The State Government has published a draft Excavation Work Code of Practice, with comment due by Friday, March 13.

The Draft Code is available online at safetyline.wa.gov.au/consultations/draft-code-of-practice-excavation-work/

Given our industry’s lack of input into the development process (see below), it’s extremely important that we closely review the Draft and provide detailed comment on any changes necessary or improvements that can be made. CCF WA has completed an initial review of the Draft WA Code of Practice, focusing on key differences with Safe Work Australia’s Model Excavation Work Code and the ‘harmonised’ Codes in other states. A summary document is available here. This document also includes space for member comment on each section of the Draft Code and can be used to provide your company’s feedback to CCF WA.

Your company’s comment is welcome by February 27 (or earlier if possible) so that CCF WA can prepare a comprehensive submission by the March 13 deadline.

Background to the flawed development of the Draft WA Excavation Work Code of Practice.

It’s disappointing that the civil construction sector, which does more excavation than any other, hasn’t had a say up until now. Drafting of the Code has been overseen by the Construction Industry Safety Advisory Committee (CISAC), which advises the WA Work Health and Safety Commission (WHSC) on construction safety issues. CCF WA isn’t a member of CISAC – we have sought a seat for many years (since at least 2013) but have been told that would upset the current employer group/union balance. 

 

What we know about the Draft WA Excavation Work Code of Practice.

Our initial review has shown that the Draft WA Code is structured and written very differently to Safe Work Australia’s Model Code and all other state Codes – so differently in fact that the WA Code can barely be called ‘harmonised’ at all. It would be very helpful to understand the reasoning behind all the changes, but Worksafe/WHSC have provided no supporting documentation.

We’ve already picked up a few specific issues of concern:

• The Draft WA Code of Practice claims that “vocational education and training (VET) courses are not available for excavation work” – the drafters were apparently unaware of the RII Civil training package.
• The Draft WA Code deletes all the Model Code’s guidance on safely identifying managing and removing asbestos, replacing it with the incorrect statement that if asbestos is encountered “work must stop immediately and the asbestos removed by a licenced contractor”. 
• A diagram in the Draft WA Code shows a backhoe backfilling a trench with the caption: “A small mobile front-end loader/backhoe should be used for backfilling”. This has been written by someone who clearly does not understand the scope of major excavation works undertaken on civil projects.

Supported by CCF WA's Safety Committee, we'll be reviewing every detail of the Draft Code over the next few weeks.

Member input is welcomed via the comment template below, or by email.

CCF WA Summary and Comment Template