Safety Matters #3 The Top 4 Most Frequently Asked Questions – with Andrew Kidd

Written and provided by Andrew Kidd, Chair of the FTMA Frame and Truss National Safety Council

Recent advice summary

Since the establishment of the Frame and Truss National Safety Council last year we have had a constant stream of questions and queries on many safety related matters. Some of the questions have been general in nature and others have been quite specific. In this newsletter we will recap the answers to the most commonly asked questions.

It is common to see a flurry of questions around certain topics as the various state-based safety regulators have their particular focus projects. Recently inspectors in Victoria, NSW and the ACT have variously been running campaigns looking at noise, chemical safety, traffic management, machine guarding and nail gun use.

As always, reach out if you would like any specific questions answered or just want more information.

1. Use of hand-held pneumatic fasteners (nail guns)

I’m sure that we all know that nail guns are a very dangerous tool that can result in significant injury if mishandled or operated with a lack of attention to the task at hand. Most F&T plants will have had experience in dealing with injuries related to the use of nail guns in their production operations. Here are a few of the most basic risk controls that should be in place for nail gun operations.

• Induction

• Employees must receive a comprehensive induction into the workplace, the job tasks they will be performing and the equipment they will be using –

• They must be aware of all reporting requirements for any task/job exceptions and who to talk to if they have problems or concerns. They must also be area of where they can get copies of all the relative documents: manufacturer’s manual, risk registers and assessments, SOPs and job instructions.
• Keep in mind that employees under 25 are defined as “young workers” and there are specific and active steps expected of employers when managing these employees.
• Instruction

• Ensure that you have copies of the tool manufacturers operating or owner’s manuals, including the inspection, maintenance and servicing guidelines. These are important reference documents, and it is important to ensure that any SOPs or procedures for tool use are written with these documents in mind – 

• There must be a full suite of instructions for the safe management and operation of nail guns. You will need: detailed employee training and assessment documents, risk assessments, isolation and tag out / lock out procedures, SOPs / JSAs for the type of work being done, records of inspection – nail gun daily checklists and records of maintenance.
• Document the basics: how far form the timber edge can you nail? How far away should your other hand be? Can you nail towards another person? Can you tap the component into position with the nail gun? How far apart do the nails get placed when laminating or stich nailing? What is the correct air pressure for operating the tool? Specifically, what should be checked on the tool before you use it?

• Training
• • You cannot rely on someone’s stated previous experience in the use of tools or working at similar tasks. Every person who uses nailing tools must have their competence checked, verified and documented before being permitted to use the tools without direct supervision.

• • You must have evidence that everyone who uses a nail gun has been trained in the use of each tool he/she uses. Treat nail and staple guns as separate tools. You should ensure that each person has been assessed as competent on all of the tools he/she uses by a person who has been themselves assessed as competent.

• • The person you use as your trainer must be competent at the task and in the use of the tools. He/she should also have good communication skills, patience and empathy with an eye for detail. Your fastest operator may not be the best person to be your trainer. The skills required to show another person how to do something are very different to the skills of doing it yourself.
  • Allocate each operator a mentor who they can go to for any advice or clarification and ask any questions needed. The mentor might be their trainer or a very experienced operator, but it should be someone who is willing and able to provide guidance and advice when it is needed.
  • Training and assessment should cover in detail all aspects of using the tools and undertaking all tasks. Train and assess them in pre-op checks, all types of joints and firing, skew nailing, stitch nailing, when to change nail sizes, how to refill nails, basic tool maintenance, fault finding and repairs, how to isolate the air when needed and when / how to tag out / lock out a tool. Ensure they know how far away from timber edge they can nail and what defects to look for in the timber before nailing. The basics like how to hold the tool and where to have your other hand must be covered.
  • Document the training and assessment in detail. If it is not documented, it could be argued that he/she wasn’t trained and didn’t know it. I’ve heard an injured worker say, “I didn’t know I had to disconnect the air line before clearing a jamb in the nail gun”.
• Supervision
  • Workers undertaking high risk activities, such as the use of nail guns, must be supervised. Supervision will include ensuring that rules, processes and procedures are being followed. Make sure nobody is taking short cuts or not following procedures. This means that leading hand or managers must do regular checks on the production line, several times per day.
  • In the event of an incident, you will need to show that the supervision of staff was adequate to detect and correct any inappropriate behaviours in tool use.
  • Supervisors should have a track record of seeing and correcting common behavioural risks such as, pre-start checks not being done, hands too close to gun when firing, using the tool as a hammer, firing towards self or other people, firing too close to the edge / end of the workpiece etc.
• Equipment
  • Have a record of what selection criteria was considered when the tool brand was chosen. Don’t buy the cheapest tools. Decide on the safety features you need and purchase based on these. Consider tool weight, handling ergonomics, safety contact tips, sequential fire mode, cordless, reduced noise etc.
  • Don’t use tools in “bump fire” mode.
  • Where possible, consider using two-hand activated nailing machines that reduce the overall number of nails fired by the hand-held nail guns in the production facility. These automatic nailers are considered a higher-order control as the operator’s hands are removed from the clamping and nailing functions and thus, they contribute to reduction of the number of nails fired by hand, which in turn, reduces the risk of operator error / injury.

We have been involved in a discussion where a member was told that the Safety Regulator did not agree with their training that an employee could hold the timber component being nailed at a distance of 150mm to 250mm away from the nozzle of the nail gun. The Regulator did not want any hands in a direct path of the line of fire.  No hands in front of the nail gun nozzle at all.

We highlighted that a prohibition on hands in the path of the nail was not reasonable and that other controls were suitable. Further, we were able to show that there is a large volume of industry guidance, both written and video, that refers to safe hand placement at distances between 150mm and 300mm when using nail guns. Our involvement likely contributed to the inspectors involved walking back their initial severe conclusion and suggestions.

2. Workplace noise issues

Noise is a well-known hazard in most manufacturing environments and the fact that conversations are difficult to have, voices must be raised to be heard over machinery etc is all an indication that exposure noise is happening and that there is an issue to deal with or. more correctly, a hazard to be identified and controlled.

All jurisdictions in Australia have set the same maximum noise exposure limits for workers. The common requirement is, if employees in your workplace are exposed to noise that exceeds the exposure standard of 85 dB(A) averaged over an eight-hour period or a peak noise level of 140 dB(C) then your workplace is too noisy. (Note dB is the abbreviation for the decibel – the unit used for sound pressure levels on a logarithmic scale).

The Safety Matters newsletter from September 2024 had an in-depth article about noise in the workplace and it is worthwhile to go back and read that edition if you need further information, but to highlight a few key points. In relation to workplace-based noise, employers are required to –

• Identify the hazard, any noise exposure at a level that is harmful to hearing
• In order to identify the actual noise level in the factory testing must be undertaken and the results documented
• If testing confirms noise levels above the exposure standard controls must be developed and implemented – a noise control plan
• Once you confirm the noise is above the exposure standard, your workers must wear PPE, and the noise they are exposed to will dictate the level (type) of PPE required
• If workers are exposed to noise levels above the standard you are obliged to provide regular audiometric testing for them
• The audiometric testing must be done within three months of them starting work in the noisy environment and every two years thereafter.

3. High Risk Work Licences

We have received a few questions regarding the need for a High Risk Work Licence (HRWL) for dogging (class DG). The questions mainly revolve around the need for a dogging ticket if you are engaged in delivering products using a Vehicle Loading Crane (VLC) or pre-slinging the loads in the yard.

The short answer is: if your driver’s have a CV class HRWL, then neither your drivers, yardies or forklift operators need the DG class HRWL.

I believe there are a few key things that all Frame & Truss (F&T) suppliers should have in place to maximise the compliance and safety of T&F deliveries to site, they include –

• Delivery drivers who operate a Vehicle Loading Crane (VLC) should have a HRWL class CV. Whilst the regulations currently only require a HRWL for VLCs with a capacity of 10 metre tonne or greater, there are many reasons that make it a good practice for all VLC operators to have a CV class HRWL regardless of the size of the VLC they operate.
  Note: A crane has a capacity of 10 metre tonnes if at any position on the crane’s load chart, the radius (in metres) multiplied by the load (in tonnes) is equal to or greater than 10.
• Loads that are to be unloaded on site with a VLC should have all planned lifts pre fitted with lifting equipment before they depart the plant. This is to reduce the necessity for the driver to climb onto the trailer to sling anything that needs to be unloaded. The pre fitting of lifting equipment to all packs to be unloaded can be done in advance by yard staff when they are pre loading trailers / road pods, or it can be done in combination by the driver and forklift operator as they load the trailer.
• All lifting equipment must be inspected by a qualified person at least annually and a lifting equipment register must be maintained showing the results of these annual inspections. Additionally, each sling should be inspected before each use to determine it is still fit for use. The workplace should have a procedure for isolating any suspect lifting equipment until it is inspected by a competent person (dogman, rigger or inspection service) and either assessed as fit for use or destruction.
• All products assembled into packs for lifting on site by VLC must be marked with the total lift weight in a manner that is obvious to the VLC operator. This is usually done by the forklift operator weighing the pack using the forklift weight scales during the loading process and then marking the pack or paperwork with the determined weight. It is critical that the VLC operator has accurate knowledge of the weight being lifted by the VLC and the radius of the lift.
• Where lifting equipment is to be pre fitted by yard staff, the employer must develop an SOP / procedure / guide which details where and how to pre fit the lifting equipment to various standard loads. This SOP should be developed in consultation with a DG or CV HRWL holder and the staff doing the pre fitting of slings. The guide should include the slinging method and placement used for all types of loads to be lifted with the VLC. Sling types, lengths and distance apart of sling points should be noted as these affect sling angles and therefore capacities. The SOP should specify the use of choke hitches and chain shorteners when required. The SOP should be reviewed regularly in consultation with those involved in the loading and unloading processes.
• All delivery vehicles fitted with a VLC for unloading should have a portable extension ladder that can reach the top of the load and is capable of being secured to the trailer. This is for safe access to the trailer / load should there be any need to access areas of the load that cannot be reached from the ground. Freeing a stuck or jammed strap or lifting equipment is a common reason to need to access the top of a load.

Whilst many of the above points are not mandated by legislation, they are industry long-standing best practice and have withstood the scrutiny of many an inspector from most state safety regulators.

However, I would strongly suggest that plants could increase the level of safety redundancy in your safety system by having one, or more, of your key logistics or yard staff trained up as a DG class LHRW holder. This would enable your forklift operators and yard staff to have a “competent person” to seek help from or ask questions of, when they are pre fitting the lifting equipment to the loads and the driver is out doing deliveries. This extra qualified DG person would also give your business another competent person to participate in the development and review of your SOPs for the pre fitting of slings and loading of trailers or road pods.

4. Safety footwear

We have been asked if the requirement for wearing ‘safety boots’ is mandated.

The question of what is appropriate footwear in a Frame & Truss (F&T) production environment is not formally specified in any legislation or industry guidance but rather is usually set by the workplace rules and procedures.

All workplaces should have a process by which they assess the hazards and risks associated with the tasks undertaken by staff in their job roles.

Usually, a F&T production person would be handling heavy tools, timber, clamps, hammers etc all of which pose a risk of injury to the feet / toes should anything be dropped. Also, the production environment usually has a range of moving plant parts such as; trolleys, pallet jacks, tug motors, forklifts etc all of which would cause a serious injury to the foot / toes should they come into contact with any moving plant.

Accordingly, it is the industry norm that anyone working in the F&T production areas, yard storage or transport areas or timber handling should wear solid construction footwear that is oil resistant with non-slip soles and compliant with Australian Standard (AS) 2210.

AS2210. 3 2019 is the standard for safety footwear and specifies that footwear is required to incorporate a toe cap that provides protection against an impact of 200 joules and a compression of 15 kilonewtons.

Any safety supplier or shoe shop will have a range of footwear that is certified to comply with AS2210 and it would be prudent for an employer to ensure all of their factory, yard and delivery workers were required to wear such footwear whilst working.

My recommendation is that the workplace should have a clear and stated policy that staff in the production, yard and delivery environments must wear AS2210 compliant footwear whilst on duty. In fact, when a staff member arrives for work in non-compliant footwear, he/she should be sent home to get the correct footwear.

Hopefully the above information answers gives you some helpful hints on managing safety in your workplace, but if you need any further guidance or information, please don’t hesitate to contact me.