076 Jemena
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
Appendix A
Appendix A (Definitions) Definitions should at least match ENA DOC 001-2008 and or
ENA NENS 04-2006.
Under the Heading How to use this code of practice (page 5) guidance is given on how
to interpret the words ‘should’, ‘may’, ‘must, ‘requires’ and ‘mandatory’. The use of the
term ‘should’ and ‘may’ throughout the document is in conflict with industry definition.
As above suggest adoption of ENA definitions. There appears to be a need to review
the use in some instances the use of the word ‘should’ particularly when it must be
realised that this Code could be referenced in subsequently produced Regulations and
therefore the requirements outlined in this Code would be legal requirements
Clause 1.3 … Suggest new 6th Dot Point as follows: “Contact Electricity Supply
Authority and comply with any control measures they may specify”;
Clause 1.2 … What is the 2nd sentence in the 3rd paragraph really trying to say.
If we are considered to be an Installer does this mean we may have to defend
building any more Bare Conductor Overhead Electric Lines on Electrical Safety
grounds? What about avoiding damage to our plant and affecting supply
reliability. This could also have an overall impact on Health and Safety.
Suggest re-wording Clause 1.2 to make these points clearer;
2.1
2.1 De-energised (dead) …this Definition conflicts with the ENA DOC 0012008 Definition. We would prefer to see a separate Definition for “Dead” or better still
remove the word “dead” inside the brackets because it does not appear elsewhere in
document;
2.1
2.1 page 11, “Local electricity supply authorities may also have more stringent
requirements. Add “The electricity authority Shall be contacted for further advice
2.1 page 12, second dot point: Reference to recognised training course. What
training course. Recommend that the following training courses are mandated
as a minimum.
UETTDREL04B Working safely Near Live Electrical Apparatus as a new
Electrical Worker.
Workplace Spotting for Service Access (21705Vic)
Construction Industry White Card CPCCOHS1001A
2.1
2.2
2.2 Electrical Part … What about Underground? Suggest delete the word “”insulated”
in this Definition;
2
Clause 2 …. Suggest add words to the end of the 2nd paragraph inside the box:
“or the requirements of any owner of a ‘private electric line’ ”. Are the
Regulations finalised?
Big ask if these are final Regulations.
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In last paragraph where reference is made to “electricity distribution networks”
reference should be made to “electricity distribution and transmission
networks”?
Beginning of last Paragraph suggest change this to read “This code is based on
the principal…” (remove assumption)
2.2
2.2 Table 1.
Recommend adopting option 1 in Issues Paper 2/4/2012
Recommend a specific distance for LV - 1.5m
2.3
2.3 page 13 table 2: These distances are far to close particularly where the
network operator may not know 3rd party are working adjacent to the line/cable.
Recommend adopting table 318 in Victorian Electricity Safety Installations
Regulation 2009 or reference to the appropriate state legislation where these
distances are documented.
Only after consultation and agreement with the electricity supply authority could
these distances be reduced with the use of Permit to Work Authorities and
other controls. Reducing distances would be contingent upon completion of
training and other mitigations previously outlined in this code
2.4
2.4 page 13 second paragraph: end of sentence “…..written approval of the
electricity supply authority” add “and include additional control measures to
restrict the movement of plant, equipment and persons from breaching safe
approach distances”
2.6
2.6: Authorised person: What training course. Recommend that the following
training courses are mandated as a minimum.
UETTDREL04B Working safely Near Live Electrical Apparatus as a none
Electrical Worker,
Workplace Spotting for Service Access (21705Vic)
Construction Industry White Card CPCCOHS1001A.
If all 3 training modules adopted an authorised person could undertake the
safety observer role.
If the Spotter course is removed from the authorised person training then the
authorised person would not be able to be a safety observer.
2.7
Section 3, p17
3.1
3.2
3.3
2.7 Safety Observer: Safety Observer/Spotter.
This function is called a spotter in some jurisdictions and has a particular
training course in Victoria. Recommend training in Workplace Spotting for
Service Access (21705Vic)
Construction Industry White Card CPCCOHS1001A
Safety Observer is a person who is trained and has an understanding of the
work activity being observed (see ENA definition)
Section 3 Intro last dot point page 17. Change to privately owned overhead and or
underground electric lines
3.1 Figure 5. Add underground cable to drawing
3.2 page 18 dot points 12, 13 and 14 “ shall be undertaken in consultation with the
Network Operating authority or the owner of the line
3.3 page 18 first dot point change de-energised to “isolated” and isolating in
remainder of section
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3.3, p19
3.3, p20
3.3, p21
3.4, p22
3.5, p23
3.5,p23
3.5,p25
3.4,p23
4.1,p26
4.1,p27
3.3 page 19 subsection “Substitute the hazard with something safer” 3rd dot
point. This should be re-written as an additional precaution and not a primary
hazard control as the person will still require a permit to work if working in the
NO Go Zone area
3.3 page 20 subsection “Isolate the hazard from the people. Reference to
“appropriately qualified person” What qualification is this referring to
(construction engineer, Qualified OHS Specialist ?
3.3 page 21. Reference to minimum 5m of barriers from the end of the work zone.
Although this is referenced in the AS/NZ 4576 Scaffolds as a requirement, this may not
be achievable due to the weight these covers may have on the conductor and the effect
of the sag impacting on circuit to circuit and circuit to ground clearance particularly on
lighter gauge aerial conductors. Recommend advisory statement only and add “where
practical
3.4 page 22. Sub heading Operators, first dot point, recommend removal. Its not a
supply authorities responsibility to check the effectiveness of the insulation porting of a
mobile plant. Recommend Dot point 3 to end in “and” to capture 4th point as
mandatory for both.
3.5 page 23. Change dot point 1 parra 2 “high voltage electric lines have been deenergised and earthed” to “high voltage electric lines have been isolated and earthed
and” to capture link to 2nd dot point
3,5 page 23 Figure 8 does not clearly show the authorised person zone compared to the
Safety Observer zone. Authorised zone is a area parallel to the exclusion zone
3.5 page 25 2nd para. Recommend removal. Don’t believe this is a supply authorities
responsibility
Clause 3.4 – A crane or operating plant is not operating in a safety observer
zone when; Three dot points follow, however, a safety observer/spotter should
be used under shutdown conditions to ensure of no mechanical damage to the
electrical distributors asset
Clause 4.1 – Managing Risks – An electricity supply authority or the person with
management or control of the electric line should in accordance with
regulations, ensure trees and other vegetation they are responsible for, are
trimmed and other measures taken to prevent contact etc.
Tree Management inside the NGZ - Approval of the Electricity Supply Authority:
Third paragraph regarding ‘authorised persons approved by the electricity
supply authority’ –
It is not the role of the ESA to approve 3rd party workers working in the NGZ.
These authorised persons should only be ESI personal or personal issued with
written approval (PTW) with conditions eg line shutdown
4.2, p28
Clause 4.2 - Identify Hazards – add conductor sway to dot points
4.4, p29
Clause 4.4 - Control Risks – 4th dot point regarding the trimming of trees from
the ground or in the tree that is touching conductors – electricity supply should
not approve ‘safe system of work’ to allow cutting. This should be part of their
training eg councils around LV or through the NGZ PTW system
Clause 4.4 - Minimise Risk – Substitute the hazard with something safer – 2nd
dot point – ‘having someone else perform the work.
If the electric line is the property of the electrical supply authority (ESA), a
request to the ESA should be made to have the work undertaken on behalf of
the customer at the customers expense or via a NGZ Permit To Work
4.4, p29
4.5, p30
Clause 4.5 - Trees or branches contacting energised overhead electric lines –
whether through pruning, storm etc. this section calls for contacting ESA in
situations where damage or outages have occurred.
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Clause 5 - should give consideration for reduced clearance when erecting
scaffold or fall restraint roof scaffolding near insulated service lines with
mechanical protection also use of Industrial grade shadecloth when erected
scaffold clearance from main is greater than regulated clearance to reduce sail
effect of hoarding
5.5, p34
First dot point, 3mm very hard to achieve, suggest 10mm
6
Section 6 should also cover underground cables.
6.1, p36
6.1, last para. Include note. “Note many supply authority assets have
underground earthing systems that may carry dangerous voltage if damaged.
Dial before you dig application shall be considered prior to any excavation”
9
Clause 9 – Electrical risks underground and in buildings – Although
Underground is in the title of this paper there is little reference and it is
proposed by SWA to develop a separate code. We think U/gnd and OH should
be incorporated together.
Definitions
Recommend the use of the standard definitions used by ENA
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
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?
5. Formwork and Falsework
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?
Other comments
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