Model Work Health and Safety WHS Laws Wayne Creaser Safety Show 26-27 October 2011

1. Model Work Health and Safety (WHS) Laws Wayne CreaserSafety Show � 26-27 October 2011

2. 2 Overview Model Work Health and Safety (WHS) laws Risk management Duty holder structure Consultation Regulations Codes of Practice Implementation Future work

3. WHS Harmonisation Government announces desire to development of model legislation to harmonise OHS across Australia (2007) Review into model OHS laws completed (Jan 2009) Governments sign IGA signed committing to implement model legislation by end of 2011 (Jul 2008) Safe Work Australia established (2009) Model WHS Act agreed by WRMC (Dec 2009) Model regulations and a number of codes released for public comment (Dec 2010) Legislation to commence in all jurisdictions 1 Jan 2012 3 Safe Work Australia is an evolution of the mechanism for dealing with national OHS policy. Started with NOHSC (mid 1980s to 2005), then ASCC (2005 � 2009), Safe Work Australia Council (2009) and Safe Work Australia (2009-). It was established as an independent statutory agency on 1 November 2009 by the Safe Work Australia Act 2008 Safe Work Australia comprises of 15 members: - an independent Chair (Mr Tom Phillips AM) - nine members representing the Commonwealth and each state and territory government - two members representing the interests of workers from the Australian Council of Trade Unions (ACTU) - two members representing the interests of employers from the Australian Chamber of Commerce and Industry (ACCI) and the Australian Industry Group (Ai Group), and - the Chief Executive Officer of Safe Work Australia (non-voting member) Safe Work Australia is jointly funded by the Commonwealth, state and territory governments through an intergovernmental agreement. Key functions of Safe Work Australia include: developing national model OHS legislation developing national policy on OHS and workers compensation collecting & analysing workplace injury and disease data and OHS activity data undertaking a program of research to inform the development and evaluation of OHS and workers� compensation policy advising the Workplace Relations Ministers� Council on OHS and workers� compensation arrangements, and driving national communications strategies to raise awareness of health and safety at work. States and territories are responsible for making and enforcing their own WHS laws. Although all primary work health and safety laws across Australia draw on a similar approach for regulating workplaces, there are some differences in how this is applied in OHS Acts and considerable differences in the regulations under these Acts. Nine principal jurisdictions, each with own work health and safety laws - was no compelling mechanism at national level to drive jurisdictions to harmonise work health and safety laws Progress to date: April 2008 - National review into model OHS laws announced July 2008 - COAG committed to harmonise OHS legislation and implement by end of 2011 � signed Intergovernmental Agreement for Regulatory and Operational Reform in Occupational Health and Safety (IGA) as part of the �Seamless Economy� initiatives The IGA commits the Commonwealth, states and territories to adopt model work health and safety laws by the end of 2011. This requires each jurisdiction to enact, or otherwise give effect to, their own laws that mirror the model laws. Harmonising work health and safety laws in this way aims to provide greater certainty and protections for all workplace parties The model work health and safety laws will consist of model WHS Act, model WHS Regulations, and model Codes of Practice. Jan 2009 - National review completed - two reports to WRMC, October 2008 and January 2009 May 2009 - WRMC responded to the Review on the optimal structure and content of a model Act Model Act drafted on the basis of the WRMC decisions. Drafted by Parliamentary Counsels� Committee Dec 2009 - WRMC agreed to model WHS Act (subject to further technical amendments) Allows for jurisdictional differences in legislative framework and court systems 2010 - drafting of model regulations and key model codes Dec 2010 - model regulations and first tranche of codes released for public comment Apr 2011 � public comment closed Final drafting of model regulations and first tranche codes Development of further codes and supporting guidance Development of compliance and enforcement policy Critical outcome of process - Single national policy framework to drive future development (and innovation?) Safe Work Australia is an evolution of the mechanism for dealing with national OHS policy. Started with NOHSC (mid 1980s to 2005), then ASCC (2005 � 2009), Safe Work Australia Council (2009) and Safe Work Australia (2009-). It was established as an independent statutory agency on 1 November 2009 by the Safe Work Australia Act 2008 Safe Work Australia comprises of 15 members: - an independent Chair (Mr Tom Phillips AM) - nine members representing the Commonwealth and each state and territory government - two members representing the interests of workers from the Australian Council of Trade Unions (ACTU) - two members representing the interests of employers from the Australian Chamber of Commerce and Industry (ACCI) and the Australian Industry Group (Ai Group), and - the Chief Executive Officer of Safe Work Australia (non-voting member) Safe Work Australia is jointly funded by the Commonwealth, state and territory governments through an intergovernmental agreement. Key functions of Safe Work Australia include: developing national model OHS legislation developing national policy on OHS and workers compensation collecting & analysing workplace injury and disease data and OHS activity data undertaking a program of research to inform the development and evaluation of OHS and workers� compensation policy advising the Workplace Relations Ministers� Council on OHS and workers� compensation arrangements, and driving national communications strategies to raise awareness of health and safety at work. States and territories are responsible for making and enforcing their own WHS laws. Although all primary work health and safety laws across Australia draw on a similar approach for regulating workplaces, there are some differences in how this is applied in OHS Acts and considerable differences in the regulations under these Acts. Nine principal jurisdictions, each with own work health and safety laws - was no compelling mechanism at national level to drive jurisdictions to harmonise work health and safety laws Progress to date: April 2008 - National review into model OHS laws announced July 2008 - COAG committed to harmonise OHS legislation and implement by end of 2011 � signed Intergovernmental Agreement for Regulatory and Operational Reform in Occupational Health and Safety (IGA) as part of the �Seamless Economy� initiatives The IGA commits the Commonwealth, states and territories to adopt model work health and safety laws by the end of 2011. This requires each jurisdiction to enact, or otherwise give effect to, their own laws that mirror the model laws. Harmonising work health and safety laws in this way aims to provide greater certainty and protections for all workplace parties The model work health and safety laws will consist of model WHS Act, model WHS Regulations, and model Codes of Practice. Jan 2009 - National review completed - two reports to WRMC, October 2008 and January 2009 May 2009 - WRMC responded to the Review on the optimal structure and content of a model Act Model Act drafted on the basis of the WRMC decisions. Drafted by Parliamentary Counsels� Committee Dec 2009 - WRMC agreed to model WHS Act (subject to further technical amendments) Allows for jurisdictional differences in legislative framework and court systems 2010 - drafting of model regulations and key model codes Dec 2010 - model regulations and first tranche of codes released for public comment Apr 2011 � public comment closed Final drafting of model regulations and first tranche codes Development of further codes and supporting guidance Development of compliance and enforcement policy Critical outcome of process - Single national policy framework to drive future development (and innovation?)

4. 4 Model WHS Act Duties of care � Primary Duty - PCBU Primary duty and related duties placed on a �person conducting a business or undertaking� � PCBU Duty owed to workers and others Captures the broad range of work relationships and business structures currently being used (and into the future) not defined by the nature of the employment relationship does not extend to a person�s own private or domestic activities Duties are non-delegable Person can have more than one duty More than one person can concurrently owe the same duty If more than one person has a duty for the same matter, then each person: retains responsibility for their duty in relation to the matter must discharge their duty to the extent the matter is within their capacity to influence or control must consult, cooperate and co-ordinate activities with all other persons who have a duty in relation to the same matter Volunteer associations are not PCBUs � a volunteer association is a group of volunteers working together for a community purpose where none of the volunteers employs a person to carry out work for the association (employ as in the traditional employer/employee relationship, not the broader PCBU/worker relationship) Penalties for duties of care � criminal offences Offence based on risk and culpability rather than outcome, not requiring actual harm - Category 1 � most serious breaches, for a duty holder who recklessly endangers a person to risk of death or serious injury - Category 2 � failure to comply with a health and safety duty that exposes a person to risk of death, serious injury of illness, and - Category 3 � failure to comply with a health and safety duty . �Gross negligence� removed from offences � cuts across criminal laws and manslaughter offences. Anticipated that most prosecutions will be under categories 2 and 3 The model WHS Act specifies penalties in dollar amounts rather than penalty units. This will ensure that penalties apply uniformly across Australia. The intention is for penalty amounts to be reviewed as part of the general review process every five years. Offence provisions: Offence provisions in the model WHS Act may be modified to comply with local drafting protocols that apply in the relevant jurisdiction. In practice, this means that the offence provisions in the Commonwealth, the Australian Capital Territory and the Northern Territory will designate strict liability elements. These jurisdictions are commonly referred to as �code� jurisdictions as they have adopted (either wholly or in part) the model criminal code. This requires those jurisdictions to take a different approach to drafting offence provisions. Duties are non-delegable Person can have more than one duty More than one person can concurrently owe the same duty If more than one person has a duty for the same matter, then each person: retains responsibility for their duty in relation to the matter must discharge their duty to the extent the matter is within their capacity to influence or control must consult, cooperate and co-ordinate activities with all other persons who have a duty in relation to the same matter Volunteer associations are not PCBUs � a volunteer association is a group of volunteers working together for a community purpose where none of the volunteers employs a person to carry out work for the association (employ as in the traditional employer/employee relationship, not the broader PCBU/worker relationship) Penalties for duties of care � criminal offences Offence based on risk and culpability rather than outcome, not requiring actual harm - Category 1 � most serious breaches, for a duty holder who recklessly endangers a person to risk of death or serious injury - Category 2 � failure to comply with a health and safety duty that exposes a person to risk of death, serious injury of illness, and - Category 3 � failure to comply with a health and safety duty . �Gross negligence� removed from offences � cuts across criminal laws and manslaughter offences. Anticipated that most prosecutions will be under categories 2 and 3 The model WHS Act specifies penalties in dollar amounts rather than penalty units. This will ensure that penalties apply uniformly across Australia. The intention is for penalty amounts to be reviewed as part of the general review process every five years. Offence provisions: Offence provisions in the model WHS Act may be modified to comply with local drafting protocols that apply in the relevant jurisdiction. In practice, this means that the offence provisions in the Commonwealth, the Australian Capital Territory and the Northern Territory will designate strict liability elements. These jurisdictions are commonly referred to as �code� jurisdictions as they have adopted (either wholly or in part) the model criminal code. This requires those jurisdictions to take a different approach to drafting offence provisions.

5. Model WHS Act Duties of care � �upstream� duties Duties placed on PCBUs who design, manufacture, import, supply, etc. Plant, structures and substances used for work are to be as safe as possible before they enter the market Provides for flow of hazard and risk information through the supply chain 5 Allows for concepts such as the chain of responsibility model developed for road transport (and hence dangerous goods transport) to fit comfortably within the WHS frameworkAllows for concepts such as the chain of responsibility model developed for road transport (and hence dangerous goods transport) to fit comfortably within the WHS framework

6. Model WHS Act Duties of care � Officers Must exercise due diligence to ensure the entity of which they are an officer complies with their duty of care 6 New duty for some jurisdictions, Is a positive duty, in that officers must proactively manage WHS issues. Modified Corporations Act 2001 definition of �officer� includes persons who influence or make decisions that affect the whole, or a substantial part, of an entity, including the Crown, but excluding Commonwealth, State and Territory Ministers Officers must: Have an understanding of the nature of the operations of the entity and the hazards and risks associated with those operations. Ensure appropriate resources and processes to enable identification, elimination or control of specific WHS hazards and risks, compliance with specific obligations (consultation, incident notification). Have up to date knowledge of WHS laws and compliance requirements Verify that risks and hazards are being appropriately controlled. Ensuring there is a process for receiving, considering and ensuring a timely response to information regarding incidents, identified hazards and risk Key elements of due diligence: The right structure for the organisation � the right people in the right place Consistency with other aspects of corporate governance, as far as is this will provide for WHS governance Effective means for information flow � information and advice The right information for the organisation, at the right time Proactive as well as responsive Clear designation of responsibilities (charters, PDs etc) Accountabilities and credible verification Be actively engaged in safety and lead from the top Currently most OHS Acts attribute liability to officers where a corporation is in breach of a duty and they have a reverse onus of proof to show that they did what was reasonably practicable or that they had no influence in relation to the breach. Key differences in the model Act are: - no attributed liability not reliant on guilt of organisation. Volunteers and local government councillors are immune from prosecution for offences committed under the model Act in their capacity as an officer New duty for some jurisdictions, Is a positive duty, in that officers must proactively manage WHS issues. Modified Corporations Act 2001 definition of �officer� includes persons who influence or make decisions that affect the whole, or a substantial part, of an entity, including the Crown, but excluding Commonwealth, State and Territory Ministers Officers must: Have an understanding of the nature of the operations of the entity and the hazards and risks associated with those operations. Ensure appropriate resources and processes to enable identification, elimination or control of specific WHS hazards and risks, compliance with specific obligations (consultation, incident notification). Have up to date knowledge of WHS laws and compliance requirements Verify that risks and hazards are being appropriately controlled. Ensuring there is a process for receiving, considering and ensuring a timely response to information regarding incidents, identified hazards and risk Key elements of due diligence: The right structure for the organisation � the right people in the right place Consistency with other aspects of corporate governance, as far as is this will provide for WHS governance Effective means for information flow � information and advice The right information for the organisation, at the right time Proactive as well as responsive Clear designation of responsibilities (charters, PDs etc) Accountabilities and credible verification Be actively engaged in safety and lead from the top Currently most OHS Acts attribute liability to officers where a corporation is in breach of a duty and they have a reverse onus of proof to show that they did what was reasonably practicable or that they had no influence in relation to the breach. Key differences in the model Act are: - no attributed liability not reliant on guilt of organisation. Volunteers and local government councillors are immune from prosecution for offences committed under the model Act in their capacity as an officer

7. Model WHS Act Duties of care � Workers and others Broad concept of worker Workers must: take reasonable care for themselves and others comply with any reasonable instruction, policy or procedure. Other persons at a workplace must: take reasonable care for themselves and others, and comply with any reasonable instruction. 7

8. Model WHS Act Risk management Must ensure risks are eliminated or minimised as far as reasonably practicable Focus on ensuring controls are in place not on the process of risk assessment 8 Requirement to undertake a risk assessment and recording risk assessments not explicit in the Act. Only requirements to undertake a risk assessment in the regulations are for some high risk activities, such as work in a confined space, diving. Found that an unnecessary level of focus placed on the risk assessment process instead of controlling risks Focus on ensuring controls are put in place Place for risk assessment process is in codes of practice, recognising it as a means of achieving the desired state (ie safety), rather than as an end pointin its own rightRequirement to undertake a risk assessment and recording risk assessments not explicit in the Act. Only requirements to undertake a risk assessment in the regulations are for some high risk activities, such as work in a confined space, diving. Found that an unnecessary level of focus placed on the risk assessment process instead of controlling risks Focus on ensuring controls are put in place Place for risk assessment process is in codes of practice, recognising it as a means of achieving the desired state (ie safety), rather than as an end pointin its own right

9. Model WHS Act Duty to consult PCBU must consult with: workers other persons conducting a business or undertaking with the same duty, to cooperate and to coordinate activities Provides guidance on what, when and how consultation should be undertaken Provides a flexible framework for consultation Provides for HSRs and committees where initiated by workers 9 The model WHS Act establishes comprehensive duties to consult in relation to specified work health and safety matters. It deals with consultation between duty holders as well as duty holder consultation with workers who carry out work for the business or undertaking. The duty to consult is based on recognition of international evidence which demonstrates that worker input and participation improves decision-making about work health and safety matters. The duty to consult will apply to all employers regardless of the number of workers they have. The legislation departs from an emphasis on the process of consultation to provide guidance on what meaningful consultation is and when persons conducting a business should consult, as well as how persons conducting a business can consult. The model WHS Act provides choice and flexibility regarding how consultation can occur to enable a person conducting a business and their workers to adopt the consultative arrangement which they believe will ensure effective and meaningful consultation without placing too much of a burden on the business. Within the flexible framework, the model WHS Act provides for use of the traditional workplace consultative tools including Health and Safety Representatives and/or a health and safety committee. Alternative consultation procedures cannot undermine the role of Health and Safety Representatives under the model WHS Act. The model WHS Act clarifies that workers have a right to cease and refuse work where they have a reasonable concern that they would be exposed to a serious risk to their health or safety. HSRs can issue PINs HSRs have right to direct work to cease The model WHS Act establishes comprehensive duties to consult in relation to specified work health and safety matters. It deals with consultation between duty holders as well as duty holder consultation with workers who carry out work for the business or undertaking. The duty to consult is based on recognition of international evidence which demonstrates that worker input and participation improves decision-making about work health and safety matters. The duty to consult will apply to all employers regardless of the number of workers they have. The legislation departs from an emphasis on the process of consultation to provide guidance on what meaningful consultation is and when persons conducting a business should consult, as well as how persons conducting a business can consult. The model WHS Act provides choice and flexibility regarding how consultation can occur to enable a person conducting a business and their workers to adopt the consultative arrangement which they believe will ensure effective and meaningful consultation without placing too much of a burden on the business. Within the flexible framework, the model WHS Act provides for use of the traditional workplace consultative tools including Health and Safety Representatives and/or a health and safety committee. Alternative consultation procedures cannot undermine the role of Health and Safety Representatives under the model WHS Act. The model WHS Act clarifies that workers have a right to cease and refuse work where they have a reasonable concern that they would be exposed to a serious risk to their health or safety. HSRs can issue PINs HSRs have right to direct work to cease

10. 10 Model WHS Act Right to cease unsafe work Where there is a reasonable concern that carrying out work would expose a worker to a serious risk to their health and safety: Workers HSR The model WHS Act clarifies that workers have a right to cease and refuse work where they have a reasonable concern that they would be exposed to a serious risk to their health or safety. HSRs have right to direct work to cease The model WHS Act clarifies that workers have a right to cease and refuse work where they have a reasonable concern that they would be exposed to a serious risk to their health or safety. HSRs have right to direct work to cease

11. 11 Other Provisions Notification of serious incidents obligation to preserve incident site Offence provisions relating to licences, permits, registrations, authorisations Workplace entry by Unions Broad anti-discrimination provisions Functions of regulator Enforceable undertakings Range of sentencing options Broad availability of review of decisions made by Authorised representatives (WHS entry permit holders) to have right of entry to a workplace: without notice to �inquire� into suspected contravention with 24 hours notice to advise or consult with 24 hours notice to request documents subject to permit and eligibility requirements, protections and accountability Provisions drafted to be generally consistent with the right of entry provisions under the Fair Work Act. Internal review first (inspector decisions) and then to external review process (as identified by each jurisdiction Sentencing options include: Adverse publicity orders Restoration orders Community service orders Injunctions Training orders Authorised representatives (WHS entry permit holders) to have right of entry to a workplace: without notice to �inquire� into suspected contravention with 24 hours notice to advise or consult with 24 hours notice to request documents subject to permit and eligibility requirements, protections and accountability Provisions drafted to be generally consistent with the right of entry provisions under the Fair Work Act. Internal review first (inspector decisions) and then to external review process (as identified by each jurisdiction Sentencing options include: Adverse publicity orders Restoration orders Community service orders Injunctions Training orders

12. 12 Model Regulations Representation and participation General risk & workplace management requirements Hazardous work & hazards Noise Manual tasks Confined spaces Falls High risk work (licensing) Electricity Diving Plant & structures Construction Hazardous chemicals, asbestos, MHFs Mining (NT, SA, Tasmania, Victoria, ACT, Commonwealth) Broad coverage of issues similar to existing jurisdiction legislation Essentially a harmonisation process of existing regulation from across the jurisdictions Where there were existing National Standards and Codes, these were used as the basis for the model regulations (chemicals, noise, plant, MHF, construction, licensing of high risk work, manual tasks, asbestos codes) Broad coverage of issues similar to existing jurisdiction legislation Essentially a harmonisation process of existing regulation from across the jurisdictions Where there were existing National Standards and Codes, these were used as the basis for the model regulations (chemicals, noise, plant, MHF, construction, licensing of high risk work, manual tasks, asbestos codes)

13. High Risk Work Licensing New category: Reach Stackers Revised categories : Boilers � from 3 to 2 categories Concrete Placing Booms � mobile and static Revision of assessment instruments for all categories Transition provisions for new and revised categories 13

14. Plant & Structures Design verification and design registration largely unchanged Plant item registration � 5 yearly renewal Greater flexibility with design standards referencing of Australian Standards on plant design will be in a Code of Practice 14

15. Workplace Hazardous Chemicals Classification Effectively combines existing hazardous substances and dangerous goods frameworks using the GHS as the basis for classification Adoption of GHS categories based on current Australian requirements largely aligns with existing Australian categories similar to the EU adoption of the GHS Transition period of 5 years will apply for existing chemicals (classification, SDS, labelling) 15 EU only picked up Cat 1-3 flammable liquids, Australia will include Cat 4 combustible liquids which picks up about half of category of C1 combustible liquids as currently defined (which is GHS Category 4 - flash point of 93oC compared with C1 - flash point of 150oC) Will preclude C2 combustible liquids from current regime We don�t pick up environmental hazard categories or some of the lowest categories of some of the hazard classes, eg. Category 5 acute toxicity, Category 2 flammable gases Placarding and manifests aligned with GHS classification but should have minimal impact on current compliance � placard categories and quantities generally have an equivalent alignment with existing DG classes and packing groups. Transition period aligns with review period for classification/SDS. EU only picked up Cat 1-3 flammable liquids, Australia will include Cat 4 combustible liquids which picks up about half of category of C1 combustible liquids as currently defined (which is GHS Category 4 - flash point of 93oC compared with C1 - flash point of 150oC) Will preclude C2 combustible liquids from current regime We don�t pick up environmental hazard categories or some of the lowest categories of some of the hazard classes, eg. Category 5 acute toxicity, Category 2 flammable gases Placarding and manifests aligned with GHS classification but should have minimal impact on current compliance � placard categories and quantities generally have an equivalent alignment with existing DG classes and packing groups. Transition period aligns with review period for classification/SDS.

16. Asbestos Asbestos register for all building erected before 2003 National competencies and consistent licensing requirements for: Class A (friable) asbestos removal Supervisor (Class A removal ) Assessor (for clearance monitoring) Class B (non-friable) asbestos removal Provisions for managing naturally occurring asbestos 16 For many jurisdictions, first time there will be comprehensive regulations around managing asbestos First time having a nationally consistent approach for licensing removalists � will allow mutual recognition of licences similar to high risk work licences. Two new licence categories for most jurisdictions � Supervisor and AssessorFor many jurisdictions, first time there will be comprehensive regulations around managing asbestos First time having a nationally consistent approach for licensing removalists � will allow mutual recognition of licences similar to high risk work licences. Two new licence categories for most jurisdictions � Supervisor and Assessor

17. 17 Model WHS Codes of Practice 11 key codes currently with Ministers: Risk management Consultation, cooperation & coordination Managing work environment and facilities Manual tasks Falls (general) Confined Spaces Noise Asbestos (Management, Removal) Chemicals (Labelling, SDS) Further 15 codes out for public comment Codes out for public consultation are: Managing risks of chemicals Managing risks of plant Managing risks in construction Fist aid Managing electrical risks Falls in housing construction Public comment closes 18 November 2011 Safe design of building and structures Demolition work Excavation work Spray painting and powder coating Abrasive blasting Welding and allied processes Safe access in tree trimming and arboriculture Preventing and managing fatigue Preventing and responding to workplace Bulling Public comment closes 18 December 2011 Intention is to have the key codes released as part of the public comment package later in 2010, along with the draft model regulations Further codes include abrasive blasting, spray painting, traffic management for road construction work, traffic management for workplaces, forestry, working near overhead power lines, etc.Codes out for public consultation are: Managing risks of chemicals Managing risks of plant Managing risks in construction Fist aid Managing electrical risks Falls in housing construction Public comment closes 18 November 2011 Safe design of building and structures Demolition work Excavation work Spray painting and powder coating Abrasive blasting Welding and allied processes Safe access in tree trimming and arboriculture Preventing and managing fatigue Preventing and responding to workplace Bulling Public comment closes 18 December 2011 Intention is to have the key codes released as part of the public comment package later in 2010, along with the draft model regulations Further codes include abrasive blasting, spray painting, traffic management for road construction work, traffic management for workplaces, forestry, working near overhead power lines, etc.

18. Implementation Model Act and regulations to commence 1 Jan 2012 Compliance and enforcement policy Transitional arrangements being developed HWSA : extensive program of developing regulator material for consistent implementation alignment of existing guidance material regulator training and compliance guidance 18 National compliance and enforcement policy developed and endorsed by Ministers � basis for a consistent approach to implementation Some transitional arrangements will apply nationally, some at jurisdiction level onlyNational compliance and enforcement policy developed and endorsed by Ministers � basis for a consistent approach to implementation Some transitional arrangements will apply nationally, some at jurisdiction level only

19. Future Work More fundamental review of areas of the regulation, including exposure standards, health surveillance, plant design, licensing Maintenance of referenced documents (eg. GHS, exposure standards, referenced Australian Standards) Develop further codes and guidance material to support model Act and Regulations 19 Work on model regulations to date has essentially been a harmonisation process with little fundamental review of the existing arrangements. There is recognition that some elements of the regulations still require a more fundamental review to be undertaken to guide future direction. The reviews wil need to include consideration of Role in regulation Process for setting Process for maintaining Further matters being looked at include � forestry traffic management stevedoring vibration blood-borne pathogensWork on model regulations to date has essentially been a harmonisation process with little fundamental review of the existing arrangements. There is recognition that some elements of the regulations still require a more fundamental review to be undertaken to guide future direction. The reviews wil need to include consideration of Role in regulation Process for setting Process for maintaining Further matters being looked at include � forestry traffic management stevedoring vibration blood-borne pathogens

20. 20 Further Information www.safeworkaustralia.gov.au