How many employees work for your organisation?
Where does your organisation operate? Choose more than one if applicable.
What sector best describes you or your organisation? Choose more than one if applicable.
Do you support the specific proposal for slewing mobile cranes?
Why?
Because licensing based on their function aligns better with the technological advancements and specific operational requirements unique to each type of 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?
- Safety Improvement: This approach would likely enhance worker safety by ensuring that operators receive training specific to the crane type they will be using. This leads to a better understanding and handling of each crane's unique operational characteristics.
- Licensing supplier: There is a need for the availability of trainers to facilitate the licensing process, especially in regional areas where this level of support is crucial. We support the model used for Victoria telehandler, where a list of RTOs was provided.
- Unintended secondary risks are not identified. Licensing based on specific crane functions should minimize the risk of operators being underprepared for particular crane types, thus reducing potential secondary risks.
If there are other alternatives, what are these and how would they improve crane safety and the operation of crane licences?
No viable alternatives have been identified. Relaxing training requirements leads to inexperienced operators, resulting in a higher incidence of injuries due to insufficient experience and training.
Do you support the specific proposal for vehicle loading cranes?
Why?
Reducing the rated capacity for vehicle loading cranes requiring a license from 10 metre tonnes to 1,000 kg ensures that more operators of smaller capacity cranes are properly trained and licensed, enhancing safety.
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?
- Safety Improvement: This change would enhance safety by ensuring that operators of lower-capacity vehicle loading cranes also receive appropriate training and certification.
- Unintended secondary risks are not identified, as specific crane functions should minimize the risk of operators being underprepared for particular crane types, thus reducing potential secondary risks.
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?
No viable alternatives identified.
Do you support the specific proposal for non-slewing mobile cranes?
Why?
Requiring a license for non-slewing mobile cranes regardless of their rated capacity ensures that all operators are adequately trained and certified, thereby enhancing safety.
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?
- Safety Improvement: This requirement would improve worker safety by ensuring that all non-slewing mobile crane operators have received proper training.
- Unintended secondary risks are not identified, as specific crane functions should minimize the risk of operators being underprepared for particular crane types, thus reducing potential secondary risks.
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?
No viable alternatives identified.
Do you support the proposal for practical experience for operators?
Why?
The proposed logbook system provides a structured pathway for trainee crane operators, ensuring they gain the necessary experience under supervision before obtaining a full crane license. This system would enhance safety by ensuring that operators have practical, hands-on experience, reducing the risk of accidents due to inexperience.
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?
Safety Improvement: Logbooks provide a detailed record of an operator's experience and skills, ensuring they are well-prepared to handle different crane types safely.
Professional Development: For operators, logbooks serve as a CV, documenting their experience and proficiency with various cranes.
Implementation Challenges: Implementing a logbook system might pose challenges, especially in finding qualified supervisors, particularly in regional areas. Training and maintaining up-to-date knowledge for supervisors will be essential.
Training Duration: Ensuring a comprehensive training duration, similar to historical models where a structured progression from beginner to advanced licenses over 3 to 4 years, will be crucial for maintaining high operator quality.
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?
Factors Impacting the Success of a Logbook System:
Availability of Qualified Supervisors: The success of the logbook system depends on having a sufficient number of qualified supervisors who can provide effective oversight and training. In regional areas, this might be a significant challenge.
Supervision Models: Developing a flexible supervision model to accommodate jobs of various sizes and supervision needs.
Continuing Professional Development: Ensuring supervisors and operators undergo continuing professional development (CPD) to keep their skills and knowledge up to date is crucial.
Important Considerations in Designing a Logbook System:
Digital Format: Utilizing a digital format for logbooks for ease of use, accessibility, and consistency in record-keeping.
Guidance from WHS Regulators: Clear guidelines from WHS regulators and the VET sector on the required supervision levels for different tasks and crane types.
Training Duration: Specifying the duration of training under supervision, similar to past models where operators progressed from beginner to advanced levels over a few years.
Are there alternatives to the proposals proposed? What are these, and how would they improve crane safety and the operation of crane licences?
There are no viable alternatives to this proposal. Relaxing training requirements could lead to underqualified operators, increasing the risk of workplace injuries. The proposed logbook system ensures comprehensive training and supervision.
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?
Supervisors should have significant hands-on experience and a comprehensive understanding of crane operations. They should undergo regular training and professional development to maintain their qualifications and stay updated on industry best practices.
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?
Yes, trainee crane operators should be employed in businesses that operate cranes to gain practical experience. This ensures they are exposed to real-world scenarios under proper supervision.
Alternative ways could include partnerships with training organizations that provide simulated crane operation experiences. However, hands-on experience in an actual working environment is preferred.
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.
| Hours | Days | Months | |
| Dogging | 12 | ||
| Tower cranes | 12 | ||
| Articulated mobile cranes | 12 | ||
| Bridge and gantry cranes | 12 | ||
| Slewing mobile cranes | 12 | ||
| Vehicle loading cranes | 12 |
Please provide the reasons for your views. Are there relevant examples from your workplace that demonstrate why a longer/shorter duration is appropriate?
It is suggested that each license should undergo a minimum of 12 months under supervision.
Previously, the historical model, was that operators underwent a structured training program, progressing from beginner to advanced levels over 3 to 4 years. This approach ensured comprehensive skill development and high operator quality.
Road Vehicle Operations Logbook: Our experience with a road vehicle operations logbook highlighted the importance of having qualified supervisors who are directly involved with the crew, ensuring accurate and practical training records.
Do you support the proposed new licences for telehandlers, piling rigs and straddle carriers?
Why?
The inclusion of training for attachments to telehandlers is very valuable because, currently, there is no standardized training that covers this aspect. This will ensure that operators are well-versed in handling various attachments, based on the aerodynamics, thereby increasing safety and efficiency. Additionally, in our business, we already implement internal training for straddle carriers to maintain high safety standards. Formalizing this through a recognized license will further ensure consistency and safety across 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?
Safety Improvement: Introducing these licenses would likely enhance worker safety by ensuring operators are trained specifically for the equipment they will be using, leading to better understanding and handling of each equipment's unique operational characteristics.
Costs: While the initial training and licensing might incur costs, the long-term benefits of improved safety and reduced accident rates could offset these expenses. Additionally, clear licensing for specific equipment can streamline hiring and training processes.
What factors would impact the success of the proposed new licences?
Availability of RTOs: Ensuring there are enough qualified trainers, especially in regional areas, will be crucial. This might require a model similar to the one used in Victoria for telehandlers, where a list of Registered Training Organizations (RTOs) is provided. It would be valuable if training programs are out prior to the changes implemented.
Training duration and quality: Ensuring that the training programs are comprehensive and of high quality, and that they cover all necessary attachments and scenarios.
Continuing Professional Development: Regular updates and ongoing training for operators to ensure they stay current with best practices and technological advancements.
Are there alternatives to the proposals proposed, including non-regulatory options? What are these, and how would they improve crane safety?
No viable alternatives identified. Relaxing training requirements could lead to underprepared operators, increasing the risk of accidents and injuries.
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.
| Hours | Days | Months | |
| Piling rig | 12 | ||
| Telehandler | 12 | ||
| Straddle carrier | 12 | ||
| Telehandler (suspended load elective licence) | 12 | ||
| Telehandler (work platform suspended licence) | 12 |
Are there specific types of plant or models that should or shouldn’t be included in the scope of each proposed licence?
Additional Considerations:
Attachment Training: Training should not only cover the operation of the telehandler but also the specific attachments. This ensures operators are proficient in all aspects of the equipment they will be using.
Integration with Existing Training: For proposals like the piling rig, it would be beneficial to integrate some training prerequisites with those for slewing mobile cranes, ensuring a comprehensive training program.
Do you support the proposal for structural changes to align training to specific skills and crane functions?
Why?
Dogging Licence Prerequisite: Introducing a dogging licence prerequisite for operating bridge and gantry cranes is crucial. It ensures operators understand rigging and lifting loads, not just the machine's operation. This foundational knowledge enhances safety and operational efficiency. Bridge and gantry crane operators should have a dogging licence prerequisite before driving any crane, as it ensures they understand the implementation of rigging and lifting loads, not just the operation of the machine itself.
Modular Licensing Structure: The proposed modular structure, with base and elective licences, provides a more tailored and comprehensive training approach. This ensures operators are proficient in specific crane functions and tasks, enhancing safety and competency.
Training and Supervision: The new structure aligns training with specific skills and crane functions, ensuring operators receive relevant and focused training. This is particularly important for advanced slewing crane operations, where specific skills are required.
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?
Safety Improvement: The proposed changes would likely improve worker safety by ensuring operators receive targeted training for specific crane functions. This reduces the risk of accidents caused by operator error or lack of understanding of the equipment.
Training and Compliance Costs: Implementing these changes would incur initial costs for training and compliance. However, the long-term benefits of improved safety and reduced accident rates could offset these expenses. Additionally, clear licensing for specific equipment can streamline hiring and training processes.
Retrospective Licenses: Managing the transition for operators with existing licenses will be a challenge. Clear guidelines and support for obtaining new elective licenses will be needed to ensure a smooth transition.
What factors would impact the success of the proposed new crane licence model?
Availability of Training Providers: Ensuring there are enough qualified trainers to provide the necessary courses, especially in regional areas, is crucial. Training providers need to be informed in advance to prepare and deliver the courses effectively.
Infrastructure and Rollout: A well-planned rollout with the necessary infrastructure in place is essential. Training providers need adequate time and resources to implement the new courses and assessments.
Continuing Professional Development: Regular updates and ongoing training for operators are necessary to maintain competence and ensure they stay current with best practices and technological advancements.
Are there alternatives, including non-regulatory alternatives, to the proposals proposed? What are these, and how would they improve crane safety?
Non-Regulatory Alternatives: Implementing industry-led training programs and certifications could be an alternative. However, regulatory oversight ensures consistency and adherence to safety standards, which is crucial for high-risk operations like crane work.
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)?
Operators should have a minimum of 12 months of experience operating a standard slewing mobile crane before applying for advanced elective licences. This ensures they have sufficient foundational knowledge and practical experience.
Does the removal of any of the current crane licences and incorporation into the new model create any WHS risks?
The removal of any current crane licences should be carefully evaluated. Any transition should ensure that operators are not left without the necessary qualifications and that there are no gaps in safety standards.
Should all bridge and gantry cranes (regardless of the number of functions) be licenced?
Should the piling rig licence be separated from the slewing crane base licence?
Why?
The piling rig licence should be separate to ensure specific training and certification for piling operations. This specialization addresses the unique operational and safety requirements of piling rigs, which differ from those of slewing cranes.
Do you support the proposal for operating cranes on vessels?
Why not?
There needs to be clear segregation between cranes on vessels and cranes on jack up barges. “Operating cranes on a vessel over water” is a very broad category. Jack up barges do not move like vessels do and are not subject the wave conditions.
We do agree training and competency assessments area required.
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 impact would be minimal as this is already an offshore requirement (Offshore Crane Operator Competence Guide and unit of competency Operate Offshore Crane – PMASUP305) but may impact river or inshore works where this requirement is not applied.
In addition, it would add to the experience of cranes operators on vessels from a HSE point of view and therefore be safer.
What factors would impact the success of the proposed new crane licence model?
If the requirements do change and the proposal is implemented, it would be beneficial to have as least a transitional period as with the new 2022 WHS regulations.
Are there alternatives, including non-regulatory alternatives, to the proposals proposed? What are these, and how would they improve crane safety?
The only alternative is to have a separate HRWL (unit of competency) for cranes on vessels.
Are the activities and equipment listed still relevant to rigging work or should they be removed from Schedule 3?
Are there any other activities or items not currently covered by a rigging licence that you think should be licenced?
Note: We do not support the initiative, the proposed single 'base' license would likely diminish skill levels due to insufficient training and specialization. Rigging involves complex tasks that require extensive, varied training.
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)?
Which activities or equipment listed could be elective licences that only some riggers would need to know how to perform?
Which activities/equipment are related and could be combined to be covered in a single licence?
What impact would change to the rigging licence framework have on you or your business?
Skill Levels: The proposed single 'base' license would likely diminish skill levels due to insufficient training and specialization. Rigging involves complex tasks that require extensive, varied training.
Safety Risks: Reducing the training levels and condensing license classes increases safety risks. Rigging is a high-risk activity, and any compromise in training can lead to accidents and operational inefficiencies.
Proposed Alternative:
- Maintain the current classification of basic, intermediate, and advanced rigging licenses.
- Achieving 6 months experience between undertaking basic rigging, prior to commencing intermediate rigging training, and another 6 months between intermediate and advance. This would ensure a minimum of 12 months of training under supervision, documented and reported in a logbook. This approach would preserve skill levels and ensure riggers are adequately prepared for complex tasks.
- Dual lift activity is suggested to be transferred to advanced rigging.
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