CFMEU (Construction & General Division)
8 Aug 2024

How many employees work for your organisation?

Not applicable

Where does your organisation operate? Choose more than one if applicable.

Nationally

What sector best describes you or your organisation? Choose more than one if applicable.

Mining
Heavy and civil engineering construction
Building construction
Construction services
Manufacturing

Do you support the specific proposal for slewing mobile cranes?

No

Why not?

[redacted] the CFMEU does not support the specific proposal that
slewing mobile cranes be licensed according to their function (e.g. wheeled vs. crawler
cranes, hydraulic vs. lattice booms) rather than their rated capacity. We are concerned that
this will lead to workers being required to operate slewing cranes of various sizes that they
have no experience on and be a safety risk not only for the operator but also all workers in
the vicinity of the crane operation.
We are however open to a stackable licensing regime for slewing cranes that caters for the
increased size and complexity of mobile cranes and different road licensing requirements
(e.g. keep the current C2, C6 and C1 licenses; change the CO license to mobile cranes up
to 250T and introduce new licenses for mobile cranes up to 600T, mobile cranes over 600T,
slewing cranes with luffing fly jib, slewing cranes with boom trailer, slewing crane with
Superlift type attachment, crawler/tracked cranes, lattice boom cranes and a license to
perform multi crane lifts).

Would you support new licences for cranes over 100 tonnes and specific licences for crawler cranes and lattice boom cranes or other alternatives?

Yes

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?

As stated above we believe there would be negative safety consequences
through workers being required to operate slewing cranes of various sizes that they have
no experience on. This is especially the case for specialised heavy lifts where superlift
devices and the like are used.

If there are other alternatives, what are these and how would they improve crane safety and the operation of crane licences?

Yes, introduce stackable slewing crane licenses which require the lower size
crane licence as a pre-requisite.

Do you support the specific proposal for vehicle loading cranes?

Yes

Why?

Yes, we support requiring a high risk work licence for vehicle loading cranes
of 1,000kg or more capacity. There have been a number of incidents involving vehicle
loading cranes including fatalities1 . Ensuring that operators of vehicle loading cranes are
trained in dogging and crane operation can only improve the safety of the industry.

Do you support the specific proposal for non-slewing mobile cranes?

Yes

Why?

Yes, we support the proposal that non-slewing mobile cranes require a licence
regardless of their rated capacity. Too many accidents occur involving non-slewing mobile
cranes. The recent Safety Bulletin from Resources and Safety Queensland demonstrates
what can happen when workers are not fully trained.

Do you support the proposal for practical experience for operators?

Yes

Why?

We support a requirement for experience working under supervision before a
person can be issued with a crane licence and the recording of the experience in a logbook.
We also support a pre-requisite of a person working as a licensed dogger before
commencing training for a crane licence.
The person signing off the logbook however should not just be a person nominated by the
employer but must be a person already qualified and licensed to operate the type/size of
crane that a worker is being trained on.

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?

Adopting the proposals referred to in in response to Q11 above would increase the safety
of all workers at a site and give them confidence in the skills and abilities of the crane
operators.

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?

For a logbook system to be successful it must have the support of employers, unions,
regulators and training organisations. The logbook must contain sufficient detail that gives
a casual reader sufficient information on the skills and level of ability reached and
performed by the operator.

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?

Generally yes, although they could be employed by a Group Training
organisation on a traineeship and then hosted by a crane business.

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.

 HoursDaysMonths
Dogging100
Tower cranes100
Articulated mobile cranes100
Bridge and gantry cranes100
Slewing mobile cranes100
Vehicle loading cranes100

Please provide the reasons for your views. Are there relevant examples from your workplace that demonstrate why a longer/shorter duration is appropriate?

The CFMEU has landed on a 100 operational hours minimum period for working under
supervision as we believe this will give sufficient time for a trainee to become familiar with
the equipment that they are using and will usually give them exposure to different loads
and tasks as required to enable them to complete their logbook.

Do you support the proposed new licences for telehandlers, piling rigs and straddle carriers?

Yes

Why?

We generally support a new licence for telehandlers but do not support a base
unit and electives. The licence should cover all aspects of what a telehandler could be used
for, and dogging should be a pre-requisite.
We support a new high risk licence for piling rigs with basic rigging as a pre-requisite.
We make no comment on straddle carriers and will defer to the views of the CMEU (MUA
Division).

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?

Adopting the new licences would improve the safety of workers as the
operators will be fully trained on the equipment’s operations, not only improving their
safety but also that of those workers in close proximity to where the equipment is being
operated.

What factors would impact the success of the proposed new licences?

The content of the licence requirements and the training required to achieve
them will be a major factor in the success of the proposed new licences. Other significant
factors would be the confidence of industry in the training providers and the cost of
obtaining the licenses.

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.     

 HoursDaysMonths
Piling rig100
Telehandler100
Telehandler (suspended load elective licence)100
Telehandler (work platform suspended licence)100

Are there specific types of plant or models that should or shouldn’t be included in the scope of each proposed licence?

• Telehandler (non – slewing, only using tines and a basket)– 100 operational hours as a
minimum.
Telehandler (slewing) – 100 operational hours as a minimum and must have a slewing crane
licence if operated that way (noting that slewing telehandlers have even more functions
than slewing cranes).
• Telehandler (suspended load elective licence) - 100 operational hours as a minimum (with
experience as a licenced dogger as a pre-requisite).
• Telehandler (work platform suspended elective licence) - 100 operational hours as a
minimum.
• Piling rig - 100 operational hours as a minimum (with experience as a licenced rigger as
a pre-requisite). (Note that there are different styles of piling rigs now coming into play.
On the Northeast Link in Victoria, they have engaged overseas operators due to the
complexity of the machine.)
• Straddle carrier – no comment.

Do you support the proposal for structural changes to align training to specific skills and crane functions?

No

Why not?

The problem with the existing training arrangements stems back to a
decision taken in the early 2000’s to remove stackable qualifications. Moving back to
stackable qualifications and applying the principles of recognition of prior learning should
remove the duplication of training that exists in the current system.

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?

We do not believe that the proposals will improve WHS or increase worker
safety. Under the proposal a worker could be trained on a 20T slewing crane and once they
receive their licence, be expected to operate rough terrain cranes and mobile cranes of 200T
or more capacity. Heavy cranes often come with superlift devices and an operator on a 20T
cranes would have no idea how to operate a crane with a superlift device let alone set it up.

What factors would impact the success of the proposed new crane licence model?

We do not support the proposed new crane licence model.

Are there alternatives, including non-regulatory alternatives, to the proposals proposed? What are these, and how would they improve crane safety?

Yes move to a stackable licence arrangement as set out in our response to
questions 1 and 3. Stackable crane licenses would improve safety as it will ensure that crane
operators have been trained on cranes of a similar capacity and capability relative to the
crane licence they are operating under.

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)?

We do not support the model of elective licences.

Does the removal of any of the current crane licences and incorporation into the new model create any WHS risks?

Yes, see our response to question 25.

Should all bridge and gantry cranes (regardless of the number of functions) be licenced?

Yes

Should the piling rig licence be separated from the slewing crane base licence?

Yes

Why?

Yes. Firstly, we do not support the slewing crane base licence. Secondly, piling
rigs now operate quite differently from cranes and given the mix of rigs now being used
(and their applications) there are many unique hazards that can arise which differ from
cranes.

Are the activities and equipment listed still relevant to rigging work or should they be removed from Schedule 3?

Response breakdown
93.3%
Still relevant
6.6%
Remove from Schedule 3
Cranes, conveyers, dredges and excavators
Still relevant
Hoists
Still relevant
Dual lifts
Still relevant
Guyed derricks and structures
Still relevant
Flying foxes and cable ways
Still relevant
Hoists with jib and self-climbing hoists
Still relevant
Mast climbing work platforms
Still relevant
Structural steel erection
Still relevant
Safety nets and static lines
Still relevant
Tilt slabs
Still relevant
Demolition of structures or plant
Still relevant
Suspended scaffolds and fabricated hung scaffolds
Still relevant
Perimeter safety screens and shutters
Still relevant
Pre-cast concrete members of a structure
Still relevant
Gin poles and shear legs
Remove from Schedule 3

Published name

CFMEU (Construction & General Division)