019 Department of Mines and Petroleum
Draft model WHS Third Set Codes of Practice - Public Comment Response Form Complete and submit this form by 5PM AEST FRIDAY 22 JUNE 2012 to [email protected]
1. Safe Design, Manufacture, Import and Supply of Plant 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. Working in the Vicinity of Overhead and Underground Electrical Lines 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. Traffic Management in 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?
4. Scaffolding Work Section/page no. Comment 2.3/8 Elimination heading and a suitable example such as using an Elevated Work Platform (EWP) should be added to this section. Often using other plant and/or equipment is a safer alternative than using scaffold equipment. 3.4/14 Figure 1: The picture depicts screw tubes and fixings not used in Australia. The picture and relevant reference to it should be replaced by relevant equipment and information. 3.4/15 Figure 2: Arrows should be added to clarify which is the soleboard and which is the baseplate. 3.4/17 Working platforms – (3rd para) – the statement that ‘These planks generally may (...) the following are met:’ should be deleted. It is not suitable to allow planks to be unsecured specially when used to cover gaps. Loose planks are a major cause of incidents on scaffold specially when pushed and moved around by wheelbarrow and workers.
Figure 3: There are a number of scaffolding members such as ledgers and toeboards missing from the picture. The picture is showing the planks covering the gap is leaning directly on other planks which is not acceptable practice as a supporting platform for planks, especially without the supporting ledger. 4.4/23 Ladders – extension ladders are not allowed to be used for scaffolding access according to the Australian Standards and should be deleted from the COP, although single ladders are ok.
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5.10/35 An additional risk control could be added to the 3rd para, for example: -be maintained and inspected on a regular basis
The COP should refer to AS 2601 (Demolition of Structures) as the standard has specific requirements for scaffold. Appendix B/41 The ‘Description of work activity for licence classes’ is not consistent with the National Standard for Licensing Persons Performing High Risk Work (April 2006). Bits have been added, for example fall arrest systems – for Basic Scaffolding) which could be misinterpreted by the industry and demonstrate inconsistency with the popular National Standard. Appendix F/56 Appendix F title – the scaffold over 4 metres sentence should be replaced, or a note added, explaining that requirements applies not only to scaffold platforms that are over 4 metres but also to scaffolds where persons or objects may fall 4 or more metres. A picture explaining this important concept, where the scaffold platform need not to be 4 metres high to need licence and handover certificate, should be added to the code Suggested -Scaffold tags at every access of the scaffold have been used successfully additions: throughout the industry as an administrative control and verification tool. Tags should be emphasised and encouraged in this code. - Requirements for scaffolders working over water should be included in this code following a recent WA fatality. - More figure, pictures and diagrams should be added to the code depicting work platform access, platforms gaps, pictures of common scaffolding members such as ledger, transom as well as pictures depicting dos and donts. 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? Yes. Engaging engineers to assess scaffold equipment and platforms will add costs although it is justifiable taking into account the safety benefit of a safer scaffold. 5. Formwork and Falsework Section/page no. Comment 3.4/17 The word ‘heave’ should be substituted for a plain English word such as ‘raise’ or ‘lift’. 5.2/23 The statement Trainee scaffolders are permitted to perform (...) by a licensed person.’ on the second paragraph should be deleted. It is not relevant in this section as talks about scaffolders’ training and could be easily misinterpreted. Also, section 6.6 of the National Standard for Licensing Persons Performing High Risk Work (April 2006) has a different definition for ‘Trainee Scaffolder’ requirements as described in the draft COP. 5.5/24 and other Under Formwork false deck, there is reference to ‘stand at heights of two sections metres or more..’. The two metres height threshold should not be used in this COP as it removes the requirement to conduct a risk assessment regardless of the height and it is inconsistent with the WHS Act and Regulations where those requirements were introduced.
Suggested Stripping and lowering of formwork additions: -remove nails and sharp fixings before stacking the components - minimise damage to the components -stack the components of the formwork so that there is no obstruction either to access ways or to work areas -do not throw or drop formwork components from any building or structure.
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? Yes. It seems that, in this draft, a ‘verifier’ and/or an ‘engineer’ are required on a number of
Page 2 of 3 019 Department of Mines and Petroleum occasions while designing and erecting formwork. There are no such prescriptive requirements in WA in those will add extra cost which are justifiable taking into account the safety benefits provided by assigning responsibility and accountability for such hazardous responsibilities. Other comments The National Standard for Licensing Persons Performing High Risk Work (April 2006) should be described within the Formwork and Scaffolding Work COP as licensing work such as rigging, scaffold and dogging is mentioned a number of times within those documents. This could be added to the reference page within both COPs.
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