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Individual/Organisational name: 038 Medilife Pty Ltd
What state/ territory are you from? NSW

     Model Work Health and Safety Codes of Practice - Public Comment Response Form

 1) First Aid in the Workplace
 Comments due by Friday, 18 November 2011
 Comments: (Guide
 Blue writing – text directly from code of practice
 Red Writing – page number
 Introduction
 Code has become too vague – grey area instead of being straight out black and white. It is
 easier for companies wanting to do the right thing when they know what is expected. It is also
 unreasonable for an auditor (either WorkCover or independent) to fairly assess adequate cover
 without definitive standards. Compliance can’t be left to the interpretation of individuals who
 may have agendas that don’t have synergy with safety It will give them peace of mind when it
 is clear and precise instead of open to interpretation.
 SCOPE AND APPLICATION Page 3
 Last sentence… The words “must” and “mandatory”, these terms are required and necessary.
 Paragraph before uses terms “should” and “may”. These terms are too loose open and may be
 abused by companies, especially those intent on doing the bare minimum in following
 guidelines. Many sections where “should” and “may” are used need to be amended to the
 term “must” to enforce that it is a requirement, otherwise it won’t be followed. An example of
 this is found in the Australian resuscitation guidelines on which first aid is based, which
 ‘recommends’ CPR be done annually, a condition which is clearly not going to be followed if it’s
 seen as a choice. Annual refreshers should be mandatory in all cases if appointed first aiders
 are to be properly equipped to handle an emergency
 ************************
 2.2 Size and location of the workplace – page 6
 In relation to the size and location of the workplace, you should take into account:
       the response times for emergency services –
 Need clarification of acceptable ‘response time’. Situation dramatically different for under 10
 minutes to over 10, 20, etc
 ****
       work is being carried out a long distance from emergency facilities – page 7, line 6
 Need clarification of “long distance” before it becomes remote and requiring different first aid
 setup.
 ****
 ……. defibrillators and oxygen provision) may be needed. – page 7, lines 17 & 18.
 Change ‘may’ to ‘will’
 ****
 You should provide portable first aid kits for mobile workers – page 7, line 19
 Change ‘should’ to ‘must’
 **************************
 3.       FIRST AID EQUIPMENT, FACILITIES AND SERVICES – page 8
 …….the business or undertaking is located with timely access to medical – page 8, line 6
 Clarification required for meaning of ‘timely access’. Length of time and distance before it
 becomes a high risk category or remote because of time and distance involved. Individuals and
 companies will all have their own meaning or interpretation of this term. Therefore workplaces
 may be dramatically different to neighbouring business even if they were both deemed to be
 low risk. Clear guidelines should be established for businesses or undertakings that cannot
 ensure ‘timely access’, including properly trained personnel, suitable equipment to manage a
                                                                                       Office Use Only
Individual/Organisational name: 038 Medilife Pty Ltd
What state/ territory are you from? NSW

 casualty while waiting for emergency services. For example, where average response times are
 greater than 20 minutes first aiders must be trained in Advanced techniques and equipment
 which would include oxygen and defibrillator
 Require set parameters.
 ****
 3.1      First aid kits
 Contents
 At least one first aid kit should be made accessible to all workers at their workplace. The first
 aid kit should provide basic equipment – page 8, lines 14 & 15
 Change ‘should’ to ‘must’
 ****
       broken bones, and
       eye injuries. – page 8, lines 20 & 21
 Add an extra bullet point – Shock. Shock is one of the major occurrences requiring first aid. Can
 be a result of bleeding, etc
 ****
 Design of kits – page 8, lines 32 to 35
 First aid kits can be any size, shape or type to suit your workplace, but each kit should be large
 enough to contain all the necessary items. Kits should also contain a list of the contents for that
 kit and have a white cross on green background that is prominently displayed on the outside
 Most first aid kits on the market today fail to do this. The logo of the company manufacturing
 or selling the first aid kit has their logo far more prominent than the first aid cross symbol.
 Need to add a statement that any manufacturer/seller details to be smaller and less obvious
 than the first aid symbol. This will save confusion of what is a first aid kit.
 ****
 …aid kit should be identified by a prominent sticker on the vehicle that either marks the
 location of the kit, or explains where it is. – page 9, lines 1 & 2
 All trucks, vans and work utes should have this signage. The issue is regarding small glove box
 kits in company cars. Imagine an expensive corporate company car, e.g. BMW, Mercedes, etc
 having the need of a ‘prominent sticker’. Where would the sticker be placed? It would detract
 from the look and feel of the vehicle and may damage the vehicle and have a negative effect
 on resale value. Where would auditors stand on this issue if most owners of these vehicles
 refused to place a sticker?
 ****
       ensure items are in good working order, have not deteriorated and are within their
          expiry dates – page 9, lines 9 & 10
 Need to consider if a sealed sterile product has been opened or tampered with. Add, “Sterile
 products to be unopened or not tampered with”
 **************************
 1.4      First aid facilities
       A first aid room is recommended for: – page 9, line 42
 Change ‘recommended’ to ‘required’. Not many companies will follow this recommendation. The
 statement needs to become a definite requirement, so that it is correctly and thoroughly followed.
     low risk workplaces with more than 200 workers, and – page 9, line 43
 Change ‘more than 200 workers’ to ‘200 and more workers’. Becomes more defined
     high risk workplaces with more than 100 workers. – page 9, line 44
 Change ‘more than 100 workers’ to ‘100 and more workers’. Becomes more defined
 ****
                                                                                   Office Use Only
Individual/Organisational name: 038 Medilife Pty Ltd
What state/ territory are you from? NSW

 The following items should be provided in the room: – page 10, line 1
 Change ‘should’ to ‘must’ – otherwise most items will be left out if not mandatory. Too open
 to interpretation
 ****
 The following is a partial list of items that make up a first aid room. Recommended changes
 and additional items that is required.
      a sink with a hot and cold water supply, soap and disposable paper towels – page 10,
          line 3
 Add to ‘soap’ definition – should be – ‘soap that can hygienically clean’
      a couch or bed – page 10, line 4
 A ‘bed’ is not suitable for a first aid room. Most beds are too low and do not have a waterproof
 surface. They are easily contaminated and hard to keep hygienically clean. It can only be used
 in rest/sleeping/nap room.
 ‘Couch’ definition should be changed to ‘Examination Couch with waterproof surface’. This
 type of couch is used in most doctor surgeries and existing first aid rooms.
      a cupboard for storage of dressings, utensils and linen – page 10, line 5
 For hygiene purposes, substitute ‘linen’ for ‘Disposable single use sheets’. To be swapped after
 use. Linen does not always get swapped after use and the issue of laundering comes up. Using
 disposable sheets is a hygienic method to ensure health and safety standards are kept and to
 mitigate cross contamination
      a container with disposable lining for soiled waste – page 10, line 6
 Reword statement to add the option of a dedicated sealable and disposable contaminated
 waste bin. Disposable linings to be biohazard material – yellow with symbol.
 New statement to read – ‘A suitable container fitted with disposable biohazard bag/liner for
 soiled waste or a disposable sealable contaminated waste container’
 The following items should be provided in the room: – page 10, lines 1 to 13
 Add the following items to contents list for a first aid room
      Pillow with disposable pillow case/sleeve
      Examination lamp with magnifier
      Sufficient supply of disposable gloves
      Current edition of a First Aid book
      Current CPR Wall Chart
      Portable Oxygen Resuscitation system
 I have compared all of the current state and territory requirements for a first aid room. By
 adding the above items, the first aid room will be an effective centre of first aid care until the
 arrival of emergency care personnel.
 *****************************
 3.5      Trained first aiders – page 11, lines 13, 17, 18
 Types of trained first aiders
 Basic first aider means a person who….
 The requirement for a ‘Basic First Aider’ should be changed to the next level - senior first aider
 (Apply First Aid). There is no point in having a mid level qualification in first aid, unless the
 intent is to have as many staff as possible adequately trained to assist the appointed first aider
 in an emergency. Most industries now require the qualification Apply First Aid not Basic First
 Aid. It is much easier for staff to cross industries or businesses if they have the Apply First Aid
 qualification rather than the basic level. Also, many more students are taught Apply First aid
 compared to the Basic First Aid. There is only 1 to 2 hours extra training involved to get the
                                                                                     Office Use Only
Individual/Organisational name: 038 Medilife Pty Ltd
What state/ territory are you from? NSW

 higher and more comprehensive Apply First Aid Qualification.
 Removing one level of first aiders and transferring the requirements to the next one up –
 (Senior) Apply first aid will streamline and simplifier the process.
 ****
 Senior first aider means a person – page 11, line 21
 ‘Senior first aider’ is an out of date term. This will give a misconception and cause confusion on
 the required qualification. Senior first aid was an old St John’s term. The correct term is ‘Apply
 First Aider’ and that marries up with its qualification Apply First Aid HLTFA301B or now
 HLTFA301C. Replace all references of ‘Senior’ to ‘Apply’.
 ****
 Remote first aider has the competencies of a senior first aider as well as competencies required
 to provide first aid to a casualty in a remote and/or isolated situation including preparing for
 aero-medical evacuation.
 The term ‘remote and/or isolated’ needs to be defined with set minimum specifications.
 What will be specifications on:
      Distance from emergency services/hospital/medical centre
      Travel time to emergency services/hospital/medical centre
      Access – How is easy to get to. Might need 4WD, plane to access
 Once defined, will help businesses know if they fall into the remote category or not.
 ****
 Training for first aiders – page 11, last two lines & – page 12, lines 1 & 2
 First aiders should hold nationally recognised Statement/s of Attainment issued by a Registered
 Training Organisation (RTO) for the nationally endorsed first aid unit/s of competency. First
 aiders should attend training on a regular basis to refresh their first aid knowledge and skills
 and to confirm their competence to provide first aid.
      1. Change ‘should’ to ‘must’ – most people will not have refresher training if not
          mandatory. The term ‘should’ is too vague and open to interpretation. A person may
          know they ‘should’ go on a diet or give up smoking. Clearly the wording must be
          stronger to ensure adequate facilities, training and equipment is provided
      2. Define and set time limits to ‘regular basis’. Currently there is great by employers,
          industry and people in general about how often first aid refresher training should occur.
          Most trained skills are enhanced because of repeated use and repetition e.g. driving,
          trade skills, etc.
          Unfortunately, First Aid skills are dramatically lost, especially CPR skills due to the lack
          of ongoing use and practice. Research into recall of learnt skills diminish progressively
          over time and in particular in the first few months. Based on international standards, as
          well as the Australian Resuscitation Council guidelines which the first aid courses are
          based on, strongly recommends annual retraining for CPR and advanced Resuscitation
          skill component. The Apply first aid and advanced first aid qualification should be
          retrained/refreshed every 3 years. Guidelines provide under this code should not rely
          on the SRC to provide recommendations for refreshing skills. Their expertise lies in
          reviewing international research and making recommendations for local conditions.
          These codes therefore must be more prescriptive. It removes uncertainty and provides
          clear guidelines on proper provision of first aid in the workplace (and other
          undertakings)
          ****
 In low risk workplaces, basic first aiders are sufficiently qualified to perform CPR and treat
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Individual/Organisational name: 038 Medilife Pty Ltd
What state/ territory are you from? NSW

 minor illnesses and injuries. – page 12, lines 9 & 10.
 There is no need to add another level of confustion by offereing an alternative course.
 Organisations who choose to offer broad based education to staff may offer an awareness
 course (non accredited), in much the same way as fire awareness training is undertaken, but
 frankly this is unlikely to happen
 Low risk workplaces should not have basic first aiders but instead Apply First Aiders as
 previously explained.
 Also, it will have a dramatic effect on small RTOs who mainly teach the longer course Apply
 First Aid who will then have their income reduced by training more students with the shorter
 course Basic First Aid.
 ****
 Number of trained first aiders – page 12, lines 11 to 19
 In low risk workplaces, consider providing:
      one first aider for 10 to 50 workers
      two first aiders for 51 to 100 workers, and
      an additional first aider for every additional 100 workers.
 In high risk workplaces, consider providing:
      one first aider for up to 25 workers
      two first aiders for 26 to 50 workers, and
      an additional first aider for every additional 50 workers.
      1. The minimum trained first aiders per workplace over ten people for both low and high
          risk should be TWO not ‘one’. Based on duty of care and due diligence, you need to be
          prepared for the possibility of incident or accident occurring to the nominated first
          aider. If he/she were the only first aider, who would administer the required first aid,
          support and comfort until the paramedics arrived. By having a minimum of two first
          aiders the risk factor will be greatly reduced by nearly always having one first aider at
          call.
      2. Ratio should be 2, (as per above comments) per 25 – 30 people for all risk categories.
          An exception to this guide could be schools, where each teacher should be a first aider
          to safely monitor the students, whether in the classroom, sporting field or excursion.
      3. An option is that all staff be trained in first aid as this skill is a life skill and is beneficial
          for work, home and play. Therefore the number of paid first aiders can be as
          recommended if all the staff are first aid trained and current with their qualification.
          Anyone then can be called upon when needed, irrelevant of circumstance, time or
          place.
 ********************************
 APPENDIX B – EXAMPLE OF CONTENTS FOR FIRST AID KITS – page 17
      Basic instructions for providing first aid – add term – current guidelines
      Cardio-Pulmonary Resuscitation (CPR) flow chart – remove - not required in kit as it
          should be covered in most first aid booklets.
      Saline (30mls) – remove – Only one brand available in Australia. Cost prohibitive – over
          5 times the price of the 15ml saline (more than 5 brands available).
          I have been advised that the 30ml saline has been approved as a box of 30 (Medicine)
          and cannot be broken down to smaller units as original directions and packaging details
          will be lost, when repacking into a first aid kit. This needs to be verified with the TGA
                                                                                   Office Use Only
Individual/Organisational name: 038 Medilife Pty Ltd
What state/ territory are you from? NSW

        and product sponsor.
        Most importantly, the vial shape and size is identical to a vial that contains antiseptic
        liquid – Chlorhexidine. It has occurred on numerous occasions that when in a rush, the
        first aider has grabbed the wrong vial because of the close similarity and flushed the
        eye with antiseptic liquid instead of saline. This just causes further harm and pain to the
        casualty. Instead 10 x 15mls saline should be placed in the standard workplace kit.
        Option – state that 2 x 15ml saline can be used as a substitute per 30ml saline.
       Wound cleaning swab (single 1% Cetrimide BP) – Change term to ‘wipe’ or ‘towellete’.
        Most antiseptic wipes are tissue size and more effective in cleansing a wound than a
        small swab which is slightly larger than a postage stamp.
       Adhesive dressing strips (packet of 50) – Specify material. Small WK should be ‘plastic’,
        while the standard WK should have ‘2 x adhesive dressing strips (packet of 50)’, one
        ‘fabric’ and one ‘plastic’.
        ‘Blue detectable adhesive dressing strips (packet of 50)’ should be added to all areas
        where there is food preparation in behalf of other people - industrial, commercial and
        internal such as cafeterias. This complies with international standards for food
        preparation.
       Splinter probes (disposable) – Probes are a necessity but where will the used ones be
        disposed of. Each kit should either have a small portable ‘sharps container’ or have a
        sharps container situated next to the first aid kit for safe and hygienic disposal.
       Tweezers – the correct term and item most commonly used throughout Australia is –
        ‘Forceps 12.5cm Stainless Steel’
       Antiseptic liquid, spray or swabs (single use packs) - Antiseptic liquid should be in ‘pre-
        diluted or correctly mixed format’ and in a ‘spray bottle’ to avoid cross contamination.
        Products such as liquid Savlon and Dettol require dilution and should not be applied
        directly to the skin or wound.
       Reusable or instant ice pack – choice depending on availability of freezer (e.g. for
        treatment of soft tissue injuries and some stings). Reusable ice pack unsuitable for a
        first aid kit. Refrigerator or microwave not readily available in most circumstances.
        Include for First Aid Room. Instant pack only should be in a first aid kit.
       Additional items that should be included in a first aid kit:
             o ‘Heavy crepe bandage 7.5cm and 10cm’ – used for sprains, strains and snake
                 bites. Conforming bandages are unsuitable for this purpose.
 ****
 The remote module – page 18, lines 13 to 17
 Where people work in remote locations, a first aid kit should include:
       emergency reference manual
       broad crepe bandages (for snake bites)
       cervical collar (for spinal/neck injuries)
 ‘Cervical collar’ should not be included as a high level of training is required and should not be
 applied by a single operator. It requires a minimum of two people.
 ************************
 Contaminated items – page 19, Second last paragraph - lines 1 to 3
 All items that are soiled with blood or body substances should be placed in plastic bags and
 tied securely. Waste disposal should comply with any state or local government requirements.
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Individual/Organisational name: 038 Medilife Pty Ltd
What state/ territory are you from? NSW

 ‘Plastic bags’ should be clearly identified, yellow plastic with the wording biohazard or
 contaminated waste.

 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 2) Managing Risks in Construction Work
 Comments due by Friday, 18 November 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 3) Preventing Falls in Housing Construction
 Comments due by Friday, 18 November 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 4) Managing Electrical Risks in the Workplace
 Comments due by Friday, 18 November 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 5) Managing Risks of Hazardous Chemicals
 Comments due by Friday, 18 November 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 6) Managing Risks of Plant in the Workplace
 Comments due by Friday, 18 November 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?
                                                                                          Office Use Only
Individual/Organisational name: 038 Medilife Pty Ltd
What state/ territory are you from? NSW


 7) Safe Design Of Building and Structures
 Comments due by Friday, 16 December 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 8) Excavation Work
 Comments due by Friday, 16 December 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 9) Demolition Work
 Comments due by Friday, 16 December 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 10) Spray Painting and Powder Coating
 Comments due by Friday, 16 December 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 11) Abrasive Blasting
 Comments due by Friday, 16 December 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 12) Welding and Allied Processes
 Comments due by Friday, 16 December 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?
                                                                                          Office Use Only
Individual/Organisational name: 038 Medilife Pty Ltd
What state/ territory are you from? NSW

 13) Safe Access in Tree Trimming and Arboriculture
 Comments due by Friday, 16 December 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 14) Preventing and Managing Fatigue in the Workplace
 Comments due by Friday, 16 December 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?



 15) Preventing and Responding to Workplace Bullying
 Comments due by Friday, 16 December 2011
 Comments: (Please include section/page numbers).


 Impacts: Do you anticipate any potential costs or safety benefits of complying with this code that are
 different to current requirements in your jurisdiction? If so what are they?




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