B.E / AVO
30 Jul 2024

How many employees work for your organisation?

200+ (large)

Where does your organisation operate? Choose more than one if applicable.

Nationally

What sector best describes you or your organisation? Choose more than one if applicable.

Building construction
Heavy and civil engineering construction
Mining

Do you support the specific proposal for slewing mobile cranes?

No

Why not?

The necessity for reform is clear. New crane licenses should be introduced for cranes over 100 tonnes (CO). However, there is debate over the suggested proposed model. Some contend that completing 1 day of Crane Safety Fundamentals (CSF), 2 days of Slewing Crane (CS), 1 day elective in crawler tracks, and logbook training on a 60-tonne crane does not adequately qualify an individual to operate a 500-tonne crane without supervision.
Once a crane's capacity begins to exceed well over 100 tonnes, its rated capacity becomes as crucial as to its function. Here's why: operating a massive crane requires a seasoned operator who understands the additional operational hazards. These include managing extra rope falls and parts for larger hooks, controlling winch speed to prevent rope spooling or rope diving, handling longer booms and/or jibs, longer fly jibs, navigating distance and visibility challenges, compensating for wind, boom deflection, deviation, momentum, avoiding structural damage, conducting additional maintenance checks, and dealing with increased bearing pressures, among others. Indeed, there is a significant difference between operating a 60-tonne slewing crane and a 160-tonne slewing crane.

Would you support new licences for cranes over 100 tonnes and specific licences for crawler cranes and lattice boom cranes or other alternatives?

Yes

If the proposal above was introduced, what impact would it have for you and your organisation?For example, would it keep workers safer? Would it improve WHS or create costs for your business? Could there be unintended secondary risks?

The necessity for reform is unquestionable, and we all share the duty to ensure a safe workplace. However, what benefits does this offer? Does this proposal genuinely improve Work Health and Safety (WHS) in our industry beyond what company in-house training, crane familiarization, and operational observations and assessments in play, particularly when the cranes are company-owned? Is it feasible? What costs are involved? Are subsidies available for businesses and employees? Are there any other alternatives?

For business owners, the costs of training, wages paid to employee's during the training and the associated downtime at worksites are major concerns. One alternative is to employ extra staff and rotate employees during the training phase. However, both strategies lead to additional expenses, and recruiting more staff might not be sustainable or equitable if there isn't enough work after the training ends.

Secondary risks and foreseeable problems must be considered, and pertinent questions should be raised.

Is the VET sector, including TAFE and RTOs, equipped to manage the training volume demanded by this proposal? Do we have an adequate number of qualified Trainer-Assessors to conduct the training? Are there enough cranes in diverse configurations and capacities available? While performance evidence might be recorded during logbook hours, is it also necessary for practical assessments? Could this requirement interrupt production on sites where a crane is needed for assessments?

There's only a brief mention of transitional arrangements with consideration of existing licence holders. What actually will occur with the existing HRWLs and VOCs? do they count towards new ones? or do we have to start again?

Everyone is concerned that seasoned crane operators may encounter employment limitations due to compliance requirements. If their work experience is not properly documented, it could potentially be disregarded.

The knock-on effect could exacerbate, potentially making it challenging for these crane operators to keep their jobs or secure employment with other firms. They might have to begin anew and gradually ascend the career ladder once more.

Should the proposed reforms invalidate these prior qualifications, it could lead to significant consequences and financial repercussions across the construction sector.

If there are other alternatives, what are these and how would they improve crane safety and the operation of crane licences?

An alternative to the proposed model, businesses and Registered Training Organizations (RTOs) could collaborate through correspondence learning, digital logbooks, recognition of prior learning, practical assessments and observation carried out by subject matter experts, operators with equivalent qualifications, or trainer assessors via video recordings to reduce downtime on construction sites and be more cost effective.

Should this alternative receive consideration and approval for in-house business training, familiarization, observations, and the endorsement of logbooks and assessments with Registered Training Organizations (RTOs), it could allow for the conversion of credits towards Units of Competency or a Statement of Attainment in functionality, linked to the existing crane licensing system.

Furthermore, if state governments could create a digital platform akin to the Services NSW website, which already manages driver's licenses, HRWL licenses, White Cards, and COVID history, it would be advantageous. This system could link all qualifications, licenses, VOCs, UOCs, SOA's, familiarisations, a new digital logbook, and a work journal to record past inductions and operational experience. It would also be advantageous for SafeWork Australia, the VET sector, and employers to have the ability to request permissions to upload or download an operator's content.

This approach would enhance regulation, facilitating that details aren't overlooked, and improve transparency in the industry. It would also hold employees more accountable for keeping their licenses current, similar to the regulation of vehicle licenses and the enforcement of laws against drivers with suspended licenses.

Do you support the specific proposal for vehicle loading cranes?

No

Why not?

A different solution could reduce WHS incidents, without the need to go down the HRWL path.

If the proposal above was introduced, what impact would it have for you and your organisation? For example, would it keep workers safer? Would it improve WHS or create costs for your business? Could there be unintended secondary risks?

The necessity for reform is unquestionable, but at what cost? Does the expensive proposed model truly offer enhancements to WHS compared to other alternatives? The new licensing requirements will impact Hiab truck manufacturers and retailers due to a decline in sales of smaller Hiab trucks. Business owners who acquired these trucks with Hiabs under 10 metre tonnes, believing they could hire several operators without licensing requirements, will now face challenges. The 10 metre tonnes HRWL, a four-day course costing over $600, in addition to a 5-day dogman licence that costs $1200 and payment of employee's wages during the training. This imposes significant expenses on companies with multiple drivers per truck. Furthermore, the cost of wages paid for during the training, employees would likely seek higher wages after acquiring the new licenses and/or start shopping the market with other firms for promotion, potentially leading to business failures.

Should the proposed reforms mandate new HRWL's, it could lead to significant consequences and financial repercussions across the construction sector.

Are there alternatives, including non-regulatory alternatives, to the proposal proposed? What are these, and how would they improve crane safety and the operation of crane licences?

Accredited short course training may reduce downtime and be less expensive which could encompass all training material within shorter timeframes, through correspondence and the addition of logbook, unlike the 3 days required to complete the new prosed High-Risk Work Licence (HRWL) in addition to log book, plus the prerequisite of a 5-day dogman course. A short course and logbook method for operating a vehicle loading crane under 10 tonnes, could be developed by Registered Training Organisations (RTOs), manufacturers, or truck retailers, to produce a Statement of attainment, reducing downtime and costs.

Do you support the specific proposal for non-slewing mobile cranes?

No

Why not?

A different solution could reduce WHS incidents, without the need to go down the HRWL path. Some may argue that some load shifting equipment also has the capability to lift suspended loads with similar functions to a non-slewing crane.

If the proposal above was introduced, what impact would it have for you and your organisation For example, would it keep workers safer? Would it improve WHS or create costs for your business? Could there be unintended secondary risks?

The need for reform is clear, but the associated costs must be weighed. Do the proposed changes offer a substantial improvement in Workplace Health and Safety (WHS) over other alternatives? There is a concern that manufacturers and retailers may see a decline in sales of non-slewing cranes under 3 tonnes. Such a downturn could affect businesses such as formwork companies, agricultural warehouse suppliers, and small construction companies, who rely on the versatility and range of employees to operate these cranes. Additionally, there is the extra burden of new licensing costs, payment of employee wages during the training and downtime for both businesses and employees. The current CN licence is a 5-day course and costs $1500 in addition of prerequisite dogman licence which is another 5 days and cost $1200.

Additionally, some may argue that some load shifting equipment also has the capability to lift suspended loads, which contradicts this proposal.

Should the proposed reforms mandate new HRWL's, it could lead to significant consequences and financial repercussions across the construction sector.

Are there alternatives, including non-regulatory alternatives, to the proposal proposed? What are these, and how would they improve crane safety and the operation of crane licences?

Accredited short course training may reduce downtime and be less expensive which could encompass all training material in a smaller timeframe, through correspondence and the addition of a logbook, unlike the time to acquire the new proposed license with a 5-day dogman licence on top of that. A short course and logbook method for operating a non-slewing crane under 3 tonnes, could be developed by Registered Training Organisations (RTOs), manufacturers, or telehandler retailers, to produce a (SOA) statement of attainment, reducing downtime and costs.

Do you support the proposal for practical experience for operators?

Yes

Why?

Providing learners with logbook would be beneficial, allowing them the time and opportunity to gain practical experience under supervision at their own pace. Training would be more specialised in house and would prevent inexperienced people flooding the market that come from a 5-day training courses.

If the proposals above were introduced, what impact would they have for you and your organisation For example, would they keep workers safer? Would they improve WHS or create costs for your business?

Trainees would likely feel more secure learning at their own pace with the assurance of a supervisor's assistance for any questions or discomfort. While complexities from construction site conditions such as congested areas, obstructions, overhead structures, traffic, and other moving equipment could introduce secondary risks, an experienced supervisor could reduce these risks with appropriate safety controls. However, this could increase costs for businesses, as hiring an additional operator or supervisor would add to project expenses.

What factors would impact the success of a logbook system for cranes? What are the most important considerations in designing a logbook system for you and your organisation?

It is advisable to include a risk control template (SWMS) as well. The trainer and supervisor should collaborate to perform a risk assessment, identifying any potential hazards and risks, and setting up safety controls prior to initiating the training.

The proposed logbook system should also incorporate a bridging system to assess skilled operators, who've significant time gaps between projects or skilled operators from overseas by way of logbook assessment and refresher short courses to facilitate bridging expired or overseas licences.

A digital logbook would be essential, as paperwork can be easily altered or misplaced. Ideally, these digital logbooks should be integrated with the Service NSW app or similar state government websites, akin to the existing high-risk work licenses.

Moreover, it would be advantageous for workers to upload or update their Verification of Competency (VOC), familiarizations, previous experiences, and in-house training records within the digital logbook. This would facilitate the documentation, recording, and validation of their operational experiences for prospective employers.

Such a system would enhance regulation, prevent loss of records, and increase industry transparency. Workers would be held more accountable for maintaining their licenses, similar to the regulation of vehicle licenses and the enforcement of laws on drivers with suspended licenses or specific conditions.

SafeWork Australia, RTO's and Businesses should also have the capability to connect to these logbooks and licenses via permissions, for ongoing development, inductions, and record-keeping purposes.

Are there alternatives to the proposals proposed? What are these, and how would they improve crane safety and the operation of crane licences?

Simulators may be an option once technology improves. Some Crane manufactures already have something in play for cranes, but there's still limitations to real life experiences.

Under the proposal, trainee crane operators who are gaining practical experience will need to be supervised by a suitably qualified competent person in the workplace. What types of qualifications and experience should the supervisor signing off the logbook have?

Crane licence above or in line with the rated capacity of the crane, as well as the dogman licence.

Should a person gaining practical experience have to be employed in a business that operates a crane? Are there alternative ways the person could gain practical experience?

Indeed, working for a company that owns cranes would be more advantageous for someone's learning experience. There aren't really any other alternatives that are feasible.

For each of the following licence or crane types, provide an indication of approximately how long a person should work under supervision before being fully qualified.

 HoursDaysMonths
Dogging100301
Tower cranes200602
Articulated mobile cranes100301
Bridge and gantry cranes100301
Slewing mobile cranes200602
Vehicle loading cranes100301

Please provide the reasons for your views. Are there relevant examples from your workplace that demonstrate why a longer/shorter duration is appropriate?

Extended hours are not only superfluous but could also result in system exploitation. To deter individuals from working unlicensed for prolonged periods after fulfilling the minimum hours, regulatory measures should be implemented. For example, operators of Slewing or Tower cranes should be required to obtain their license within six months of initiating their logbook hours and within three months of completing the minimum logbook hours necessary. Keep in mind that it is currently possible to obtain an Open Crane (CO) High Risk Work License (HRWL) in five days, with less than two days of actual seat time.

Do you support the proposed new licences for telehandlers, piling rigs and straddle carriers?

No

Why not?

Piling rigs are a prime example, offering a plethora of types and models, each with unique functionalities. The complexity of these machines may perplex the VET sector, as they differ from Slewing Cranes, highlighting the necessity for a dedicated HRWL.
Regarding telehandlers, one could argue for a distinct comparison with load shifting equipment, front-end loaders, excavators and Backhoe licences, which also permit attachments and functionality for suspended loads.
Additional information on Straddle Carriers is needed, focusing on rated capacity, size, and functionality. It is argued by some that they should have their own licencing system, with specific licences or (SOA's) based on size, functionality, and capacity.

If the proposals above were introduced, what impact would they have for you and your organisation For example, would they keep workers safer? Would they improve WHS or create costs for your business?

We all have a responsibility to demonstrate duty of care, and there is bilateral support for reform. However, businesses, employers, and PCBUs may express concerns about the proposed changes to the existing crane licence model. The question arises as to whether these changes will improve WHS safety more effectively than existing measures. For instance, Piling rigs currently have in-house training, familiarisations, nationally recognised RIICFW304E, RIICFW305E licenses, the PileSafe Operators license endorsed by the Piling Federation, and VOCs already in effect, especially considering that the businesses already own the piling rigs, cranes, and equipment.

Should the proposed model be implemented, and the existing crane licenses be abolished, it would undoubtedly affect the industry. This change could lead to additional costs due to project downtime, the need for extra staff, expenses for new licenses, payment of wages during training, potential unemployment for experienced operators whom businesses may not afford to retrain, and a shortage of trainer-assessors, as well as cranes, piling rigs and equipment for training purposes.

Businesses feel that the goal posts keep changing on compliance rather than safety. Sometimes conformance to compliance creates secondary risks to businesses and their employees. For instance, Piling Companies are struggling with what's currently accepted and what is not in terms of operating piling equipment. At the moment we only have Band-aid solutions to comply, until we see a HRWL that is nationally recognised by the construction sector and in line with their regulations.

What factors would impact the success of the proposed new licences?

Piling rigs are a prime example, with their various types and models, each featuring unique functionalities. These complexities could perplex the VET sector, underscoring the relevance to the proposed slewing crane license and elective (UOC). Furthermore, there are additional considerations, such as the VET sector/RTOs possibly lacking sufficient trainer assessors to conduct this license, or not possessing the piling equipment necessary for training.

Telehandlers might also face challenges with the new proposal. It may be argued that linking the proposed telehandler license to a crane license may contradict the existing acceptance of load shifting equipment like frontend loaders, excavators and backhoes which also have suspended load attachments.

Similarly, Straddle Carriers could face issues due to their functionality, size, and capacity, potentially necessitating distinct licenses.

Are there alternatives to the proposals proposed, including non-regulatory options? What are these, and how would they improve crane safety?

It is recommended that piling rigs have their own unique High Risk Work Licence (HRWL).

Ideally, in-house training, familiarization, observations, logbooks, and Verification of Competency (VOC) represent the most practical and safest methods, considering businesses conduct the work, possess the piling rigs, cranes, and equipment. However, regarding conformance and insurance, the piling industry has been historically overlooked and lacks a High Risk Work Licence (HRWL) for its piling equipment.

Without a HRWL most of the issue revolves around compliance, as in-house training, VOCs, and familiarisations and Statement of attainments, often don't not meet construction site regulations. Consequently, businesses must obtain units of competency, licenses, and VOCs from third parties who may not be familiar with the machinery or know how to tailor the training material in line or relevant with all our piling equipment's functionality.

Alternatively, if we could resolve the compliance issues and site regulations in the construction sector, businesses could be able to conduct their own verification of competencies, familiarisations, logbook training and in-house training in line with our piling equipment unquestioned, as we understand the hazards, risks involved and the safety controls for our equipment above anyone else.

If a licence was designed for piling rigs as a standalone HRWL, the industry would expect a compliance structure nationally recognised and abolish the need for the current band aid solutions that are currently in place.

Telehandlers under 3 tonnes could go down the (SOA) path, similar to Frontend loaders, excavators and Backhoes.

Staddle carriers could have their own distinct licencing system, based on size, capacity and functionality which would determine a statement of attainment or HRWL.

For each of the licences or crane types proposed, provide an indication of approximately how long a person should work under supervision before being fully qualified.     

 HoursDaysMonths
Piling rig100301
Telehandler100301
Straddle carrier100301
Telehandler (suspended load elective licence)100301
Telehandler (work platform suspended licence)100301

Are there specific types of plant or models that should or shouldn’t be included in the scope of each proposed licence?

The complexity arises from the multitude of brands, models, capacities, and functionalities inherent to each piece of equipment. Designing a unit of competency that is applicable to specific models and yet relevant across the board would be an impractical task.

Do you support the proposal for structural changes to align training to specific skills and crane functions?

No

Why not?

In this specific structure, it seems the current crane licenses will be abolished, with very little information on transitional arrangements proposed for existing licence holders. This will have a major effect on the industry.

If the proposals above were introduced, what impact would they have for you and your organisation For example, would they keep workers safer? Would they improve WHS or create costs for your business?

We all bear the responsibility to exercise a duty of care, and there is widespread support for reform. Nevertheless, businesses, employers, and Persons Conducting a Business or Undertaking (PCBUs) may voice concerns over the proposed revisions to the current crane license model. It raises the question of whether these changes will enhance Work Health and Safety (WHS) more effectively than the current measures or other alternatives.

If the suggested model is adopted and the existing crane licenses are phased out, the impact on the industry would be significant. Such a shift would result in additional costs due to project delays, the necessity for more staff, expenses for new licenses and training, potential job losses for skilled operators who may be too costly for businesses to retrain, and a lack of trainer-assessors, as well as a shortage of cranes and piling rigs for training purposes.

Should the proposed reforms invalidate prior crane qualifications, it could lead to significant consequences and financial repercussions across the construction sector.

What factors would impact the success of the proposed new crane licence model?

The VET sector and businesses would struggle to manage due to a shortage of assessors, cranes, equipment, and piling rigs. Additionally, workers would be discontented if their licenses were to be abolished.

Are there alternatives, including non-regulatory alternatives, to the proposals proposed? What are these, and how would they improve crane safety?

An alternative could be to approve the use of Logbooks and recognise in-house training by businesses to address these various functions first. Subsequently, an industry collaboration between businesses, RTO's and the VET sector could better design relevant training material and determine what needs Individual HRWL's, Statement of Attainments, Units of Competency or furthermore create a scaffolding structure of (UOC's) that link to existing HRWL's.

How much experience should an operator have operated a standard slewing mobile crane before being allowed to apply for advanced elective licences (see Figure 4)?

The complexity of functional elements relating to a crane's operation depends on a number of things. Use the proposed elective licence for fly jib for instance. There are various fly jibs, each with unique features and capabilities. Some are fixed, others are telescopic, luffing, and or equipped with an additional hoist function. A smaller 40-ton telescopic crawler crane may have a less complex fixed fly jib, whereas a 500-ton crawler crane with a luffing fly jib upwards of 20-30 meters in length and a Superlift attached is significantly more complex. Two completely different scenarios. To give accurate answer to the question, there would need more details on the specific elective licences proposed to determine the level of experience needed.

Does the removal of any of the current crane licences and incorporation into the new model create any WHS risks?

Indeed, conformity may take precedence over experience and skill, leading to a rise in less experienced operators filling positions instead of seasoned veterans across the industry that have trouble demonstrating previous experience relating to functionality.

Should all bridge and gantry cranes (regardless of the number of functions) be licenced?

No

If not, what types should be exempt from a licence?

Mobile gantry cranes that are manually operated, freestanding workstation gantry cranes, Bridge or Gantry cranes that only have a maximum of three powered operations. Alternatives to improve WHS don't necessarily facilitate the need of a HRWL. Alternatives could be recognition of prior experience, in-house training conducted by businesses, approve logbook use and/or create statement of attainments related to functionality.

Should the piling rig licence be separated from the slewing crane base licence?

Yes

Why?

With the vast array of types and models, each featuring unique functionalities, the complexities of these machines could perplex the VET sector when considering their inclusion as an elective unit in the slewing crane license curriculum. This should be a (HRWL) High Risk Work licence of its own, recognised nationally across the construction and mining industry.

Do you support the proposal for operating cranes on vessels?

No

Why not?

While the existing crane licensing model does not encompass this operational area, Businesses PCBU's already conduct in-house training, competency verification (VOCs), and familiarization processes to serve as evidence of experience.

If the proposals above were introduced, what impact would they have for you and your organisation For example, would they keep workers safer? Would they improve WHS or create costs for your business?

The responsibility to exercise due care is a collective one, and there is broad support for reform. However, businesses, employers, and Persons Conducting a Business or Undertaking (PCBUs) may express concerns about the proposed changes to the existing crane license model. This leads to the question of whether this additional elective will improve Work Health and Safety (WHS) more effectively than the present system or other potential alternatives.

Businesses that have not engaged in certain these types of applications or have had significant time gaps between projects may find it challenging to conform with the proposed reforms. These reforms may overlook the value of previous experiences. Many experienced operators may struggle to maintain compliance if their employers do not regularly undertake work in those specific applications.

Only contractors that are operating in this industry constantly, will progress with the proposed reform, other businesses in competition could drop out of the market.

Should the proposed elective prerequisite be mandated, it could lead to significant consequences and financial repercussions across the construction sector.

What factors would impact the success of the proposed new crane licence model?

Lack of cranes on vessels available for assessment, Significant time gaps between projects for businesses and employees.

Are there alternatives, including non-regulatory alternatives, to the proposals proposed? What are these, and how would they improve crane safety?

Recognition of prior experience, approve logbooks and recognise in-house training to further demonstrate and document operators experience.

Are the activities and equipment listed still relevant to rigging work or should they be removed from Schedule 3?

Response breakdown
100%
Still relevant
Cranes, conveyers, dredges and excavators
Still relevant
Hoists
Still relevant
Dual lifts
Still relevant
Guyed derricks and structures
Still relevant
Flying foxes and cable ways
Still relevant
Hoists with jib and self-climbing hoists
Still relevant
Mast climbing work platforms
Still relevant
Structural steel erection
Still relevant
Safety nets and static lines
Still relevant
Tilt slabs
Still relevant
Demolition of structures or plant
Still relevant
Suspended scaffolds and fabricated hung scaffolds
Still relevant
Perimeter safety screens and shutters
Still relevant
Pre-cast concrete members of a structure
Still relevant
Gin poles and shear legs
Still relevant

Are there any other activities or items not currently covered by a rigging licence that you think should be licenced?

Possibility of Abseiling, rope access.

Which of the activities and equipment listed could be included in a ‘base’ rigging licence (i.e. activities all riggers should be competent to perform)?

Structural steel erection
Cranes, conveyers, dredges and excavators
Tilt slabs
Dual lifts
Pre-cast concrete members of a structure
Hoists

Which activities or equipment listed could be elective licences that only some riggers would need to know how to perform?

Mast climbing work platforms
Cantilevered crane loading platforms
Hoists with jib and self-climbing hoists
Demolition of structures or plant
Gin poles and shear legs
Guyed derricks and structures
Suspended scaffolds and fabricated hung scaffolds
Flying foxes and cable ways
Safety nets and static lines
Perimeter safety screens and shutters

Which activities/equipment are related and could be combined to be covered in a single licence?

Response breakdown
37.5%
Combination 1
37.5%
Combination 2
25%
Combination 3
Tilt slabs
Combination 1
Demolition of structures or plant
Combination 2
Pre-cast concrete members of a structure
Combination 1
Guyed derricks and structures
Combination 2
Perimeter safety screens and shutters
Combination 3
Flying foxes and cable ways
Combination 3
Suspended scaffolds and fabricated hung scaffolds
Combination 3
Safety nets and static lines
Combination 3
Gin poles and shear legs
Combination 2
Cranes, conveyers, dredges and excavators
Combination 1
Cantilevered crane loading platforms
Combination 2
Structural steel erection
Combination 1
Hoists with jib and self-climbing hoists
Combination 2
Hoists
Combination 1
Mast climbing work platforms
Combination 2
Dual lifts
Combination 1

What impact would change to the rigging licence framework have on you or your business?

The obligation to exercise due diligence is a shared responsibility, and there is widespread agreement on the need for reform. Nevertheless, businesses, employers, and Persons Conducting a Business or Undertaking (PCBUs) may voice apprehensions regarding the suggested modifications to the current riggers license framework. This raises the question of whether these proposed changes will enhance Work Health and Safety (WHS) more effectively than the existing system or other possible alternatives.

Ideally, individuals with existing Riggers licenses must have the ability to transition their credentials to the new licensing framework. Numerous workers who work with cranes, plant, machinery, Structures and conduct dual lifts, have obtained both basic and intermediate rigger licenses to perform their duties. Should the proposed reforms invalidate these prior qualifications, it could lead to significant consequences and financial repercussions across the construction sector.

Published name

B.E / AVO