[Robert Parton]

HI James

These are my thoughts, I haven’t had the opportunity to develop this with others in the business.

I think the proposed changes highlighting & clarifying overlapping and shared primary duties of care, 3 Cs, Control & Influence are useful for the contracting PCBU, though we should already be aware of and acting in that way.

I think the focus on risk and not prescription is well intentioned but will need constant encouragement from Waka Kotahi and examples of success – this is a big shift for TTM companies who have trouble keeping staff as it is, and training to prescription is quicker than developing shared risk appetite and judgement. This could lead to lower level prescription in industry bodies (something for EEA to look out for) TTM companies and contracting PCBU rather than genuine consultation, cooperation and coordination site by site job by job risk by risk.

Losing the reliance on road level categories as a proxy for risk is a useful shift, however it leaves the various PCBU looking for alternative data sources for type, amount and speed of traffic at that point at that time.

The overt statement about emergency response being different and that you do the best you can with what you’ve got in the first response is useful for us, along with the corresponding insistence that the longer the emergency lasts the better planning and implementation should be.

Aligned to the previous point is the recognition that some jobs can be safely carried out just waiting for a lull in the traffic so long as that has been carefully assessed as a reasonably practicable solution rather than just doing it while no-one is looking.

The parallel development of NZTA training looks good with onsite assessment as well as class room learning.

The overarching GPG will be interesting to read as it has legal authority and so shapes our implementation of HSWA & NZGTTM, though I expect it’ll be as generic as other GPG with no straight answers so as to ’empower’ the PCBU to make the safest decision based on assessing risk of harm rather than risk of non-compliance.