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PPE • ACCESS • HAZMAT • HEALTH • INJURY • MANAGEMENT • ENVIRONMENT • FOCUS September - October 2014 VOL 9 NO. 3 Price $9
Fatigue • Hearing • HAZMAT standards
Safe workplaces require
SOUND CHEMICAL MANAGEMENT
Employers must ensure employees are trained and equipped to safely handle dangerous goods and hazardous substances.
WE CAN HELP! Our experts deliver cost-effective training customized to meet your needs: HSNO Test Certification How to Implement HSNO in your Business
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CONTACT US TODAY TO DISCUSS YOUR SPECIFIC CHEMICAL TRAINING NEEDS.
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FIRST WORD>>HAZMAT by Barry Dyer
Please, don’t give up on HSNO The state of ‘suspended animation’ resulting from not passing Phase One of the new workplace health and safety legislation prior the election means a new and possibly still optimistic target of April 2015
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onsidering the raft of Select Committee submissions and contributions from advisory groups, passing the Health and Safety at Work Act, together with the supporting regulations and adding the subsequent 1-2 year implementation phase, means little change to your HSNO compliance obligations in the immediate future. Industry needs certainty – not achievable until post-election policies, portfolios and priorities are known. What is certain is the importance of continuing to improve the unacceptable level of HSNO compliance, particularly where the ‘How To’ is well-known. Regardless of progress with the new legislation, there is much to be done to enhance chemical safety in your company - and now is the time! Too many sites where chemicals are present do not yet meet basic HSNO compliance requirements. Avoiding the need for qualified workers by obtaining Approved Handler exemptions or by slipping under arbitrary quantities defeats the intention to protect people from harm. Renewing Approved Handlers ‘by correspondence’, while permitted by a regulatory loophole, fails to realise the importance of ensuring only compliant workers
safely handle and use chemicals, undermining the drive for safer and healthier workplaces. Ensure you have compliant safety data sheets (SDS) or hassle your supplier. SDS are public documents. Having to log into a company website and register in order to search for and download SDS is unlikely to meet the regulatory availability requirement of “within 10 minutes”. Emergency plans must extend beyond fires. Potential catastrophic events could include flooding, earthquakes and a major chemical
standards while restricting government involvement to issues which people cannot readily do for themselves. Workplace chemical safety is a well-traversed topic. HSNO is more than 10 years old so “I didn’t know what to do or how to do it”, reflected in substandard industry performance, will not survive increased public and government demands for improved workplace health and safety. The effective (though poorly executed) HSNO Approved Handler concept is under threat in the new legislation; sensible employers will continue to maintain this valuable resource by ensuring workers involved with chemicals are competent to safely carry out their tasks. The next 12-18 months present a ‘phony war’ situation for business operators, providing further opportunity for addressing HSNO
“Too many sites where chemicals are present do not yet meet basic HSNO compliance requirements” incident. Your response can range from evacuating the site and the neighbourhood to containing and cleaning up a small chemical spill without involving the emergency services, who will not always have the required expertise and equipment. Effective self-sufficiency must be regularly demonstrated. User-friendly regulations The Productivity Commission recently noted the need for clear and user-friendly regulation which enables compliance with clearly expressed national performance
compliance. The obligation for ‘Good Employers’, Prospective Persons in Charge of a Business or Undertaking (PCBU) and existing Persons in Charge (PiC) to ensure employees and customers are compliant with their HSNO and workplace health and safety obligations, continues unchanged. Chemical suppliers complying with their Responsible Care® best practice obligations provide accurate and timely advice regarding the safe storage, handling and use of their products throughout the supply chain, but not necessarily for your entire chemical inventory. This is best achieved by WorkSafe NZ inspectors and your Approved Handlers, supplemented by HSNO Approved Codes, together with specialized advice from Test Certifiers and Responsible Care NZ. Free site assessments It will take time for WorkSafe NZ to expand its enforcement capability. Meanwhile, workplace inspectors encourage and enable HSNO compliance using CHEMSAFE® compliance software to provide clients with free and ac-
curate site assessments. The CHEMSAFE® reports comprehensively explain compliance and remediation requirements. Seek out suppliers who offer effective product stewardship through compliant SDS and product labels and perhaps even training your staff. The Health and Safety at Work Act highlights occupational health, singling out asbestos in a drive for healthier working environments. Managing asbestos, chemical vapours and explosive dust will add to pressure on scarce resources, requiring greater industry self-sufficiency. Safely managing workplace chemicals is critical to every initiative seeking to safeguard workers and the community. The global chemical industry’s acclaimed Responsible Care® initiative proves that companies making the extra effort to push beyond regulatory practice are many times safer places to work than other high-risk industry sectors. The extra investment is not as costly as an incident. To paraphrase a Kiwi icon or two, ‘She’s a hard road finding the perfect HSNO-compliant site!’ How about you help push HSNO compliance beyond 23 percent? ‘It won’t happen overnight, but it will happen.’ The pending court cases facing a forestry contractor (a WorkSafe NZ prosecution and a civil suit brought by the Combined Trade Unions over the death of a forestry worker) may provide additional motivation. Barry Dyer is the Chief Executive of Responsible Care NZ, which provides practical products and services to enable compliance with New Zealand’s world class chemical management regime. Tel: +644 499 4311, email: info@responsiblecarenz.com, visit: www.responsiblecarenz. com
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THIS ISSUE HAZMAT
29 New Zealand’s safest construction companies will be unveiled at the Site Safe 2014 Construction Health and Safety Awards on 5 November in Auckland.
3 Please, don’t give up on HSNO says Content Partner Barry Dyer. The failure to pass the first phase of the workplace health and safety Access - Height safety legislation prior the election means 10-11 Content Partner Steve Tilling a new target of April 2015. says hazard assessment the safest 7 The Standards Association re- way to ensure compliance with conminds organisations to spend time fusing regulations and guidelines. identifying and managing the Regulators look at what is common chemicals used and stored in their practice throughout the industry workplaces. And details some of and guidance comes in the form of the applicable Standards that can approved publications be obtained from its website. 11-12 There remains a lot of conStandards fusion among sellers, users and 6 New Zealand adopts internamanufacturers about the AS/NZS tional machinery safety standards 1891 group of standards relating to after Standards Australia released a height safety products in New Zeanumber of revised parts of the Ausland says IANZ accredited signatory tralian Standard AS/NZS Jason Myberg. 4024.1 Series - Safety of Machinery. Pilz benchmarks its products 12-13 For some time, working at to align with global standards and height and preventing falls has been identified as a serious area of strengthen workplace safety. 7 The Standards Association re- concern in New Zealand. Buddle minds organisations to spend time Finlay Partner Sherridan Cook looks identifying and managing the at whether or not the law does chemicals used and stored in their enough to define and advise on fall protection regulations. workplaces. Events 8-9 The National Safety Show will join buildnz | designex on 21-23 June next year at the ASB Showgrounds. Participants should book early for this expanded show following the purchase of the Safety Show by XPO Exhibitions.
Editor Geoff Picken 0212 507 559 geoff@ mediasolutions.net.nz Managing partner Phil Pilbrow 027 564 7778 phil@mediasolutions.net.nz
13 A recent court case has highlighted yet again the importance of installing and using fall protection equipment. CMP Construction Ltd was fined $30,000 and ordered to pay reparation after an employee of a sub-contractor fell from a height of five metres. Design & pre-press Jamie Laurie jlaurie@hayleymedia.com Web development Neo Chen 021 507 318 neo@appsolutions.co.nz Publisher Mike Bishara 027 564 7779 mike@mediasolutions.net.nz
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Sept/Oct – 2014
Health
list of recommendations that it be-
16-17 The one app that might just lieves will significantly improve the save your life. Red Cross First Aid industry’s safety record. and Emergency App is fast becom22-23 Forestry industry must cut ing very popular. its own deadwood. WorkSafe New 24-26 Fighting the devastating Zealand believes there is too much dangers of tiredness is a major focus on the regulator as the soluchallenge for local business says Content Partner Matthew Beattie. tion to the forestry industry safety problem. 26 The effects of high blood pressure are well documented – greater risk of heart attack or stroke being top of the list. There’s also a link between high blood pressure and a lack of good-quality sleep.
23 The University of Canterbury is to launch a new research project to make sure New Zealand’s new forestry roads are safe and are 27-29 Bad assumptions about hearing protection. Any good proof is based upon assumptions: if the assumptions are good, the proof is valid. If the assumptions are bad, then the proof is worthless.
established with minimal environmental impact. 23 A Kerikeri-based forest management company is showing the industry the way forward by helping its staff grow their health and safety
Forestry focus
knowledge.
18-19 A war of words is brewing as the forestry industry awaits the release of the independent Forestry Review Panel’s final report with its recommendations to reduce the sector’s death and injury toll. Who is to be the regulator?
Products
19 The Independent Forestry Safety Review has been completed and the panel is now working on its Final Report, which is due for completion by the middle of October.
nostic options.
20-21 SICK introduces the unique decentralized integration design of Flexi Loop, costsaving cascading of safe switches and sensors within a machine as well as extensive diagSupporters Buddle Finlay P7, Charles Parsons P31, Eyepro P5, N.Z. Red Cross P17,
Pilz NZ P 19, Quality Safety P 13, Re20-21 The New Zealand Council sponsible Care P 2, Sick Pty P21, St. of Trade Unions (CTU) submission to the Independent Forestry Safety John P32, Technical Rigging Services Review panel offers an exhaustive P11, Xpo National Safety Show P8. Subscriptions mail@mediasolutions.net.nz Rates: $30 incl GST and postage for 5 issues, plus digital editions to five email addresses. Overseas rates available on request.
ISN is endorsed by NZ Safety Council
CONTENT PARTNERS Advertisement
Editor Geoff Picken updates the Forestry Safety Review due for release in October – 18
Steve Tilling on hazard assessment for height safety – 10
Sherridan Cook asks if the law provides enough support to ensure height safety – 14
Barry Dyer on the handling and treatment of dangerous chemicals – 3
Brad Witt on bad assumptions people make when it comes to hearing safety – 27
Jason Myburgh is the manager of the QSI Testing Laboratory and an authorised signatory to Standards 1891.1, 1891.3 and 5532 – 12
Phil Pilbrow is managing partner of Industrial Safety News
Mike Bishara is the publisher of Industrial Safety News
Neo Chen is the web developer of Industrial Safety News
Don’t take chances with your eyes. They’re just too important to risk getting it wrong NZ has a special quality of light shaping how we see. Our country is a combination of peoples, places and experiences that are unique in the world.
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hen you see an Optometrist you need to be certain that they meet the highest possible standards. That they’re independently New
because it’s their business, the advice and service you’ll receive will be personal, friendly and knowledgeable. They’ll make sure you’ll get frames that are a perfect match for
Zealand owned and operated and able to offer an extensive range of quality eyewear options sourced from specialized manufacturers. That’s why you should see Optometrists and Opticians that are members of EYEPRO – a truly independent network of eyecare professionals. They’re not salespeople – they’re experts. Only the best can be belong to EYEPRO, because they meet specialist standards of professionalism, accountability and competency that you can entrust your vision to – after all, their reputation and word-ofmouth recommendations are critical to their business. And
you, as well as making sure you get the right lenses for the essential health of your vision. After all, your eyes are very special, and they deserve very special treatment. That’s why EYEPRO was launched in 2005. The EYEPRO brand network also gives our independently owned and operated members the buying power and strength to compete effectively with the larger overseas owned optical chains operating in the our market. At the same time we can keep a local touch, because EYEPRO is built on the vast experience and trust inherent in our practices.
www.isn.co.nz Free access online to an interactive digital edition. Free access to the industry’s most comprehensive, key word searchable archives in eight key industrial safety categories: PPE, Access, Hazmat, Health, Injury, Management, Environment, Focus. Free access to daily updated news with the ISN online carousel Printed by Crucial Colour 24 Fairfax Aveenue, Penrose, Auckland +64 9 589 1550 Published by Media Solutions Ltd Level 2, 9 Anzac St, Takapuna PO Box 31397, Milford 0741 09 489 8663
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STANDARDS>>Machine safety
New Zealand adopts international machinery safety standards
Standards Australia has recently released a number of revised parts of the Australian Standard AS/NZS 4024.1 Series - Safety of Machinery to align with global standards and strengthen workplace safety.
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he revised parts have been individually issued at this stage with the entire standard due to be released as a 2014 version once the application guide (part 1100) is finalised later this year. The AS/NZS 4024.1 series provides designers, manufacturers, suppliers, employers and users of machinery with guidelines to help reduce the risks of working with, or near, machinery. According to Tony Catterson of Pilz New Zealand, the Safety of Machinery Standard has grown in relevance over time. It has recently been adopted as an AS/NZS Standard and is now being revised to form closer alignment to the European machinery safety standards. It is also set to incorporate the new conveyor standard (AS1755) in the near future. “It is a logical step to continue to update The AS/NZS 4024.1 Series to European standards as they lead the world in this area of machinery
safety,” says Mr Catterson. Standards Australia’s Technical Committee says the principal task of the 2014 revisions for the AS/ NZS 4024.1 Series was to consider the latest international standards and incorporate these into the original 2006 Standard. “The original standard was published as a series of small parts so that when new editions of relevant ISO, IEC or EN standards became available they could be adopted
seded and withdrawn (1101, 1202, 1301, 1802) with the application guide (1100) to follow. The main changes are: • The risk assessment approach parts 1201 & 1303 (new) have been updated to reflect the global standards of ISO12100 (Machine Safety, General principles of Design, risk assessment and risk reduction) and ISO14121-2 (Practical examples of Risk Assessments)
“It is a logical step to continue to update The AS/NZS 4024.1 Series to European standards as they lead the world in this area of machinery safety.” and published within the framework of the AS/NZS 4024 with minimum delay.” In total 19 Parts have been revised 1201, 1302, 1401, 1601 & 2, 1604, 1701-4, 1801 & 3, 1901-7); two new Parts have been added 1303, 1503; and four Parts super-
• A new Part 1503 that now gives the practitioner the option to design safety related control systems using ISO13849-1 and the Performance Level (PL) approach. Note that Part 1501 (Category approach) still remains in the standard and the designer still
AS/NZ 4024-1
2014 Training Course Pilz have provided AS4024-1 training in New Zealand for more than 12 years, with great feedback from our attendees.
has this option • Parts 1602 (Interlocking devices) and 1604 (Emergency Stop) are now both direct text adoptions of their international standards, ISO14119 and ISO13850 respectively • Guarding Parts 1801 (Safety Distances) and 1803 (Minimum Gaps) are also now both direct text adoptions of their international standards ISO 13857 and ISO 13854. “Pilz Australia and New Zealand are well placed to assist our customers with the revised Standard as our company has a rich European background and a large number of technical experts locally and globally who are very familiar with all the European standards,” says Mr Catterson. To find out more about the how the revisions to AS 4024.1 may affect your operation call Pilz NZ on+64 9 6345350 or visit www.machinesafe.com.au
Take advantage of our experience, enquire about a training course today. Contact:
With the standard now being updated and jointly adopted as AS/NZ 4024-1 it’s a great time to take advantage of our knowledge and understanding of the standard. We offer one day introduction courses along with advanced two day courses. Both will give you and your staff an understanding of the requirements of AS40241. Whilst the two day will provide more assistance on selecting and applying appropriate, COMPLIANT!! Machine guarding solutions.
office@pilz.co.nz 09 634 5350
Courses can be run at your site and tailored to meet your needs. This can include practical sessions where we look at a production machine. Pilz and our distribution partner Ellis and Co are the most experienced companies in New Zealand when it comes to machine guarding and AS4024-1.
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info@ellis.co.nz 09 570 5269
STANDARDS>>HAZMAT
Safe handling of chemicals
It’s important for organisations to spend some time identifying and managing the chemicals used and stored in their workplaces
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orkers can be injured by chemical accidents, fires, leaks, or spills if the safety requirements for handling hazardous chemicals aren’t clear. Many standards are available to help organisations to identify chemicals and set up processes to transport, handle, and store them safely. These standards reduce the risk of chemical exposure and protect workers, the environment, and the public. They provide best practice safety requirements for transporting dangerous goods (sometimes also referred to as hazardous substances), responding to an emergency or accident, handling chemicals, and protective clothing. Safety during transport The chemical, packaging, and transport industries use New Zealand’s standard for the transport of dangerous goods on land, NZS 5433, to meet the latest
Protection and safe handling Safety standards for agrichemicals, ammonia, chlorine gas, combustible dust, dangerous goods and articles, and toxic substances include: • agrichemicals – NZS 8409:2004 Management of agrichemicals • ammonia – AS/NZS 2022:2003 Anhydrous ammonia – Storage and handling • chlorine gas – AS/NZS 2927:2001 The storage and handling of liquefied chlorine gas • combustible dusts – AS/NZS 4745:2012 Code of practice for handling combustible dusts • dangerous goods and articles – AS/NZS 4681:2000 The storage and handling of Class 9 (miscellaneous) dangerous goods and articles • toxic substances – AS/NZS 4452:1997 The storage and handling of toxic substances.
safety requirements. Users of the standard include organisations that make, package, transport, or regulate the transport of dangerous goods by road or rail within New Zealand. The standard covers best practice to reduce the risk of harm, including how to package, label, and separate dangerous goods during transport. Part 1 covers the technical information including classification and packaging performance standards, while Part 2 is a list of dangerous goods with rules that apply to particular dangerous goods. In addition to the standard, there are several NZS 5433 tools that workers can use to comply with safety requirements. These tools include dangerous goods declaration forms, a wall chart showing which packages to segregate, and a segregation wheel. This wheel is a quick reference guide on which dangerous goods can and cannot
Protective clothing Clothing that complies with these standards meets the minimum safety requirements. Protective clothing standards include: • eyes – AS/NZS 1336:2014 Eye and face protection – Guidelines • footwear – AS/NZS 2210.3:2009 – Occupational protective footwear – Specification for safety footwear • gloves – The AS/NZS 2161 series for occupational protective gloves, including protective gloves against chemicals • lungs – AS/NZS 1715:2009 Selection, use and maintenance of respiratory protective equipment • protective clothing against liquid chemicals – AS/NZS 4503 Parts 2 and 3 Protective clothing – protection against liquid chemicals. All of these standards can be purchased from the Standards New Zealand website www.standards.co.nz.
be carried with other dangerous goods. Standards New Zealand updated NZS 5433 in 2012, to align it with the latest United Nations recommendations and New Zealand road transport rules. An expert committee consulted widely with affected parties and the revision process included technical review by industry experts and public input. Whenever a standard is developed or revised, Standards New Zealand uses this consensus-based approach to ensure the standard is practical and widely supported. Emergency response If something goes wrong, people handling chemicals need to know what to do. A useful handbook is available that provides emergency response information on how to deal with accidents, spills, leaks or fires involving dangerous goods. The handbook, SAA/SNZ HB 76:2010 Dangerous goods – Initial
emergency response guide, provides advice that anyone first on the scene of an incident should be able to follow. It fits in a vehicle glove compartment – it’s durable, A5, and wire-bound. Trained emergency responders use the handbook, but it also provides step-by-step instructions. This means that people without a technical background can respond to dangerous goods emergencies safely and effectively. The handbook isn’t a substitute for emergency response training, experience, and sound judgement. But, if it’s used properly, it will speed up emergency response and help prevent an incident from becoming a catastrophe. Standards provide critical support to the safe handling of chemicals. They help workplaces and workers to improve safety, provide protection, reduce accidents involving chemicals, and respond to emergencies safely and effectively to protect the public and the environment.
Work safe. Our experienced team is dedicated to providing expert employment and health and safety legal advice with a strategic and commercial approach. ........................................... Sherridan Cook, 09 358 2555 // sherridan.cook@buddlefindlay.com Hamish Kynaston, 04 499 4242 // hamish.kynaston@buddlefindlay.com Peter Chemis, 04 499 4242 // peter.chemis@buddlefindlay.com Kerry Smith, 03 379 1747 // kerry.smith@buddlefindlay.com
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TRADE SHOWS
Positive news for the industry XPO Exhibitions Ltd has announced exciting new plans for its recently acquired trade events The National Safety Show and Material Handling & Logistics
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ntil 2013 these two trade only events have run concurrently at the ASB Showgrounds in Auckland. They will now run alongside and in conjunction with two of XPO’s most successful and longest running trade events being Foodtech Packtech (FTPT) for Material Handling & Logistics (MHL) and buildnz | designex for The National Safety Show (NSS). The first to be launched will be The National Safety Show which will feature at buildnz | designex 21-23 June 2015, ASB Showgrounds. “We are excited to be in a position to rejuvenate and grow this event, aligning it to the award winning buildnz |designex event makes a lot of sense. “When you consider workplace health and safety, whilst important to any business, is particularly so in the building and construction industry then there’s a good cross-alignment of trade visitors across these events.” says managing director of XPO, Brent Spillane “NSS exhibitors will be able to reach a valuable new visitor database. buildnz | designex had nearly 5000 unique visitors in 2013 (CAB authenticated) so the opportunities for The NSS event to grow is huge.” The Material Handling & Logistics (MHL) exhibition will now feature alongside Foodtech Packtech with a full launch being planned for the October 2016 event. MHL exhibitors had an earlier opportunity to be a part of FTPT 2014 scheduled
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in September. FTPT 2014 was almost sold out but organisers, XPO, have an opportunity for select MHL exhibitors to be present. The alignment of Foodtech Packtech and MHL is not new, having been co-located prior to Foodtech Packtech being purchased by dmg world media more than 10 years ago. MHL exhibitors on hand to showcase their products and the opportunity to explore new equipment, services and innovations for the materials handling, supply chain, transport and logistic industries met directly with the thousands of FTPT visitors. “The complementary nature of FTPT and MHL delivers crossovers that will work to both an exhibitor and visitor advantage. Exhibitors are able to reach a far greater pool of quality visitors and potential customers and visitors will be able to see everything under one roof.” says Mr Spillane XPO is investing heavily into its marketing and promotional programs for each of these events. XPO has a growing database containing more than 220,000 unique (mostly SME) business visitors who have registered or attended an XPO show in the past four years (including those shows recently purchased from Hayley Media). This database is an incredibly powerful marketing tool and combined with DM, Online, Print, Radio and investment in other media activity, XPO is confident that these events will go from strength to strength.
ABOUT BUILDNZ | DESIGNEX For more than 20 years buildnz | designex has been NZ’s leading trade event for the building, design and construction industry with a solid reputation for bringing building professionals and industry innovators together. Attracting more than 200 exhibiting industry suppliers and nearly 5,000 building & construction, architecture & design trade professionals it’s an event to share ideas, showcase the latest products, develop business relationships and to work
packaging & processing professionals, it’s an event not to be missed for anyone serious about their business in the F&B or packaging sector. FTPT 2016 featuring Material Handling & Logistics (MHL) will be at the ASB Showgrounds, Greenlane, Auckland 11-13 October 2016. FTPT 2014 will be at the same location later this year on 23-25 September.
together on the opportunities and challenges presented by the industry. buildnz | designex featuring The National Safety Show (NSS) will be at the ASB Showgrounds, Greenlane, Auckland 21-23 June 2015.
chased the majority of its trade shows from dmg world media NZ Ltd in January 2010. In 2013 XPO acquired an additional portfolio of industry trade shows from Hayley Media. XPO now owns and organises 13 of New Zealand’s largest and longest running industry specific ‘business to business’ trade show exhibitions and events with around 35,000 trade visitors frequenting XPO shows each year in New Zealand. XPO prides itself on delivering first class events and memorable experiences for all visitors while offering Exhibitors a unique business environment in which to showcase, educate and sell their products to targeted niche industry attendees.
ABOUT FOODTECH PACKTECH Foodtech Packtech (FTPT) is NZ’s premier event for the food & beverage packaging technology industries attracting leading companies from NZ and around the world. Foodtech Packtech showcases the freshest ideas, latest technologies and the newest developments entering the Food and Packaging Technology market. Attracting over 200 exhibiting food, beverage & packaging industry suppliers and more than 3,000 food & beverage manufacturing,
ABOUT XPO EXHIBITIONS XPO Exhibitions Ltd (XPO) is a family owned business. XPO pur-
www.xpo.co.nz
ORGANISED BY
Co-locating with
BIGGER. STRONGER. BETTER. Under new management of NZ’s largest Trade Exhibition Organisers Co-locating alongside the award winning buildnz | designex 5000+ trade visitors in attendance Showcase. Educate. Sell.
INTERESTED IN EXHIBITING?
BOOK YOUR STAND NOW
www.safetyshow.co.nz | www.buildnz.com | www.designex.co.nz
CALL OR EMAIL OUR TEAM NOW 09 976 8350 sales@safetyshow.co.nz
EEAA
Excellence Awards Winners Best Trade Show in Australasia Best Overall Show in New Zealand
HEIGHT SAFETY>>The Practice by Steve Tilling
Hazard assessment answers the working at height puzzle The term working at height is a misnomer - it really stands for something infinitely more dangerous
Regulators look at what is common practice throughout the industry and guidance comes in the form of publications like Approved Codes of Practice, Best Practice Guidelines, ASNZS standards and industry-agreed publications
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hat is working at height? Let us first clear this up by stating that what we usually mean by working at height is “at risk of falling”. Being high does not always apply. Whenever there is a level lower than you the potential for a fall is present. The definition of a “fall” is “to move from a higher to a lower level, typically rapidly and without control”. When considering fall protection it is important to remember this point as the law applies equally in both cases. What does the law say? Surprisingly the law has very little specific to say. In the Health & Safety in Employment Act 1992 the words ‘fall’ or ‘height’ are not present – the terms are not even defined. The same can be said for the Health & Safety in Employment Amendment Act 2002. The overriding requirement is to take “all practicable steps” to pre-
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vent harm. This is important as it implies the duty of care employers and principals have. Your responsibility thus extends to preventing harm from falling. 2A All practicable steps (1) In this Act, all practicable steps, in relation to achieving any result in any circumstances, means all steps to achieve the result that it is reasonably practicable to take in the circumstances, having regard to – (a) the nature and severity of the harm that may be suffered if the result is not achieved; and (b) the current state of knowledge about the likelihood that harm of that nature and severity will be suffered if the result is not achieved; and (c) the current state of knowledge about harm of that nature; and (d) the current state of knowledge about the means available to achieve the result, and about the likely efficacy of each of those means; and
(e) the availability and cost of each of those means. (2) To avoid doubt, a person required by this Act to take all practicable steps is required to take those steps only in respect of circumstances that the person knows or ought reasonably to know about. How high is high In the Health & Safety in Employment Regulations 1995, height does get a mention. This regulation spells out the often-quoted regulation 21, specifically detailing responsibilities for heights above three metres. The essence of this rule is just a restatement of the goal of the act: To take all practicable steps with the added caveats that “Means are provided to prevent an employee from falling” and “Those means are suitable for purpose”. This rule is often the source of the retort that you do not need fall protection below three metres. This is incorrect and ignores the parent Acts requirement to take all
practicable steps to prevent harm – even harm below three metres. Most falls happen from ladders and below three metres. Designing effective fall arrest systems for low heights is actually quite tricky. There are two options that we shall cover later. The regulations define the interpretations of advanced scaffolding, basic scaffolding and certificate of competence. And also cover when working at height is notifiable to the regulator. They are any construction work: • where any person may fall five metres or more • erecting or dismantling scaffolding from which a person may fall five metres or more • work in a void more than 1.5 metres deep and having a depth greater that the width at the top • work in any excavation which has a vertical height of five metres or more and a slope ratio of 1 horizontal to 2 vertical. Additionally the legislation covers principles that are indirectly relat-
ed to managing the risk of falling. These include the assessment of hazards and the hierarchy of control. Identification and assessment Identifying the hazard is the easy part. Can you move from a higher level to a lower level involuntarily? If the answer is yes, you have a hazard. Assessing the hazard takes a little more thought and is the balance between how serious that involuntary excursion is and how likely it is to happen. The hierarchy of control is very important when choosing a prevention or mitigation strategy. The law requires you to consider hazard controls in this order: 1. First: Eliminate – is it possible to avoid doing the work at height (eliminate the risk) or is it possible to remove the possibility of a fall (eliminate the hazard) 2. Second: Isolate – is it possible to restrict access to the areas where a fall may occur? 3. Third: Minimise – this is the last resort and is acknowledging that you cannot practicably implement the first two methods. You accept some risk that a fall may happen and are taking steps to make the consequences of that potential fall as small and as unlikely as possible. 4. Best practice New Zealand law does not tell you how to be safe but only that you are required to act safely in all areas of your business. So if I can do what I like, where do all these other laws come from? It should be noted that it would be very difficult for a regulator to
demonstrate that you have failed in your obligations if they did not have guidelines to compare your performance against. They do this by looking at what is common practice throughout the industry and this is usually documented in endorsed publications. This guidance comes in the form of important but entirely voluntary publications like Approved Codes of Practice (ACOPs), Best Practice Guidelines, ASNZS standards and industry-agreed publications. Common confusion One problem is common confusion between the law (required by Acts and Regulations) and the guidance (on how to meet the law). The result is that you may be told something like “it is illegal not to have the safety system on your roof recertified.” This is simply inaccurate as recertification is a requirement for compliance with ASNZS 1891.4 Industrial fall arrest systems and devices –Selection use and maintenance – section 9.1 summary of inspection requirements. Compliance is voluntary. If compliance with this standard is how you demonstrate that you have taken all practicable steps, then you should make sure the system is compliant. But it is misleading to claim it as a law. Examples abound but the key takeaways should be that many publications exist to help you decide practicable steps, they don’t all agree and the regulator uses them when measuring your performance. Fortunately there are many sup-
port publications and it wholly depends on the risk you are trying to mitigate and the duration of the tasks to be completed. Different options Systems can be temporary or permanent and they all manage the risk differently. * Avoid the area • If the work can be completed without being exposed, this should be your first choice. * Hand rails and edge protection • These are a great choice for preventing a fall and require no skill to use, but should be balanced against the risk exposure in setting them up. Ideal for permanent installations where the protection over time outweighs the initial risk. For short duration, one off jobs this solution may not be the best. Edge protection is also great for low heights where fall clearances are an issue. * Restraint technique • A technique that involves managing personal equipment attached to anchors, structure or safety lines to prevent access to an area. This requires skill and discipline to be executed safely. * Fall restraint • Often used in climbing situation where a fall is arrested within 600mm on a line or rail using a Type 1 fall arrest device or by Type 2 or 3 retractable lifeline devices. * Fall arrest • The method of arresting a fall within two metres exerting a maximum force on the body of less than 6kn (600kg). Most anchor points and horizontal lifelines fit into this category. Fall
Most falls happen from ladders. It is wrong to believe you do not need fall protection below three metres. The requirement under the Act is to take “all practicable steps to prevent harm’ and that includes harm below three metres
arrest systems need to be very carefully designed. Training is required to use them. * Access platforms • This category includes scaffolding, swinging stages, mobile work platforms, elevating work platforms, crane man cages and building maintenance units. Some platforms require skilled construction but are easy to use; mechanical platforms need specific operator training. Access platforms provide comfortable
Continued on page 12
FOR ALL YOUR WORKING AT HEIGHT SOLUTIONS THROUGHOUT NEW ZEALAND Permentant and and temporary fall Permanent fall arrest arrest systems systems All permanent systems CPEng certified Equipment sales and hire Contact TRS, your height safety specialists
Telephone: 09 571 0675 Email: sales@technicalrigging.co.nz www.technicalrigging.co.nz www.isn.co.nz
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HEIGHT SAFETY>>Compliance by Jason Myburgh Sponsored article
Sorting out standards, guidelines and branding Height safety is largely a matter of trust - we trust that the equipment we use has been subjected to rigorous testing and meets the required safety standards
Q
SI is one of the first IANZ accredited facilities in New Zealand to test to the AS/ NZS 1891.1 and AS/NZS 1891.3 standards. The qualification took more than three years to achieve but has given the company much greater insight into the testing and marking of products to this set of standards. Unfortunately there remains a lot
of confusion among sellers, users and manufacturers about the AS/ NZS 1891 group of standards relating to height safety products in New Zealand. It is important that both end users and companies providing equipment are educated on what the standards cover. The difficulty of obtaining information about the standards has
allowed some manufacturers to create the illusion that certain products meet a non-existent standard. If anyone feels a product is not up to standard they have the right to ask for the testing certificates. Each model of height safety equipment is required to have its own testing certificate. As users, resellers and distributors become better educated on the
details of the AS/NZS and EN standards, we hope to see a greater level of compliance for all height safety equipment sold in New Zealand. In the meantime, consumers need to be vigilant and not take any manufacturer’s claims at face value. Ask questions, ask for certificates, double-check, get educated – your life and your business could depend on it. AS/NZS 1891.4 is not a testing standard The most common products
Hazard assessment continued from 11
working, mobility FOR ALL YOUR WORKING good AT HEIGHT SOLUTIONS and opTHROUGHOUT NEW ZEALAND tions suitable for all time frames.
Permanent and temporary systems should The set-upfall arrest involved All permanent systems CPEng designed be balanced against the work Equipment sales and hire Contact required. TRS, your height safety specialists Telephone: 09 571 0675 * Specialists Email: sales@technicalrigging.co.nz www.technicalrigging.co.nz • Rope Access technicians can manage their own safety using any of the methods above in addition to rope support systems that allow access almost anywhere. They are excellent for quick and low profile access and can manage their own rescue requirements. The downside is they may not be as skilled in the specific task as a ground specialist in that area. * Soft landing systems • This category includes catch nets, mesh and other proprietary systems. They are great in situations where there is a risk of falling through a roof or from a low height. They work best where the risk is in a small area or enclosed in a larger space with supporting walls on all sides for the net attachments.
Guidance and common practice To be considered common practice all systems require some level of competence (training, knowledge, skill and experience), a safe working plan, appropriate equipment and PPE. Where the risk of a fall is not eliminated or where a person may be
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stuck at height, a rescue plan that does not rely on emergency services is also required. This implies any equipment and training required by the plan is also available. Fall arrest systems are by far the most widely installed on buildings. They range from simple anchor systems to complex travel restraint systems. They are commonly proprietary systems although totally engineered systems do exist. Systems should be installed by a competent installer, one that is authorised by the manufacturer. Systems are installed to the manufacturer’s guidelines, using a suitable configuration after an engineer has confirmed the structure is suitable. The system will then be certified in accordance with the relevant standard and tagged as such. When it is time to recertify a system, a company cannot certify a system for which it does not have specifications. This includes the system’s design use and the manufacturer’s guidelines. If you engage a company and cannot provide that information, it is possible that the systems will be certified against a general usage criteria and the relevant standard. This is more easily done for anchor systems than for lifelines as lifelines involve many more factors to ensure safety. In this type of case an installer may
not be able to certify that system. This does not mean the system is illegal as they may tell you. What it does mean is that you will need to engage a company that also installs that type of system. You will still need to provide the original design use if the system was for a specific application like access to antenna systems. If that company fails the system they should tell you why and against what criteria it failed in a language that should be easily understood. An uncertified system should not be used. Careful consideration Considerations when planning a fall arrest system are: • the structure and fixings are of adequate strength • safe access to the system – can a person avoid the risk of falling prior to attaching to the system? • the system is suitable for its intended use – this should be documented • that the system can be used by the intended number of users. • the system does not impede access or other activities • the performance characteristics are in line with the manufacturers tolerances • fall clearances and swings are accounted for • the system will limit the force on
the body to less than 6kn in the event of a fall • a rescue can be completed safely in the event of a fall. You should receive from your installer: • producer statements indicating structural suitability • an area plan indicating the layout of the system and how to use it • certification document confirming compliance • installer and system details including recertification requirements, design use, special requirements like double or shock absorbing lanyards and limitations of the system. As a principal you have responsibility to ensure: • users of the system know how to use it • they have relevant information about the system • they have the right PPE and system gliders • their work plan is suitable and includes a rescue plan • they are competent for the tasks involved • that the system has a current certification tag Steve Tilling is Team Leader at Technical Rigging Services NZ Ltd, specialists in height rigging for commercial, industrial & telecommunications industries
QSI makes the majority of its products in New Zealand or sources product directly from manufacturers which meet the company’s standards. All QSI Products conform to AS/NZS 1891 or equivalent EN standards
bearing the mark of the AS/NZS 1891.4 standard on it, or claiming to be tested to and complying to the AS/NZS 1891.4 standard, the product should be examined carefully as it is not possible to test to this standard. Any document claimThe most common products marked with ingstandard to be aaretest certificate this this anchor points andtoslings, but we haveisalso seen harnesses standard likely tosome be incorrect. and pole straps marked this way. Some importers of product mark The 1891.4-2009 standard clearly states harnesses, shock absorbing ittheir is for selection use and maintenance. Iflanyards you askedand QSI Testing Laboratory pole straps to to both test to this standard we would tell you EN and as AS/NZS 1891.1 standitthe is impossible there are no testing specifications methods of testing laid ards on theand same product.
There is nothing wrong with EN certified product and we at QSI sell and use EN product ourselves. The only difference is that we market it as having the 5 year life span it conforms to, unless we have a UV certificate showing the webbing to this standard is likely to be incorrect. complies to the AS/NZS UV testing The new AS/NZS 5532:2013 standard isrequirements. a part of the AS/NZS 1891 group and deals tripods, and both Thewithtable indavit thisarms, article details temporary and fixed anchor points. The some distinct differences. standard was published in late 2013.
Spotlight On Height Safety Standards Compliance Height safety is largely a matter of trust. As users, we trust that our equipment has been subjected to rigorous testing and meets the required safety standards. Unfortunately tell you standards it is impossible understanding height safety equipment canas bethere are testing specifications difficult for distributors, resellers no and consumers alike. and methods of testing in this document. There has been much confusion and The table below details some distinct Section 1.5 of the standard states misunderstanding of the AS/NZS 1891 differences. group of standards relating to height safety Itthat will not be possible for EN labelled compliance to anthe standard products in New Zealand. It has become product’s test certificate to pass the AS/ cannot be claimed on any product. apparent that some manufacturers have NZS 1891.1:2007 standard as they been marking product to non-existing Thenot criteria ofmeet section 1.5 ofand AS/ could possibly the labelling testing standards, and possibly misleading marking requirements, just as it would NZS 1891.4 2009 is as follows: consumers as a result. Added to this, not be possible for the AS/NZS 1891.1 WAHA Australia have recently uncovered product 1.5 PERFORMANCE to meet the EN standard because issues with roof anchors and fixed life line the marking, labelling and instructions are REQUIREMENTS systems not meeting the new AS/NZS different. 5532:2013 marked standard. with this standard are There Thisis Standard does include nothing wrong with not EN certified QSI has been working to become one product and we at QSI sellrequirements and use EN anchor points andhard slings, but we product performance of the first IANZ accredited facilities in New product ourselves. The only difference is have also seen harnesses for we height safety equipment. ComZealand to test to some the AS/NZS 1891.1and and that market it as having the 5 year life AS/NZS 1891.3 standards. it conforms unless we UV pole straps marked thisThis way.has taken span pliance to this to, Standard ofhave any asuch over 3 years to achieve but has given us certificate showing the webbing complies Although thethe 1891.4-2009 stand- to equipment cannot be claimed. much insight into testing and marking the AS/NZS UV testing requirements. of to this the set of standards. ardproducts falls under family of testing AS/NZS Performance with 1891.4requirements is not a Testing EN versusitAS/NZS Standards standards, is actually not itself a Standard which items of equipment dealt Some importers of product mark their of concernshall is thecomply testing standard but rather a user Another within big thisarea Standard harnesses, shock absorbing lanyards and tendency of some companies to mark selection maintenance guide. are specified in AS/NZS 1891, Parts pole straps and to both the EN and AS/NZS product to the AS/NZS 1891.4 standard. 1891.1 standards on the same product. If you asked QSI Testing Laborato- Although 1, 2 andthis 3. falls under the family of We are often asked, “what is the difference testing standards, it is actually not itself a ry to testthetoAS/NZS this standard we would If you have product marked or between 1891.1 standard and the equivalent EN standards?”
instructions are different.
testing standard but rather a user selection is not possible to test to this standard. Any document claiming to be a test certificate and maintenance guide.
5532 IANZ 1891.1 and 1891.3 authorized signatory
Height Safety You Can Trust
Key Differences between EN and AS/NZS Height Safety Standards Test Criteria
AS/NZS 1891.1 Standard
EN Standard
UV Testing and Lifespan
We are required to conduct a determination of resistance of webbing to light test as per Appendix A of AS/NZS 1891.1. This gives us our 10-year life span on webbing products certified to the AS/NZS 1891.1 standard. Actual certificate is needed on the webbing, not the thread.
EN standards do not require UV testing as the product is only required to last 5 years.
Dynamic Drop Testing
The AS/NZS 1891.1 dynamic drop test is conducted on a 2m x 12mm diameter, three-strand, polyester hawser-laid rope. Each harness will have a head up and head down drop on the fall arrest attachment points. On a head up drop it will generate over 12kN of force during the drop and the head down could be as much as 16kN to 18 kN. The AS/ NZS standard does not specify a force requirement that the harness needs to be exposed to, but the force generally exceeds the 12kN load due to the lack of stretch in the polyester rope. Thus, most of the energy ends up in the harness.
The EN 364 standard requires a single mountaineering rope of 11mm diameter. This is known as kernmantle rope and has more stretch in it than the 12mm polyester rope. The EN test also requires a head up and head down drop on the fall arrest attachment points.
The marking and labelling requirements as per AS/NZS 1891.1 section 6.1 (Instructions for use) and section 6.2 (marking) are very specific on font size, label layout, and details that need to be included in the warning labels as well as instruction book. The AS/NZS 1891.1 product needs a clear date of withdrawal.
The EN requirements are vastly different in terms of labelling and instructions for use, even to the point of using an “A” symbol to indicate the fall arrest attachment point.
Marking and Labelling
It is important that both users and companies providing equipment to AS/NZS 5532:2013 be used are educated on what the The new AS/NZS standards cover. The difficulty5532:2013 of obtaining out in this document. Furthermore, Section information about the standards has standard is a part of the AS/NZS 1.5 of the standard states that compliance allowed some manufacturers to create to the standard cannot be claimed on any the AS/NZS 1891.1 and EN 1891 group. It deals withmeets tripods, illusion that certain product a product. non-existent standard. anyone feels a standards davit arms, and Ifboth temporary The criteria of section 1.5 of AS/NZS product is not up to standard they have the What is isthe difference between right andtofixed anchor points. 1891.4 2009 as follows: ask for the testing certificates, and model of heightwas safetypublished equipment isin 1.5 AS/NZS PERFORMANCE the 1891.1REQUIREMENTS standard and each The standard required to have its own testing certificate. This Standard does not include the equivalent EN standards? late 2013 and WAHA AustralAs users, resellers and distributors product performance requirements savvy and better educated It will notsafety be possible for an EN become ia hasmore recently uncovered issues for height equipment. on the details of the AS/NZS and EN Compliance to this Standard of any labelled product’s test certificate standards, with roofweanchors anda other prodhope to see greater such equipment cannot be claimed. to pass the AS/NZS 1891.1:2007 level uctsofnot meeting newsafety AS/NZS compliance for the all height Performance requirements with sold in New Zealand. In the standard as they could not possibly equipment 5532:2013 standard. which items of equipment dealt meantime, we advise consumers to be within this Standard shall comply are meet the labelling and marking re- vigilant and not take any manufacturer’s specified in AS/NZS 1891, Parts 1, 2 face value. Ask questions, quirements – just as it would not claims JasonatMyburgh is the manager and 3. ask for certificates, double-check, get Ifbe youpossible have product marked or bearing the for the AS/NZS 1891.1 educated; of the QSI Laboratory afterTesting all, your life and your mark of the AS/NZS 1891.4 standard on it, business could depend on it. product to meet the EN standard and an authorised signatory to or claiming to be tested to and complying by Jason Myburgh to the AS/NZS standard, the and Standards 1891.1, 1891.3 and because the1891.4 marking, labelling QSI Testing Laboratory Manager product should be examined carefully as it
If the testing facility uses dynamic mountaineering rope, this has a lot of stretch to allow for some shock absorption during a climbers fall, this is why the EN standard specifies a minimum force of 7.5 kN that needs to be achieved on the first drop.
New Zealand’s first IANZ Accredited 1891.1, 1891.3 and 5532 Height Safety Laboratory. QSI are accredited by IANZ to test height safety equipment to the AS/NZS 1891.1,
The EN product only requires a date of manufacture. The 5 year life is standard unless specified differently by the manufacturer on the basis of a UV certificate.
AS/NZS 1891.3 and 5532 standards. This means every height safety
product we make has been tested to the most stringent standards. Having our own testing facility on site gives us the unique opportunity to take our products to the limit multiple times
throughout the development process instead of relying on fewer, more expensive tests in a foreign lab.
AS/NZS 1891.1 AS/NZS 1891.3 AS/NZS 5532
This allows us to identify and solve problems quickly, greatly reducing development costs, resulting in a better and more affordable product for our customers.
Visit www.qsisafety.com for more information.
www.isn.co.nz
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HEIGHT SAFETY>>The Law by Sherridan Cook
Fall protection by regulation does the law do enough? For some time, working at height and preventing falls has been identified as a serious area of concern in New Zealand. In 2011 it became a priority for the Ministry of Business, Innovation and Employment (MBIE), which started the Falls from Height Project to raise awareness about working safely at height and to reduce the effects of falls
A
ccording to MBIE, in 2012 falls from height cost the construction sector an estimated $24 million, not to mention the significant physical and emotional impact on the victims and their families. The project was accompanied by targeted enforcement, which resulted in over 1,000 enforcement steps being taken in 2012 for non-compliance while working at heights (in the form of written warnings and improvement, infringement and prohibition notices). While the statistics supported the need for such a project, it may be questioned why the regulatory regime had not prevented the situation from becoming so bad. As outlined below, the legal responsibilities on employers and workers to prevent falls are non-specific, and simply stem from an employer’s duty to take all practicable steps to provide a safe workplace and an employee’s corresponding duty to ensure their own safety. This raises the question whether more regulation in this area would result in fewer falls. As New Zealand is shortly to follow the Australian Model Law, we suggest that a similar degree of prescription in New Zealand to that in Australia
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is likely to reduce the injury toll. What is working at heights? Working at height is defined in MBIE’s Best Practices Guidelines for Working at Height in New Zealand as: Working at a place, above or below ground level, where a person could be injured if they fell from that place – that is, falling from one level to another.… Work at height does not include a fall at the same level, such as falling or slipping on ground level. It spans many different industries, including construction, forestry, domestic tradesman and aerial and satellite dish installers. However, the extent of the risk of working at height can vary greatly depending upon many different factors, such as the height worked at, the surface worked on (including its pitch), the duration of the work (which could be as short as a few minutes) and weather conditions. These factors need to be balanced against the cost, convenience and practicability of providing fall elimination or prevention controls. What are the current legal obligations? Somewhat surprisingly given the
prevalence of working at heights across many different industries, the current regulatory regime contains little prescription over working at heights. HSEA The Health and Safety in Employment Act 1992 (HSEA) contains the basic obligation on employers to take all practicable steps to provide a safe place of work and ensure safe work practice. Undoubtedly this duty, together with the other general duties on persons in control of a place of work, self-employed persons, principals and contractors, includes ensuring the safety of workers working at height and exposed to the risk of a fall. The hazards created from working at height also fall to be identified, and then eliminated, minimised or isolated, as part of an employer’s usual hazard management processes. However, neither the HSEA nor the regulations made under it prescribe how this might occur. Of course, employees are also under a duty to take all practicable steps to ensure their own safety while at work, including using the protective equipment provided, and that they cause no harm to others. However, it is still primarily the employer’s responsibility to ensure that appropriate systems and procedures are developed and implemented for protecting people from the hazards associated with working at height. Regulations Beyond the Act, only the Health and Safety in Employment Regulations 1995 (Regulations) refer expressly to working at heights. But the regulations are only concerned with heights of more than three metres, suggesting that this limit has some “magic” to it when it does not. Regulation 21 states that every
employer shall take all practicable steps to ensure that where any employee may fall more than three metres, there are means provided to prevent the employee from falling and that those means are suitable for the purpose for which they are to be used. This regulation has been described as “odd” by at least one judge who held that employers in all cases, regardless of height, must assess whether it is reasonable to provide fall protection (see Department of Labour v Hassett t/a Hassett Builders [2009] DCR 398). The only other relevant rule is regulation 22. This provides that if construction work cannot be carried out safely without scaffolding, then scaffolding that is suitable, properly constructed, adequately strong and of sufficient amount must be provided. The dearth of regulation means that duty holders must themselves interpret and apply their general obligations when working at heights, which unfortunately has contributed to the development of varying practices across different industries, and sometimes within them. Guidelines Perhaps as an attempt to address the lack of specific regulation, in 2012, MBIE (as part of the Height Project) released the Best Practice Guidelines for Working at Height as well as the Best Practice Guidelines for Working on Roofs. These are to be read with more tailored information for specific industries available on WorkSafe NZ’s website. While the uninitiated may find it difficult to navigate all of these guidelines, brochures and factsheets, they do provide some much needed detailed assistance when working at heights and abiding by them will assist with compliance and in defending any enforcement action taken by WorkSafe NZ. But, like any guidelines, they are not binding on duty holders and they may choose not to follow them. In addition, the courts may also deviate from them, for example, if the expert evidence is to the contrary.
Offences and penalties Under the HSEA, if a person acts (or fails to act) knowing that serious harm is reasonably likely to result, then they are liable on conviction and imprisonment of up to two years and/or a fine of up to $500,000. However, given this high threshold, prosecutions are usually brought under the lesser offence of a failure to comply with a duty, which carries a fine of up to $250,000. Criminal liability may also be imposed on directors, officers and employees who directed, acquiesced or participated in an organisation’s failure. A prosecution may be brought even though no accident has occurred, which will be seen increasing often as part of WorkSafe NZ’s reinvigorated approach. For example, in July 2014, a roofing company was convicted and fined $15,000 for failing to ensure it had adequate measures in place (such as scaffolding and edge protection) to protect its workers from the risk of falling from a second-storey roof. The position over the ditch Compared to our regulations, the Australian Model Regulations are more comprehensive. Falls are identified as “hazardous work”
and specific control measures must be adopted, where these are reasonably practicable. The Australian regulations require the duty holder to manage the risks of a fall from one level to another that is reasonably likely to cause injury. This includes the risk of a fall in or on an elevated workplace, near an opening or an edge, on a
minimised by providing adequate protection from falls, such as by providing fall prevention devices, work positioning systems or fall arrest systems. Definitions and explanations of these terms are also included. Fall prevention devices include secure fences, edge protection, working platforms and covers. Work posi-
“Somewhat surprisingly the current regulatory regime contains little prescription over working at heights” surface, or any other place from which a person could fall. To avoid or eliminate the risk, the duty holder must ensure, so far as is reasonably practicable, that any work involving that risk is carried out on the ground or on “solid construction”, which means an area that has: • a surface structurally capable of supporting people or things located or placed on it; • barriers around its perimeter and any openings to prevent a fall; • an even and readily negotiable surface and gradient; and • a safe means of entry and exit. However, the Australian regulations prescribe that if the risk cannot be eliminated, it must be
tioning systems enable a person to be positioned and safely supported at a location for the duration of the work being carried out. Examples of fall arrest systems include industrial safety nets, catch platforms and safety harness systems (other than a system that relies entirely on a restraint technique system). Specific criminal offences and fines are prescribed for breaches of each of the Australian regulations, which further enhance their importance and enforceability.
A recent court case has highlighted yet again the importance of installing and using fall protection equipment when he stepped on a piece of timber that had yet to be fixed down, causing him to fall five metres onto the concrete floor below. Fall protection equipment including mobile scaffolds, a scissor lift and thirty ‘fall arrest’ bean bags were available at the site, but was not being used. CMP Construction was convicted in the North Short District Court and sentenced under sections 18 and 50 of the Health and Safety in Employment Act for failing to take all practicable steps to ensure Mr
Sherridan Cook is employment partner at Buddle Finlay, one of New Zealand’s leading commercial law and public law firms with offices in Auckland, Wellington and Christchurch
Where to from here? While some may balk at this level of prescription, the inadequacies in New Zealand’s health and safety regulation have been laid all too bare by Pike River.
No excuse for failing to reduce risk of falls CMP Construction Ltd was fined $30,000 and ordered to pay reparation of $10,000 in September after an employee of a sub-contractor fell from a height of five metres. Mohammad Ouzoun suffered multiple fractures and significant head injuries after the fall in August 2013, and suffers ongoing medical effects including headaches and amnesia. Mr Ouzoun was installing the supporting frame for the roof of a new retirement home in Albany
The thinking underlying the current reforms is that more comprehensive regulation is more likely to result in compliance and better behaviours by duty-holders. Assuming that is right, more prescriptive regulation of working at heights should result in fewer falls. Therefore, we are likely to see a similar degree of prescription in New Zealand as in Australia when our corresponding “hazardous work” regulations come into force in April 2017 (as currently planned). In October 2013, SafeWork Australia said that after a comparison with figures from 20 years ago, the number of workers who die each year due to a fall from height had halved. Hopefully New Zealand will soon be able to boast similar statistics.
Ouzoun was not harmed at work. WorkSafe New Zealand’s Programme Manager Construction and Manufacturing Marcus Nalter
says CMP Construction should have ensured that the fall protection equipment that was provided was used. “CMP Construction had verbally advised Mr Ouzoun’s employer that the scissor lift and bean bags should be used while work was being done on the upper area of the roof trusses,” he says. “But it did not ensure that the sub-contractor’s fall protection controls were properly documented or that the risk analysis for the task was reviewed, updated and followed.” Falls from height are one of the most common causes of serious injuries in construction, Mr Nalter adds. “There is simply no excuse for construction companies not to ensure there is a proper plan in place to minimise the risk of falls.”
www.isn.co.nz
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TECHNOLOGY>> New Zealand Red Cross
The one app that might just save your life
The New Zealand Red Cross First Aid and Emergency App was officially launched on World First Aid Day, Saturday 13 September, and is fast becoming very popular
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n 2012/2013 ACC accepted 1.7 million new claims with more than one million of these occurring in the home and community. Given the importance of first aid in all parts of our lives New Zealand Red Cross is not all that surprised about the App’s instant popularity. Being able to provide first aid is essential to help those you care about most. The App was developed for Aotearoa as part of a global project by the Red Cross’ Global Disaster Preparedness Centre. It is designed to give people life-saving skills at their fingertips It is free and features simple, easy advice on everyday first aid scenarios, tips on how to prepare for natural disasters, and step-by-step instructions during an emergency For workplaces which have invested in the health and safety of their workers the app is a great tool to have people thinking about first aid and assist employees, with step-by-step instructions to guide you through emergency first
aid situations. Sections such as dealing with a broken bone and even recommending when to call an ambulance are available with a push of the button right from the app. The app doesn’t replace the need to do a first aid course but allows staff to revisit knowledge and skills between refreshing their first aid certificate every two years. Skills like how to stop bleeding or deal with an allergic reaction. Staff who are untrained in first aid can
app thoroughly. Thirty-five school and community groups registered to take part in the app ‘Test Pilot’ programme. For
to be prepared. The app is a great way to have people thinking about what they might need to do to be prepared
learn about essential skills so they have the confidence to help in an emergency. It may be that their co-worker has a medical condition such as asthma and they want to be prepared should they have an asthma attack. New Zealand Red Cross can provide graphics and media materials for organisations to promote the app to their employees to further enhance their ability to respond in an emergency. Over the last few months Red Cross has been testing the
many of the test pilots it was their first Red Cross mission. They were expected to provide detailed feedback on each section they tested on a range of devices. We couldn’t have thought of a better group than our tech savvy teenagers. Civil Defence Emergency Management (CDEM) Groups around the country, will be promoting Get Ready Week 2014 – 21 to 27 September throughout New Zealand aimed at raising awareness of potential hazards and the need
in their community or workplace and develop plans with colleagues, family friends and neighbours. During the Christchurch earthquakes these plans were put into practise time and time again and the co-operation between workplace, schools, and communities became very coordinated. People were far more resilient as a result. Download the app today from www.redcross.org.nz/app and help us in our mission to enhance community resilience.
Red Cross First Aid and Emergency app LEARN Simple, easy-to-understand advice and frequently asked questions on everyday first aid scenarios and CPR. Videos, step-by-step instructions and animations make it fun and easy to pick up.
PREPARE Get expert tips on how to prepare for some of the most common emergency situations. Includes checklists on how to prepare and tips on what to do during a natural disaster.
EMERGENCY This instantly accessible, step-by-step section gives you just
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enough information to know what to do in emergency first aid situations and allows you to call 111 from the app.
TEST Find out how much you’ve learned by taking interactive quizzes. Earn achievement badges and share them with your friends on Twitter and Facebook to show off your life-saving knowledge.
INFO Find out more about the life-saving work of New Zealand Red Cross, including volunteering opportunities, and the latest news and information on first aid courses
FOCUS>>Forestry Safety Review update
Forestry industry groups at loggerheads regarding safety recommendations A war of words is brewing as the forestry industry awaits the release of the independent Forestry Review Panel’s final report with recommendations to reduce the sector’s death and injury toll
Is self regulation an acceptable solution? The different opinions of key forestry players (from left: Collins, MacDonald, Stulen and Kelly)
“Responsibility for effectively managing risk and harm lies where it is created – in the workplace and with duty-holders” – Gordon MacDonald
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he battle lines have been clearly drawn, with the New Zealand Council of Trade Unions (CTU) and WorkSafe New Zealand in particular holding diametrically opposing views on how the industry can improve its appalling safety record. The CTU insists that self-regulation isn’t the answer to the problem, while WorkSafe is of the opinion that the industry is responsible for its own destiny and its members should police themselves. “The CTU does not support Worksafe’s submission to the independent Forestry Review Panel that there can be an “industry led” approach to addressing the serious issues workers in the sector are facing.” CTU President Helen Kelly says. “We believe Worksafe should learn by the experience of its predecessors, where industry-led initiatives have not worked.” She cites the Ministry of Business, Innovation and Employment’s (MBIE) 2011 development of a number of Sector Action Plans in New Zealand’s most dangerous industries – construction, agriculture, forestry, manufacturing and fishing. “They ran until 2013 and were intended to result in a significant reduction in injuries in these sectors,” she recalls.“They were industry driven in industries that had shown a lack of capacity to deal
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with the safety issues.” Four of them had an “industry lead” Safety Council structure with only manufacturing having worker representation, with most of the remaining sectors being left to their own devices. However, Maritime New Zealand took a different approach with regard to fishing and led the Safety Council initiative in the form of Fishsafe. “The only industry where serious harm injuries notably reduced was fishing – in others the figures increased,” Ms Kelly observes. “It is imperative that the Forestry Review Panel recommend that Worksafe is established as regulator and that the Forest Expert Advisory Group is put in place to
looking for evidence of sustainable change from the sector beyond its decision to convene the Independent Forestry Safety Review. “The mixed signals emerging from our engagement with the sector present us, as the Regulator, with some difficulty in determining its future approach,” Mr MacDonald admits. “Principals appear to be meeting their legal obligations within the contracting chain, yet men are dying on the hill.” His concern is illustrated by the fact that WorkSafe inspectors made 501 workplace visits between August 2013 and June 2014 and issued 698 notices where workers were at risk of serious harm because basic accepted con-
“Forestry Industry Contractors Association looks forward to working with everyone in our industry, including WorkSafe, on this action plan” provide advice.” WorkSafe, meanwhile, says there are principals, contractors and workers across the sector who are making safety a non-negotiable priority in their workplaces: the challenge is to move the whole sector to best-practice behaviour. WorkSafe Chief Executive Gordon MacDonald notes that the sector killed 10 workers in 2013 – the highest death toll in a decade – and adds that his organisation is
trols were not in place. “Contractor leaders are too often not acknowledging the safety failures in their membership that we are uncovering,” Mr MacDonald believes. “Some crew bosses are walking past potentially fatal health and safety failures on a regular basis and not acting on them. Furthermore, some are not involving their workers enough in the design and planning of operations; the men who are on the hill and
can tell them where the risks are.” “The Regulator has a role to play, but loading us with too much of the responsibility will maintain a position where the sector is too dependent on being told what to do by the Regulator rather than devising, implementing and sustaining its own improvements,” Mr MacDonald maintains. The panel’s suggestion, for example, that WorkSafe, rather than industry, should convene a forestry sector expert advisory group sends the wrong message about where responsibility lies, he says. “Responsibility for effectively managing risk and harm lies where it is created – in the workplace and with the duty-holders,” Mr MacDonald avers. “Most importantly, a reactive approach will not deliver the improvements we all want to see.” “Sustainable change in this sector will not occur without everyone committing to it, holding each other to that commitment, and, critically, working together rather than in a fragmented way.” The forestry sector must lead the development of the blueprint, strongly supported by WorkSafe. “A blueprint could be in place by March 2015 if the sector made a firm commitment to change and backed that up with the resources to put in place credible plans.” Mr MacDonald’s comments were
welcomed by Forestry Industry Contractors Association spokesman John Stulen because they highlighted “vital issues” such as an economic model that it says creates tension between profit and worker, and problems with the supply chain and short-term contracts. Mr Stulen also welcomed WorkSafe’s intention to work alongside industry to create a ‘‘Blueprint for Safer Forests’’. “They have said they are dedicated to collaborative action, strong problem identification (including root cause accident investigation) and accountability for all,” Mr Stulen says. For its part, the Forest Owners Association (FOA) says point scoring in the media will not make forests safer places to work. “The unions are claiming credit for a sudden reduction in the fatality and serious accident rate and Worksafe NZ is slamming us for a lack of safety leadership. These comments are unbalanced and unhelpful,” says association president Paul Nicholls. Political posturing and blaming others won’t save workers lives, he insists. “To transform the industry’s safety culture, participants will need to acknowledge their past shortcomings and to share experiences and knowledge – they are less likely to be open to this if they are being publicly pilloried.” Mr Nicholls says this year’s lower accident rate is “great news”, but points out that it’s the long-term trend that counts – accident rates fluctuate from year to year. He also claims the FOA has been associated with every major safety initiative in the industry in the last 20 years. “In that time the long-term serious accident rate in the sector has halved, relative to the number of trees harvested. Also, the accident rate in forests managed by FOA members has fallen to 25 per cent of that in non-member forests. “We still have a long way to go before we achieve our goal of being a zero serious harm industry, but we are heading in the right direction.” “Our safety resources are freely available on the web to all operators,” Mr Nicholls explains. “But
we don’t have the power to enforce good practice – that’s the job of the regulator.” Mr Nicholls says improved safety requires the commitment of the owner of the forest, the employer, the employee, ACC and MBIE/ Worksafe. “Until last year, ACC and MBIE/Worksafe were not pulling their weight,” he maintains. “They have acknowledged this and have pledged to work with the industry on safety initiatives and to properly resource the safety inspectorate.” The FOA “welcomes that” but says more could and should be
done. “Worksafe inspections – especially of operations where the risks are the greatest – need to be routine – not just something that’s done in those years when there is a spike in the accident rate.” He says the trade union campaign and publicity about the industry-funded Independent Forest Safety Review (IFSR) have raised awareness of the need for safe work practices, but he argues that short-term campaigns do little to improve long-term safety outcomes. “We have to make permanent
Forestry safety review group completes task
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he Independent Forestry Safety Review has been completed and the panel is now working on its Final Report, which is due for completion by the middle of October. The report will recommend a package of practical measures that would be expected to result in a significant reduction in the rate of serious injuries and fatalities in the forestry sector over the next five years. The panel received 111 written
submissions on its consultation document from government agencies, forest industry stakeholders and individuals and travelled to several forestry regions to hold public consultation meetings and private meetings with contractors and workers The panel spoke with more than 540 forestry workers, contractors, forest managers and owners, trainers and assessors and a range of other stakeholders, and also conducted a survey of some 340
changes to forest operations so that safety is still seen as a top priority when the publicity fades away,” Mr Nicholls concedes. “We are putting a lot of effort into a joint ACC/FOA injury prevention programme, with materials being rolled out over the next six months.” Mr Nicholls says the industry initiated the review with government support and sought to include the views of all people with an interest in the sector. “The Combined Trade Unions is one of those parties, but they represent only four per cent of the forest workforce.”
forestry workers to date. Panel members George Adams (left), Hazel Armstrong and Mike Cosman began work in January this year, having been appointed by the forestry industry and funded by the Forest Owners Association, Forest Industry Contractors Association and Farm Forestry Association. The appointment of the independent panel and its terms of reference were endorsed by forest industry organisations, ACC, relevant government agencies, the Council of Trade Unions and the Business Leaders’ Health & Safety Forum.
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FOCUS>>Forestry Safety Review update
CTU plants seeds for healthy forestry The New Zealand Council of Trade Unions (CTU) submission to the Independent Forestry Safety Review panel offers an exhaustive list of recommendations that it believes will improve industry safety
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he CTU submission notes that there have been 967 serious injuries in the industry since 2008 but the Forestry Industry Contractors Association (FICA) holds a data base of 10,000 additional near-miss incidents. Any of these could have resulted in harm and the level of accidents combined with near-misses must cause extreme alarm, the union body observes, though it concedes that accident rates have fallen since a disastrous 2013 that claimed 13 lives in the forestry sector. “The reduction in accidents for this part of the year shows two things – firstly, it can be done and there is no valid excuse for the years and years of appalling safety outcomes,” Ms Kelly believes. “Secondly, sustained worker organisation is essential to ensuring the performance of the system.” The CTU submission says the reality is, however, that none of the activities are sustainable. “The review will finish, Worksafe does not have the resources for continual inspection at the levels currently being undertaken and the union and family campaign is taking huge resources from its participants.” The union believes the job of the Review Panel must be to recommend changes to the structure of the industry that embed this safety focus and ensure the accident rate
continues to fall. “What the reduction has shown is that reduction is possible. What the recommendations must do is set the platform for a sustained and permanent change,” Ms Kelly maintains. The union body recommends that: • an emphasis is given to the role of Government as regulator in the first instance unless the panel is confident industry-led change is achievable with the current leadership • the Review Panel develop proposals to reduce the use of sub-contracting in the sector, and consider if the current level of contracting by forest owners should also be addressed • the Forestry Industry Contractors Association (FICA) and the Forestry Owners Association (FOA) commission research to determine the state of wages and conditions of work in the sector • the Review Panel consider the benefits of recommending separate forestry safety legislation in New Zealand • the panel call for worker representative systems and committees to be a requirement in all workplaces in forestry including the ability in the new health and safety law for the Minister to designate a roving representative system in forestry
into each of the issues above and • the panel call on the government that the industry co-operate with to ensure new health and safety that research to provide the data law includes responsibilities for forest owners who may be based • Worksafe and employers respond to recommendations from the off shore Coroner • the panel recommend that employers facilitate opportunities for • the industry and union negotiate an employment standards guide workers to get genuine informain forestry and that this guide is tion about the union and how to promoted through supply chain join and that rhetoric opposing contracts to regulate safe and fair unionisation in the sector ceases minimum terms and conditions • the industry commit to training (this guide should include (but 500 health and safety elected not be limited to) issues such as representatives by the end of the weather, representative systems, year and to develop a plan with training including payment for the First Union for the period foltraining, PPE gear including wet lowing to ensure a sustainable weather gear, driving time, hours worker participation system in of work and wages) the bush regional inspector hubs which • the industry including unions and • also include roving industry workWorksafe develop an implemeners representatives be considered tation map for the new health in forestry intensive areas of the and safety legislation including country the necessary steps, clarifying the various roles and a timetable • specific forestry safety legislation and industry tripartite structure to be considered, including a “safe rates” commission carry it out the quality of investigations • Worksafe enforce the notification • be reviewed including some requirements including through standardisation of essential eleprosecution and use them in inments and the development of vestigations and for planning best practice investigation and interventions reporting • farm notifications be inspected • standardisation of essential elebefore the work begins ments of investigations be agreed • Worksafe develop a website with and that data from investigations compulsory public recording of is indexed to enable easy idennotices tification of common accident • Worksafe commission research
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Sept/Oct – 2014
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causes and Person Conducting a Business or Undertaking (PCBUs) • there be a separate Worksafe inquiry into logging truck safety and that logging truck accident data be identifiable to the forestry industry • Worksafe and the industry engage with the families to agree protocols on communication, treatment of the dead body and information regarding family’s rights in regards to the investigation including the notification requirements in regards to prosecution, rights to be represented at Coroners hearings etc • a “one-stop shop” be developed for access to relevant forestry regulations and guidelines and that were possible documents include detail of essential elements rather than cross referencing • the current Approved Code of Practice (ACOP) be immediately and comprehensively reviewed • effective ways to communicate with forestry workers be explored by Worksafe and new approaches developed • accident reports be made available by Worksafe as soon as possible • consideration needs to be included in the panel findings of mechanisms to manage production pressure • research and testing of resources for workers be undertaken • the industry move to a system of qualifications including built-in experience requirements • terms of employment should
be linked to both training and service with qualified workers attracting a pay premium • training should not be funded by the workers • mandatory training standards for all jobs be set and a qualifications board established to support the development of curriculum, recognise programmes and providers, register trained workers and offer ongoing professional development • trained workers continue to have professional development • time off for training be part of the negotiated minimum standards of employment. • the government reintroduce the forestry apprenticeship • the industry set targets for training and be monitored against them • forest owners take the primary role for ensuring training targets are met and training is supported including through funding • return to work policies for trained workers returning to the sector be developed to ensure skills are refreshed • mechanisms be developed to ensure contracting rates are safe • forest owners and contractors behave neutrally to the issue of union membership and provide access to union information to their workers • the industry set a target for elected health and safety reps to attend CTU health and safety training in the next year and agree a programme of delivery
with the CTU including shifting a significant number of reps to level 2 training and for inspectors to know these reps and meet with them to support them in their regions 3 or 4 times a year • there be greater enforcement of the facilities provisions, the minimum wages code and the requirement to have written agreements in forestry • a plan be developed to implement the “stop work” rules in the new legislation • there be as much standardisation as possible around the expectations for infrastructure • basic rules should make stopping mandatory unless the whereabouts of a worker can be established • trucks and other safety zones on skid sites should be coned off to ensure people stay out of them • lighting should be required if night or early morning work is undertaken • communication needs to be twoway and modern technologies (such as GPS systems) need to be invested in for better identification of worker location and hazards • systems need to ensure breaks are taken, hours are managed and driving is not done by tired workers • work speed needs to be understood as a hazard and managed • machines and gear specifications should be regulated including the use of machines • those maintaining machines
should be suitably qualified for these types of machines and the work they will do • wet weather gear be regulated as part of PPE • adequacy of lighting be required • two-way mobile communication equipment be required • drivers qualified for machines • qualifications of those maintaining machines be examined • partial mechanisation creating pressure on those working manually must be factored into safety systems • recommendations on fatigue be separated out from other impairment issues • research and policy work be undertaken to identify the impact of fatigue, how it is caused in forestry work and how to manage it so that it is not a hazard • the ACOP regulate for fatigue and industry standard conditions of work include provisions to address it.
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FOCUS>>Forestry Safety Review update
Forestry industry must cut its own deadwood, regulator insists WorkSafe New Zealand believes there is too much focus on the regulator as the solution to the forestry industry safety problem and recommends a Safer Forests Blueprint for Action plan to right the wrongs
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he country’s workplace health and safety regulator’s submission to the Independent Forestry Safety Review panel identified five specific problems which WorkSafe say must be addressed with urgency: • supply chain issues • undervaluing safety • competency deficits • poor safety culture • insufficient investment in forestry infrastructure. WorkSafe stresses that these problems will not be resolved by the regulator alone and the forestry industry must take responsibility for improving its safety standards by addressing several major challenges. Leadership The regulator says there are obvious issues with the consistency of leadership in this sector. WorkSafe has identified a potential role as a catalyst for, and contributor to, the sector achieving its own leadership, and believes that until that is in place, resolving many of the following challenges will be made more difficult than it should be. Hazards versus risk The sector (including the regulator) has traditionally focused on visible hazards rather than identifying the underlying causes. Moving to a risk management focus which deals with the root causes of poor practice is a high priority for WorkSafe – and must be for every participant in the sector. Worker Participation At and around the bushline, there is too little worker involvement in safety matters. In some cases this is in contravention of the law, but in all cases, it is a failure to understand the value those at the frontline can bring to safety development. There is also some evidence that legal requirements under employment
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relations law are being flouted. Creating Sustainable Change The ability to create sustainable change lies with the sector. WorkSafe’s firm position is that responsibility for resolving risk and harm in this sector lies where it is created – in the workplace, office and boardroom and by individual workers and the relevant duty holders. Workers need training and the opportunity to participate in decision-making processes that will lead to this change. The Safer Forests Blueprint for Action should focus strongly on this aspect. The regulator as a solution WorkSafe believes the sector turns too early and too regularly to it for solutions and notes that the Independent Forestry Safety Review panel’s discussion document also places significant responsibility on the regulator to achieve the change it seeks. However, it believes the regulator is not the solution to this sector’s problems. WorkSafe says it has duties which it will discharge to the best of its ability, while also having responsibilities to help identify solutions to the problems. Shared responsibility and clear accountability WorkSafe says the forestry sector is not yet sharing responsibility and accountability for the state of its safety performance. The evidence WorkSafe has gathered to date indicates there is a significantly variable acceptance of accountability for safety in the sector. The good operators in this sector need and deserve others to stand alongside them. A fragmented sector The panel has identified a lack of cohesion in the varying elements that make up this sector and WorkSafe agrees. It believes this lack of cohesion is a substantive barrier to
achieving sustainable change. The whole sector must put its collective strength behind safety improvements. This will require collective acceptance and ownership of problems created and resolvable within the sector. The “fault and blame” culture must be replaced with a culture of collaboration to achieve markedly improved safety performance in the interests of every worker. Support at the bushline WorkSafe believes one of the critical points of intervention is with the contractors and crew bosses. The variability of safety performance at this point must be addressed. It is concerned that the structure of the sector transfers the risk and responsibility for safe performance to this level, which is too low. The sector must address this pivot point with the assistance of the regulator. Regulation The panel advocates strongly for mandatory (read: regulated) standards in many areas. WorkSafe believes further investigation is required into the impact of regulation on safety performance, and is open to the concept in some, but limited areas. But it says regulation is not the fundamental problem – it maintains that the obligations on duty holders are sufficiently clear in current and future legislation and that imposing regulation above these obligations requires careful analysis. Data There is a widely acknowledged need for better data in forestry. WorkSafe is building a bank of reliable information and analysis about a range of safety-related issues in the sector and will continue to develop that resource, which it intends to share widely. It notes that the Forest Owners Associa-
tion holds a significant amount of data which is of considerable value to the sector and should be made more widely available. The right to operate WorkSafe strongly believes it’s acceptable if some operators leave the industry as a result of the safety improvements required and this should not become a barrier to action. If an operator cannot reach acceptable safety performance standards, no matter what part of the contract or supply chain they are in, that operator has no automatic right to continue operating. The regulator’s performance WorkSafe accepts that its performance has been lacking over time and says it has responded with a more sophisticated approach involving multiple levers. It is continuing to refine its approach in the interests of making the most effective impact on safety performance. WorkSafe is investing in inspector capacity and capability, support resources and systems. It believes its acceptance of past failings and active development of a new, more sophisticated approach will make a difference, but will make an even greater difference if it is matched by each participant in the sector doing the same. The regulator can never be resourced to act as the first line safety check; the lead must come from industry. Continuing regulatory action and support WorkSafe must, by law, continue to regulate this sector. As future, sector-led programmes to improve safety are developed, WorkSafe will continue: • compliance and enforcement work – there is still too much evidence that safety compliance is variable and in some areas failings are at concerning levels • guidance – revision of one section
Forestry road safety
T of the Approved Code of Practice is underway and further, wider work will begin shortly • education and engagement activity at all levels in the forestry sector • working in partnership with ACC. The regulator’s approach to its role WorkSafe will implement a new intervention approach shortly which will move its focus firmly onto risk and safety systems performance. That will include high levels of engagement with the sector, continuing support with guidance and education, and a strong enforcement line where people are put at risk of serious harm. The outcomes of the Independent Forestry Safety Review WorkSafe believes is confident that the wide input from inside and outside the sector will inform a strong, relevant and implementable set of recommendations. WorkSafe will be open to these and to working within its legislative and regulatory mandate to embed and assist the embedding of new behaviours in the sector. Conclusion WorkSafe recommends a Safer Forests Blueprint for Action be developed by the sector, which ultimately creates the harm and risk and must therefore manage it. The regulator will make significant contributions but expects the industry to step up to take on responsibility for safety leadership, allowing WorkSafe to revert to those activities for which it has responsibility and accountability. WorkSafe is adamant in its belief that this blueprint must be led by the sector if is to be a successful lever to effect sustainable change, and believes the blueprint could be in operation within six months with the right level of commitment and support.
he University of Canterbury is to launch a new research project to make sure New Zealand’s new forestry roads are safe and are established with minimal environmental impact. The New Zealand forestry industry is building more than 1400km of new roads a year and the research, to be conducted by Dr Kris Brown, will help improve design standards. The research at the university’s School of Forestry is designed to help raise standards for design, construction and maintenance of forestry roads. “The likelihood of accidents can increase when infrastructure is not specifically designed for heavy forestry machinery and logging trucks,” Dr Brown explains. “Infrastructure not wide or strong enough to withstand repeated heavy loads has been cited by the coroner as a contributing factor in accidents.”
Associate Professor Visser says building a new road to access forest areas for harvesting can easily cost more than $100,000 per kilometre, which has to be recovered from the value of the trees harvested. The industry spends about $200 million a year on roads, he notes. “As such our industry is seeking to build ‘fit-for-purpose roads’, a concept that attempts to minimise costs while not compromising safety and environmental performance,” Associate Professor Visser adds. Research done to date at the University of Canterbury has indicated that the forest industry can readily improve its road construction practice by correctly testing, and subsequently compacting the substrate on which the road will be built. “Most forestry companies use aggregates from in-forest quarries, and these aggregates do not typi-
cally meet a strength standard on which the national design curves are based,” Associate Professor Visser explains. “While new design standards for the lower quality material being used have been developed, we still need to test their validity.”
Forest managers branch out
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Kerikeri-based forest management company is showing the industry the way forward by helping its staff grow their health and safety knowledge. With forestry acknowledged as one of New Zealand’s most dangerous and hazardous industries, Northland Forest Managers co-owner Liz Kingsford decided to get ahead of current and upcoming health and safety legislation. By bringing senior staff and contractors together in one programme specifically designed and tailored to their needs by NorthTec the company has created a strong safety culture. Northland Forest Managers’ bases in Kerikeri and Dargaville are responsible for nearly 20,000 hectares of forest land which it manages on behalf of its land-owning clients and has 10-plus crews comprising a contract workforce of more than 150 people. Liz Kingsford said that she and husband and company Managing Director Nick decided last year that
Forestry supervisor Kieran Sharp says the programme is giving him a better understanding of health and safety legislation and a clearer overview of safety practices across the industry they wanted to raise the baseline level of health and safety management within their business. “Health and safety is a learned skill,” she insists. Northland Forest Managers takes the view that it’s a management company in a position of managing other organisations and operations. “We needed to have a certain level of expertise in-house to ensure we
were doing it diligently,” Ms Kingsford explains. It is an applied science that also shares the responsibility across the organisation and creates a culture of health and safety. “We wanted everyone to be competent managers of operations in terms of the health and safety aspects they would have to manage,” Ms Kingford says.
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HEALTH>>Fatigue
Fighting the devastating dangers of tiredness is a major challenge for local business There’s an invisible and potentially destructive force at work in New Zealand workplaces the recent WorkSafe New Zealand fatigue and impairment in construction forum was told
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atigue isn’t just feeling sleepy – it’s an acute, ongoing state of tiredness that impairs people both physically and mentally, prevents people from functioning normally and safely and affects their fitness for work says workplace behavioural consultant Matthew Beattie. “It manifests itself in loss of alertness and performance from too little or poor quality sleep, working at normal sleeping times such as the end of a long day or shift work,” the CEO of BSSNZ explains. “Fatigue is particularly prevalent in mentally or physically demanding work or routine or cyclic work where each cycle appears same as previous.” As such, it is a leading cause of impairment at work, along with alcohol, illegal drugs, medication, caffeine and nicotine, psychological factors, medical conditions and stress. “Fatigue management is extremely important to 21st century businesses principally because today we are working longer hours – a month longer per year since 1900 on average,” Mr Beattie adds. Other key factors include: • global demand for products and services • a demand for instant rather than delayed gratification – ‘we want it now’ • the fact that 70-hour working weeks aren’t unusual • a desire to use the other hours of the day for family and relaxation such as night sport and entertainment rather than rest • working some distance from established family or support structures • smart technology that ‘demands’ instant availability. Add all this up and we have become time-poor, leading to a battle within, Mr Beattie believes. “Opposing forces include the fact that the human body operates at peak efficiency when we are awake for 16 hours and get eight hours sleep,” he says. “Our demand for time keeps drawing on the eight to extend the 16.” In addition, the body has natural cycles. “The circadian rhythm prefers that we wake post dawn and go to sleep early evening – there are circadian ‘dips of low alert’ after lunch and in the pre-dawn,” Mr Beattie explains. “The problem is being awake when we should be asleep and asleep when we should be awake, but we are all different and we must learn how to manage this battle individually.” Several severe health problems can result from poor sleep, which is characterised as less than six hours sleep per day often broken by insomnia: • a 45 per cent higher risk for cardiovascular disease (weight control,
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cholesterol, poor diet, smoking, lack of exercise, higher stress) • obesity (poor diet, weight control, lack of exercise) • a 2.5 x higher risk for diabetes (particularly adult-onset Type 2) • a lowered immune system (more colds, flu, headaches etc – more so for shift workers) • reducing life expectancy by 12 per cent (8-9 years). However, the average time asleep per person per day in New Zealand, Australia and the US is five to six and a half hours when the desirable time should be seven and a half hours, Mr Beattie notes. “Sixty per cent of adults in New Zealand, Australia and the US have a sleeping disorder such as sleep apnoea, insomnia, narcolepsy, restless legs or gastroesophageal reflux,” he says. “Up to 50 per cent of the population suffers from insomnia at some point in their life, which is defined as failing to sleep within 30 minutes after lights out or waking after a couple of hours and failing to get back to sleep easily again.” Poor sleep and associated fatigue have obvious impacts on organisations and businesses including: • increased rates of incidents and accidents (including near misses) • loss of productivity • higher maintenance costs • higher levels of absenteeism, presenteeism and turnover. Similar adverse effects are experienced by employees: • increased accident rates, both at work and elsewhere • increased medical disorders (gastro, cardiovascular etc) • higher levels of stress and associated illness (e.g. anxiety, depression) • higher rates of personal and relationship problems. “In addition, those already suffering from digestive disorders, diabetes, heart disease, psychological, alcohol and drug addictions and chronic sleep disturbances face additional burdens,” Mr Beattie adds. As if that’s not enough, the fatigue and disruption that results from shift work or continual long hours often makes having a normal family life impossible. “As a consequence, over time employees become disaffected with their employer because it is easier to blame outsiders rather than make a personal change,” Mr Beattie warns. “This disaffection in turn impacts on safety, health, productivity, morale, absenteeism and turnover.” Mr Beattie cited three key misconceptions regarding fatigue: • that fatigue can be effectively addressed by a focus on rosters and hours of work • those efforts to control fatigue should have as their primary focus the establishment of workplace ‘systems’ to reduce the role of the individual in managing fatigue • that there will be a technological ‘silver bullet’ that will solve all fatigue problems. “This is misplaced thinking because two well-researched beliefs by Dr William Dement of the Stanford University Sleep Research Center and Harvard Medical School Dr Lawrence Epstein show the primary cause of fatigue is inadequate or poor quality sleep, and the effective management of fatigue depends on the organisation’s culture and on the promotion of self-management rather than technological solutions,” Mr Beattie explains. Employers should therefore be aware of and on the lookout for the signs of fatigue: • alert - perky, strong eye contact, normal eye blinks, attends to sur-
roundings, co-ordinated movements • slightly fatigued - irritable, impatient, wandering thoughts, rubs eyes, restless, yawning • moderately fatigued - tired appearance, quiet, withdrawn, long blinks (1-2 seconds), trouble following instructions, frequent yawning • dangerously fatigued - little or no activity, fixed staring, unresponsive, long blinks (2 or more seconds), sudden startle responses, micro sleeps The effects of sleep loss are almost immediate and reasonably obvious: • loss of two hours sleep per day for 1-2 days – mood change • loss of two hours sleep per day for 3-4 days – impaired vigilance • 24 hours without sleep – coordination & memory problems • 48 hours without sleep – micro-sleeps, hallucinations Unfortunately, while the effects of fatigue and sleep deprivation are well known, there is very little information specifically related to the construction industry, Mr Beattie admits. “There are quite a lot of anecdotal stories such a micro-sleeps, near
The haul truck driver fell asleep on his third consecutive night shift, having been continuously awake for almost 16 hours with an accumulated sleep loss of approximately nine hours and was driving just before daybreak, one of the most difficult times to stay awake
Employee Fa gue Profile (SCIRT – Christchurch)
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16
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100%
65%
misses and accidents, but only recently have we started to gather data on the construction sector, particularly in Christchurch.” “This data is gathered by aggregating the individual assessments done at training to produce an organizational profile. It tells a story” The construction industry can better to manage risk from employee fatigue by implementing the training in fatigue and sleep management suggested by Dr Epstein – to wit “the effective management of fatigue depends on the organisation’s culture and on the promotion of self-management rather than technological solutions.” To this end, BSSNZ utilises the BSS Complete Fatigue Management Workbook, a 100-page manual that is composed of two-thirds informa-
Individual to Organisational
Employees
12
41%
10
8
6
4
2
0
Low Risk
24: Is 13: 20: 16: your 25: 26: 21: 17: 18: 19: 12: Sleep 1: How 27: 22: 23: Health Outsid 2: 6: 7: 8: 10: 11: drinkin Drugs Smoke Major Family Work Work Sleep disturb red 3: Days 4: Day 9: Exercis Caffein Alcohol and e Sleep Insomn Apnoe Narcol Restles Sleep g to help before health commi enviro stress enviro ance are off shi Reflux e e use selfcommi type ia a epsy s Legs habits danger sleep sleep issues tments nment level nment by you? care tments ous? partner 0
1
10
9
4
11
13
16
12
0
8
11
6
11
2
8
3
12
12
14
9
15
7
Medium Risk 12
11
5
7
2
5
2
0
2
16
7
2
4
4
11
7
10
2
4
1
5
1
1
9
High Risk
5
2
1
11
1
1
0
3
1
2
3
7
1
3
2
3
1
1
1
2
0
0
1
5
15
tion and one-third assessments. “The training uses the VAK or Visual, Auditory, Kinesthetic method and takes about six hours,” Mr Beattie explains. “It’s designed so that individuals can compare themselves against a ‘traffic light’ standard and if they decide that they want to improve, they can conduct their own intervention and implement their customised fatigue management plan.” This hands-on, self-help approach helps supervisors monitor fatigue every day and has proved so effective that it is used as a checklist at prestart in mining. “We train every participant to use the approach shown in the same way as if they were monitoring for the impact of drugs and alcohol,” Mr Beattie adds. However, he says is important to be aware that the workbook is not a magic one-stop, cure-all. “Some people, particularly chronic insomniacs, will need follow-up from training,” Mr Beattie advises. “Some people have real clinical needs”.
Continued on page 26 www.isn.co.nz
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HEALTH>>Sleep and blood pressure
Sound sleep the key to better blood The effects of high blood pressure are well documented – greater risk of heart attack or stroke being top of the list
T
here’s also a link between high blood pressure and a lack of good-quality sleep. Blood pressure is carefully monitored at the Sleep Laboratory at the New Zealand Respiratory & Sleep Institute (NZRSI), where clients with
will develop hypertension • hypertension is the most important treatable cause of premature disability and death • although hypertension is more common in those aged 40 years and above, it can and does
High blood pressure and sleep At night, the normal physiological response is for an individual’s blood pressure to drop to under 120/70: this natural process, which is part of our circadian rhythms, is known as ‘dipping’ and is beneficial to the
during the day to exercise and so lack motivation. Once they start to use the CPAP (continuous positive airway pressure) machine at night, their sleep improves and their ability and willingness to exercise does too.
“High blood pressure or hypertension is the most common chronic disease in adults: at any one time, 26% of all adults with suffer from hypertension” possible sleep apnoea are tested overnight. That’s because about 10 percent of individuals with high blood pressure have an underlying (“secondary”) cause. One of the important and common secondary causes is obstructive sleep apnoea (OSA). In untreated OSA, disturbed sleep often means that blood pressure goes up overnight rather than falling as it is meant to. This nocturnal rise is an important risk for heart disease and stroke, and one of the important benefits of OSA treatment is to restore a healthy overnight drop in blood pressure, even if overall blood pressure is still a little high. High blood pressure: Did you know: • medical term for high blood pressure is hypertension • it is the most common chronic disease in adults: at any one time, 26 percent of all adults with suffer from hypertension • each year 20,000 more people in the greater Auckland area
occur at any age, even in otherwise slim, healthy, active people • the reason it has become known as ‘the silent killer’ is because it is mostly asymptomatic: most people with high blood pressure have no symptoms at all, until they present with a complication • high blood pressure tends to go undiagnosed for long periods, especially in younger men who tend not to visit the doctor frequently • the only way to detect hypertension is to have your blood pressure checked at least once a year • being overweight, and high dietary sodium (salt) intake, are the two most important environmental risk factors for developing high blood pressure • untreated high blood pressure is a risk factor for stroke, heart failure, heart attack, kidney disease, and visual loss • in general a blood pressure of 140/90 (when measured at a clinic or doctor’s surgery) is the threshold for treatment.
body and the brain people with OSA do not experience deep sleep, and so this dipping may not occur. A typical sufferer will endure a nightly cycle of loud snoring and a temporary cessation of breathing (which results in a drop in oxygen levels). After this, they will wake up and gulp for air - and their body is flooded with adrenalin. in poor sleepers with OSA, the sympathetic nervous system (which controls involuntary activities such as bowel movements and blood pressure) can be in a constant state of over-stimulation. This is effectively a ‘fight or flight’ physiological state and your blood pressure will naturally rise. people who work shifts or are chronically sleep deprived have a higher risk of hypertension. there is evidence that chemically induced sleep (as in sleep that results from pharmaceutical or is alcohol-induced) does not cause the same beneficial ‘dipping’ of blood pressure levels. patients with untreated sleep apnoea (OSA) usually feel too tired
Devastating dangers of tiredness (continued from page 25) In these cases, an employee is asked to keep a sleep diary for at least a week and send it to BSSNZ for a free consultation. “Good data will also assist any further referral to a sleep clinic, to a District Health Board for sleep apnoea CPAP assessment or to one of the cognitive behaviour therapy for insomniacs programmes that we deliver for our Employee Assistance Programme clients,” Mr Beattie says.
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“This information is vital if we are going to help organisations and industries of all shapes and sizes identify and avoid the potentially disastrous consequences of fatigue and impairment.” Matthew Beattie is CEO of BSSNZ, a joint venture between national behavioural healthcare provider Instep and Australian fitness for work
training and consultancy BSS Corporate Psychology that provides New Zealand training and consultancy solutions for fitness for work issues such as fatigue management, alcohol and other drugs management, supervisor and manager leadership, soft skills and mental health and wellbeing
Ever heard of White Coat Syndrome? If you’ve ever felt slightly stressed before visiting the doctor or dentist, you’re not alone. When it comes to blood pressure results, about 20% of individuals, not on treatment, will have an elevated reading recorded at the doctor’s office or other clinical setting. This is known as white coat hypertension or syndrome. When these individuals are re-tested by wearing a 24-hour ambulatory blood pressure monitor on their upper arm, they’ll have a normal profile. These people do not need blood pressure medication (although they do need close monitoring). The NZ Respiratory & Sleep Institute opened in April 2009 at Ascot Office Park in Greenlane, Auckland, is a private specialist medical practice providing respiratory and sleep clinical consultation, lung function testing and sleep testing as well as undertaking clinical research.
PPE>>Hearing
Bad assumptions about hearing protection Any good proof is based upon assumptions: if the assumptions are good, the proof is valid. If the assumptions are bad, then the proof is worthless, says Brad K Witt
The steps to properly fit earplugs aren’t complicated: Roll, Pull and Hold
I
n the world of personal protective equipment, bad assumptions are hazardous and can result in injury - or worse. Unfortunately, despite 25 years of solid regulation, some persistent bad assumptions are very widespread in Hearing Conservation Programmes (HCPs). Here are six of the most common bad assumptions about hearing protection for noise-exposed workers. Perpetuated unchecked, these assumptions torpedo an otherwise healthy Hearing Conservation Programme, and leave the door open to hearing loss among workers exposed to hazardous noise. Assumption 1 Hearing protection is self-explanatory Assuming that proper use of hearing protection is fairly intuitive (“just put it in your ear...”), many safety managers provide little or no training in how to use protection properly. Or they generously assume that workers will read the manufacturer’s instructions on the packaging. A comprehensive study of HCPs in the UK revealed that when Hear-
ing Conservation training had been provided by posters or leaflets, less than half of the “trained” workers could recall the content. But repeated studies show that the most effective use of hearing protection comes after one-on-one training. Large group training in hearing protection seems to have little effect in proper usage; only individual training can be linked to high attenuation results. For proper fit of earplugs, the fitting steps are not complicated. A simple three-step process conveys the essence of a proper fit for foam earplugs: Roll, Pull, and Hold. Roll down a foam earplug into a small crease-free cylinder, pull the outer ear up and back to open the ear canal, insert the earplug and hold in place while it expands. For proper fit of earmuffs, move aside any thick hair, and seat the earmuff so that it encloses the entire ear. Avoid safety glasses with thick temple bars at the frames. For safety eyewear or prescription glasses with a thin frame (a width of 2mm or less at the temples where the earmuff cushion meets the frame), eyewear causes no significant decline in attenuation.
The ideal hearing protector should not block all sound but rather reduce hazardous noise levels while still allowing a worker to hear the sounds that are critical to the job But safety eyewear with wider frames causes noticeable gaps in the cushion seal, resulting in a loss of attenuation of 5-10 dB in some cases. User-friendly instructions showing how to properly wear and care for hearing protectors are found in free training materials available from www.hearforever.org. Assumption 2 Any earplug in the ear is blocking some noise It simply isn’t true. An earplug just sitting in the bowl of the outer ear, without sealing the ear canal, is simply nice ear decor - but it is offering little protection from noise. In fact, attenuation measurements show that a poorly-fitted earplug often creates a resonance cavity in the ear canal, actually increasing the noise level by a few decibels (similar to cupping your hand around your ear to hear better). This is problematic for a safety manager who is trying to judge compliance visually. He or she might assume that any earplug that can be seen in a worker’s ear must be doing some good, and focus more on the workers who are wearing no protection at all. In re-
ality, a poorly-fitted earplug offers no protection, just like the worker with no earplug. Here is one visual cue of a proper earplug fit: when viewing yourself in a mirror straight ahead (or when looking at a co-worker faceto-face), a poorly-fitted earplug is clearly visible protruding from the ear canal, while a properly-fitted earplug is hardly visible. For the user, a good self-test of proper fit of earplugs is easily performed. Prior to inserting your earplugs, press the palms of your hands tightly against your ears, and say some words out loud. Your own voice sounds louder and deeper when your ears are covered. Now insert your earplugs, and repeat that voice check. If the earplugs are properly fit, there will be very little difference in the sound of your voice when you cover and uncover your ears with your hands. Assumption 3 An earplug halfway in the ear blocks about half the noise It seems plausible that if a well-fitted earplug blocks 30 dB of noise, then a half-fitted earplug must block 15 dB of noise. Unfortunately, the math of hearing protection
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PPE>>Hearing does not work that way. Instead, a half-fitted earplug is often providing 0 dB of attenuation. Workers in noise levels of 85-95 dB (close to the US government’s Occupational Safety & Health Administration (OSHA) Permissible Exposure Limit of 90 dB Time Weighted Average) are routinely offered earplugs with Noise Reduction Ratings (NRR) of 30 dB or more. When worn properly, that 30 dB hearing protector can make the worker feel isolated - unable to hear warning signals, co-workers, machine maintenance sounds, or communication radios. To hear critical sounds, workers will sometimes remove their earplugs about halfway, assuming they are still adequately protected. But in noise attenuation, any small channel or leak allows the noise to enter, and the protection quickly deteriorates from “all” to “none.” How do we protect a worker who does not need 30 dB of protection? Use hearing protectors with lower Noise Reduction Ratings (NRR). When used properly, a lower-attenuating earplug will provide protection without sacrificing communication ability. In a series of research studies designed to find out why workers do not use their earplugs more consistently, National Institute of Occupational Safety and Health (NIOSH) reports that the predominant reasons are inability to communicate (“I can’t hear my co-workers talking to me”), and
interference with job performance (“I can’t hear the maintenance sounds from my machine, or warning signals”). The ideal hearing protector should not block all sound (overprotection), but rather reduce hazardous noise levels while still allowing a worker to hear the sounds that are critical to the job: co-workers, warning signals, and equipment maintenance sounds. While there is no magic valve in hearing protectors that lets “good” sound in and keeps “bad” sound out, there are some hearing protectors that are more speech-friendly than others. These “uniform attenuation” hearing protectors attenuate all frequencies fairly equally, meaning speech and warning signals will sound more natural, rather than inaudible or distorted. Many users of uniform attenuation earplugs, for example, report they can still hear what they need to hear for their job performance. Assumption 4 Cut the NRR in half to predict real-world protection Since the US Environmental Protection Agency (EPA) promulgated its NRR on all hearing protector packaging since 1974, many studies have shown that attenuation achieved in the real-world is sometimes far below the laboratory NRR. There are a number of good reasons for this difference: users in the real-world might not receive proper training, or might adjust their hear-
ing protectors for comfort rather than protection, or they may intentionally compromise the fit in order to hear co-workers and machine noises more clearly. A 50 percent de-rating method, defined by OSHA to determine feasibility of engineering controls, is often misapplied to try to predict real-world protection for workers in a Hearing Conservation Programme. Such de-rating is arbitrary and usually wrong! Using a fit-testing system for earplugs, we visited eight industrial sites and measured real-world attenuation of 100 workers using earplugs from a variety of manufacturers. Workers were instructed to fit their earplugs just the same as they usually do. A Personal Attenuation Rating (PAR) was then measured on each ear. The PAR results showed that one-third of the workers achieved attenuation slightly higher than the published NRR, one-third of workers showed attenuation within 5 dB below the published NRR, and about one-third showed significantly lower attenuation (anywhere from 0 to 25 dB). Recognising this disparity between real-world and laboratory results, the EPA has announced its intention to update the NRR in the near future. Instead of a single-number attenuation rating (31 dB, for example), the new NRR label will likely show a two-number range of
Instead of relying upon the population estimates of the NRR, a safety manager can now measure each worker’s Personal Attenuation Rating (PAR
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measured attenuation for a given earplug (18-29 dB, for example). The lower number indicates the expected attenuation for groups of workers with little or no training, while the higher number represents the expected attenuation for groups of workers with some individual training in hearing protector fitting. Most experts agree that the new NRR range will provide a more realistic indicator to safety managers of how hearing protectors operate in the real world, but the new NRR still will not predict exactly how much protection an individual workers achieves. That would require individual fit testing, described below. Assumption 5 There’s no way to measure real attenuation on a worker wearing earplugs There definitely are several methods of measuring real-world attenuation on workers wearing earplugs. Instead of relying upon the population estimates of the NRR, a safety manager can now measure each worker’s protection level. While each method of fit-testing has its own merits, one of the most popular methods is called VeriPRO. And as the name implies, it verifies the protection achieved by a worker wearing earplugs. In the VeriPRO method, employees are given a special listening test without their ear-
When Hearing Conservation training had been provided by posters or leaflets, less than half of the “trained” workers could recall the content
The ideal hearing protector should not block all sound but rather reduce hazardous noise levels, allowing a worker to hear the sounds that are critical to the job
Ideally, the best way to know if a worker is protected from hazardous noise is to take a noise dosimetry measurement under the hearing protectors plugs, and then repeat the test while wearing their right earplug,
particular fit. Fit-testing might not be feasible for some employers
fined by OSHA to be the Action Level at which Hearing Conserva-
whether a worker has lost hearing due to workplace noise. But using
followed by their left earplug. The difference in the results of these three special hearing tests is a measurement of how much protection is being offered by the earplugs, just as they were fitted by the worker. VeriPRO works with any earplug from any manufacturer, and a quiet test booth is not required to administer the test (it can be administered in a lunchroom or office). Some workers in the Hearing Conservation Programme may achieve a poor fit with the earplugs they are using. In these cases, there are two good options to improve protection: VeriPRO offers short training videos showing the proper fitting techniques for nearly every style of earplug. Workers typically show an immediate improvement in attenuation when they are retested after watching the short training video. Perhaps a different earplug should be tried. In a field study of real-world fit, many workers received 20-30 decibels more protection simply by trying a different earplug. Using a fit-test method like VeriPRO to verify attenuation, a safety
to administer on every noise-exposed worker in the facility, but it is certainly feasible for new hires, or workers demonstrating a significant threshold shift in their audiometric testing. OSHA regulations require these workers to be retrained and to re-fit with appropriate hearing protection, and the fit-test systems available now allow employers to accomplish that very effectively.
tion measures are implemented (generally at an 8-hour TWA). But such ambient dosimetry measurements tell us nothing about the noise level reaching the eardrum under the hearing protectors. QuietDose uses dual miniature micphones, each inserted under the earplug or ear-muff, to measure the noise dose at the eardrum. If a worker has a proper fit of the hearing protectors, the noise dose will be safe - under 50 percent for the work shift. But if the worker has an inadequate fit, or removes the protectors repeatedly in high noise, the resulting noise dose at the end of the work shift will be excessive. This immediate feedback gives the worker (and safety manager) the critical information to make immediate corrections. In a typical Hearing Conservation Programme, it takes several years of audiometric testing to ascertain
in-ear dosimetry, any worker can know immediately and precisely whether hazardous noise levels are reaching the eardrum. And if we can stop the noise exposure at the eardrum, we have stopped the hearing loss. Bad assumptions sink many well-intentioned safety initiatives. But avoiding these simple bad assumptions about hearing protection helps a Hearing Conservation Programme stay on solid ground, and do just what it is designed to do: prevent noise-induced hearing loss.
manager can document exactly how much protection a worker receives with a given earplug. The result is a Personal Attenuation Rating (PAR). But that PAR is specific only to that earplug, that worker, and that
and accurately gives a reading at end of shift showing the noise dose of the worker for that day. A dose over 100 percent exceeds OSHA’s Permissible Exposure Limit of 90 dB for an 8-hour TWA, while a noise dose of 50 percent is de-
Assumption 6 There’s no way to measure the noise dose of a worker under the hearing protectors throughout their workday Ideally, the best way to know if a worker is protected from hazardous noise is to take a noise dosimetry measurement under the hearing protectors – that is, place a microphone at the eardrum. This concept of in-ear dosimetry is now available in a product called QuietDose. Noise dosimetry is typically measured by clipping a microphone on the collar of a noise-exposed worker. The dosimeter samples the noise levels throughout the day,
Brad K Witt is Director of Hearing Conservation at Howard Leight/Sperian Hearing Protection, LLC, a leading global provider of passive and intelligent hearing protection solutions, and the founder of the HearForever initiative
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LAST WORD>>Site Safe Awards
Safest sites under the spotlight New Zealand’s safest construction companies will be unveiled at the Site Safe 2014 Construction Health and Safety Awards on 5 November
C
arters Petone won the Unitec Institute of Technology ‘Safety Innovation Award’ in the small business category last year’s awards. The Carters team move packets of timber into storage racks on a daily basis - a task that presented several manual handling and working at height hazards that the team could only minimise. The 30-minute job meant lifting heavy timber into racks and working from a mobile platform. They came up with an innovative forklift design and a new safer work method to completely eliminate the hazards. The idea significantly improved safety and created efficiencies by turning a 30 minute manual handling task into a three minute mechanical one. The new process sthe use of two forklifts and a purpose built attachment to safely hold the timber in place as it is mechanically pushed into the rack. The Carters team also developed a ‘how-to’ video to better communicate how the job is done safely and ensure the team was fully trained on the new process. “By implementing this we have been able to completely eliminate several hazards as opposed to just minimising them with the controls
we had in place,” says Petone Branch Manager Matt Wiig. Site Safe spoke with Mr Wiig about how winning the award impacted on the company’s staff and business. How is this initiative going now - a year on? “It has just become part of everyday business for us. All the previous hazards have been eliminated and the team is kept much safer. The efficiency gains have been fantastic and the team is able to be far more productive. The boys are also very proud of their initiative and the inspiration they have provided to the wider Carters business. Overall there has been a very positive impact on the team’s attitude towards safety.” After winning the award did your team and the wider Carters feel
inspired to come up with other innovative ways to improve health and safety? “At Carters Petone we encourage innovation and we reward outstanding safety behaviour or individual initiatives at our branch meeting every month. Recognition is incredibly important to us and prizes include items like first aid kits, fire extinguishers, smoke alarms etc, generally things that can keep our people safe outside of work. “Some initiatives we have recognised include: • Couriers would sometimes deliver heavy and small packets of stock into our ‘inwards goods’ area and place packets on the ground - which presented a manual handling hazard. It was decided we needed a parcel shelf (40cm wide and 180cm long) so that the cou-
rier could take packets straight from the van and put them on the shelf in one movement. The shelf also allowed our “inwards goods” person to move packets into the store without bending down to ground level. • Staff were concerned about our fire exit door going into the yard. It was a concern that people were unable to see each other when entering and exiting the yard, which had the potential for a collision. Firstly we tried to have the door open one way, however it had to open both ways since this was a fire exit door. The only safe way was to put up a twoway mirror, which a team member suggested. Now there is safe visibility for people going in and out, which has minimised the collision hazard.”
The Site Safe Awards categories The Unitec Institute of Technology Safety Innovation Award - Small to Medium Business (20 employees or less) This Award is for a site or company demonstrating the best new idea or initiative to drive improvements in health and safety systems or behaviours, address or manage a specific hazard, create a design solution to address a problem, or to improve productivity. The AWF Group Safety Innovation Award - Large Business (21 employees or more) This Award is for a site or company demonstrating the best new
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idea or initiative to drive improvements in health and safety systems or behaviours, address or manage a specific hazard, create a design solution to address a problem, or to improve productivity. The MSA Safety Leadership Award (small, medium or large business) This Award is for a site or company where an initiative has been implemented that involves organisational leaders in developing safety culture, making safety positive, encouraging engagement in health and safety and demonstrating leadership at the highest level.
This award is open to organisations of all sizes. Organisational leaders can be from the CEO and senior managers through to site managers, supervisors and foreman. Judging A confidential four-person panel is judging the awards - an independent expert operating in the field of occupational health and safety in the construction industry, a construction industry representative, an employee representative, and a Site Safe representative. Entries are judged on ideas, initiatives or innovations that have: • clearly demonstrated real bene-
fits to health and safety • displayed real innovation with respect to health and safety (thinking outside the square) • encouraged others to be involved and buy into health and safety • made health and safety positive. The awards will be presented at Site Safe’s Evening of Celebration at the Ellerslie Event Centre in Auckland on 5 November 2014, with winners in each category receiving an award trophy, a $1000 gift certificate from the award category sponsor, and featuring in Site Safe’s membership newsletter ‘Safety Insite’.
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