Improving crane licensing under the model work health and safety laws

Yes, this makes sense for slewing cranes. Although, we do not operate slewing cranes in the business.

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Yes. Standardising the requirement for a VLC licence without a dogging prerequisite, but with the crane safety fundamentals pre-requisite is supported. It would help cover a lot of risks and standardise the training provision.

Reducing the 10-metre-tonne current ruling on licencing to 1,000kg will have significant impacts upon our business and on Australia’s trucking & logistics businesses in general. There are thousands of VLCs fitted to trucks now that are just under the 10-metre-tonne capacity and currently require no license to operate.
“Would it keep people safer” OR “Would it improve WHS” is unquantifiable however in general terms, a consistent National approach for VLC licensing would be of benefit.
This initiative will add cost to business and SWA needs to provide details on anticipated course duration and potential training costs for a VLC licensing program.
A common risk to all impacted businesses is the high likelihood of industry poaching of newly licensed VLC operators to avoid businesses having to pay for their own licensing. It is expected this would create an environment where higher costs for product deliveries will be passed on.
It is unlikely that unintended secondary risks would emerge from a WHS perspective, however retention of VLC licensed staff will become a significant business risk as other companies start to pay more to attract license holders to them, rather than arrange their own license training. This will place a burden on organisations who are proactive in arranging VLC licenses for their operators, resulting in higher-than-average staff turnover, high licensing costs and increased wages.
The licensing process needs to include RPL for existing VLC operators seeking a CV license during the approved transitional period. The provision of the RPL evidence needs to be commensurate with the RPL and not the training. Often RPL provision of evidence for assessment is more rigorous than just going through the training again.
The transitional period needs to be sufficient to allow for the complete transition, without undue delay, for companies to meet the requirements, using an active method to complete the transition. This includes time for RTOs to conduct training, assess RPLs, submit records and for licences (or interim acknowledgement) to be received
The proposed “Crane Safety Fundamentals” pre-requisite for a CV license must be transferrable for all other license classes that also require this pre-requisite.

No. In order to implement safer practices you need to regulate the industry, regularly assess RTOs for provision of training and include the controls into OHS/ WHS legislation for education, encouragement and enforcement.

Not relevant to our business

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Logging operator timed experience prior to providing a license is worthwhile, however many crane types (such as Bridge or VLC) do not operate continually, therefore accruing the nominated experience hours, needs to occur over a longer period of time. There needs to be more information supplied on this proposal to accurately assess business impacts (resourcing, cost, availability, downtime of operators-in-training). VLCs should not require any supervised logging of hours and the competency assessment should be rigorous enough to counter any real world risks – see answer 17.

Some supervised experience hours prior to issuing a licence would provide higher safety in the workplace. However, the proposal as it stands is not sufficiently detailed as it doesn’t indicate the total number of supervised hours or supervisor’s competencies. There is cost associated with providing supervision for operators while they accrue hours. There is also the (very real) risk of businesses falsifying logbook entries to acquire licenses quicker.
SWA must nominate a transitional period that outlines the time/ stages businesses have to move to a fully licensed system. This transitional period needs to be broken down into steps (6 months each) or provide sufficient total time for for businesses to source training, the training to be provided (limited number of RTOs/ over-subscription to training), the RTOs to administer the process and then for the regulators to get on board and administer the licence issuing and other processes. This SWA guidance also needs to address how businesses can address the issue of providing competent supervisors for logging hours in early stages where no license holders will be available to supervise trainees – eg; CB.
Recognised Prior Learning (RPL) processes should be introduced as a viable process without the onerous requirements through existing RPL where the provision of evidence and assessment outweighs the time and impost of just doing the actual course. RPL should be simplified. This would be an opportunity to try that.

The proposal suggests logbooks are completed prior to a license being issued. There needs to be clarification on whether logbook hours occur prior to conducting the license course or after doing it. There are benefits for both, but it may be best from a WHS perspective if the person has been course trained and acquired basic crane competencies first, then completes their logged hours prior to applying for a licence.
How to ensure the logbook system isn’t rorted (e.g. operators signed off by supervisors without completing a comprehensive training program).

No. In order to implement safer practices you need to regulate the industry, regularly assess RTOs for provision of training and include the controls into OHS/ WHS legislation for education, encouragement and enforcement.

A ‘competent person’ must hold the license/ s for the work the trainee is performing. In our business a competent person must supervise the practical experience while a trainer and assessor reviews the completed evidence for entrance into the Learning Management System (LMS).
However, this would mean identification of a cohort of competent assessors (possibly through the RPL process) that are licensed first to then be able to conduct the further assessments of less experienced trainees.

Crane trainees don’t have to be employed in a business that operates cranes, but the trainee still has the obligation to accrue their logged and supervised practical experience. How this happens needs to be explored once an understanding of how many hours experience is required for a license (eg, potential cross-hosting employees in other organisations), noting hours should vary based on crane type and complexity.

VLC - Zero Supervised Hours for VLC. Compared to other cranes, VLCs are far less complex and limited in operational movements. Currently only basic training is provided by the crane manufacturers for the 10-metre-tonne units prior to operators using them. So going forward, logging supervision hours for VLC should NOT be applicable prior to attaining a licence. For VLCs, licences should be issued immediately after completion of the CV course and following a full competency assessment by the course provider.
Bridge/ gantry - We currently log (via logbook) 20 hours as an offsider, working with a competent bridge crane operator, followed by 40 hours as an operator of a bridge crane while under supervision.

N/A to telehandlers and piling rigs as we do not operate these in the business. However, licensing (and appropriate training) would increase safety by standardising the approach to training and assessment of competency.
We are introducing straddle cranes into our new QLD factory to handle transiflats. We are supportive of the optional elective licence element.

There would be a time, resourcing, employment and cost (employment, training, licensing and wages) impact to the business, but the provision of a nationally recognised HRWL following on from consistently driven training by RTOs, would provide a basis on which to build competency relevant to our business.
We would like more RTOs to offer training specific for our business needs. We handle bundles of steel bar and mesh in various configurations, so a simple course involving lifting stable loads just isn't sufficient. Finding an RTO able to offer this bespoke service isn't easy.

Not than can be seen from our perspective. Again, the application of a practicable transition period is key. This has been discussed previously and needs to be extremely conservative in timing (allow more, rather than less to counter supply issues) and robust.

As stated before, this must be a regulated process. Non-regulated options have led to the confusion and inconsistent applications of knowledge across industry, as it is. Including blatant rorting of the system (look at FLT training).

Not that we can think of

Yes, removing Dogging as a prerequisite for CV and CB licenses and replacing with a Crane Safety Fundamentals pre-requisite is a very positive improvement. It clearly recognises the difference in operational complexity between VLCs / Bridge Cranes, as opposed to cranes used in widely variable conditions. The proposal on grouping of licenses is also appropriate.

The proposed changes would streamline licensing requirements across industry. However, for our organisation there would be a significant initial cost burden due to training (or RPL processing) existing operators to acquire their licenses (as we have many operators who currently don’t require a licence for VLCs and Bridge Cranes). With a consistent licensing program to support operators, there would be improved safety outcomes.
Additionally, we would incur increased wage costs as licensed skills are recognised under our EBA.
To transition to a licensed system for all cranes will be costly to business. It is reasonable that all operators should be licensed, however for Bridge Cranes, the existing fourth movement principle could be continued, in which case the fourth movement licensing could become an elective on the base CB licence. This would also assist in deciding the number of hours required for supervision of trainees, which should be relative to operational complexity.

The transitional arrangements need to be very clearly structured and must provide sufficient time for businesses to adapt, RTOs to process training and regulators to administrate the process (typically, regulators are under resourced to manage additional administrative burden). There are some general barriers to success outlined above (refer to question 12).

Not really. The proposal is a logical step for improving safety around cranes. You cannot trust industry to manage this process if the alternative was non-regulated.

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Not obvious at this stage

N/A to business

N/A. Business does not rig cranes