please also note: the change to singular form of ‘Marine Order’ since 1 July 2013.
6.5 Storage and stowage
It is considered this section should include ‘securing’ of cargo, so should be headed; Storage, stowage
and securing, with additional mention of securing, where applicable.
Also, the second dot-point:
 whether goods are classified as hazardous chemicals
** Please refer to General Comments section below, regarding use of term ‘hazardous chemicals’.
Chapter 7: Plant and Equipment
Comments: (Please include section/page numbers).
Page 34 – 7.2 Cranes and workboxes
It is considered that some reference needs to be made to the practice of ‘duel’ or ‘twin lifts' by cranes,
particularly with regard to hazard identification and risk management, even if it refers to another
document for guidance. For example, a reference could also be made to Section 6.4 of the Safe Work
Australia, Code of Practice – Cranes.
Reasoning: This opinion is formed on the basis that AMSA has responded to many queries about twin or
dual lifts; and the same requirements need to be applied whether the cranes are mounted on ships or on
the shore.
Page 34 – Ship-based cranes
The pre-operational inspection should be carried out for ship based cranes to check:…
It is considered that an additional dot-point should be included, to check:
 that ‘emergency escape’ provisions are provided and suitable
Also, in relation to the last paragraph on this page - Please refer to General Comments section below,
regarding references to specific provisions of MO 32.
Page 38 - last sentence re PPE; should a list of standard PPE be provided here?, or possibly as an
Appendix? (i.e. provision of PPE may also require the inclusion of hearing protection)
Chapter 8: Mooring and Unmooring
Comments: (Please include section/page numbers).
Pages 39 and 40 – While AMSA considers the inclusion of Mooring Guidance in this Code to be
worthwhile, further AMSA comment has been provided below in the Comments on specific issues section
below.
APPENDIX B: Example checklist – Vessel inspection – Container operations
Page 43 – AMSA notes that the only reference to a specific physical distance for provision of a clear
space between and at the ends of cargo transport units, occurs on this page as part of:
1. Access / Egress
(9th line down in table ) Working space is clear of all obstructions over a width of at least 550mm.
Comment: It is considered that this reference is fairly obscure, as the only other reference appears to be
on page 23 at 5.1 Access and egress - (4th dot point) and the physical distance is not included there, so
AMSA believes the 550mm should be included in the body of the code, with page 23 considered the
most appropriate place.
Reasoning: This opinion is formed on the basis that AMSA has responded to many queries about such
requirements and it is considered to be a critical part of ensuring a safe workspace/workplace.
General Comments
Comment sought
Comment is sought on whether the guidance in this Code:
 requires additional examples to provide clarification. If so, please provide relevant examples that
you think should be included.
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AMSA comments
It is considered that this Code of practice would benefit from inclusion of a ‘glossary of terms’ or
‘definitions’ section, as there are a number of terms which require clarification to provide certainty for
readers/users of this code.
For example, the Code includes many references to a ‘competent person’, and as included in AMSA’s
comments relating to pages 27 and 28 above, the terms ‘qualified personnel’ and ‘qualified person’ are
also included. Even though on page 38 for ‘qualified person’ the code includes; ‘for example a rigger’,
these terms are not defined anywhere else in the code.
AMSA is seeking clarification as to whether such terms used in this Code, will align with the definitions for
‘competent person’, and /or ‘responsible person’, as included in MO 32?
AMSA considers that this Code of practice could also include a statement that: ‘relevant additional
information and examples can be found in the International Labour Organisation publication: ILO Code of
practice - ‘Safety and health in ports’.
References to Marine Order 32 (MO 32)
Please note; that it is AMSA’s intention to update MO 32 and any quoted specific references to the
current version of MO 32, Issue 3, could be subject to change.
Use of the term ‘hazardous chemicals’
AMSA considers that this term should be amended to: ‘hazardous chemicals including dangerous goods’.
Reasoning: AMSA recognises that Safe Work Australia primarily references the GHS and that there are
many hazardous chemicals that are not classifiable as dangerous goods. However, it should be noted
that dangerous goods can present additional hazards and includes a broader scope than just chemicals,
encompassing dangerous goods articles, which the term hazardous chemicals does not cover.
Comments on specific issues – specific questions can be found in the draft model Code.
Code of Practice or Guide:
AMSA considers that a Model Code of Practice would provide a more robust legal document to support
safe outcomes for managing risks in the stevedoring industry.
Interaction with Marine Orders:
The Safe Work Australia Model Code of Practice, Managing Risks in Stevedoring, will need to be applied
to operate concurrently, but separately to, Marine Orders. This is necessary, as Marine Orders are not
intended to apply Occupational or Workplace Health and Safety (OHS/WHS) provisions for Australian
workers. However, Marine Orders may need to include comparable provisions to apply to ships officers
and crew, including the Master or Captain of the vessel. For example, provision of adequate lighting to a
prescribed safe level.
There should also be no impediment to the replication of the same provisions in both regulatory
documents, as complying with one law should also ensure compliance with the other. For example,
where cargo gear such as cranes or slings are required to bear markings to show evidence of their
capacity and certification, such evidence should ensure compliance with any prescribed requirement.
Additionally, if such requirements are set out in the relevant legislative instrument, in this case the Model
Code of Practice, Managing Risks in Stevedoring, without cross reference to another legislative
instrument not administered by Safe Work Australia i.e. Marine Orders; then any modification to a Marine
Order would not inadvertently affect a provision of the Stevedoring Code of Practice.
It is for these reasons that AMSA has repeatedly included in the specific comments above, that direct
reference to provisions in Marine Orders is not a desirable outcome for ensuring compliance with the
Safe Work Australia Model Code of Practice, Managing Risks in Stevedoring.
Reference to AMSA legislation in the Safe Work Australia Model Code of Practice, Managing
Risks in Stevedoring:
As of 1 July 2013, AMSA’s overarching maritime legislative instrument the Navigation Act was updated
from the 1912 version to the Navigation Act 2012, a copy of which is available at:
http://www.amsa.gov.au/vessels/standards-regulations/nav-act-2012/
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As a result, please note that:
Marine Orders were amended to reflect all references to the new Act and to incorporate contemporary
drafting practices. For instance; inclusion of penalty units relating to offences, references to provisions
are now references to Divisions, Sections, paragraphs and subparagraphs; while Appendices are now
included as Schedules.
An AMSA Fact Sheet explaining the changes is available at:
http://www.amsa.gov.au/forms-and-publications/Fact-Sheets/MOFactSheet.pdf
Most importantly however, the titles of the orders have been amended to the singular form and the
application dates of the orders have been updated. So on that basis, the Safe Work Australia Model
Code of Practice, Managing Risks in Stevedoring will need to amend references to AMSA marine orders
e.g. Marine Order 32 - (Cargo handling equipment) 2011.
Guidance on mooring and unmooring:
As advised above, while AMSA considers the inclusion of Mooring Guidance in this Code to be
worthwhile, it is AMSA’s considered opinion that, Safe Work Australia should undertake a survey to
determine whether stevedores regularly carry out mooring/unmooring duties, or whether those duties are
usually carried out by specialist mooring/unmooring workers. The results of such a survey should then
inform Safe Work Australia’s decision as to whether to include mooring/unmooring provisions in the
Model Stevedoring Code, or to develop separate guidance material.
Regardless of how the requirements are published by Safe Work Australia, it is again AMSA’s considered
opinion that they should reflect the relevant information included in the ILO Code of Practice – Safety and
health in ports, including the provisions for specific training of workers carrying out mooring/unmooring
duties.
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SAFE WORK AUSTRALIA – CONSULTATION REGULATORY IMPACT STATEMENT for
the DRAFT MODEL CODE OF PRACTICE: MANAGING RISKS IN STEVEDORING
Foreword - Page ii – no AMSA comment
Executive Summary - Pages iii and iv – no AMSA comment
Section 1 – Introduction - Page 1 – no AMSA comment
Section 2 – Industry Overview - Page 2
Refers to ‘bulk’ imports and exports but should include reference to packaged
cargoes, as the proposed Model Code of Practice: Managing Risks in Stevedoring,
will predominantly address loading and unloading of packaged cargoes and
package units, as well as bulk cargoes.
AMSA notes that on Page 4 under Codes of Practice, it advises that; ‘There are
currently no approved codes of practice specific to stevedoring under Australian
WHS laws’; and under Guidance material, it advises that; ‘This material was
developed prior to harmonisation of WHS laws, and has been adopted or referenced
by only three of the nine jurisdictions’.
2.1.2 Other marine safety laws - Page 4
Although Marine Orders have a role in ensuring safety, they were never intended to
include Occupational Health and Safety(OHS)/Workplace Health and Safety(WHS)
provisions (see further comment in Section 2.1.3 and Section 3.1 below).
Occupational Health and Safety (Maritime Industry) Act 1993 (the OHS (MI) Act) Page 5
It is considered that this RIS document does not fully explain that while the OHS
(MI) Act has an objective of Occupational Health and Safety, the Act has limited
application in so far as protecting all persons involved in loading and unloading of all
ships at Australian ports. This is because it only applies to certain vessels
(‘prescribed ships’, ‘prescribed units’) and the operators of those ships or units.
2.1.3 Relationship between WHS laws and Marine Orders Part 32 - Pages 5 and 6
As previously advised, although Marine Orders have a role in ensuring safety, they
were never intended to include OHS/WHS provisions. It should be noted however,
that certain aspects of such safety have been included in MO 32, primarily with the
aim of preventing incidents/accidents. As advised in AMSA’s comments relating to
the Model Code, AMSA has already notified Safe Work Australia and members of
the Stevedoring Temporary Advisory Group (TAG) established by Safe Work
Australia, that once mainstream OHS/WHS legislation is in place for stevedores,
AMSA intends reviewing MO 32, with the intention of removing any apparent WHS
provisions. MO 32 is intended to apply only to cargo handling equipment and
associated gear, fitted or located on-board, and for use on-board, when loading or
unloading a ship (further comment is included against Section 3.1 below).
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Section 3 – Statement of the Problem - Page 8
While this section seeks to identify problems resulting in poor safety performance in
the stevedoring industry, and the RIS elsewhere identifies there is a lack of specific
codes of practice (refer 2.1.1 Work Health and Safety laws – Page 4 Codes of Practice) and poor
uptake by jurisdictions of existing guidance for the stevedoring industry (refer Page 4
Guidance material), it neglects to identify there is a lack of legislation specifically aimed
at addressing workplace safety in the stevedoring industry. So while some limited
guidance material is available, there is no specific legislative regime in place to
ensure use of this guidance material.
3.1 - Confusion between the application of WHS laws and Marine Orders - Page 8
It is AMSA’s opinion that confusion amongst industry stakeholders is as a result of
the fact that Marine Orders were never designed to apply to
Occupational/Workplace Safety.
(refer to previous comments against Section 2.1.3 above). AMSA wishes to reiterate that it has
advised Safe Work Australia, including industry and union representatives
participating in the TAG, that once mainstream OHS/WHS legislation is in place for
stevedores, AMSA intends reviewing MO 32 with the intention of removing any
apparent WHS provisions.
3.2 - Quality of existing guidance material – Pages 8 and 9
(refer to AMSA comments above noting statements on page 4 of the RIS relating to Guidance Material)
Question for Public Comment - Page 9
Are there any other issues with the quality of existing guidance which are an
impediment to its application in the stevedoring industry?
AMSA considers that the existing guidance material is fragmented (three separate
publications) and the introduction sections of each document do not advise reading
in conjunction with the other two documents to provide readers with the most
extensive knowledge. It is not clear why three separate guidance documents were
initially developed and published.
AMSA also considers that the ILO publication, Safety and Health in Ports, is a
quality guidance document providing consolidated and comprehensive information.
3.3 – Uptake by jurisdictions - Page 9
Questions for Public Comment - Page 9
Are there any other issues which may affect jurisdictional adoption of existing
guidance material?
How does jurisdictional adoption of guidance affect compliance with safety
requirements in the stevedoring industry?
AMSA considers that to be fully effective, guidance material would need some form
of legislative application and this would need to be provided in a consistent manner
across all jurisdictions.
3.4 – Duty holder compliance - Pages 9 and 10
As explained in this section of the RIS, compliance is currently voluntary and the
extent of business compliance is unknown. On that basis, AMSA would support the
opinion expressed by some other members of the TAG, that a mandatory code of
practice would have better application and uptake than guidance material.
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Section 4 – Objectives of the proposed reform - Page 10
AMSA supports the outlined objectives.
Section 5 – Options to achieve the reform - Pages 11 and 12
Option 1: Retain the status quo
This discussion paper does not identify whether any existing legislative instruments
currently obligate use of the guidance material released in 2009.
Option 2: Updating guidance material on stevedoring
There does not appear to be any real cost saving or additional benefit supporting
this option over option 3.
Option 3: Develop a model Code of Practice
Safe Work Australia has already invested considerable time and effort in developing
a draft model code of practice. With some minor amendment, adoption of this code
would appear to provide the greatest benefits to the stevedoring industry, for the
most reasonable cost outcomes to both industry and the government.
General comment - While section 5.2.3 of the RIS intimates that the shipping
industry is already highly regulated, it neglects to identify that currently, very little
regulation actually targets OHS/WHS safety in the stevedoring industry.
Option 4: Include industry specific provisions in the model WHS Regulations
While this section identifies a current overlap between WHS and maritime
regulation, the remainder if the RIS document does not elaborate on the extent of
any overlap or how this overlap has come into existence. It is acknowledged that
currently Marine Order 32 includes some apparent OHS/WHS provisions, mainly
owing to the absence of other existing provisions under alternative legislation. From
the outset of this process, AMSA has advised Safe Work Australia and the other
industry and union TAG participants, that once suitable WHS safety legislation is
enacted, it will review with an intention of removing any apparent WHS provisions
from its Marine Orders.
Again, reference here to the OHS (MI) Act should include its limited application.
Section 6 – Analysis of expected changes from the reform
6.1 - Overview
AMSA wishes to again emphasise that Marine Orders were never intended to
include OHS/WHS provisions, but were designed to ensure the physical structure of
ships and attached or related cargo handling equipment, e.g. ship-board cranes,
hoists, chains, slings, and other associated gear, are fitted and maintained in a safe
condition for use in cargo loading/unloading operations.
6.2 - Comparison of the draft model Code with existing requirements
Question for Public Comment – Page14
For each of the key components of the draft model Code (listed in Appendix B),
what are the costs and benefits of implementation for you and/or your business?
**Please note, AMSA has included specific comment against the topics included in
the table in Appendix B of the RIS document which has been incorporated below.
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6.2.1 - Training needs analysis and training delivery plans
AMSA can agree that whatever approach to training is finally agreed and adopted
as part of the proposed Model Code of Practice, it should preferably be systematic
rather than ad hoc. Any requisite training should provide a consistent framework, to
ensure industry has a clear basis for developing, delivering, and meeting their
training outcomes. Such a framework will also facilitate compliance auditing by the
regulator.
6.2.2 - Use of hatchmen/cargo space lookouts
Currently, MO 32 includes and will retain provisions requiring use of hatchmen in the
prescribed circumstances. AMSA considers that if the Model Code provisions for
hatchmen are not inconsistent then there should not be any issues.
**AMSA specific comments against the table in Appendix B of the RIS
document.
Key provisions in the draft model Code
and AMSA comments
AMSA comments on expected
impacts.
1. Introduction
Appears to be consistent with current WHS
provisions.
1. - No expected impact for AMSA
2. Risk Management
Model CoP should provide more clarity for
employers and stevedores.
Appears to be consistent with risk
management provisions of MO 32.
2. - No expected impact for AMSA.
3. Planning
Model CoP should provide more clarity for
employers and stevedores, particularly with
regard to shore based planning requirements.
Appears to be consistent with Marine Order
load planning provisions.
3. - AMSA expects that land based
traffic management procedures will
be clearer and may result in safer
loading and unloading operations.
(Noting the RIS document includes statistics
relating to stevedores being struck by moving
vehicles or other objects).
4. Inspections
The Model CoP inspection provisions appear
to be consistent with current Marine Order
provisions’ particularly with regard to ‘plant’
and ancillary cargo gear.
5. The working environment
5.1, 5.2, 5.3, 5.4 - It would appear the Model
CoP requirements will not impact on access
4. - No expected impact for AMSA.
General Comment
Should now ensure that shore
based ‘plant’ and ancillary
equipment is inspected and
certified in a consistent manner to
ship based lifting machinery and
material handling equipment.
5.1, 5.2, 5.3, 5.4 - No expected
impact for AMSA.
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**AMSA specific comments against the table in Appendix B of the RIS
document.
Key provisions in the draft model Code
and AMSA comments
AMSA comments on expected
impacts.
arrangements, lighting provisions or
atmospheres in working spaces as prescribed
in MO 32.
5.5 - The Model CoP will introduce
requirements for considering adverse weather
conditions. While AMSA is aware that such
conditions have been considered for
loading/unloading operations in the past,
these provisions will now be formalised.
5.6 - The Model CoP includes requirements
for consideration of ‘falls’ and ‘falling objects’,
including reference to the separate Safe Work
Australia Falls CoP. MO 32 also includes
specific ‘falls’ provisions.
5.7 - The Model CoP will include requirements
for considering noise management.
5.8 - The Model CoP will introduce
requirements for considering fatigue
management.
5.5 - AMSA does not expect formal
provisions for consideration of
adverse weather conditions to
impact on existing practices, so
again, no expected impact for
AMSA.
5.6 - No expected impact for
AMSA.
5.7 - The Model CoP noise
provisions will cover more
circumstances than current
provisions in MO 32, so will
enhance safety in regard to noise
exposure.
5.8 - The Maritime industry already
strictly monitors working hours
under Standards of Training
Certification and Watchkeeping
(STCW), so no impact is expected
for ship-board workers.
6. Handling loads and cargo
6.1 - Suspended loads
The Model CoP requirements appear to be
consistent with current MO 32 provisions.
6.1 - No expected impact for
AMSA.
6.2 - Lashing and unlashing containers
6.2 - No expected impact for
The Model CoP does not appear to include
AMSA.
any specific requirements in relation to lashing
and unlashing containers, as this work is
carried out on-board a ship, so it would be
expected that MO 32 provisions would prevail.
6.3 - Working in ships’ holds:

Hatches and openings
6.3 - No expected impact for
AMSA.
General comments
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**AMSA specific comments against the table in Appendix B of the RIS
document.
Key provisions in the draft model Code
and AMSA comments
AMSA comments on expected
impacts.


AMSA is aware that Safe Work
Australia is working with industry to
resolve issues with regard to a
perceived need for provisions of
hatchman (lookout), additional to
those specified in MO 32.
Ladders
Monitoring cargo operations
The Model CoP requirements appear to be
consistent with current Marine Order
provisions.
Although the risk of falls into holds
needs to be considered, the
reference here to WHS regulation
78 with regard to managing falls
has been addressed in AMSA’s
response to 5.6 above.
6.4 - Types of cargo:
 General
 Dry bulk
 Liquid bulk
 Containers
 Roll-on/roll-off activities
 Livestock
6.4 - No expected impact for
AMSA.
General comment
The Marine Order references in the
RIS document are not consistent
with the Marine Order references in
the Model CoP. References to MO
42 - Cargo Stowage and Securing,
and MO 44 - Safe Containers, are
not referenced in the RIS
document.
6.5 - Storage and stowage for goods not in
containers
6.5 - No expected impact for
AMSA.
General comment
This column in the RIS document
omits reference to other Marine
Orders covering such work
activities, such as; MO 44 - Safe
Containers, and MO 42 - Cargo
Stowage and Securing, which
contains specific provisions for RoRo vessels which are also included
in the Model CoP.
7. Plant and equipment
7.1 - Powered mobile plant
7.1 - No expected impact for
AMSA.
General comment
Again, this column in the RIS
document omits reference to other
relevant Marine Orders considering
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**AMSA specific comments against the table in Appendix B of the RIS
document.
Key provisions in the draft model Code
and AMSA comments
7.2 - Cranes and work boxes





Ship-based cranes
Shore-based cranes
Adverse weather conditions
Emergency procedures
Crane work boxes
References Marine Orders for requirements
relating to cranes on ships and the model
Code of Practice Cranes for shore-based
cranes.
7.3 - Other lifting equipment
Loose gear
7.4 - Personal protective equipment (PPE)
8. Mooring and unmooring
8.1 - Prior to mooring
8.2 - Mooring
8.3 - Unmooring
AMSA comments on expected
impacts.
such work activities, in particular
MO 42 - Cargo Stowage and
Securing, which contains specific
provisions for Ro-Ro vessels which
are also included in the Model CoP.
7.2 - No expected impact for
AMSA.
(also refer to AMSA comments against 5.5
above)
General comment
AMSA notes that the Stevedoring
Model CoP will refer to a separate
Safe Work Australia, Cranes Code
of Practice, which will apply to
shore-based cranes.
7.3 - No expected impact for
AMSA.
General comment
Again, this column in the RIS
document omits reference to a
separate Safe Work Australia,
Cranes Code of Practice, which will
include provisions for material
handling equipment associated with
shore-based cranes.
7.3 - No expected impact for
AMSA.
8. AMSA does not anticipate any
conflicting impact.
General Comment
Currently each vessel includes
specific mooring and unmooring
procedures in the ship’s
documented Safety Management
System (SMS), required under
International Safety Management
(ISM) provisions of the Safety of
Life at Sea (SOLAS) Convention.
AMSA considers that Safe Work
Australia should provide specific
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Individual/Organisational name: Australian Maritime Safety Authority (AMSA)
**AMSA specific comments against the table in Appendix B of the RIS
document.
Key provisions in the draft model Code
and AMSA comments
AMSA comments on expected
impacts.
requirements for planning and
carrying out safe mooring and
unmooring procedures, when
undertaken by shore-based
personnel. Whether this is included
in this Model Stevedoring CoP, or
as a separate document, is a
matter for Safe Work Australia to
decide.
Section 7 – Anticipated costs and benefits
AMSA is unable to comment on anticipated costs, but anticipates that Safe Work
Australia’s cost benefit analysis will provide an accurate reflection of implementing
the proposed Model Code of Practice.
AMSA would expect that introduction of clear duty based requirements will provide
the stevedoring industry with the following benefits:



a raised awareness of the risks involved in undertaking stevedoring work;
consistent mechanisms for meeting their regulatory obligations; and
result in improved safety outcomes for the industry.
Safe Work Australia has also advised that the proposed code should provide
nationally consistent regulation that will compliment Marine Order provisions
administered by AMSA.
It is anticipated that the introduction of consistent WHS regulation in all jurisdictions,
will also assist industry and regulators in delineating the areas of coverage for land
based and ship based stevedoring operations.
Overall general comment - Clarifying AMSA’s intentions with regard to proposed
review and modification of Marine Orders.
In providing comment on the Safe Work Australia, Consultation RIS and Draft Model
Code of Practice, AMSA has reiterated its proposal to review, with an intention of
removing any apparent WHS provisions from its Marine Orders. However, there will
always be a need for inclusion in Marine Orders, of provisions to allow AMSA to
ensure that safety is paramount to the operation of the Navigation Act and Marine
Orders.
Provided there is no conflict between the requirements of the proposed mandatory
Model Code of Practice – Managing Risks in Stevedoring and the provisions of
AMSA Marine Orders, they should be able to operate concurrently with no
unintended impacts.
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