The Heritage Steam Code of Practice. Update 1 of 2010
Update 1 of 2010
The Steam Management Committee apologizes that no Updates appeared last year. This was largely due to a personal tragedy suffered by one of the four committee members. However, work has continued on the Code and we thought it timely to give you an update.
Code Drafting
The majority of the 11 chapters of the National Code of Practice for The Management, Training, Operation, Maintenance, Repair and Construction of Heritage Steam Plant have been drafted. It is the committee’s intention to have the first draft completed by July so that it can be passed through government at Federal and State level for comment and ongoing dialogue. We have aimed for acceptance prior to 2012 as this is a key year for the Federal Government’s high risk licensing standard.
The current chapter headings are:
• Introduction
• Management and Duty Holder Responsibilities
• Risk Management
• Training, Assessment and Operator Authorisation
• Operation, Maintenance and Documentation
• Driving and Conduct
• Inspections
• Repairs and Construction
• Boiler and Plant Registration
• Records and Reports
• Appeals and Arbitration
Content is from a number of sources including the UK NTET Code of Practice, Australian practitioners and Australian standards. The intention is to provide useable information that complies with Australian laws and standards that can be used as part of a self regulation system. This does not mean that users can take short cuts or ignore procedures to keep costs down or behave in a renegade style. Essentially the Code provides all the information and procedures for heritage steam plant operators in a non workplace environment.
You as a steam plant owner or operator will not be forgotten in the consultation process and will have the opportunity to comment well before the Code is issued by the Federal Government. Just remember that we cannot make up our own rules – they have to be accepted by government and comply with existing laws. One of the strengths of the Code is that we can retain procedures, practices and standards no longer used in industry and also link to current standards.
Government Changes
The Federal Government is still drafting model OHS legislation aimed at producing common OHS laws at Federal, state and territory level. The Steam Management Committee put in a submission in 2008 stressing the importance of government considering equipment operation of a heritage nature and this was accepted.
Part of the process of ongoing change has involved the renaming of The Office of the Australian Safety and Compensation Council (ASCC) to Safe Work Australia. It is now an agency in the portfolio of the Department of Employment, Education and Workplace Relations.
The Steam Management Committee continues to be in contact with Safe Work Australia and the working relationship is positive. The Committee was also contacted by a consultant engaged by Work Safe Australia to review the assessment instruments for the reciprocating engine certificate of competency and dialogue continues.
Register of Support
Ron Jackson still maintains the register of people who support the Heritage Steam Code of Practice. Email is the best way for contact and we would hope people will use this whenever possible. We encourage everybody with an interest in steam to register and further information can be obtained from Ron at ron.jackson@activ8.net.au. People who do not have access to e-mail will still be contacted by post once they have registered. If you are in this situation please send a letter (include name, address and phone number) to Gary Barker at the School of Engineering and Information Technology, ADFA, ACT 2600. If you would like further information you can contact Gary on 0409 446 475.
Publicity
You can play your part to publicise the Code of Practice by forwarding this Update on to other owners and operators, and if you are responsible for your Club’s News Sheet a few lines stating that the Update is available would be appreciated. The Update is also on the TOMM website at http://www.tomm.com.au – go to the Steam Codes Update link to find the set of Updates.
Steam Management Committee.
March 2010.
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The Heritage Steam Code of Practice. Update 2/08
The background and need for a Heritage Steam Code of Practice was covered in the first update for 2008 issued in February. Since that time the Steam Management Committee aided by a small team of supporters has continued to make progress including two days of meetings in Adelaide with officials from the South Australian and Federal Governments. While both levels of Government gave strong support for the concept and need of the Heritage Code of Practice, they also raised additional concerns that need to be addressed by heritage steam plant operators. These relate to existing procedures but do not appear be understood by the heritage steam community.
Adelaide Meeting
This meeting took place in mid July with the assistance and support of The Office of the Australian Safety and Compensation Council (ASCC). This Federal Government body, that among other things provides OHS policy in Australia, sent their representative, Mr Philip Hillsdon, from Canberra for the meeting. Several senior SafeWork SA officials addressed the meeting and Senior Plant Inspector, John Garvey, stayed for the full two days and provided greatly valued assistance and advice.
Right from the start, strong Government support was openly expressed for the concept of the Heritage Code of Practice. Bryan Russell, (Director, Strategic Intervention, SafeWork S.A.) made it clear that the Executive Director of SafeWork S.A. (Michele Patterson) has promoted a nationally consistent approach to OHS and the development of procedures that ensure safety is paramount. She is very supportive of the concept of the Heritage Code of Practice, if it can achieve an agreed understanding of how to operate this equipment safely. It is clear that this government support would not be forthcoming if these senior officials did not believe there was a need. The need is to maintain the skills and knowledge in regard to all facets of the steam plant, which for all intents and purposes are fixed in time, but their operation must still comply with 21st century procedures and safety standards.
It is not possible to cover all the items discussed over the two days of the meeting, but some relevant factors were raised that not only relate to the operation of heritage steam but also to rallies. Peter Wong, (Chief Advisor, Engineering, SafeWork SA) made the point that OHS legislation in South Australia regulates the use of boilers (and other pressure plant) whether they are located in workplaces or not. Another aspect of this is that legally if a passenger is carried on a heritage machine, such as a traction engine, it is an amusement structure and would have to comply with additional regulations.
One particularly relevant issue that became apparent was that although the operator qualifications are national, the inspection and boiler registration is still State based. Some jurisdictions require boilers to be registered whether they are heritage items or not. If you move a boiler from one jurisdiction to another, make sure you check with the local OHS Authorities on this requirement. The requirement appears to vary from State to State, but in one State at least there is a substantial fine (up to $10,000.00) for operating a boiler not registered in that State.
This is relevant for persons taking steam plant to the NHMA National Rally at Murray Bridge in April next year. The Rally organisers have been provided with details of what is required for interstate steam plant owners. As a result of the meeting the process, for South Australia, appears to be fairly straight forward but steam plant owners planning to exhibit should contact the rally organisers promptly so that the necessary documentation can be completed. Note this requirement for registration may impact on many rallies, not just Murray Bridge.
Some of these issues will be resolved when the Heritage Steam Code of Practice is introduced, because it will be a National Code with a common set of rules and standards. Even so, there will still remain the need for a strong relationship with the various State and Federal SafeWork Authorities. The Committee’s plan is to have a draft of the Code completed by mid next year noting that it will then have to be approved by all OHS jurisdictions which will take time. In the meantime comply with the procedures for your OHS jurisdiction and if you are not sure contact one of the committee members via Ron Jackson.
Other Activities
A major part of the task that will eventually lead to the introduction of the Code of Practice is the production of a vast quantity of documentation, Manuals, Training Modules, Standards, Procedures, Instructions and so on. Extensive work has already gone into the development of Skill Sets, Training Modules and Assessments and this part of the task is well in hand.
Work is now underway on documentation pertaining to boiler and plant inspection, maintenance, repair and construction, and audit processes. This is a major task that will take time due to its complexity and the small number of people involved. There is however no intention of trying to reinvent the wheel. Much use will be made of existing documentation where ever possible.
The guiding principle that will govern much of this task is that it complies with AS/NZ 3788, 2006, “Pressure Equipment – In Service Inspection”. This document is used as a guide for pressure equipment inspections of the type generally associated with heritage steam plant and already includes a Normative Appendix on the Inspection of Heritage Boilers and Pressure Vessels. There are also many other Australian Standards that will have to be related to in some aspects of the document.
Other Developments
One thing that is certain in Occupational Health and Safety is change. There are expectations by the public that the workplace is as safe as it can be, and Government policy is to reduce work place accidents. In this, they all have our overwhelming support, however, this also leads to a cycle of continuous change in rules, regulation and standards.
Most steam engine operators will have dealt with or will be dealing with the current change from boiler and engine driver’s certificates to five yearly National Licenses. Further changes in regard to these qualifications are expected. The National Licensing Standard which deals with licensing of plant operators will be undergoing Stage 2 of the review process. The review will look into the definition of classes of licences including boilers and will also be looking into the justification or otherwise of a number of licence classes. This review will have a direct impact on heritage steam boilers and the Steam Management Committee will be monitoring developments and will represent our case.
In addition the Australian Government is conducting a National Review into Model Occupational Health and Safety Laws. Note that ‘model’ in this case refers to standardized laws and procedures. This review is looking at OHS legislation at all levels of Government and will then make recommendations for the optimal structure and control of a model OHS Act. How this will affect heritage steam remains to be seen, but it has the potential to do so. The Steam Management Committee has put in a submission in regard to Heritage Steam and the Code of Practice so that it can be taken into consideration at the appropriate time. This is another example of where the Committee has acted in your interests to ensure that we are heard and do not get overlooked which has happened many times over the last 15 years or so. Our submission, number 016, can be via the link to public submissions at: http://www.nationalohsreview.gov.au
Register of Support
Ron Jackson maintains the register of people who support the Heritage Steam Code of Practice and around 260 people across the nation are listed. As the four Committee Members work full time and do this work out of hours you can assist us by letting Ron know in advance if your contact details are about to change. When the last Newsletter was issued in February there were a significant number of email bounces and letters returned to sender. We also had a number of complaints of the Newsletter not getting through – in all cases it was down to the individual having moved or changed email providers! Email is the best way for contact but we do understand that not everybody is comfortable with this method but encourage its use where possible. We encourage everybody with an interest in steam to register and further information can be obtained from Ron; his email address is: ron.jackson@activ8.net.au
Publicity
You can play your part to publicise the Code of Practice by forwarding this Newsletter on and if you are responsible for your Club’s News Sheet a few lines stating that the newsletter is out is all that is required. The Newsletter is also on the NHMA web site at http://www.nhma.com.au/index.htm
Summary
In a world where OHS legislation continues to develop and change, heritage steam operators need to find a way to continue operating machines that were designed to operate at a time when safety standards were very different to what they are now. This is why all this work is being done on the Code and your contribution and involvement would be welcomed.
The Steam Management Committee of the NHMA is doing everything it can to ensure that heritage steam is able to continue to operate within 21st century safety rules and still maintain the historic integrity of the equipment itself to a standard of utmost safety. We believe the way ahead is the Heritage Steam Code of Practice. It is intended to make the operation of heritage steam simpler, more uniform and safer. The time to stand up and be counted is now. The worst thing that steam engine operators can do is nothing.
Steam Management Committee.
August 2008.
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The Heritage Steam Code of Practice Update 1/08
Welcome
The Steam Management Committee (SMC) of the National Historical Machinery Association welcomes all heritage steam owners and operators to our first update for 2008. One of the challenges we face is keeping people informed on progress so please spread the word including club newsletters, notice boards and the like. Club editors are encouraged and welcome to include the Updates in club newsletters.
Updates also appear in The Old Machinery Magazine and on the TOMM web site (Steam Section) at http://www.tomm.com.au/ and will also appear on the newly established NHMA web site at http://www.nhma.com.au/index.htm
This issue includes a ‘frequently asked questions’ segment. This will be a regular feature or at least until all questions get answered! The ones in this issue relate to the area of change and in the next update we will cover how the Code will operate.
Please take the time to read and digest the information as rumours, innuendo, and misinformation do nothing for anybody and in particular for the small team that is volunteering their time to write the Code for you and those that follow you.
Background
The concept for a Heritage Steam Code of Practice was first mentioned in The Old Machine Magazine in the Steaming Along the Road column in 2002. This was discussed again in 2005 when The Office of the Australian Safety and Compensation Council (ASCC) sought comment from Industry on a proposed High Risk Work Standard that intended to introduce, among other things, five year licences for the operation of certain types of equipment including boilers and steam engines.
There was widespread concern in the heritage road steam community on the proposal, particularly for young people trying to gain steam qualifications, and this led to support for the development of a Code of Practice. A small volunteer committee formed, and in December 2005 a paper was sent to The Office of the ASCC arguing the case for a Heritage Steam Codes of Practice.
The Office of the ASCC gave approval in May 2006 for the development of a Code of Practice as a National document. This was a significant outcome and signifies the first occasion that Government has agreed to work with industry to prepare a National Code. It also means that the States and Territories will also be involved with its issue.
Purpose
The purpose of the Heritage Steam Code of Practice is to provide a basis for the generational transfer of skills and knowledge so that heritage steam may continue to operate as we know it, and provide a basis for self regulation.
Progress
• In April 2006 the NHMA, after a vote, agreed to the concept of establishing a Steam Management Committee (SMC) provided the government approved a Code of Practice. This association represents historic machinery and equipment clubs throughout Australia, and has approximately 9000 members.
• In August 06, with support from The Office of the ASCC, eight members of the inaugural steam committee met in Adelaide and held a two day workshop to further develop the Code. This also included a discussion with members of the Licensing Technical Group Committee.
• Following the meeting a team under Mr Kevin Lord was established to write Training Modules. To date 15 draft modules have been produced covering the operation of the locomotive type boiler and steam plant such as traction engines.
• In July 2007 the SMC, comprising four positions, was established as an NHMA specialist group to administer and control the Heritage Steam Code of Practice.
• A register of non-rail heritage steam operators has been established and as of August 07 approximately 260 people have indicated their support for the Code.
• The SMC is in communication with the Association of Tourist and Heritage Railways of Australia (ATHRA), the UK based National Traction Engine Trust (NTET), and maritime heritage steam operators.
Underlying this is the sound relationship that has been developed with government where our case has been heard and supported. This is a major achievement and advice is that the new Federal Government is positive to the need for Industry Codes.
The Process of Change
For most of the twentieth century in Australia, steam operators were able to operate under a qualification system that meant a ‘ticket for life’ where the training was generally related to the type of boiler and engine. Advice on the standard of the boiler was based on the comments from the boiler inspector at the annual inspection.
As such, most heritage steam operators could enjoy their hobby, did not need to be a united group, as they were catered for by government. This is no longer the case as responsibility now rests with the owner and/or operator. The tickets for life have gone and there is a dire shortage of boiler inspectors who have sound knowledge on heritage steam boilers.
These changes have occurred over the last two decades and relate to significant changes in the way Government Occupational Health and Safety organisations operate including major changes in legislation, the procedures they use and how risk and responsibility is assigned.
With few exceptions most training and assessment procedures, along with qualifications are developed for Industry through a consultative process between the various industries and government. As industries evolve including updated and more automated equipment so does the training and qualifications.
This has meant that ‘heritage steam equipment’ that is ‘locked in time’ has essentially been overlooked by governments. Hence training and qualification procedures for Industry equipment such as boilers will become less relevant for heritage steam trainees as the trend will continue toward automation of operation. This can produce a potentially dangerous situation as a heritage steam boiler operation relies on the continuous attendance and vigilance of the operator who must have sound knowledge on this type of plant that will not be gained by completing OH&S training courses on boilers or reciprocating engines.
Some heritage steam people consider this to be an advantage and take it to mean that they are exempt from compliance; do not need operator qualifications, and boiler inspections are not required, regardless of where the steam plant is operated. This is not the case.
Frequently Asked Questions
Why is all of this needed?
The skills and knowledge in Government and industry for operator training and assessment along with boiler inspections of heritage steam plant has all but gone. If we don’t become involved we face a very uncertain future.
What is a Code of Practice?
A document that is taken to be the current state of knowledge about a particular issue, and approved under legislation. It is not mandatory to comply with a Code of Practice; however, a Code can be used as evidence in legal proceedings.
If it is not mandatory to comply with a Code and I am not in a workplace why should I bother?
The simple answer is for you own well being and others around you. There are also legal reasons noting that a person who has not complied with an approved Code will be taken to have failed to exercise the required standard of care unless they can prove otherwise.
This means that an individual who chose not to use an approved Code would have to develop their procedures including documentation before the event and would then face the time and significant expense of proving ‘otherwise’ in Court.
A Code implies self-regulation therefore I will be able to inspect my boiler and issue a certificate?
No - self regulation does not mean ‘do as you please’ but means that you are following and complying with an endorsed set of procedures such as a Code of Practice.
The Code of Practice will cover boiler inspection but inspection by first parties (ie owners or operators) on their boiler will not be allowed.
The intent is that the Code will provide a basis, including insurance cover, for people in the heritage steam community, who have the competencies, skill and knowledge, to inspect and certify heritage steam boilers.
Even if you never take your boiler out in a public area, self inspection and certification is potentially dangerous and is not recommended practice.
The National Traction Engine Trust in the UK has just published their Code of Practice on their website. Why can’t we just use their one and not re-invent the wheel?
The SMC and NTET are in communication with each other and the NTET has most kindly offered their help. However, Australian legislation in regard to operation of boilers, steam engines, and Codes of Practice is different to the UK and therefore the Australian Code will differ that produced by the NTET.
An important outcome is that an Australian Steam Association is communicating with an overseas body and this is a first at the national level.
What will the Australian Heritage Steam Code of Practice cover?
The Code, to be issued as a national document in partnership with government, will include administrative procedures, training, assessment and qualification, boiler inspections, maintenance, repairs and construction, and audit procedures.
What is the purpose of the Steam Management Committee and who is on it?
The purpose of the SMC is to administer and control the Code of Practice. The four committee positions are Chair (Bob Butrims), Register Secretary (Ron Jackson), Treasurer (Kevin Lord) and Technical Director of the Code of Practice (Gary Barker).
Why do we need representation with government?
The simple answer is for our own well being. One of the outcomes of the formation of the SMC and its recognition by government is that we are being consulted. One of the changes in OH&S procedures is that industries are advised of changes and not individuals. An example was the need to changeover from the ‘paper’ tickets to the national class of qualifications which was required to be completed in a designated timeframe after which the original ticket became null and void. This was advised to the Heritage Steam community through the Updates. Recent advice from government is that there will be further change this year including a review of boiler qualifications.
Unity is critical as is the passage of information and that is why the Register of Supporters for the Heritage Steam Code of Practice was set up. If you would like to register contact Ron Jackson at ron.jackson@activ8.net.au You are welcome to also contact the committee members or ring Gary Barker on 02 6268 8327 (bh).
If you change your email or home address please let Ron know in advance so that we can continue to keep you informed.
NHMA Steam Management Committee
22 January 2008
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