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Model Work Health and Safety Regulations and
Codes of Practice Public Comment Response Form
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management
Part 3.1 General working environment
Individual/Organisational name: Victorian Volume Home Builders safety Alliance (VVHBSA)
Section A: Model Work Health and Safety Regulations Exposure Draft
General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements)
No comment
Chapter 1: Preliminary (e.g. definitions)
VVHBSA raises concern in relation to the definition of the term “Person Conducting Business or
Undertaking” (PCBU). The term may be confused with “Principle Contractor “ (PC) which now is defined as
Person with management and control of the workplace.
VVHBSA requests that there be clearer definitions regarding PCBUs to include Employers who also employ
contractors and subcontractors in their own right who then undertake work for a PC or PCBU. The shared
duty of care and responsibilities to apply to all Employers.
The relationship between PCs and suppliers/trades had been particularly problematic in
Victoria
since the introduction of similar legislation in 2007. Regulators appear to be of the
opinion that the only entity with responsibilities on construction sites is the PC. In most
cases where suppliers and trades are non compliant on site, notices are issued against the PC
and not the Suppliers/trades (who is also a PCBU).
The new regulations have an opportunity to clarify the duties relating to the PCBUs working
under the control of the PC.
Chapter 2: Representation and participation (e.g. power to request review of risk control measures in
certain circumstances)
No comment
Chapter 3: General workplace management