Working On, In, Over, or Near Water Procedure

3.1.1   Risk assessment

A risk assessment must be conducted in consultation with relevant workers to identify and assess all the risks associated with working on, in or near water. The risk assessment must be undertaken in accordance with the Corporate OHS Procedures Manual- Risk Matrix and Risk Assessment process.

This involves the following:

3.1.1.1 Workplace / asset based risk assessment

• Identify work locations where activities that involve working on, in or near water may be carried out.
• Where possible, the risk of falling into a water body and drowning shall be assessed and captured in the relevant workplace site hazard register.
• Where a workplace is not covered in any workplace site hazard register, but is regularly accessed by workers, a risk assessment must be conducted for the site.

3.1.1.2 Task / activity based risk assessment

A risk assessment must be completed for any task that is outside of the current Procedure or Safe work instruction or if the current task presents newly identified risks or hazards to the team. You must have a procedure or Safe Work Instruction for any routine task before commencing the work and if it is determined by the team that a risk assessment must be completed if either of these documents are not in place prior to commencing any work that involves working on, in or near water. Should the activity include any of the GMW Fatal Risks then the risk assessment should be documented.

When undertaking the risk assessment, the following factors must be considered:

• Access / egress to or from the location on, in or near water, where the work will be carried out
• The frequency and duration of exposure to the identified hazards
• The water body factors that impact on the consequence of a fall into the water body e.g. depth, speed of the water flow, turbulence, debris load and type and slope of the water bed
• Types of equipment to be carried and used
• Restricting work during wet weather and storm events unless deemed an emergency
• Environmental conditions which may impact on the work activity and rescue (i.e. remoteness of the workplace, weather conditions such as wind, rain, temperature and lighting)
• Controls that can eliminate or mitigate the hazards in accordance with the hierarchy of controls as outlined in the following section.

3.1.2   Hierarchy of controls for managing risks of working on, in or near water

The hierarchy of controls must be used to identify the most appropriate risk control measures to manage the risk. The identification and selection of risk control measures must be undertaken in consultation with workers.

The following are possible control measures associated with working on, in or near water:

Hierarchy Of Controls

3.1.3   Safe work environment

Where reasonably practicable, appropriate access and egress arrangements must be provided and maintained to a workplace where work activities are being undertaken on or in the vicinity of a water body. Requirements of security, ongoing maintenance and emergency rescue must be considered when selecting these access and egress methods.

Where reasonably practicable, appropriate edge protection e.g. handrails and/or guardrails which prevent a worker from falling into a water body must be provided, installed and maintained.

The selection and configuration of the access and egress structures and associated handrails and guardrails must comply with AS 1657:2018 Fixed platforms, walkways, stairways and ladders – Design, construction and installation.

Temporary edge protection and barriers should be considered where the provision of permanent structure and protection is not reasonably practicable. The temporary edge protection and barriers must comply with the requirements of the AS/NZS 4994.1-2009 Temporary Edge Protection part 1 and part 3.

Good ground condition and housekeeping must be maintained where reasonably practicable to minimise the risk of falling into a water body.

Appropriate security, locks and signage may be installed to prevent inadvertent access to unprotected water edges at GMW workplaces by any workers and/or members of the public.

Where activities that involve working on, in or near water are being carried out at a workplace where natural light is not sufficient, additional lighting that is appropriate to the work being undertaken, should be provided and maintained.

3.1.4   Safe work equipment and rescue equipment

Where identified through a risk assessment, the following equipment pertaining to working on, in or near water must be provided:

• Fit for purpose equipment e.g. vessels, kayaks and mobile plant.
• Where there is a risk of falling, a fall restraint system and fall arrestment system e.g. anchor points, ropes and harness.
• Lifejackets (PFDs) that comply with AS 4758.1:2015 Lifejackets - Part 1:General Requirements - Victoria when selecting and using a safe lifejacket.
• Rescue floatation device (e.g. life ring, life floats and throw bag) with a rope attached. Where required it should be in a location readily available from the work being undertaken.
• A first aid kit.
• Temporary Bank Ladders to be used whilst conducting works.
• Other appropriate equipment to facilitate the retrieval of personnel from the water will be provided based on the risks and control measures identified in the risk assessment.

All equipment used for working on, in or near water must be stored maintained, inspected and serviced as per manufacturer’s instructions. Where required by a GMW procedure or manufacturers recommendations a service tag must be affixed to the equipment.

3.1.4.1 Situations where a lifejacket (PFD) must be worn

A lifejacket (PFD) must be worn at all times in the following circumstances:

• When on board any GMW vessel
• When working within two metres of an unprotected edge that is adjacent to a body of water into which a worker could fall into water to reasonably drown while carrying out the intended work (a risk assessment will determine the proximity to the edge, but reference to and compliance to the risk of falls procedure must be considered).
• Water where both self-rescue or rescue by others is difficult without a lifejacket
• Any persons operating a Powered Vessel or Human Powered Vessel (such as a Canoe, Kayak or punt) shall at all times be wearing appropriate personal floatation device and be assessed as medically fit to self-rescue.
• A water body into which there is a high likelihood of a worker becoming unconscious should they fall in
• Other situations identified through a risk assessment

3.2.1   Work planning

Appropriate planning must be carried out prior to commencing any work activities that involve working on, in or near water. The work planning may involve:

• determining the most appropriate work methods that minimise the risk of falling into water, becoming submerged under water and drowning
• allocating adequate and competent persons/workers to perform the task
• selecting fit for purpose equipment
• planning most appropriate access / egress to or from the area you will be working in (e.g. it may be safer to access from the water rather than from land)
• planning the journey including journey via vehicle and/or vessel
• developing or reviewing a risk assessment
• developing a rescue plan where identified through a risk assessment

3.2.1.1 High Risk Activities works permits

Where the work activity involves high-risk work activities, the following permits and their support procedures also apply:

• Work at Height Permit
• Confined Space Entry Permit
• Hot Works
• Energy Isolation plan and Permit.

3.2.1.2 Energy isolation

Where isolating and de-energising the source of a water flow or any other energy source is identified as a control measure in a risk assessment, the GMW Isolation Procedure and Permit must be followed. e.g. isolating regulator’s or pumps.

3.2.1.3 Remote or isolated work

If the work to be carried out is considered as remote or isolated work, GMW’s Working Alone or Remotely Procedure- A3795409 must be followed.

3.3.1   Working near water bodies in a fixed structure without edge protection

Where workers need to enter and work within two metres of an unprotected water’s edge in a fixed structure a risk assessment must be developed and reviewed by the working Group and relevant SLT member and all the identified controls must be implemented prior to commencing the work. The following controls need to be considered when developing the risk assessment:

• Installation of temporary barriers or edge protection where reasonably practicable.
• Use of a fall restraint system set up by competent person where reasonably practicable.
• Maintaining visual sight by a second person.
• Wearing a Suitable Lifejacket that has been serviced/Inspected and in date.
• An easily accessible floatation device for rescue e.g. life floats, life ring or throw bag with retriever rope.

3.3.2   Channels, Drains and Natural water bodies without fixed protection

Where workers need to access and work within two metres of a channel, drain or natural water body without any edge protection, and the water is enough that workers could reasonably drown if they fell in, a risk assessment must be developed or reviewed and all the identified controls must be discussed with their Manager/Supervisor. The controls must be implemented prior to commencing the work. The following controls need to be considered when developing a risk assessment.

Options to eliminate or minimise the need to work near the natural water body:

• Minimum of two persons required for the task. Workers should remain within sight and sound of each other at all times.
• Use of a fall restraint system set up by a competent person where reasonably practicable.
• The means and frequency of welfare monitoring.
• Wearing a Lifejackets (PFDs) that comply with AS 4758.1:2015 Lifejackets - Part 1: General Requirements - Victoria when selecting and using a safe lifejacket.
• Developing a rescue plan where identified as necessary.

3.3.3   Working on water

A fit for purpose vessel or other means of transport or floatation equipment must be selected where any work activities require working on a water body. The risk of falling into water from the vessel or other means of transport and floatation equipment must be managed as per the GMW Safe Boating Procedure.

3.3.4   Working in water

GMW personnel should not enter and work in any water body.

Where the work requires entry into the body of water a documented risk assessment must be completed. Considerations which must be considered for the documented risk assessment:

• Requirement for training
• Size of person
• Individual capabilities/experience

Where workers need to enter, walk, swim and undertake work in water, a risk assessment must be developed or reviewed and all the identified controls implemented prior to commencing the work. The following need to be considered:

• An assessment of the depth and flow of the water prior to entering the water.
• Minimum of two persons required for the task. Workers should remain within sight and sound of each other at all times.
• Wearing fit for purpose foot wear e.g. wading boots, gum boots or other foot wear suitable while working in the water.
• Lifejackets (PFDs) that comply with AS 4758.1:2015 Lifejackets - Part 1:General Requirements - Victoria when selecting and using a safe lifejacket.
• Any changes in substrate or objects in water.
• Developing and completing a rehearsal of the rescue plan

3.3.5   Diving

GMW personnel are not permitted to perform any diving work. Licensed contractors must be engaged for this purpose. Diving work must be performed in accordance with all legal requirements and applicable standards and codes. 

The following table outlines minimum requirement that need to be undertaken at each stage of diving work:

The following records must be retained by both GMW and the contractor:

• Certificate of medical fitness for anyone participating in the diving work.
• Appropriate qualifications or certificate of attainment to prove the divers’ competency.
• A formal written Dive Plan and risk assessment covering the tasks to be undertaken.
• Dive Safety Log.
• Divers current Senior First Aid qualifications.
• Any records that relate to any incidents occurred during the diving work.

3.3.6   Operating mobile plant on or near water

Where workers need to operate a ride on mower, excavator, mobile crane or other mobile plant near a water body, a SWI/ SWMS must be developed or reviewed and all the identified controls must be implemented prior to commencing the work. The following controls need to be considered:

Walk through to assess the conditions of the work areas prior to commencing work.

• Fit for purpose equipment.
• Operating the plant to conditions.
• Establishment of exclusion zones and barriers to prevent falling into or submersion under water where reasonably practicable.
• A spotter to guide the operator and monitor person working in the vicinity.
• A lifejacket may be worn in case of fall and loss of consciousness.

No ride on Lawn mower activities to be conducted near the body of water if on a gradient greater than 15 Degrees.

3.3.7   Workers suspended over water

If there is a requirement for workers to be suspended in a workbox or in an elevated work platform (EWP) while working over water, the workers may not be required to be attached to the workbox or EWP via a harness subject to the following conditions:

• The risk of falling into water and drowning is higher than the risk of being injured by hitting the water surface or submerged objects.
• A dedicated spotter/dogger must be present at all times to guide the operator and monitor the person working over water.
• A floatation device is readily accessible for rescue purpose e.g. life ring and life floats.

Other uses of a workbox or Elevated Work Platform (EWP) outside of these specific circumstances (e.g. when traversing to the water’s edge) must follow the GMW Working at Heights Procedure.

 3.3.8   Operating electrical equipment on or near water

When operating tools on or near water, the use of pneumatic tools, or battery powered tools should be the priority equipment to use.

 Where electrical equipment and leads are selected to be used on or near water, they must be:

• Connected to an earth leakage safety switch or residual current device (RCD) if the equipment and lead needs to be plugged / connected to a main electricity supply
• Physically prevented, as far as practicable, from falling into water and protected from exposure to water unless specifically rated for that purpose i.e using a lanyard or tethered to the worker or EWP
• Properly water proofed with appropriate International Protection (IP) rating for liquid ingress
• checked for damage before use
• Within test and tag date.
• The electrical Equipment to be no older than 3 years from date of purchase

A SWI/SWMS must be developed and/or reviewed prior to commencing any boat electrofishing operation.

3.3.9   Environmental Considerations

Working on or near water increases the consequence of environmental incidents as any pollution incidents in a waterway have the potential to affect large areas. Any chemical spill that goes into a waterway must be reported to the water quality team. Ensure the requirements in Environmental Procedures A2739763 are followed.

3.4.1  Health monitoring and Immunisation

Health monitoring and immunisation requirement for roles that undertake work activities on, in or near water are to be identified and implemented in accordance with the GMW Health Monitoring and Immunisation Procedure

Immunisations may be required for workers who may be exposed to biological hazards should they be required to work with contaminated water, or may be at a risk of falling into contaminated water (e.g. Hepatitis B).

Health monitoring will include pre-employment medicals to identify any medical conditions that may impact on a worker’s ability to rescue themselves should they fall into water.

A worker must notify the relevant supervisor or manager if any adverse changes to their medical conditions that may affect the health and safety of the worker. Appropriate control measures and reasonable adjustments can be identified and implemented to support the worker based on a risk assessment.

3.4.2  Fitness for work

All workers and contractors must have a blood concentration of 0.00% for alcohol and illicit drugs at all times while at the workplace, work associated on, in, over or near water, diving work or operating any form of water vessel.

Training will be provided in accordance with GMW’s Training and Development Operational Policy and Procedure.

The following training and competencies are specific requirements associated with working on, in or near water:

• Vessel operation related training for workers operating vessels and vessel induction for passengers - refer to GMW Safe Boating Procedure for further information.
• Appropriate instruction on how to check, use and care of a lifejacket must be provided to any workers who are required to wear a lifejacket. Refer to the GMW Personal Protective Equipment (PPE) procedure for further information

• Approval
• Ownership and implementation

• Communicate, consult and ensure a process or system is in place to supervise workers involved in activities where they may be exposed to any risks associated with working on, in or near water.
• Regularly monitor and review the effectiveness of controls for managing the risks related to working on, in or near water within their area of responsibility and implement corrective actions and treatment plans where required.

4.2.1 Line Supervisors

• Make sure that risks associated with working on, in or near water by members of their team are identified, assessed and managed in consultation with workers and/or health and safety representatives.
• Implement and regularly review controls to mitigate the risks.
• Provide workers with fit for purpose equipment as required by this procedure and ensure they are correctly used and maintained.
• Develop and review SWI/SWMSs for any work activity that involves working on, in or near water as per this procedure.

• Provide advice, support and monitoring in relation to the implementation of the GMW Safe Boating Procedure.
• Establish and implement processes to ensure the lifejackets used in GMW are properly selected, used and serviced.

• Identify the risks associated with working on, in or near water at the work planning and scoping stage.
• Communicate with the contractors of the identified risks and the requirements from this procedure.
• Obtain and review the SWI/SWMS and other required documents to ensure the risks associated with working on, in or near water are identified and appropriate control measures are developed.
• Conduct assurance activities to ensure controls are implemented.

• Provide advice, support and consultation on managing the hazards and risks, including identification and implementation of effective risk controls.

• Conduct a risk assessment e.g. SWI/SWMS and implement risk control measures prior to commencing any work that involves working on, in or near water.
• Turn up fit for work when undertaking any tasks that involve working on, in or near water.
• Wear and maintain personal protective equipment (PPE) as required by this procedure.

This Appendix is designed to provide an overview of the requirements of this procedure – it is to be used as an aid/refresher to the procedure, and is not to be used in isolation without prior training of the procedure.  Section 4 – Responsibilities has not been included within this Appendix (Please see Procedure for respective details)

This Procedures applies to all GMW activities involving work on, over, in or near water.