AFCA is leading the development of an industry and national Forestry Log Haulage Registered Code of Practice (FLHRCoP).
The National Heavy Vehicle Regulator (NHVR) has developed new framework which encourages industry to work with them to develop a voluntary registered Code of Practice (RCoP) that is appropriate for the industries circumstances. The NHVR released an introduction and guidelines in January 2017 to support those who wish undertake the development of a RCoP. To view the guidelines or see further information visit the NHVR website at https://www.nhvr.gov.au/safety-accreditation-compliance/industry-codes-of-practice
The forest industry has a responsibility to ensure the supply chain, particularly log haulage is conducted in a safe and efficient manner under the Heavy Vehicle National Law (HVNL). The project aims to identify how everyone can address their Chain of Responsibility obligations. Given the importance of safety to our industry and the risk associated with log transportation it is important for industry to consider and agree on national best practice approach for log haulage and provide guidance on the steps. The overall objective being to improve and support safety outcomes and drive best practice in log haulage.
It is expected that the Log Haulage RCoP will identify and assess the risks along the supply chain for log haulage and establish standards and procedures to mitigate risks with respect to the HVNL. The Log Haulage RCoP will specifically cover the haulage of logs and specifically consider risks relating to loading, log restraint, rollover prevention and unloading and safe driving practices.
What will the LHRCoP Do?
• Support industry to demonstrate compliance with the new legislation
• Create a system that can be third party and internally audited
• Improve safety of log haulage
• Address and manage forest industry specific risks
• Provide for an industry wide standard with consistent elements
• Opportunity to create “best practice standards”
• Clarify responsibilities along the supply chain
• Provide a legal defense if something goes wrong
What will it cover and how will it be delivered?
It will address aspects specifically relating to the haulage of logs including, loading, restraint, dispatch, transportation and unloading. This means that it will also consider all those within the supply chain that have a role to play including, landowners/forest managers, harvesters, hauliers, processors and port operators.
Broadly the project will include a literature review to capture the good work that has already been done in this space followed by a thorough Risk Assessment by an independent expert and it will involve representatives and consultation with participants from all of the supply chain.
A formal governance structure is proposed which allows all of industry to guide and provide input into the project - to view click below.
AFCA has now filled the 2 positions available on the Project Steering Committee and is pleased to have James Asher from Queensland and Barry Fennell from the Green Triangle representing forestry contractors businesses. There are still 2 positions on the Project Working Group currently being filled. The Working Group will assist in the risk assessment work and help shape the Log Haulage RCoP development.
There will also be a range of other opportunities to become involved and provide feedback into the project in addition to the 4 positions available mentioned above. If you would like to register for project updates -please register your details at this link
How is it being funded?
The Australian Forest Products Association membership has agreed to provide funding for 50% of the project and the Forest and Wood Products Association will provide additional funding to support the project. The AFCA Board has agreed to provide $50,000 in kind support in order for the General Manager to project manage the project given the importance of this project to our members.
Ernst & Young Appointed to assist in background project work
At the Australian Forest Products Association meeting in September 17 it was supported to appoint Ernst & Young (EY) to undertake a Review Report and Risk Assessment that will inform the development of the Log Haulage RCoP. This was the recommendation of the Project Steering Committee following an Expression of Interest Process.
The Review Report will review and assess policies, existing codes of practice, and documented practices and procedures relating to the transportation of logs within the forest industry. The purpose of the review is to capture and summarise the current information that exists, identify inconsistencies and gaps to inform the preparation of the Log Haulage RCoP.
The Risk Assessment for Log Haulage will be developed in the context of the National Heavy Vehicle Law. The Risk Assessment is requirement of the NHVR's Guidelines and is to be developed in accordance with AS/NZS ISO 31000:2009 Risk Management — Principles and Guidelines.
In addition, as part of the process, there will opportunities for all of industry to provide input and feedback to inform the Risk Assessment which will provide the basis for the Log Haulage RCoP.
Risks and Key Issues Report, June 2018
Following feedback on the Draft Risks and Key Issues Report it has now been finalised. Thanks to all those who took the time to review the Report and provide feedback. The final report can be view below.
All background work has now been completed to inform the preparation of the FLHRCoP. The next stage is to draft the FLHRCoP.
Work has already commenced on drafting the FLHRCoP, including an outline and key contents. Over the coming weeks further work will continue to populate a Draft FLHRCoP, with the Project Working Group. A focus is also to identify any gaps in technical information and whether there is a need to source technical expertise to draft components of the code.
Once a draft FLHRCoP is completed further industry wide consultation will occur to test the proposed response to risks as outlined the the draft.
Risk Assessment Findings, April 2018
DRAFT Risks and Issues Report
To support the development of a national code of practice specifically for log haulage, the FLHRCoP process has provided multiple opportunities for industry to engage and contribute, and EY have undertaken a number of consultation and risk assessment activities.
The ‘FLHRCoP – Risks and Key Issues Draft report’ is a summary of the risk assessment, research and consultation activities undertaken by EY, and has been developed to inform the code of practice.
Thank you to those who took the time to provide feedback to the Risk and Issues Report. The time to provide feedback has now closed and the DRAFT Risk and Issues Report is now being finalised.
The next step is drafting the FLHRCoP which is expected to be drafted by end of June 2018.
NOTE: There has been extensive consultation and analysis regarding the risks that have been assessed and included in this report. The risks have been finalised and agreed and will not be revised – the purpose of this survey is to collate additional data with regards to the selected risks.
Workshop Findings and Key Risks, February 2018
Following on from the workshops held in November and December 2017 EY have now presented the data that was collated and analysed to provide additional insight into the different types of incident events, as well as their frequency and severity. Analysis was presented back to the Steering Committee and Working Group for final comment. The outcomes of the consultation and summary of the keys risks identified for log haulage can be downloaded here
The proposed risks to be assessed and included in the CoP are as follows:
1. Partial loss of load
2. Loss of control of log during loading/unloading.
3. Loss of debris
4. Manual handling
5. Rollover and/or full loss of load.
6. Third party collision
7. Loss of control of the vehicle
8. Load shift
9. MHE crash/ crush
The next steps will be to hold discussions with the National Heavy Vehicle Regulator regarding the risks identified and to discuss possible controls and best practice with industry.
Master Code of Practice - Version 4 Final Consultation May 2018
Version 4 is now available of the Master Code of Practice and is the final stage of the consultation process prior to being finalised and submitted to the NHVR. Following this the final Master Code will then be assessed by the NHVR for registration.
In order to inform the Risk Assessment component and the development of the FLHRCoP a Preliminary Report has been prepared. The Preliminary Report considers the current state and key safety issues of log haulage and identifies current gaps, deficiencies and variations in practice within industry. The Report was supported by consultation with industry through interviews, workshop and day in the life activities. The Preliminary Report will inform the next steps of the process including framing the Risk Assessment consultation and development of the code.
To support the development of a national code of practice specifically for log haulage EY have completed the risk assessment consultation phase of their project. Three workshops were delivered over late November and early December, with over 70 people attending. There was a healthy representation from forestry contracting businesses, land owners and consigners, and trailer manufacturers. Each workshop was also attended by Aaron Moeller from the NHVR and Peter Elliot from the Australian Logistics Council who spoke about changes to the NHVL and the development of a Master Code of Practice (MCoP).
The objectives of the workshops were to get industry involvement in the identification of critical risks associated with log haulage and collect information and data about controls and better practice. The information and insights collated is to inform EY’s report to AFCA that will then be used to build the Forestry Log Haulage Code of Practice (CoP).
The purpose of the risk assessment is to identify risks specific to log haulage that will require the CoP to provide guidance and specification. Risks not specific to log haulage are to be addressed in the MCoP or other legislation, such as the Workplace Health & Safety Act.
This briefing paper provides a summary of the risks identified throughout the workshops and their categorisation of whether the risk is considered:
Risk to be included in the CoP (Table 1)
Risk to be determined for inclusion in CoP (Table 2)
Risk that will not be included in the CoP (Table 3)
Industry feedback is being sought to:
Validate the risks to be included in the CoP (Table 1)
Consideration of whether the undetermined risks should be in or out of CoP (Table 2)
Validate the risks that should not be included in the CoP (Table 3)
Feedback can be provided via email to email@example.com by no later than 15 January 2018.
Risks to be included in the CoP
The below Table 1 provides a summary of the keys risks identified for log haulage as a result of the consultation and workshops that are proposed to be included in the CoP.
Context & Justification for inclusion
This risk includes trailer and/or cab rollover. This is specific to log haulage due to the organic nature of the load, road conditions, trailer design requirements, and SRT.
Loss of control of the vehicle
This is specific to log haulage due to the organic nature of the load, road conditions, trailer design requirements, and SRT.
Full loss of load
This risk considers loss of a whole bay, not just whole load. This is included as load restraint requirements are unique due to the organic nature of the load and equipment type/design.
Partial loss of load
This risk is defined as loss of single or multiple logs. While very similar to full loss of load, it is viewed as a different risk profile. This is included as load restraint requirements are unique due to the organic nature of the load and equipment type/design.
Rolling log during loading/unloading.
This risk is considered due to the very specific loading and unloading requirements of the load, and the environment/conditions under which the activities are undertaken. While the risks are slightly different, they have been clustered as there is a high level of similarity.
This risk considers any shift of the load from under restraint straps during transport. This is included as load restraint requirements are unique due to the organic nature of the load and equipment type/design.
Loss of Debris
This risk considers loss of bark, branches, rocks or other foreign matter during driving.
This risk is specific to load restraint manual handling risks only. Other manual handling risks (such as replacing a tyre) are not specific to log haulage.
MHE crash/ crush
This risk considers crash or crush involving loader/unloader/forklift. While not often identified in the workshop, once raised, there was consensus from industry that it was a risk worth assessing.
Risks to be determined for inclusion in CoP
There were also risks identified in the below Table 2, that are yet to be confirmed as risks to be addressed in the CoP due to the scope and role of an industry specific CoP.
Third party collision
Initially, this risk was identified as significant for the log haulage industry. However, addressing controls specific to this risk are largely out of the control of industry. It may be excluded as it is not unique to log haulage, other than logging often occurs in smaller communities with higher levels of tourism and smaller roads.
This risk included catastrophic infrastructure failure such as bridge collapse or road slide (not wear, tear and poor conditions). The risk is potentially worth assessing due to the frequency of operating in high risk infrastructure yet it may be considered out of scope in terms of the role of an industry specific CoP.
Bogged vehicle retrieval
While there are specific factors relevant to log haulage, this risk could be addressed within an organisations safe operating procedures.
Risks that will not be included in the CoP
In addition, there were a number of risks identified summarised in Table 3 below that are proposed to be excluded. These have been categorised as follows:
Not a risk - The issue assessed is considered a contributing factor or consequence (and therefore should be reflected in other risk analysis and considerations).
Not in scope – It is expected that this risk should already be considered as part of the organisations risk management process. While this is an important risk for organisations to address, it is too specific to operations. Not specific – This risk occurs in other industries and other types of heavy vehicle operations. Therefore, this risk should be covered by the MCoP or other legislation.
Falls from heights
Non-specific – This includes falls whilst getting in and out of cabin.
Not in scope – A fall resulting from climbing on a load. This is considered a risk event/operational risk to be covered by an organisation’s safe operating procedures. The CoP may indicate that this activity should also not be undertaken.
Medical event (e.g. heart attack)
Non-specific - As a top event this is not a specific risk to log haulage, but emergency response procedures may be impacted by remoteness.
It could be a contributing factor to an event occurring.
Not a risk - While some participants identified overloading as a risk in itself, it has been assessed as a contributing factor.
Site conditions (t)
Not a risk – A site contributing factor are not deemed a risk in themselves.
Loss of social licence to operate
Not within scope – The loss of social licence to operate is a consequence of poor safety management. Risk of occurrence is an organisational/ strategic risk not a safety risk.
Mechanical failure (inc decoupling)
Not a top risk – This is a contributing factor that may trigger an event.
Struck by foreign body
Not within scope – This is a risk event rather than risk category. It is deemed too specific for the CoP.
Environmental damage (e.g. fire)
Not specific – This event may occur in multiple industries, and is not specific or significant enough to log haulage. This could be considered a consequence rather than a risk.