126 - NSW Nurses Association

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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). General New South Wales Nurses’ Association supports Unions NSW submission in relation to the First Aid Code of Practice, in addition:

 The Code requires more prescription in order to assist PCBUs in their responsibilities under the Work Health and Safety Legislation and Regulations

 Reference to ‘facilities’ is inadequate. Where such arrangements are required as a result of risk assessment these should be dedicated for first aid purposes to ensure they are available at all times when they are needed

 The concept of ‘low-risk’ facilities is a generalisation. Any workplace may become high risk under certain circumstances and therefore a ‘classification’ is not an appropriate way to determine what is and may be needed in the future

 The proximity to medical assistance is a marker of the need for a level of first aid expertise and equipment i.e. where medical assistance is remote, a high degree of first aid personnel training and equipment is essential. Note that it may be feasible to incorporate remote first aid with services such as the Flying Doctor Service which has communication channels available to assist with medical management of casualties, additional to first aid . This should be included as a source of guidance for PCBUs

 There is a clear lack of understanding of first aid in the workplace. First aid personnel are frequently required to address common medical emergencies eg diabetes events, heart attacks, epileptic fits etc. P6 – 2.1 The text suggests that factories, kitchen etc have more need of immediate medical treatment than offices of libraries. This is a good example of where common medical emergencies are not considered. Issues such as an ageing workforce and the stress of the work, plus the possibility of an intruder have not been documented for consideration by the PCBU. P7 - 2.2 An extra dot point should be included to address difficulties in accessing and ill or injured worker eg confined spaces, platforms, barriers such as locked gates etc. P7 -2.2 para 3  Types of emergency facilities should be specified eg emergency showers  Para 3 dot point 4 should add that structural formations such as platforms, gated separations should be considered. P7 2.3 Add issues such as manual handling, not just fatigue to the possible reasons why workers may be injured, particularly where there are reduced staff on particular shifts eg night shift. P8 Once again there is reference to ‘medical treatment’. The relationship between first aid and medical treatment should be defined in the Code. P8 – sections 3 & 3.1 Common medical emergencies should be added to both these clauses. P9 – 3.1 There needs to be some extra guidance in ‘Maintenance since the Code requires first aiders to do some kind of risk assessment on a worker who has been injured. The role of the first aider is expanded by this dot point. A first aider may not be aware of the circumstances of an injury when they perform first aid. This is part of the broader risk management framework. The first aiders role should be defined more Office Use Only Individual/Organisational name: NSW Nurses’ Association 126 What state/ territory are you from? National

clearly as whether they are required to report the details of the first aid treatment or to do an investigation and report on the incident leading to the need for first aid.. P9 – 3.4 The contents of the first aid room or other facility should include equipment and supplies to cater for the first aid of common medical emergencies. P10 – Medical Centres Medical Centres should include equipment such as ‘spills kits’ and other remedies for high risk environments. P11 – Eye wash etc Eye was and shower facilities should be supplied in any workplace where contamination from any source may be identified. Eg a manufacturing environment of any type may have risk of chemical splashes as also the health industry with cytotoxic drug spills, contamination. P11 – Types of first aiders The difference between the various types of first aider is unclear, particularly between the basic and senior first aider. What does ‘appropriate’ first aid mean in this context. The distinction should be clarified. P11 – Training for first aiders Reference should be made to standards of CPR training here eg Australian Resuscitation Council or other recommendations. Training of first aiders for low risk environments should also include their ability and competence to treat common medical emergencies. P14 – Procedures Incorporation of first aid procedures into emergency planning procedures should be recommended rather than suggested, particularly where medical assistance is remote or tardy. ‘You may....’ should be replaced by ‘You should...’ P15 Much of the table related to review of first aid and access assumes that workers will have direct access to first aid kits. Workers should have access to trained first aid personnel, who in turn have access to first aid kits/rooms etc. P16 The first aid and risk management process fails to consider common medical emergencies. These should be factored as a priority. P18 Outdoor modules should also be assessed for factors such as sun exposure and sun screen included where indicated. P18 The remote module should be set up for common medical emergencies eg oral glucose for diabetics, defibrillator or other equipment required by risk assessment P18 The burn injury module should specify that ‘low pressure’ shower hoses are considered to prevent debriding and complication to a burn. P20 The cleaning spills section should introduce an assessment of whether a professional is required to clean a spill in some circumstances.