008-K&S Freighters Pty Ltd

Individual / Organisation name: 008 K&S Freighters Pty Ltd What state/territory are you from? Victoria (however, the organisation operates across multiple states: Qld, NSW, Vic, SA & WA). 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

3. Traffic Management in Workplaces Section/page no. Comment 3.5 Safe Loading K&S were part of an Industry Committee project, known as the LUEZ (Loading, and unloading / Unloading Exclusion Zone) Steering Committee who commenced work in the page 12 or 20. second half of 2009, with the completion and launch of an Industry best practice Guideline – known as LUEZ in February 2011.

The Safe Work Australia draft COP (April 2012) takes no consideration of the Industry best practice principles and/or controls developed that are required to ensure that loading and unloading of vehicles is performed safely. The LUEZ Committee met in April 2012, and agreed for a submission to be made to Safe Work Australia advocating that either the principles and controls of the LUEZ Guidelines be included into the COP or a link / reference made to the LUEZ Guidelines (copy enclosed).

These Guidelines have been endorsed by Industry members, regulators and Monash University Accident Research Centre (MUARC).

3.5 Safe Loading Figure 2 within the Safe Work Australia draft COP (April 2012) is outdated (prior and unloading / to LUEZ project) and does not factor or consider best practice principles and page 13 of 30 controls which were developed as part of LUEZ project.

The figure depicts conflicting messages in respect to best practice principles and controls.

The LUEZ Guideline now defines current “state of knowledge” on this subject.

4. Scaffolding Work

of 2 Individual / Organisation name: 008 K&S Freighters Pty Ltd What state/territory are you from? Victoria (however, the organisation operates across multiple states: Qld, NSW, Vic, SA & WA). Section/page no. Comment

5. Formwork and Falsework Section/page no. Comment

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