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?
Yes, this makes sense for slewing cranes.
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?
N/A
If there are other alternatives, what are these and how would they improve crane safety and the operation of crane licences?
N/A
Do you support the specific proposal for vehicle loading cranes?
Why?
Yes. Standardising CV licences without a Dogging HRL pre-requisite is supported.
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?
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.
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?
We support a VLC licensing program that does not require a Dogging HRL pre-requisite.
Do you support the specific proposal for non-slewing mobile cranes?
Why?
We support this initiative and recognise any form of external training as beneficial. Incorporating public road driving into the training would be especially advantageous. At present, operators can drive non-mobile slewing cranes on public roads with just yard driving experience. Including public road driving in the training would be widely seen as a significant improvement.
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?
Impact on our business would be minimal, as fewer than 10 workers would need the new license. Currently, there are no initial opinions on whether holding this license would enhance workplace health and safety, since all current operators are highly experienced. If the proposed license falls under higher capacity license requirements, there would be no effect, as the current workers already possess higher-level licenses.
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?
Our Crane department has internal SOPs and a competency reconnection process. Holding a license alone does not make a person competent to operate a non-slewing crane onsite. The team consists of approximately 10 people, with crane operators already holding various HRWLs. The introduction of a license will not supersede the business' existing competency procedures; rather, it will serve as an additional control measure.
Do you support the proposal for practical experience for operators?
Why?
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. VLCs should not require any supervised logging of hours – see answer 17.
For Bridge cranes, there should be a structured RPL system applied for previously logged operator hours, that reduces the requirement for experience hours by the same amount as already logged by that operator.
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?
Some experience hours prior to issuing a license 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 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 licensing system. 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.
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?
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 license.
Are there alternatives to the proposals proposed? What are these, and how would they improve crane safety and the operation of crane licences?
On-Site competency assessment could be considered as an alternate verification method in place of hours logging in a production environment, particularly if a system of RPL is adopted. Assessment should include operator dexterity and understanding of how the product behaves under certain conditions as this is critical to safe outcomes.
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?
A ‘competent person’ must hold the license/s for the work the trainee is performing.
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?
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.
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 | |
| Bridge and gantry cranes | 10 | 1.5 | 0 |
| Vehicle loading cranes | 0 | 0 | 0 |
Please provide the reasons for your views. Are there relevant examples from your workplace that demonstrate why a longer/shorter duration is appropriate?
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 license. For VLCs, licenses should be issued immediately after completion of the CV course and following a full competency assessment by the course provider.
10-20 Supervised Hours for Bridge cranes.
Currently operators don’t require a license to operate these cranes if they are not 4 or more movement cranes. Hours of supervision should apply, relating to the complexity and risk associated with the crane operation (hence potential for a range of hours depending on movements). Therefore, a crane with less operational movements should require less supervised hours to be logged. Bridge cranes generally operate in a fixed location within a building and are often used to lift and move a limited range of products in a reasonably consistent manner. An acceptable number of supervised hours following a trainee completing their CB license course should be between 10 and 20 hours (10 hours for base license with additional hours required for 4th movement electives).
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?
N/A for our business
What factors would impact the success of the proposed new licences?
N/A for our business
Are there alternatives to the proposals proposed, including non-regulatory options? What are these, and how would they improve crane safety?
N/A for our business
Are there specific types of plant or models that should or shouldn’t be included in the scope of each proposed licence?
N/A for our business
Do you support the proposal for structural changes to align training to specific skills and crane functions?
Why?
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 mobile situations or widely variable conditions. The proposal on grouping of licenses is also appropriate.
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 proposed changes would streamline licensing requirements across industry. However, for our organisation there would be a significant initial cost burden due to training 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.
What factors would impact the success of the proposed new crane licence model?
The transitional arrangements need to be very clearly structured and must provide sufficient time for businesses to adapt. There are some general barriers to success outlined above (refer to question 12).
Ideally businesses should be able to use existing recognised competencies (such as completion of Nationally recognised courses) as a mechanism to attain some RPL credit and this would be a key enabler to a smooth transition to a licensing regime.
Are there alternatives, including non-regulatory alternatives, to the proposals proposed? What are these, and how would they improve crane safety?
Not really. The proposal is a logical step for improving safety around cranes.
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)?
N/A for our business
Does the removal of any of the current crane licences and incorporation into the new model create any WHS risks?
N/A for our business
Should all bridge and gantry cranes (regardless of the number of functions) be licenced?
If not, what types should be exempt from a licence?
We believe cranes should be licensed or at least have a structured training for operators. It will be costly to business to transition to a licensed system for all cranes.
The proposal supports that all crane operators should be licensed. In which case for Bridge Cranes, the existing 4th movement principle could be continued, and then the 4th movement licensing could become an elective on the base CB license. This would also assist in deciding the number of hours required for supervision of trainees, which should be relative to operational complexity. Our business feedback has also suggested that without differentiating between the classes required to perform the tasks required, it will add unnecessary costs with training and impact staff retention as it is likely that a higher qualified licence will attract employees to a higher wage opportunity.
Alternately, not all bridge and gantry cranes may need to be licenced if the 4th movement definition is not made obsolete. In this case, for 3 movement cranes, there could be a set of recognised National competencies alongside a period of logged hours for experience (like what is proposed but not formally a license). Training may also include the safety fundamentals pre-requisite as a component of these national competencies. Under this approach, there will still be formalised standard training for all crane operators, but licensing would only apply if 4th movement cranes were needed to be operated.
Where Nationally recognised Bridge crane courses have been completed by an operator, a RPL system should be applied to recognise the course learnings and where applicable reduce the content and / or timeframe for the proposed base license course.
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?
N/A for our business
What factors would impact the success of the proposed new crane licence model?
N/A for our business
Are there alternatives, including non-regulatory alternatives, to the proposals proposed? What are these, and how would they improve crane safety?
N/A for our business
Are there any other activities or items not currently covered by a rigging licence that you think should be licenced?
N/A for our business
What impact would change to the rigging licence framework have on you or your business?
The current pre-requisite for a rigging license prior to attaining a CB license for a 4th movement crane or a CV license is not necessary. Replacing this requirement with the crane safety fundamentals pre-requisite for both CB and CV licenses would be good move.
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