Download Coward, Patricia

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
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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