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Model Work Health and Safety Regulations and Codes of Practice Public Comment Response Form Individual/Organisational name: Section A: Model Work Health and Safety Regulations Exposure Draft General Comments (e.g. regulatory impact, level of prescription, notification, record-keeping requirements) Chapter 1: Preliminary (e.g. definitions) Page 2, Section 1.1.5, Definition of ‘airborne contaminant’ Airborne contaminant is defined as ‘a contaminant in the form of a fume, mist gas, vapour or dust and includes bacteria’. Comment: Bacteria are only one type of microbiological airborne contaminant. Other microbiological airborne contaminants may include viruses and fungi. Recommendation: The term ‘bacteria’ should be replaced with ‘micro-organisms’. This will also ensure the regulations are consistent with the terminology used in Australian Standard 1715:2009 Selection, use and maintenance of respiratory protective equipment which uses the term ‘micro-organism’ in the context of microbiological airborne contaminants. Chapter 2: Representation and participation (e.g. power to request review of risk control measures in certain circumstances) Chapter 3: General workplace management Part 3.1 General working environment Part 3.2 Personal protective equipment Page 65, Section 3.2.5(4), PPE, Duties of workers This section states ‘the worker must inform the person conducting the business or undertaking of any damage to, defect in or need to clean or sterilise any of the equipment of which the worker becomes aware’. Comment: ‘Sterilise’ is a technical term that means to destroy all micro-organisms, including spores. Sterilisation can only be achieved by using specialist equipment such as an autoclave. Sterilisation of PPE is neither necessary nor practicable except in specific situations such as surgery. In most situations PPE will only require cleaning, and occasionally cleaning and disinfection such as when there is contamination with blood and body substances and the item may have contact with a person’s non-intact skin or mucous membranes. Recommendation: The term ‘clean or sterilise’ should be replaced with ‘decontaminate’. Part 3.3 First aid Part 3.4 Emergency plans Part 3.5 Review of general workplace management measures Chapter 4: Hazardous work Part 4.1 Noise Part 4.2 Hazardous manual tasks Part 4.3 Confined spaces Part 4.4 Falls Part 4.5 High risk work (e.g. Accreditation of Assessors) Part 4.6 Abrasive blasting Part 4.7 Electrical work Part 4.8 Diving work Chapter 5: Plant and Structures Chapter 6 Construction (e.g. construction induction requirement) Chapter 7: Hazardous chemicals Part 7.1 Hazardous chemicals Part 7.2 Inorganic lead Part 7.3 Asbestos Chapter 8: Major hazard facilities Chapter 9: Mines Chapter 10: General Part 10.1 Review of decisions Part 10.3 Exemptions Section B: Model Codes of Practice General Comments How to manage work health and safety risks Page 8, Table 1, Examples of common hazards The table states, ‘Viruses, bacteria, fungi can cause hepatitis, legionnaires’ disease, Q fever, HIV/AIDS, allergies’. Comment: o Viruses, bacteria and fungi are not the only infectious agents that can cause infectious diseases at work. Parasites can also cause diseases such as scabies outbreaks in the aged care industry. o ‘Hepatitis’ means inflammation of the liver and is not an infectious disease per se. o Pathogenic micro-organisms can cause many more infectious diseases than the four diseases listed. Recommendation: This sentence should read, ‘Micro-organisms can cause infectious diseases such as hepatitis B, legionnaire’s disease, Q fever and HIV/AIDS, and non-infectious diseases such as allergic respiratory disease. How to consult on work health and safety Managing the work environment and facilities Page 17, Section 3.4, Hand washing, Design Comment: Workers who work away from base locations or at outdoor sites also have hand hygiene needs, especially if they have contact with contaminated items or are exposed to infection risks. These workers should be provided with portable hand washing facilities (e.g. water in a portable container, soap and paper towels, hand wipes or alcohol-based hand rub). Examples of such workers include community healthcare and veterinary workers, and workers who work in areas where there is contact with infectious material, soil, etc. such as gardeners, cleaners working in public areas, plumbers, maintenance workers, waste workers, etc. Recommendation: Section 3.4 should include a statement to the effect ‘If work is undertaken away from base locations or at outdoor sites where there is no ready access to hand washing basins, you should ensure that your workers have access to alternative hand hygiene facilities, such as a water container with soap and hand towels, hand wipes or alcohol-based hand rub (Note: alcohol-based hand rub should only be used when hands are visibly clean)’. Managing noise and preventing hearing loss at work Hazardous manual tasks Confined spaces How to prevent falls at the workplace Labelling of workplace hazardous chemicals Preparation of safety data sheets for hazardous chemicals How to manage and control asbestos in the workplace How to safely remove asbestos Facilities for construction sites Appendix Penalty levels Infringement notices Other Comments