086-Aurecon Australia Pty Ltd - Safe Work Australia Web viewSubmission to Safe Work Australia24...

Submission to Safe Work Australia24 August 2012 086 Aurecon Australia Pty Ltd

Draft Guide for Tunnelling Work

Submissions to Safe Work Australia on behalf of Aurecon

24 August 2012

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1 About Aurecon

1.1 Aurecon is an international entity that conducts engineering, management and specialist technical services for a variety of public and private sector clients. It has offices across 24 countries, including Australia, and has been engaged in projects in over 80 countries worldwide.

1.2 A specialist aspect of the services offered by Aurecon is the planning, designing and construction of infrastructure and transport systems including roads and railways, which frequently necessitate tunnelling activities and operations.

1.3 Aurecon is committed to maintaining and persistently improving the health and safety of workers. It strives to achieve maximum compliance with its legal obligations and assist in the development of industry specific, guidance material.

1.4 In light of these circumstances, Aurecon respectfully makes the following submissions to Safe Work Australia on the Draft Guide for Tunnelling Work (Guide).

2 Executive Summary of Submissions

2.1 Below is a brief synopsis of primary issues or submissions noted by Aurecon.

2.2 Specific details and references to the Guide are included below in the table setting out our submissions.

3 Language of the Guide

3.1 Aurecon has concern about the mandatory language of the Guide.

3.2 The Guide should primarily include guidance information and issues for duty holders to consider when determining how to comply with their obligations under the WHS Act and Regulations. Mandatory language should only be used to state legislative requirements and where this is done, the legislative requirement should be clearly identified in the Guide.

3.3 Consideration could be given to utilising the approach set out in the Scope and Application of the Codes of Practice regarding the use of language, which explains as follow:

This Code includes references to both mandatory and non-mandatory actions. The references to legal requirements contained in the WHS Act and Regulations are not exhaustive and are included for context only.

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The words ‘must’, ‘requires’ or ‘mandatory’ indicate that legal requirements exist, which must be complied with.

The word ‘should’ indicates a recommended course of action, while ‘may’ indicates an optional course of action.

3.4 Having regard to 3.3 above, we also make the following comments:

(a) the Guide tends to reflect the subject matter and intent of the WHS Act and Regulations, however does not accurately state what the relevant provisions of the WHS Act and Regulations actually say.

(b) there are examples (noted in the response table below) where the word ‘must’ has been used to describe a requirement that is not mandated by the WHS Act or Regulations.

(c) there are examples in the Guide (noted in the response table below) where the word ‘ensure’ or ‘must’ has been used to describe a legislative requirement that is qualified by ‘as far as is reasonably practicable’ but this qualification is not included in the Guide. This means the language of the Guide suggests an absolute rather than a qualified duty and therefore a higher duty than is owed under the WHS Act.

(d) the Guide refers to the term ‘duty holder’ when explaining legislative requirements or recommended actions, though does not provide any clarity as to who the duty holder might be or recognise that different duty holders have different legislative obligations in different circumstances.

(e) the Guide refers to some mandatory requirements in the WHS Regulation without including information as to who has the obligation to fulfil those requirements.

3.5 Any mandated requirement in the WHS Act or Regulations must be clearly identified (in a grey text box) as such in the Guide and accurately state what the legislation requires, including relevant qualifications. The Guide should be amended to reflect the requirements of the WHS Act and/or Regulations as it relates to such matters. Any references to legislative requirements must be clearly identified as such any paraphrasing/interpretation of legislative requirements should be avoided.

3.6 Codes of Practice provide guidance to organisations in how to meet their compliance obligations. Where the Guide refers to requirements in Codes of Practice, the approach outlined in 3.5 above should be adopted, with the appropriate use of language (see 3.3 above).

4 Articulating duties and obligations or providing necessary references

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4.1 Aurecon considers that any parts of the Guide that purport to describe legislative requirements need to be reviewed and redrafted to ensure legislative requirements are not paraphrased or interpreted. As indicated above, legislative requirements should be clearly identified (in a grey text box) and accurately state what the legislation requires.

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5 Importance of clarifying terms used

5.1 An opportunity exists to make a number of amendments and/or additions to dictionary section of the Appendix in the Guide to assist with the understanding and/or interpretation of the Guide. These are outlined in the response table below.

6 References to Guidance Material and Academic References

6.1 The Guide should include reference to all relevant Codes of Practice applicable to the interpretation of the Guide.

6.2 Guidance material in its nature should be more limited, do not include excessive detail and, only provide practical guidance using widely accepted industry practice.

7 The Submissions

Draft Guide for Tunnelling Work Colour coded text has been adopted in this submission with the following meanings:Key:

Submission to insert into GuideSubmission to delete from GuideSubmission to amend in Guide

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Section of Guide

Page Reference: Comment:

Foreword N/A

(inserted before page 5)

As provided for in the relevant codes of practice, a foreword should be included to qualify and clarify the terminology utilised. For example, the following section should be included with a sub-heading and words to the following effect

How to use this Guide

In providing guidance, the word ‘should’ is used in the Guide to indicate a recommended course of action, while ‘may’ is used to indicate an optional course of action.

This Guide also includes various references to provisions the relevant WHS Acts, Regulations and Codes of Practice which set out legal requirements. These references are not exhaustive and all duty holders should take proactive steps to familiarise themselves with the legislative obligations applicable in their circumstances.

The words ‘must’, ‘require’ or ‘mandatory’ indicates that a legal requirement exists and may be applicable in the particular circumstances.

2.

Planning and Preparation

Page 7 At the commencement of this section, include a reference to the applicable primary and general duties regarding the design of structures under the WHS Act, including sections 19 and 22. A reference to the Safe Design of Structures Code of Practice should also be included.

It is proposed that these items be addressed in a separate text box at the commencement of the section, to identify the applicable general and specific duties that should be considered when using or having reference to the Guide. An example of this approach is detailed below at schedules 1 and 2.

Under heading 2.1 – Responsibilities of Duty Holders – Design stage, a comprehensive summary is included regarding the obligations for designers, however does not include the same level of detail for Principal Contractors in this context. An equivalent level of detail regarding the obligations for Principal Contractors should be included consistent with the obligations in the WHS Act and Regulations.

Consideration should also be given to the inclusion of recommendations actions for Principal Contractors

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during the design stage, including that they are responsible for the design review for construction and should provide feedback to the designer regarding construction requirements.

Aurecon submits that the following paragraphs should be included as recommended actions for Principal Contractors:

‘The Principal Contractor should review the design for construction and advise the designer where construction amendments are required. In addition, the Principal Contractor should review the design for construction and advise the designer immediately if, in their opinion, the design cannot be constructed safely.

However, the Principal Contractor should not amend the tunnel design itself including ground support but instead request any amendments/modifications to the design from the designer’.

We note the following terminology contained in the Guide:

‘The principal contractor must ensure that a workplace-specific WHS Management Plan is prepared and documented for the project before work commences’.

This provision relates to requirements under the WHS Regulations. The WHS Regulations do not state that the WHS Management Plan be documented. As the requirement outlined in the Guide is not the legislated requirement it is not appropriate to use the language of ‘must’. Alternatively, the Guide should be amended to reflect the requirements of the WHS Regulations as they relate to this matter.

We note that under the sub-heading Designers, the following terminology is used:

‘Designers must ensure that……’;

‘Designers must also ensure that hazards associated with the following are identified before commencing construction work’; and

‘…The designer must ensure that information is included with the design information to alert others to the risk’

‘The designer must give adequate information to the PCBU that commissions the design regarding the results

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of any calculations, analysis, testing or examination that were necessary to ensure the design is without risks to health and safety…’.

Any references to legislative requirements must be clearly identified as such in a text box. Any paraphrasing and/or interpretation of legislative requirements should be avoided. The Guide should be amended to reflect the requirements of the WHS Act as they relate to the above matters, including relevant qualifications. For example, under the WHS Act the obligation to ensure any plant or structure is designed for safe erection, use, repair, cleaning, maintenance and demolishing so the health and safety of any person is not put at risk is qualified by so far as is reasonably practicable.

Further, the requirement to provide information regarding the results of calculations, analysis, testing or examination extends to a requirement to provide that information to any person who is provided the design, i.e it is not limited to the person commissioning the design as stated in the Guide.

Under the sub-heading ‘Designers’, at paragraph 1, dot point 1, reference is made to a requirement for designers to ensure (so far as is reasonably practicable - as submitted above) the design so the health and safety of persons are not put at risk when demolishing the plant or structure.

This requirement appears to come from buildings constructed above ground and clarification is required as to how this can be transferred to an underground construction environment. Demolition of tunnel linings would not ordinarily be considered feasible as part of the life-cycle of a tunnel as demolition of the tunnel lining may cause the surrounding ground to collapse. De-commissioning of a tunnel, depending on size, might more often entail filling or grouting up of the tunnel. Aurecon submits that de-commissioning of a tunnel would more accurately describe the activity to be undertaken.

At paragraph 1, dot point 2, it is stated that:

Designers must ensure that:

Information is provided to the person conducting a business or undertaking that commissions the construction work about the health and safety aspects of the design.

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The obligation under the WHS Regulation requires a designer to provide a safety report to a person who commissions a design which specifies the hazards relating to the design of the structure that, so far as the designer is reasonably aware, creates a risk to the health and safety of persons who are to carry out any construction work on the structure or part and are associated only with the particular design and not with other designs of the same type of structure.

Any references to legislative requirements must be clearly identified as such in a text box. Any paraphrasing and/or interpretation of legislative requirements should be avoided. The Guide should be amended to reflect the requirements of the WHS Regulations as they relate to this matter, including relevant qualifications.

At paragraph 2, dot point 2, reference is made to a requirement for designers to ensure that hazards associated with systems of work required to erect, repair, clean and maintain the structure are identified before commencing construction work. The systems of work utilised to build and maintain a structure are often the responsibility of the Principal Contractor, i.e. the Designer does not always design how a structure is built or what machines etc are to be used. This should be reflected in the Guide.

At paragraph 3, an obligation is imposed upon the PCBU, where there is more than one designer, to ensure critical aspects of the project are documented to facilitate consultation, cooperation and coordination between the designers. Further clarity should be required as to who the intended PCBU is being referred to.

Firstly, it is unclear which ‘PCBU’ this obligation is sought to be imposed upon. Secondly, the word ‘ensure’ is being used to describe a requirement that is not mandated by the WHS Act or Regulations in the manner currently stated. The obligation to consult, cooperate and coordinate activities is upon each person who has a duty in relation to the matter under the WHS Act.

We reiterate our submission above regarding the use of language ‘should’ for a recommended course of

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action or ‘may’ for an optional course of action.

2.1

Responsibilities of duty holders – design process

(Workplace Investigation)

Page 9 Under the sub-heading ‘Workplace Investigation’, at paragraph one, dot point three (at the top of page 9), the reference to ‘Underground and structural survey’ should be amended to state ‘Geotechnical / structural instrumentation and monitoring’.

At paragraph 2, dot point 8, the reference to ‘Likely scale and nature of the ground (eg/ movement)’ should be amended to state ‘Likely scale and nature of the ground behaviour including movement’.

Under the sub-heading ‘Tunnel Design’, at paragraph 2, dot point 2, reference is made to ‘final support and lining requirements for each location within the tunnel’.

It is not always possible to determine the final support and lining requirements for each location within a tunnel. For example, for tunnels at great depth where surface investigations are not possible, the design needs to rely on geological interpretations sometimes based on surface mapping only. In this case, a percentage distribution of anticipated design types would have to be used instead of determining a final support and lining requirements for each ground type anticipated within the tunnel.

Aurecon submits that additional dot-points should be inserted as follows:

Specify limitations for the installation of support elements within the excavation cycle (such as maximum and minimum distances from the tunnel face).

Temporary supports if applicable in the circumstances.

2.2

Design for safe tunnel construction

(Design review for construction)

Under the sub-heading ‘Design review for construction’ (see paragraph 1 on page 10), the following additional paragraphs should be inserted:

‘The Principal Contractor should review the design for construction and advise the designer where construction amendments are required. In addition, the Principal Contractor should review the design for construction and advise the designer immediately if, in their opinion, the design cannot be constructed safely.

However, the Principal Contractor should not amend the tunnel design itself including ground support but

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instead request any amendments/modifications to the design from the designer’.

At paragraph 1, reference is made to concept designs being produced during the design review process which may include the ventilation, construction electrical and materials handling systems. These designs are ordinarily undertaken by a Contractor and not the tunnel designer and would not ordinarily be produced during the design review process being contemplated in this section of the Guide. We recommend that these designs, produced by the appropriate parties, are inputs into the ‘Design review for construction’ as opposed to outputs of the review.

2.2


(Ground support design)

Page 10 Under the sub-heading ‘Ground support design’, at paragraph 3, reference is made to the term ‘unsupported ground’. Clarification should be provided as to the definition of this term to assist in the interpretation of the Guide. This is important because man access should not be permitted under unsupported ground. For example, is ground only deemed supported when the required support design has been installed in full, or can partial installation (i.e. rock bolts and initial layer of shotcrete) provide adequate temporary roof support? The term ‘unsupported ground’ should be defined, a suggesed definition is provided in Appendix A (See below).

At paragraph 4, reference is made to the term ‘temporary ground support’ which is described as a potential alternative to overhead protection.

Overhead protection should be considered to safeguard against any residual risks. It should not be seen as a mere alternative. This applies to areas where support is manually installed irrespective of whether or not the support is temporary or permanent.

For example, where temporary bolting is conducted manually, overhead protection for the installer should be provided regardless.

It is recommended that the paragraph be re-phrased and amended to remove phrasing that suggests that overhead protection may only be required as an alternative means of protection.

2.2 Pages 10 and 11 Under the sub-heading ‘Inspection Plans’, in paragraph 1 (on page 10), the following terminology is used:

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(Inspection Plans)

‘Risks from falling objects that are reasonably likely to injure a person must be managed’.

Any references to legislative requirements must be clearly identified as such in a text box. Any paraphrasing and/or interpretation of legislative requirements should be avoided. The Guide should be amended to reflect the requirements of the WHS Regulations as they relate to the above matters, including relevant qualifications.

An additional paragraph should be included which requires that Inspection Plans are developed in collaboration between the PCBU and Principal Contractor. Further, the Principal Contractor should be required to inspect and confirm that all support elements have been installed in accordance with the design and corresponding construction sequences.

A suggested paragraph is outlined below:

‘Inspection Plans should be developed in collaboration between the person conducting a business and undertaking and the Principal Contractor. In addition, the Inspection Plans should include a section for the Principal Contractor to confirm that all support elements have been installed in accordance with the design specifications and the corresponding construction sequences.’

It is noted the observational method is not always a suitable risk mitigation measure in tunnels. Having regard to the Eurocode 7 – Geotechnical Design 2.6 Observational method which states:

‘the observational method should not be used where a sudden collapse could occur without warning, such as when ground and the interaction between ground and structure are not sufficiently ductile (brittle behaviour).

Such conditions for example exist in rock tunnels where high stress fields combined with rock mass defects can result in bursting failures. In addition, often issues not visible from within underground excavation are most critical to determine support stability, such as proximity to basements, utilities or other natural or manmade features. It is therefore critical to consider what cannot be seen from within the tunnel.

Based on the above, the following should also be inserted as additional dot-points in the list of information

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to be included in an Inspection Plan (paragraph 3 on page 11):

the potential for sudden failure modes to develop within the tunnel.

proximity to adjacent structures including building basements, services and utilities.

results of surface settlement monitoring.

Finally, at paragraph 2 on page 11, reference is made to the review of Inspection Plans ‘after adverse weather conditions’. Clarification is required as to what constitutes adverse weather conditions that will influence underground work. We suggest this may be heavy rain events which has the potential to increase groundwater levels and/or groundwater inflows into a tunnel.

2.3

Workplace specific planning and preparation

(Communication systems)

Page 11 Under sub-headings ‘Workplace specific planning and preparation’ and ‘communication systems’, at paragraph 2, it is stated that:

‘The communication system should be used to link major workplaces, tunnel portal and face(s), or shaft top and bottom, site offices and safety critical locations on-site’.

This requirement should be amended state that communication systems should also link other confined spaces such as smoke ducts or conduit passages.

Page 12 Under the sub-heading ‘Workplace Facilities’, at paragraph 1, it states:

‘The regulation requires that principal contractors ensure that appropriate amenities are available for workers’.

We note that this aspect appears to be referring to the obligations and specifications under part 3.2 of the WHS Regulations. This regulation specifies particular requirements regarding workplace management and the management of facilities.

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Any references to legislative requirements must be clearly identified as such in a text box. Any paraphrasing and/or interpretation of legislative requirements should be avoided. The Guide should be amended to reflect the requirements of the WHS Regulations as they relate to the above matters, including relevant qualifications. For example, the obligation under the WHS Regulations is upon PCBU’s, not Principal contractors and is qualified by so far as is reasonably practicable. Consider also including reference to the applicable Code of Practice for further guidance.

Page 13 A reference to the ‘Managing the Work Environment and Facilities Code of Practice should be inserted immediately prior to the sub-heading ‘Personal Protective Equipment’. This is desirable to emphasise the duties and necessary steps that a duty holder should strive to implement in relation to Workplace Facilities.

It is proposed this reference be included in a separate text box to emphasise an additional, useful resource to assist in compliance. An example of this proposed insertion is detailed below at schedule 2.

2.3


(Personal protective equipment)

Under the sub-heading ‘Respiratory protective equipment’ the following terminology is used:

‘Persons using respiratory protective equipment must be provided with information, instruction and training……’.

We note that this aspect appears to be referring to the obligations under clauses 39 and/or 44 of the WHS Regulations relating to the provision of information, training and instruction.

Any mandated requirement in the WHS Act or Regulations must be clearly identified (in a grey text box) as such in the Guide and accurately state what the legislation requires, including relevant qualifications. The Guide should be amended to reflect the requirements of the WHS Act and/or Regulations as it relates to such matters. Any references to legislative requirements must be clearly identified as such any paraphrasing/interpretation of legislative requirements should be avoided.

Further, at bullet point 2, titled ‘Safety helmets’, safety helmets plus cap lamps should be detailed as personal protective equipment that is mandatory in underground construction as there is always the

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potential and risk of injury of falling objects.

2.3


(First aid and emergency plans)

Under the sub-heading ‘First aid and emergency plans’ there is a reference to the Code of Practice: First Aid in the Workplace.

It is proposed this reference be included in a separate text box to emphasise an additional, useful resource to assist in compliance. An example of this proposed insertion is detailed below at schedule 2.

Page 16 Under the sub-heading ‘First aid and emergency plans’ there are numerous references regarding what a PCBU ‘must’ do.

This statement appears to be referring to the obligations under Clauses 42 and/or 43 of the WHS Regulations relating to the provision of first aid and preparation, maintenance and implementation of emergency plans.

Any mandated requirement in the WHS Act or Regulations must be clearly identified (in a grey text box) as such in the Guide and accurately state what the legislation requires, including relevant qualifications. The Guide should be amended to reflect the requirements of the WHS Act and/or Regulations as it relates to such matters. Any references to legislative requirements must be clearly identified as such any paraphrasing/interpretation of legislative requirements should be avoided. An example of this submission in an analogous context is detailed below at schedule 1.

It is proposed the reference to the Code of Practice be included in a separate text box to emphasise an additional, useful resource to assist in compliance. An example of this proposed insertion is detailed below at schedule 2.

2.3 Page 17 Under the sub-heading ‘Fire and Explosion’ the initial sentence states:

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(Fire and explosion)

‘The person conducting a business or undertaking and principal contractor have a duty to control risks associated with fire and explosion’

This statement appears to be referring to the obligations under Clauses 70 to 74 of the WHS Regulations relating to issues regarding combustion or hazardous vapours.


2.3


(Existing services)

Page 19 Under the sub-heading ‘Existing Services’ it is stated that:

‘Before excavation work is to be performed, the location of any underground services, such as gas, water, sewer, electricity and telecommunication cables, must be identified by the principal contractor’.

This statement appears to be referring to the obligations under Clauses 304 and/or 305 of the WHS Regulations relating to excavation work.

Any mandated requirement in the WHS Act or Regulations must be clearly identified (in a grey text box) as such in the Guide and accurately state what the legislation requires, including relevant qualifications. The Guide should be amended to reflect the requirements of the WHS Act and/or Regulations as it relates to such matters. Any references to legislative requirements must be clearly identified as such any paraphrasing/interpretation of legislative requirements should be avoided. For example, the reference to Principal Contractor in this context is not included in the WHS Regulations the obligation is upon a person with management or control of a workplace.

2.3 Page 21 Under the sub-heading ‘Workplace Security’ it is stated that:

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(Workplace security)

‘The workplace must be secured, so far as is reasonably practicable, from unauthorised access’’.

This statement appears to be a reference to the obligations under Clause 298 of the WHS Regulations. These regulations pertain to security of workplace.


2.3


(Identification and location of persons in tunnel)

Page 22 Under the sub-heading ‘Identification and Location of Persons in the Tunnel’ there are references regarding what a PCBU ‘must’ do.

This information appears to be referring to the obligations under Clause 48 of the WHS Regulations relating remote or isolated work.


3. Risk controls in excavation methods

Page 23 At the commencement of this section, reference should be included to the applicable duties and responsibilities regarding excavation work (Part 6, Division 3 of WHS Regulation) and a reference to the Excavation Work Code of Practice.

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These items should be addressed in a separate text box at the commencement of the section, to again, emphasise the applicable general duties that should be considered when using or having reference to the Guide. An example of this submission in an analogous context is detailed below at schedule 1 and 2.

3.5

Inspections and scaling

Page 25 Under subheading ‘3.5 Inspections and Scaling’ the term ‘unlined tunnel’ is used. This term should be defined at Appendix A (See below) as it is unclear what type of tunnels or structures are intended to be covered by this terminology. For example, what is the difference between an unlined and unsupported tunnel.

Further, an additional paragraph should be inserted below the dot-points contained at paragraph 3 under the subheading ‘3.5 Inspections and Scaling’ which states as follows:

‘Where hand scaling is used it should be from an elevated work platform (Basket). Where hand scaling is undertaken from beneath partially completed support, the basket shall be fitted with adequate overhead protection to safeguard the workforce from potentially falling rocks. In addition, ground support, where required, should always be installed immediately following inspection and scaling, without delay ’

3.6

Ground support controls

Page 26 Under sub-heading ‘3.6 Ground Support Controls’, at paragraph 1, reference is made to ‘this may be followed by the installation of a non-structural secondary lining’. Secondary linings are structural even if support is only provided to its self-weight. Consideration should be given to defining the term ‘non-structural secondary lining’ to provide clarity. The term ‘non-structural lining’ should be defined at Appendix A (See below).

At paragraph 4, reference is made to the installation of ground support from supported areas or using equipment which provides overhead protection for the operator or installer. Further it is stated that:

‘Where this is not possible, control measures should be implemented to avoid ground or materials (eg/ shotcrete) falling on people’

Apart from access isolation no other control measures can be as effective in providing protection as overhead support on that basis it should be mandatory in the circumstances identified above. The requirement should be amended to remove the initial words so that it reads as follows:

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‘Where this is not possible, Control measures should be implemented to avoid ground or materials (eg/ shotcrete) falling on people’.

4.0

Risk controls in specialist construction methods and activities

Page 27 At the commencement of this section, include reference to the applicable duties and responsibilities regarding construction work (Section 26 of the WHS Act and Chapter 6 of the WHS Regulation) and a reference to the Construction Work Code of Practice.

These items should be addressed in a separate text box at the commencement of the section, to again, emphasise the applicable general duties that should be considered when using or having reference to the Guide. An example of this submission in an analogous context is detailed below at schedule 1.

5.

Air quality and ventilation systems

Page 31 At the commencement of this section, include reference to the applicable duties and responsibilities regarding the relevant issues contained in this section, namely hazardous contaminants, monitoring air quality, hazardous atmospheres. (Part 3, Divisions 7 & 8 of WHS Regulation).


Appendix C

Ventilation systems

Page 32 Reference to Appendix C is not readily apparent and there is potential for its reference to be overlooked. Consideration should be given to including an additional subheading ‘Ventilation Systems’, where the content for the section can be an appropriate cross reference to the Appendix for information.

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Plant related risks

Page 39 It is recommended that the reference to the Code of Practice: Managing Risks of Plant in the Workplace be moved to the top and commencement of this section (as with the other sections). In addition, there should be a reference to the applicable duties and responsibilities regarding the relevant issues contained in this section, namely risks associated with Plant, being sections 22, 25 and 26 of WHS Act. We note that Regulations 59, 61, 64, 70 and Chapter 5 of WHS Regulation may also be relevant however, these items

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are routinely referred to in the Code of Practice, which may sufficiently reference the applicable duties and responsibilities in this regard.


6.9

Specialist plant

Page 42 Under the sub-heading ‘Specialist Plant’, heading ‘Shotcrete rigs, jumbos, road headers, TBMs and electric tunnel muckers’, significant issues are identified regarding specialist plant (shotcrete rigs and road headers) which include (under dot point 1):

‘avoiding standing under unsupported ground unless protected by overhead protection’.

Not all specialist plant are fitted with overhead protection, for example road headers. Such equipment is often controlled via remote controls from the deck of the machine which requires the operator to step outside the protection of the operator’s cabin. Also, in circumstances of manual bolting from the deck of the road header, the standard overhead protection fitted by manufacturers is often insufficient. Overhead protection should therefore be provided to the work area, as opposed to being limited to the area defined by the operator’s cabin of a particular type of equipment. As a result, overhead protection equipment may need to be retro-fitted to existing equipment prior to use in construction.

Consider whether a definition could be included of overhead protection (at Appendix A) which has regard to the protection provided by the work area as opposed to the type of equipment.

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Other tunnelling risks

(Hazardous chemicals)

Page 44 Under the sub-heading ‘Hazardous Chemicals’ include a reference to the applicable provision(s) of the WHS Regulation, in this instance, Part 7.1.

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(Electrical safety)

Page 46 Under the sub-heading ‘Electrical Safety’ include a reference to the applicable provision(s) of the WHS Regulation, in this instance, Part 4.7.

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(Falls from heights)

Page 48 At the commencement of this section, it is submitted that there should be a reference to Code of Practice relating to the Managing of the Risk of Falls at Workplaces.

This item should be addressed in a separate text box at the commencement of the section, to again, emphasise the applicable general duties that should be considered when using or having reference to the Guide. An example of this submission in an analogous context is detailed below at schedule 2.

Under the sub-heading ‘Falls from heights’ include a reference to the applicable provision(s) of the WHS Regulation, in this instance, Part 4.4.


Page 49 Under the sub-heading ‘Falling Objects’ should a reference to the applicable provision(s) of the WHS Regulation, in this instance, clauses 54 and 55.


Appendix A Definitions

Page 52 The terminology ‘Person conducting a business or undertaking’ is used throughout the Guide and a definition should be included at Appendix A in accordance with the WHS Act.

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The terminology ‘Principal contractor’ is used throughout the Guide and a definition should be included at Appendix A in accordance with the WHS Regulations.

A definition of ‘unsupported ground’ should be included within the Guide and a definition should be included at Appendix A. A suggested definition for consideration is as follows:

:

Ground that is not, through its own strength and additional support provided, able to remain stable at both the small scale and large scale for the required time.

A definition of ‘unlined tunnel’ should be included within the Guide and a definition should be included at Appendix A. A suggested definition for consideration is as follows:

Areas of ground exposed by recent excavation and which are not, at the time of inspection, obscured by ground support.

A definition of ‘non-structural lining’ should be included within the Guide and a definition should be included at Appendix A.

Appendix E

Other useful resources

Page 59 A sub-section should be included which includes references to applicable Codes of Practice’ relevant to interpretation of the Guide and where copies may be obtained from.

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SCHEDULE 1

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SCHEDULE 2

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