Work Health and Safety (Welding Processes) Code of Practice 2015

The Work Health and Safety (Welding Processes) Code of Practice 2015 is an approved code of practice made under section 274 of the Work Health and Safety Act 2011. It is a practical guide to achieving the standards of health, safety and welfare required under the WHS Act and the Work Health and Safety Regulations for welding work.

For businesses, the legal status matters. The Code says approved codes of practice are admissible in court proceedings under the WHS Act and Regulations. Courts may regard a code as evidence of what is known about a hazard, risk or control, and may rely on it when deciding what was reasonably practicable in the circumstances. Inspectors may also refer to an approved code when issuing an improvement or prohibition notice.

The Code does not mean there is only one lawful way to manage welding risks. The text says compliance may also be achieved by following another method, such as a technical or industry standard, if it provides an equivalent or higher standard of work health and safety than the code. Even so, most businesses should treat this Code as the starting benchmark for safe welding systems.

The Code applies to all workplaces covered by the WHS Act where welding processes are carried out and to all persons involved in those activities. It is written mainly for persons conducting a business or undertaking, but it also identifies duties for designers, manufacturers, importers and suppliers of plant or substances used in welding, officers such as company directors, and workers.

The scope is broader than many businesses expect. The Code focuses on welding processes, but it says it may also be relevant to allied processes because they involve similar hazards and sometimes the same control measures. The examples given include metal preparation, metal cutting, gouging, brazing and soldering.

That means a business does not need to be a dedicated welding shop before this Code becomes relevant. A repair workshop, manufacturer, builder, maintenance contractor, transport business or farm machinery operator may all need to use it if welding or allied processes form part of the work.

The practical trigger is simple. If welding activities are being carried out in your business or at your workplace, the Code becomes relevant. Once that happens, the primary duty holder must ensure, so far as is reasonably practicable, that workers and other persons are not exposed to health and safety risks arising from the business or undertaking.

For welding specifically, the Code says a business carrying out welding activities must eliminate risks arising from welding, or if elimination is not reasonably practicable, minimise those risks so far as is reasonably practicable. The WHS Regulations then add more specific requirements for hazards commonly linked to welding, including hazardous chemicals, airborne contaminants, plant, noise, confined spaces and electricity.

This is important because welding risks often affect more than the welder. Nearby workers, visitors, passers-by and contractors can also be exposed to fumes, radiation, noise, electrical hazards, heat or fire risks. A business should therefore look at the whole work area, not just the person holding the torch or electrode holder.

The Code identifies several categories of duty holders. The person conducting a business or undertaking has the primary duty to manage welding risks. Designers, manufacturers, importers and suppliers of plant or substances used in welding must ensure, so far as is reasonably practicable, that the plant or substance is without risks to health and safety. That includes testing and analysis, and providing specific information about the plant or substance.

Officers, including company directors, have a due diligence duty. The Code explains that this includes taking reasonable steps to ensure the business has and uses appropriate resources and processes to eliminate or minimise welding risks. In practice, that means officers should not assume welding safety is only an operational issue for supervisors or tradespeople.

Workers also have duties. They must take reasonable care for their own health and safety, must not adversely affect the health and safety of others, and must comply with reasonable instructions and policies or procedures relating to health and safety. If PPE is provided, workers must use it in accordance with the information, instruction and training provided.

The Code ties welding safety directly to the WHS Regulations risk management process. In broad terms, a duty holder must identify reasonably foreseeable hazards, eliminate the risk so far as is reasonably practicable, or if elimination is not reasonably practicable, minimise the risk by implementing control measures in line with the hierarchy of control. The business must then maintain those control measures so they remain effective, and review and revise them where necessary.

The Code describes this as a systematic process involving identifying hazards, assessing risks if necessary, implementing control measures, and reviewing those control measures. For business owners, the practical point is that welding compliance is not a one-off purchase of PPE or a generic safe work method statement. It is an ongoing process of identifying what could go wrong, deciding what controls are strongest, and checking whether those controls still work in the actual conditions of the job.

The Code places strong emphasis on consultation. A business must consult, so far as is reasonably practicable, with workers who carry out work for it and who are or are likely to be directly affected by a WHS matter. If workers are represented by a health and safety representative, the consultation must involve that representative. The Code says consultation is necessary at each step of the risk management process.

This is not just a paperwork requirement. The Code explains that by drawing on workers' experience, knowledge and ideas, a business is more likely to identify all hazards and choose effective controls. It gives a practical example involving cleaning metal surfaces before welding. If chemical treatments are being considered, consultation can help the business understand the work practices workers actually use and the hazards they face.

The Code also requires consultation, co-operation and co-ordination with other duty holders who share responsibility for the same matter. If you hire a welder to repair machinery at your workplace, both businesses should exchange information, plan the work together, discuss safety issues and agree how risks such as fumes and noise will be controlled.

Training, instruction and supervision are also mandatory. The Code says information, training and instruction for workers carrying out welding should include the proper use, wearing, storage and maintenance of PPE, how to work safely in hazardous environments such as confined spaces, first aid and emergency procedures, how to access safety data sheets for hazardous chemicals, and the nature of and reasons for any health monitoring if required. The information must be suitable, adequate and readily understandable.

The first step is to identify all hazards that have the potential to cause harm. The Code says this can be done by conducting a walk-through assessment of the workplace, observing the work, talking to workers about how work is carried out, inspecting the materials and equipment used, reading product labels, safety data sheets and manufacturer instructions, talking to manufacturers, suppliers, industry associations and health and safety specialists, and reviewing incident reports.

This is useful because it shows hazard identification is not limited to a form or checklist. It is a practical review of the task, the environment, the materials, the equipment and the people involved. For welding, that may include looking at base metals, coatings, solvents, fluxes, paint, plastics, ventilation, electrical conditions, nearby work, heat, noise and whether the work is being done in a confined or reflective environment.

The Code says a risk assessment is not mandatory for welding generally, but it is required in specific situations, for example when working in a confined space. Even where it is not mandatory, a risk assessment may still help identify which workers are at risk, what sources and processes are causing the risk, what controls should be implemented and whether existing controls are effective.

The Code notes that risk depends on factors including the properties of the materials being welded, surface coatings on the items being welded, the condition of the welding equipment, the conditions under which welding is carried out, and the skills, competence and experience of the welder. Different welding processes can also change the risk profile.

The Code explains that some controls are more effective than others and ranks them through the hierarchy of control. A business must always aim to eliminate the hazard and associated risk first. The example given is designing fabrications to include pre-cast components or extruded shapes so the need to weld is removed.

If elimination is not reasonably practicable, the risk must be minimised using one or more higher-order controls before relying on lower-order controls. The Code gives examples of substitution, such as using submerged arc welding instead of flux-cored wire welding to reduce exposure to radiation and fumes. It gives examples of isolation, such as carrying out noisy ancillary processes away from general fabrication areas. It also gives engineering controls such as ventilation systems to remove welding fumes.

If risk remains, it must then be minimised with administrative controls and suitable PPE. The Code gives an example of limiting time in a very hot environment and allowing rest and cooling-off periods to reduce heat exhaustion risk. It also gives an example of rubber-soled boots reducing electric shock risk where a welder has to stand on metallic surfaces that may become live.

The Code is clear that administrative controls and PPE rely on human behaviour and supervision and, if used on their own, tend to be the least effective controls. A combination of controls may be required. Businesses should also check that a chosen control does not introduce new hazards.

The table of contents and extracted text show that the Code deals with a wide range of welding hazards. These include airborne contaminants, radiation, electrical risks, fire and explosion, burns and exposure to heat, compressed and liquefied gases, noise, lead and other hazards. It also contains sections on welding equipment, ventilation, PPE, maintenance of equipment and health monitoring.

That breadth matters for businesses because welding is often treated too narrowly as a spark and burn issue. The Code instead treats welding as a task that can create chemical, respiratory, electrical, thermal, physical and environmental risks at the same time. A compliant approach should therefore look at the whole job setup, not just the welding arc itself.

The Code gives detailed guidance on airborne contaminants. Welding can generate fumes, mists, dust, vapours and gases, including ozone. The amounts and types vary depending on the process and the materials being used, such as metals, solvents, flux, paint and plastics. The health effects can include irritation of the upper respiratory tract, chest tightness, asphyxiation, asthma, wheezing, metal fume fever, lung damage, bronchitis, cancer, pneumonia and emphysema.

The Code notes that some welding fumes are easy to see, but many gaseous fumes and vapours are invisible. It also explains that intense ultraviolet radiation emitted by arcs may travel significant distances, especially in reflective environments, and may generate significant quantities of ozone. One example given is phosphine being generated when steel coated with a rust-proofing compound is welded.

To determine the risk of exposure, the Code says businesses should identify what equipment and materials are being used and the level of fumes, dust, vapour and gases generated. For exposure to welding fumes, total fume concentrations as well as individual fume components should be considered.

Control measures include eliminating exposure to hazardous airborne contaminants where reasonably practicable, or otherwise minimising the risk through substitution, reducing the quantity of hazardous chemicals used, handled or stored, isolating the source of exposure, using engineering controls such as ventilation, implementing administrative procedures for safe handling, and providing appropriate respiratory protection. The Code also says businesses should check the safety data sheet for welding rods and wires to identify which gases and fumes are released during welding.

The Code links this topic directly to hazardous chemical duties. It says the business must manage risks associated with using, handling, generating or storing a hazardous chemical at the workplace, including ensuring hazardous chemicals are correctly labelled and that workers can access current safety data sheets.

The Code says a business must ensure that no person at the workplace is exposed to a substance or mixture in an airborne concentration that exceeds the relevant exposure standard. It explains that exposure standards represent airborne concentrations that must not be exceeded and refers readers to the Workplace Exposure Standards for Airborne Contaminants and the Hazardous Substances Information System.

Air monitoring becomes mandatory in certain cases. The Code says air monitoring must be carried out to determine the airborne concentration of a substance or mixture to which an exposure standard applies if the business is not certain on reasonable grounds whether the airborne concentration exceeds the relevant exposure standard, or if monitoring is necessary to determine whether there is a risk to health.

The Code explains that air monitoring can be used where there is uncertainty about exposure levels, to indicate whether exposure standards are being exceeded or approached, and to test the effectiveness of control measures. It says monitoring should be carried out by a person such as an occupational hygienist with the skills to monitor according to standards and interpret the results.

Where monitoring is used to determine a person's exposure, it must be undertaken in that person's breathing zone. The Code also says monitoring should be conducted in the breathing zones of other workers in the vicinity to ensure they are not exposed to hazardous levels of fumes. If monitoring shows the exposure standard is being exceeded, control measures must be reviewed and any necessary changes made.

The record keeping rule is significant. Records of air monitoring for airborne contaminants with exposure standards must be kept for a minimum of 30 years and must be available to workers who are exposed.

The Code says electric arc and laser welding emit ultraviolet, visible light and infra-red radiation, while gas welding emits visible light and infra-red radiation. The effect on the body depends on the type and intensity of radiation, the distance from it and the duration of exposure.

Exposure can cause eye disorders and skin burns. The Code specifically refers to arc eye or welders flash, which is a painful inflammation of the cornea. It also notes that the effects of ultraviolet and infra-red radiation are not normally felt until some time after exposure. Workers directly involved in welding are at greatest risk, but other workers and passers-by may also be exposed.

The control measures listed include installing non-flammable screens and partitions, using signs to warn that welding is occurring, restricting entry into the work area unless safeguards such as PPE are used, and providing PPE including filter shades for goggles and face shields, gloves and protective clothing to cover exposed skin.

The Code says a business must manage risks associated with electrical risks at the workplace. Unsafe electrical equipment must be disconnected from its electricity supply. Electrical equipment used in environments where normal use exposes it to conditions likely to result in damage or reduce its life, including moisture, heat, vibration, mechanical damage, corrosive chemicals or dust, must be inspected and tested regularly by a competent person.

Where relevant, and so far as is reasonably practicable, electrical risk associated with supply through a socket outlet must be minimised by the use of an appropriate residual current device. The Code notes that electric shock or electrocution can occur through direct contact with the electrode, live parts, the work piece, or through contact with devices such as an unearthed cable or tool. Moisture and high humidity can make the risk worse.

For businesses, this means electrical safety in welding is not just about the machine itself. It includes the environment, the condition of leads and accessories, whether equipment is exposed to damaging conditions, whether unsafe equipment is promptly taken out of service, and whether the power supply setup includes suitable protection where required.

The Code says control measures should be reviewed regularly to make sure they are effective. It gives the example of atmospheric monitoring to measure the amount of welding fume in the welder's breathing zone after fume extraction equipment has been introduced. If the control measure is not working effectively, it must be revised.

Common review methods listed in the Code include workplace inspection, consultation, testing, and analysing records and data. If problems are found, the business should go back through the risk management steps, review the available information and make further decisions about controlling the risk.

This is a practical point many businesses miss. Installing extraction, issuing PPE or putting up screens is not the end of the process. The business should check whether those controls still work with the actual materials, actual work practices and actual site conditions involved.

The instrument was made on 18 March 2016 and registered on the Federal Register of Legislation on 30 March 2016. The instrument text says it commences on the day after it is registered. On that basis, the commencement date is 31 March 2016.

The register entry identifies the instrument as in force. The Code was developed by Safe Work Australia as a model code of practice for adoption by the Commonwealth, state and territory governments. Because model code adoption can differ between jurisdictions, businesses operating outside the Commonwealth scheme should check the local position as well as the Commonwealth instrument.