Draft model Work Health and Safety Codes of Practice
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1 Submission to Safe Work Australia Draft model Work Health and Safety Codes of Practice MANAGING RISKS IN CONSTRUCTION WORK PREVENTING FALLS IN HOUSING CONSTRUCTION Prepared by Roofing Tile Association of Australia Inc. November 2011 Roofing Tile Association of Australia Inc. PO Box 1037 Spit Junction NSW 2088 Phone Web site:
2 Draft Codes of Practice RTAA submission to SWA Managing Risks in Construction Work Preventing Falls in Housing Construction Both these codes (along with sections of the Act, Regulations and the Code of Practice: How to Prevent Falls at Workplaces) apply to tasks undertaken by both roof tilers and sheet metal roof fixers in the housing industry. Since mid-2004 the Roofing Tile Association of Australia (RTAA) has participated in the development of a code to address the fall risks inherent in these trades. This culminated with the declaration of the existing National Code of Practice for the Prevention of Falls in Housing Construction in May It was the expectation of all stakeholders that upon declaration it would be taken up by each jurisdiction as required under their separate Acts and Regulations. However, with the decision to move to harmonised OH&S laws the code has remained in abeyance pending the finalisation of the total harmonised package. The information contained in the May 2010 National Code of Practice for the Prevention of Falls in Housing Construction was required to be interpreted with reference to the Acts and Regulations operating in separate jurisdictions. The Model Act and Regulations has removed this need but a housing roof worker still requires knowledge of more than just the Code of Practice: Preventing Falls in Housing Construction in order to fully understand their responsibilities, duties and possible approaches to controlling risks. The RTAA recognised that the various codes are not trade specific, even a code dealing with falls in the housing industry will cover many separate trades, each with their own particular issues and methods of controlling risks. The RTAA supports the current code structure and specifically those covering the broader construction industry (Code of Practice: Managing Risks in Construction Work) together with those of a more specific nature (Code of Practice: How to Prevent Falls in Workplaces and Code of practice: Preventing Falls in Housing Construction). These documents are invaluable to in setting out duties and responsibilities and generally accepted methods to assess and control risks. When addressing a trade within the housing industry such as roof workers we suggest that Safe Work Australia, once the new laws are finalised, provide Page 2 of 5
3 assistance and support for the development of specific trade guidance material. With reference to key documents within the new laws it would be possible for the roofing industry (both tile and sheet metal) to produce a simple guide showing how to address the risks that these trade people will encounter in their ever day work. In summary the RTAA supports the current drafts of the codes; Managing Risks in Construction Work Preventing Falls in Housing Construction, and looks forward to their adoption in all jurisdictions. Finally, a major frustration for the RTAA is that the work on the housing falls code was finalised in early 2010 but it has yet to be adopted in all jurisdictions. Tragically there have been at least 2 fatalities and several major and/or disabling injuries to workers in the housing industry that would have been prevented had the declared code been adopted in mid Roofing Tile Association of Australia November 2011 Page 3 of 5
4 Appendix Background information on the Roofing Tile Association of Australia and the residential roofing industry Who we are. The Roofing Tile Association of Australia Inc. (RTAA) objectives are to encourage, foster and promote the interest of the concrete and terracotta roofing tile industry. It represents in excess of 90% of manufacturing and installation activities of the industry across all of Australia. Manufacturing members of the association are; Alice Roofing (a division of the Barro Group) Boral Roofing (a division of Boral Limited) Bristile Roofing (a division of Brickworks Limited) CSR Roofing (a division of CSR Limited) Harmony Roofing (a division of the BGC Group) Monier Prime Roofing (a joint venture between CSR and Prime Roofing) Associate members (representing distributors and tilers) include; Master Tilers and Slaters Association of NSW Queensland Master Roof Tilers Association Western Australia Roof Tilers Association Victorian Roof Tile Distributors Association Holmesglen TAFE Northern Melbourne Institute of TAFE Individual roof tile installation businesses in Victoria and South Australia The association s members have had a long history of involvement in safety and training issues (including falls prevention) and are well qualified to provide a commentary on the proposed codes of practice. Based upon members operating experience, surveys of roofing contractors and industry data, the RTAA has developed a position that is based upon fall prevention when working on roofs at height, rather than injury minimisation. This effectively means control measures to prevent fall from roofs on all housing construction. The association believes this is economically viable, Page 4 of 5
5 with a positive cost benefit in view of the high community cost of falls from heights and the potential for civil liability. The RTAA welcomes this opportunity to present its submission to the Safe Work Australia. About the roof tile industry. For over a century roof tiles have set the standard for Australian housing. On a national basis, around half of new homes have tiled roofs. The industry is unique in that the supply of roof tiles is almost always linked to their installation, a system known as supply and fix. The RTAA manufacturing member companies are responsible for the installation of about 60% of the tiled roofs in Australia. Of the remaining 40%, the vast majority are supplied and installed by RTAA associate members. Therefore, collectively the RTAA membership is responsible for nearly all the installers of roof tiles. Furthermore many of the association s associate members install sheet metal roofs as well as tiled roofs and this gives the RTAA a voice in this aspect of roofing work. Therefore RTAA has major interest in the draft codes and an unquestionable authority when representing the views of the roof installation industry. Page 5 of 5
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