The short answer is, yes we are. The reason why is set out in the slightly less short answer below.
After a long time in the draft, comment and review phasesAS5327:2019 Earth-moving machinery – Access Systemswas released on the 29th of July 2019.
AS5327:2019 is as I mentioned in previous articles a modified version of ISO2867:2011 Earthmoving Machinery – Access Systems. My previous articles (see links below) have focused on the differences between the draft Australian standard and ISO2867:2011 as well as one other differences between ISO2867:2011 and ISO14122-3:2016 Permanent means of access to machinery – Stairs, stepladders and guardrails.
The main focus has been the height above the ground or nearest platform at which a platform requires a guardrail. The draft version of AS5327 required guardrails on platforms above 1m from the ground or nearest platform.
The newly published Australian Standard AS5327:2019 has changed to be in alignment with ISO2867:2011 by requiring a guardrail on platforms above 2 or 3m depending on the distance from the edge of the walkway/platform to the edge that you can fall from.
The 2 or 3m height is in stark contradiction to AS4024-1201:2014 General principles for design – Risk assessment and risk reduction which is identical to ISO14122-3:2016 Permanent means of access to machinery – Stairs, stepladders and guardrails which require a guardrail on any platform above 0.5m.
The relevant extracts from each standard are below.
AS5327:2019 & ISO2867:2011 state the following –
AS4024:2014 & ISO14122:2016 state the following –
WHS laws weigh in on the management of risk from falls as well. Regulation 78 & 79 of the WHS Regulations require that a person conducting a business or undertaking manage the risks to health and safety associated with a fall by a person from one level to another. These regulations talk about risks and suggest risk controls but do not specify the exact risk control.
It is important to note that Regulation 78 & 79 are laws where as all of the standards referenced are guidelines. Guidelines are there to help us determine what compliance could/should look like.
In summary there are 3 relevant pieces of information for consideration –
- AS5327 & ISO 2867 which are both specific to earthmoving machinery require guardrails above 2 or 3m
- AS4204 & ISO14122 which are applicable to all machinery require guardrails above 0.5m
- Regulations 78 & 79 require the most practicable risk control to be in place, which is a guardrail in most circumstances, but do not specify a height
So the question then becomes – How do we reconcile these 3 pieces of information, particularly the obvious contradictions between the standards?
The answer lies in the risk assessment process. The risk assessment process has 4 steps –
1. Identify hazards
2. Assess the risk – consequence vs likelihood3. Control the risk – hierarchy of risk control
Plant Assessor uses this process, in particular steps 2 & 3 to determine how to apply the available information from the various laws, standards, codes of practice and so on to each machine.
As a result of our interpretation of the available information and our application of the risk assessment process from August 26th 2019 onwards Plant Assessor will require all platforms above 0.5m from the ground or nearest platform on all machines that may have such a platform to have a guardrail unless certain criteria can be constantly maintained.
The new question will be –
Do all operator work platforms that are either –
a. above 0.5m and below 2.0m from the ground or nearest platform, where three points of contact cannot be constantly maintained by any person
on the platform performing expected tasks or
b. above 2.0m from the ground or nearest platform
have an approved handrail that meets the following requirements:1. All handrails are at least 1.1m high
(answer n/a if there are no platforms where the operator’s feet are above 0.5m & below 2.0m where a constant 3 points of contact is possible during access performing expected tasks)
The constant three points of contact requirement allows for operators checking fluid levels etc on machines such as motor graders where the operator’s feet may be in excess of 0.5 m above the ground, however three points of contact can be maintained because the operation is a single handed operation. An appropriate hazard warning label should be adjacent to advise that 3 points of contact is required in these areas.
Standards update table as of August 2019 –
Earth-moving machinery. Access systems
Earth-moving machinery, Design guide for access systems
Current – modified version of ISO2867:2011
Safety of machinery application guide
Safety of machinery – Electrical equipment of Machines – Part 1: General requirements
Current – supersedes 2014 version
Current – revision of AS60204.1 2005 version
Human body measurements – Basic human body measurements for technological design
Current – revision of 2014 version
Safety distances and safety gaps – Minimum gaps to prevent crushing of parts of the human body
Current – revision of
Current – revision of 2018 version
Variable message signs. Fixed signs
Current – revision of 2009 version
Variable message signs. Portable signs
Current – revision of 2009 version
Cranes – Test code and procedures
Current – modified version of ISO4310:2009
As always, Plant Assessor customers can ask me a question regarding standards or legislative obligations anytime, simply email your question to email@example.com and they will be answered in this section of the newsletter each month.
Disclaimer: This information is intended to provide general information on the subject matter. This is not intended as legal or expert advice for your specific situation. You should seek professional advice before acting or relying on the content of this information.