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?
As someone with a CO and RA licence, I know what it was like getting a licence and having to learn the 'hard ' way. As a lifting coordinator and supervisor, I see the differences in poor training and good training. As a trainer/assessor I see people's lack of understanding of key fundamentals at times and feel this would certainly tighten up the process. As the BHP WAIO Lifting and Cranage procedure co-author (which is being tidied up), I have seen why we need to be so robust in our administrative controls, just to keep people safe at times.
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?
It would create costs, but would definitely make the industry safer. particularly at BHP, where we have so many new to industry trainees, so it is not even a question. So long as those already with the qualifications ie CO) don't need to go back and do a heap of training. You always need to start fresh and honor what has been done in the past. And I don't say that with purely selfish intent.
If there are other alternatives, what are these and how would they improve crane safety and the operation of crane licences?
Enhance the mapping/framework of the existing high risk training.
Do you support the specific proposal for vehicle loading cranes?
Why?
Crane is a crane. Though I don't lose sleep on this one either way
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?
Wouldn't be that big of an impact and we could manage it through our procedure, associated documents and training systems
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?
I don't like blurred lines. Currently still awaiting a formal response from the regulator as to whether side loading cranes (container side loaders) are classed as a VLC. Make a call and keep it in the high risk space or not at all. REMOVE AMBIGUITY AND VARIABILITY AT ALL COSTS!!! Great opportunity here.
Do you support the specific proposal for non-slewing mobile cranes?
Why?
Crane is a 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?
Wouldn't be that big of an impact and we could manage it through our procedure, associated documents and training systems
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?
I don't like blurred lines. Currently still awaiting a formal response from the regulator as to whether side loading cranes (container side loaders) are classed as a VLC. Make a call and keep it in the high risk space or not at all. REMOVE AMBIGUITY AND VARIABILITY AT ALL COSTS!!! Great opportunity here.
Do you support the proposal for practical experience for operators?
Why?
Used to work well.
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?
It would make it harder to crack into the industry and people do need to get a start somewhere. But this would definitely make the industry safer. So long as the process as aligned across the industry
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?
Misalignment, lack of opportunity. But if we as leaders implement it properly with clear guidance from the regulator, then it could work. We are currently implementing something similar for our Future Fit Academy trainees.
Are there alternatives to the proposals proposed? What are these, and how would they improve crane safety and the operation of crane licences?
If not mandated, you would never get consistency across the industry. At BHP, we have a robust training framework with practical assessments, etc. Other smaller companies certainly do not.
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?
Dependent on the crane I'd assume. But at a minimum, a dogging licence. As for a crane licence, I don't see size as absolutely necessary (ie a CO to manage a 250t crane), so long as the supervisor has the fundamental knowledge through a crane licence particular to that being managed (slew, non-slew, VLC, VMC, etc)
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 yards could offer programs and make a killing out of it. Would also give them an insight into potential employees. Just a thought. Otherwise, RTO's could create programs.
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 | 3 | ||
| Tower cranes | 6 | ||
| Articulated mobile cranes | 6 | ||
| Bridge and gantry cranes | 3 | ||
| Slewing mobile cranes | 6 | ||
| Vehicle loading cranes | 3 |
Please provide the reasons for your views. Are there relevant examples from your workplace that demonstrate why a longer/shorter duration is appropriate?
Dogging could be longer, bridge and gantry could be less. It all depends on how much exposure they get. If it were hours, I'd hope they were getting 50-100 hours in a month. Sorry, I'm been under the pump at work all week and am now rushing to complete this, so haven't given this question a heap of thought.
Do you support the proposed new licences for telehandlers, piling rigs and straddle carriers?
Why?
Particularly telehandlers, as I have issued multiple RIIHAN309 licences and it is a hybrid of 2 x high risk machines. Removing the ambiguity here would be great and reduce the constant questions around jib, capacity, etc. And just generally make the industry safer. Farmers will hate it, but too bad. Though if that's the sticking point, I'm sure they could be somehow de-scoped for the HRWL.
Haven't had too much exposure to the others.
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?
Big impact, But for us, the teams spend 2 days getting the RIIHAN309, so why not just get a HRWL that will probably take the same amount of time. The big impact will be if there is no transition available for current holders of RIIHAN309 and we all need to get the new licence. But I still think it is definitely worth it and there isn't a trainer assessor I know that thinks differently.
What factors would impact the success of the proposed new licences?
Robust comms piece, realistic transition period and potential transfer of existing training.
Are there alternatives to the proposals proposed, including non-regulatory options? What are these, and how would they improve crane safety?
High Risk. Already has other options.
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 | 3 | ||
| Telehandler | 3 | ||
| Straddle carrier | 3 | ||
| Telehandler (suspended load elective licence) | 3 | ||
| Telehandler (work platform suspended licence) | 3 |
Are there specific types of plant or models that should or shouldn’t be included in the scope of each proposed licence?
Again, months would be dependent on actual exposure in those months, but I don't think we need to make this too hard.
Can't really comment on the others
Do you support the proposal for structural changes to align training to specific skills and crane functions?
Why?
I personally wouldn't break them down that far, but understand why they have been split like that. So long as a person could be trained and passed out on all electives at the time of getting their licence, with the log book then dictating when they can be let loose on their own.
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?
Again, this impact is heavily dependent on the transition piece for existing licence holders. Regarding the altering/adding of training packages, we will whinge, but it's not that big a deal. I will need to update a heap of documents, but gain, it's for a reasonable cause.
What factors would impact the success of the proposed new crane licence model?
Solid comms, transition period and regulator support
Are there alternatives, including non-regulatory alternatives, to the proposals proposed? What are these, and how would they improve crane safety?
Possibly, but that sounds like work for us and how would you govern it holistically?
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)?
3-6 months, dependent on skill and hours in the logbook.
Does the removal of any of the current crane licences and incorporation into the new model create any WHS risks?
It will be ugly, but you already know that.
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?
Piling rig is a completely different machine
Do you support the proposal for operating cranes on vessels?
Why?
Many dangers, often overlooked. We actually do it quite well at Port, but there is so much that can go wrong.
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?
Not 100% sure of the impact on the transient nature of VMC operators on ships
What factors would impact the success of the proposed new crane licence model?
Good comms, transition period and regulator support
Are there alternatives, including non-regulatory alternatives, to the proposals proposed? What are these, and how would they improve crane safety?
Probably, but again, you lose your holistic alignment and governance if you don't mandate it.
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?
Lifting beams/spreader bars,
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?
This is a big one no doubt, but only because we always don't like change. As a trainer, I would love to see a shake up. I personally thing dual lifts should be normalised for all riggers, with the paperwork requirements remaining robust, as we do for tilt panels, which I almost pushed into category 3, but for the fact that this is captured in separate tilt panel training. Same with cranes. Basic riggers should be helping with crane assembly, instructed and coached by a competent operator.
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