Improving crane licensing under the model work health and safety laws

24. We do not fully support the Crane Safety Fundamentals, although we agree with the introduction of the Telehandler licence.

25. 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?)? Please provide as much detail as possible :

Transition Plan and Mitigation Strategies
• What measures are planned to ensure a smooth transition from the current framework to the new one, minimising disruptions?
• How will potential training gaps be identified and addressed during the transition? Will this impact RTOs and Training Assessors significantly? Will existing license holders need to undergo retraining?
• What support mechanisms (e.g., workshops, online resources) will be provided to assist RTOs, trainers, and trainees during the transition?

Administrative Burden and Logbook Management
• What strategies can streamline managing multiple electives within the licensing framework?
• How can logbooks be designed to capture required competency depth without becoming burdensome for trainees, supervisors, and administrators?

Cost Implications and Financial Impact
• How will the costs of updating administrative systems, resources, marketing, and training materials be balanced against the long-term benefits of the new framework? What support will be provided to RTOs facing financial strain?
• How will the financial impact on candidates be minimised during the transition phase, and will there be compensation for RTOs to mitigate the impact on course costs?

Costs for Candidates (Crane Operators)

• Training Fees: Increased fees due to more comprehensive training programs.
• Certification Costs: Higher costs for exams and certification.
• Travel and Accommodation: Additional expenses if training is not locally available.
• Lost Wages: Potential income loss during training periods.
• Career Interruption: Delays in career progression due to training and certification.
• Job Market Impact: Increased competition if new certification raises entry barriers.

Costs for Employers
• Employee Training: Expenses related to sending employees to new training programs.
• Operational Downtime: Reduced productivity during employee training.
• Compliance Costs: Ongoing costs for audits, inspections, and regulatory compliance.
• Equipment Investments: Costs for upgrading or purchasing new equipment to meet new standards.
• Insurance Premiums: Potential changes in insurance premiums due to new risk assessments.
• Recruitment Challenges: Difficulty in hiring qualified crane operators during the transition.
• Supply Chain Disruptions: Potential operational delays affecting the supply chain and leading to financial penalties or loss of business.
• Client Relationships: Strain on client relationships due to service delivery changes during the transition.

Costs for Registered Training Organisations (RTOs)

• Development Costs: Significant expenses for developing the new licensing framework, including consultations and regulatory drafting.
• Training Delivery: Costs associated with ongoing training programs, including instructor salaries, facilities, and equipment.
• Regional Training: Additional costs for travel and accommodation for trainer assessors in regional areas, affecting productivity.
• Implementation Expenses: Costs for rolling out the new framework, including public awareness campaigns and stakeholder meetings.
• Monitoring and Enforcement: Additional resources needed for compliance monitoring and enforcement.
• Updating Training Programs: Costs for revising curriculum, training materials, assessment methods, and marketing.
• Market Competitiveness: Small RTOs might lose market share to more agile competitors.
• Economic Ripple Effects: Increased costs could affect related services and goods, passing through the supply chain.

We have always used logbooks for all cranes courses for this reason. Using a practical methods works for increased confidence and competency for canditates.

Hour or time on a machines should only be a baseline. It also depends on the candidates competency at the time, they may be green with no work experience or a slow learner and require more hours or you could have someone who has re-entered into the workforce that has prior experience who only needs a few hours to refresh. This decision should be left for the trainer assessor to decide based on competence.

It makes sense they are two completely different machines.

24. We do not fully support the Crane Safety Fundamentals, although we agree with the introduction of the Telehandler licence.

25. 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?)? Please provide as much detail as possible :

Transition Plan and Mitigation Strategies
• What measures are planned to ensure a smooth transition from the current framework to the new one, minimising disruptions?
• How will potential training gaps be identified and addressed during the transition? Will this impact RTOs and Training Assessors significantly? Will existing license holders need to undergo retraining?
• What support mechanisms (e.g., workshops, online resources) will be provided to assist RTOs, trainers, and trainees during the transition?

Administrative Burden and Logbook Management
• What strategies can streamline managing multiple electives within the licensing framework?
• How can logbooks be designed to capture required competency depth without becoming burdensome for trainees, supervisors, and administrators?

Cost Implications and Financial Impact
• How will the costs of updating administrative systems, resources, marketing, and training materials be balanced against the long-term benefits of the new framework? What support will be provided to RTOs facing financial strain?
• How will the financial impact on candidates be minimised during the transition phase, and will there be compensation for RTOs to mitigate the impact on course costs?

Costs for Candidates (Crane Operators)

• Training Fees: Increased fees due to more comprehensive training programs.
• Certification Costs: Higher costs for exams and certification.
• Travel and Accommodation: Additional expenses if training is not locally available.
• Lost Wages: Potential income loss during training periods.
• Career Interruption: Delays in career progression due to training and certification.
• Job Market Impact: Increased competition if new certification raises entry barriers.

Costs for Employers
• Employee Training: Expenses related to sending employees to new training programs.
• Operational Downtime: Reduced productivity during employee training.
• Compliance Costs: Ongoing costs for audits, inspections, and regulatory compliance.
• Equipment Investments: Costs for upgrading or purchasing new equipment to meet new standards.
• Insurance Premiums: Potential changes in insurance premiums due to new risk assessments.
• Recruitment Challenges: Difficulty in hiring qualified crane operators during the transition.
• Supply Chain Disruptions: Potential operational delays affecting the supply chain and leading to financial penalties or loss of business.
• Client Relationships: Strain on client relationships due to service delivery changes during the transition.

Costs for Registered Training Organisations (RTOs)

• Development Costs: Significant expenses for developing the new licensing framework, including consultations and regulatory drafting.
• Training Delivery: Costs associated with ongoing training programs, including instructor salaries, facilities, and equipment.
• Regional Training: Additional costs for travel and accommodation for trainer assessors in regional areas, affecting productivity.
• Implementation Expenses: Costs for rolling out the new framework, including public awareness campaigns and stakeholder meetings.
• Monitoring and Enforcement: Additional resources needed for compliance monitoring and enforcement.
• Updating Training Programs: Costs for revising curriculum, training materials, assessment methods, and marketing.
• Market Competitiveness: Small RTOs might lose market share to more agile competitors.
• Economic Ripple Effects: Increased costs could affect related services and goods, passing through the supply chain.

The introduction of a Telehandler licence.

We support a separate licence for all shipping. Ships have purpose-built cranes, and having a dedicated Crane Licence that covers the basics of cranes, including those using modified mobile cranes for barges and for dredging, would be useful.
International shipping falls under the National Law Act 2012, limiting our ability to enforce local licensing requirements on foreign workers. However, education can mitigate confusion in this complex regulatory space.

Introducing these proposals would streamline crane operator training and certification across vessels Australia wide. This would enhance safety by ensuring all crane operators are appropriately trained under a unified licensing framework. While it may create initial costs for training and certification, it will ultimately standardise practices and improve Workplace Health and Safety (WHS) outcomes.

The success would depend on universal compliance from vessel owners to ensure their crane operators are trained and licensed. Regulatory support and effective enforcement mechanisms would also play critical roles in ensuring compliance.

Non-regulatory alternatives could include voluntary industry certifications or partnerships with international maritime organisations to promote standardised training and safety protocols. These alternatives could complement regulatory efforts by fostering a culture of safety and competence among crane operators without imposing strict legal mandates.

• Turbine work, Milling work and Stacker Reclaimer Assembly

Riggers shouldn’t touch scaffolding, the scaffolding component should only be for a Advanced Scaffolder.