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Model Work Health and Safety Codes of Practice - Public Comment Response Form
1) Safe Design Of Building and Structures
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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) Excavation Work
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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) Demolition Work
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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) Spray Painting and Powder Coating
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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) Abrasive Blasting
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
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6) Welding and Allied Processes
Comments due by Friday, 16 December 2011
Comments:
Marketing of a product in legislative documents is illegal
according to the competition watchdog (ACCC) in Australia.
Table 2: Procedures to reduce the risk of electric shock. Pg 11
“Use a voltage reducing device to reduce the open circuit voltages to a safe level”.
Reduction to how much? What is a safe level? The answer to that lies in the electrician’s golden
rule: “test for dead”, meaning zero volts is the only safe level.
This statement must be deleted as it specifies a product (VRD) not a process. Any Standards or
CoP must describe a function/process and not name/market a specific device; therefore the
statement must say “Use an isolation switching system to eliminate the open circuit voltage or a
hazard control device to reduce the risk”
This is further emphasised in Standards AS 60974.1-2006 Arc welding equipment.
“Welding power sources, which are electronically controlled, shall be; fitted with a
protection system, which switches off the voltage at the output terminals within 0.3 secs
and shall not be reset automatically”
Also stated in this CoP; Part 2.3 – Control the risks, there is a ‘hierarchy of risk control’, which
states that the 1st step is to “eliminate the risk” and if this cannot be done in a practical manner
then the next step is to “minimise the risk”.
No safety device exists or will there ever be one invented to fully protect the boilermaker from
electrocution during the welding process where voltages of 20-40 volts exist all the time. Only
the use of Personal Protection Equipment such as dry gloves and uniforms, rubber mats/boots,
etc can minimise the electrocution hazard.
Why a voltage reducing device (VRD) is not the safest option for boilermakers
The Voltage Reducing Device (VRD) is a 35 year old technology that was developed in South
Africa. For two years it was introduced to South Korea but was dropped, as it was not a
workable safety device. Now it is used in Australia and still does not live up to expectations with
it being a costly exercise to the welding industry and approximately 80% are bypassed. The
world welding industry does not accept the VRD technology as it goes against the welding
norm. Why reduce the voltage when full voltage, around 95V, is required to start an arc. This
system is defective and creates more of a hazard to the boilermaker then a welding machine
without one installed.
Attached is a summary of the negative benefits a Voltage reducing device brings to the welding
industry.
Also attached is an opinion from South Africa by a company using Voltage reducing devices.
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If newer technology exists and is available then why can’t it be recommended? This goes against
AS 4024.1201-2006: Safety of machinery; section 6 where it states “a machine design, which is
acceptable at a particular time, may no longer be justifiable when technological development
allows the design of an equivalent machine with lower risk”
According to Ohm’s law, fundamental electrical calculation, the use of a voltage reduction
device in welding presents a high chance of being electrocuted. The lowest voltage level for a
VRD is 12 Volts but this can sometimes be as high as 30V or full 113 V OCV. While the
resistance to activate the output needs to be less than 200 Ohms. Using these figures in Ohm’s
law it will become clear what currents can flow through a person and why it is not a safe device.
(This is 2x to 6x more than RCDs and VRD never switch off welding
output in 0.3 sec)
(This is 5x to 15x more than RCDs and VRD never switch off welding
output in 0.3 secs)
The trip calibration of safety switches (RCD) in hospitals is 10mA while in domestic areas it is
30mA and they are designed to switch off in 0.3 seconds and remain off until reset manually.
VRDs on the other hand reset automatically and the user is unsure whether the output welding
voltage has been safely reduced or not.
The attached OH&S article mentions about electric shocks in welding and says “Currents of
approximately six milliamperes (6 mA) can be enough to cause death in some instances”. It also
mentions that “As a general rule, remind workers to turn the equipment off when not in use”.
The voltage reducing device is a device that can be used only in Category A welding
environments, where the boilermaker is never part of the welding circuit and will never be
electrocuted anyway.
The following educational link is a basic explanation of how electrocution can occur
http://www.youtube.com/watch?v=rN3QhtnlCSw&feature=youtube_gdata_player
Why is the VRD used on stick welding only? What about all other welding processes Tig, Mig,
Plasma or the gouging process which is more dangerous than stick welding.
Summary
I would like to request that all references to the VRD word be removed from this and other
related documents, such as Tech. Notes 7, 22 and AS 1674.2:2007, to allow industry a selection
of devices so that companies might make their own choice with regards to the level of protection
and safety that they seek.
Tech notes 7, 22 must be reviewed publicly for comments before being accepted as a reference
guide to the CoP -2012.
To date, previous editions of Tech note 7, 22 and WTIA bulletins have been used as advertising
material to promote VRDs for welding businesses and not for the safety or benefits of users as it
discriminates against other systems and technology.
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Below are the changes I would like to be seen done in this CoP
Table 2: Procedures to reduce the risk of electric shock. Pg 11
Delete – “Use a voltage reducing device to reduce the open circuit voltages to a safe level”.
Add – “Use an isolation switching system to eliminate the open circuit voltage or a hazard
control device to reduce the risk”
Following from procedure “Do not change electrodes with bare, perspiring hands or touch either
the bench or the work piece”, I would like to include a procedure that must say “Confirmation of
safe welder output shall be confirmed by placing electrode on the workplace before changing
electrode”.
Appendix B of the CoP. Pg 26
I strongly recommend that the AS 60974.1 - 2006 Standard be referenced in Appendix B in this
CoP.
Also AS4024.1 – 2006 has not been mentioned as it has relevant material in regards to confined
spaces, machinery, barriers and other information related to safety equipment.
Figure 1. Pg 21
The figure in question, what is it actually representing? Is the observer switching off the fume
hood with the main switch or is he turning off the welder?



Change the picture so it only shows the fume hood, as that is the topic concerned.
Change the picture to properly show the main switch switching the power off to the fume
hood and/or welder.
Change the caption to address the true nature of the figure.
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?
7) Safe Access in Tree Trimming and Arboriculture
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
8) Preventing and Managing Fatigue in the Workplace
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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?
Individual/Organisational name: ZRID Pty Ltd
What state/ territory are you from?
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9) Preventing and Responding to Workplace Bullying
Comments due by Friday, 16 December 2011
Comments: (Please include section/page numbers).
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