Do We Really Need Dogging Licences?

Is a Dogging Licence required for this task? That’s the question that seems to be asked over and over, highlighting a level of confusion amongst employers and employees alike.

What does the law say about Dogging Licences?

Let’s start with the source of the information – the Occupational Health and Safety Regulations 2017 (Vic.), which defines dogging work as one or both of the following:

• The application of slinging techniques, including the selection or inspection of lifting gear, to sling a load
• The directing of a crane or hoist operator in the movement of a load when the load is out of the operator’s view

Additionally, the Regulations define slinging techniques as:

• Those slinging techniques that require the exercise of judgment in relation to the suitability and condition of lifting gear, and the method of slinging, by consideration of the nature of the load, its mass and its centre of gravity

Collectively, we can merge these two definitions to define dogging work as one or both of the following:

• The application of slinging techniques (that require the exercise of judgment in relation to the suitability and condition of lifting gear, and the method of slinging, by consideration of the nature of the load, its mass and its centre of gravity), including the selection or inspection of lifting gear, to sling a load
• The directing of a crane or hoist operator in the movement of a load when the load is out of the operator’s view

How does the law apply in the field?

WAM Training’s General Manager, Aaron Monaghan and Business Development Manager, James Sandman, have met with several members of WorkSafe Victoria’s Inspectorate to look at the practical application of this definition. That is to say – How does this definition apply in the field? To get to the bottom of this question, we’ve broken the definition into four activities which trigger the need for a Dogging Licence:

• The selection of slings
• The pre-use inspection of slings
• The application of slinging techniques
• The directing of a Crane Operator whilst the load is outside of the Operator’s view

The selection of slings

This one’s pretty simple. If the person slinging loads has to make a decision about which slings to use – a Dogging Licence is required. If that person is following a detailed procedure which tells them which slings to use on each load, a Dogging Licence isn’t required.

The pre-use inspection of slings

Perhaps not as clear cut – mainly due to this wording being misunderstood as referring to periodic inspection and tagging. WorkSafe Victoria has clarified with WAM Training that this requirement is referring to the need for slings to be inspected prior to use by the user (in the same way that a forklift needs to be inspected by the Operator prior to use). To go one step further, WorkSafe Victoria also advises that the use of procedures and checklists to guide the sling user through the inspection is not sufficient, as judgment would still need to be exercised whilst performing the sling inspection. So – The person who inspects lifting equipment prior to each use must hold a Dogging Licence.

Food for thought – What if a system where two bins (one green and one red) were used – with the green bin holding slings which are pre-inspected by a Licenced Dogger (all ready to go) and the red bin being used to isolate each sling after each lift. Would that remove this trigger for a Dogging Licence for the user? Yes!

According to WorkSafe Victoria:

• Slings, including synthetic slings, flexible steel wire rope slings and chains must be inspected prior to each use, throughout each shift. (I.e. if a sling is used for multiple lifts throughout a shift, it must be inspected multiple times by a Licenced Dogger)
• The person performing the sling inspection must hold a current and valid Dogging Licence, regardless of whether or not that person has received specific and/or additional training on sling inspection. (I.e. Even in cases where an inspection checklist is provided by the employer, the person inspecting the slings would still be required to exercise judgment throughout the inspection against the criteria in the inspection checklist, thereby making the task a licensed activity which should only be completed by a person who holds a valid Dogging Licence

The application of slinging techniques

Let’s remember the legislative definition of slinging techniques:

• Those slinging techniques that require the exercise of judgment in relation to the suitability and condition of lifting gear, and the method of slinging, by consideration of the nature of the load, its mass and its centre of gravity

We know that sling selection can be controlled by ensuring procedures exist to specify which slings are to be used on each load. And we know that sling inspection can be performed by a Licenced Dogger in advance (provided that the slings are used for one lift only prior to being isolated for another inspection). What about slinging techniques? Can they be defined by procedure? Yes.

The caveat here is that the procedure must apply to the exact load in question, and must completely remove the need to exercise all forms of judgment. If the procedure requires the sling user to make any decisions throughout the lift whatsoever – then that person must hold a Dogging Licence.

The directing of a Crane Operator

Finally, the last trigger. Any time that a person is directing a Crane Operator in the movement of a load, where that load moves outside of the view of the Operator – the person providing the commands must be a Licenced Dogger.

But surely my team doesn’t need Dogging Licences?!

Ask these four questions, and if you answer ‘Yes’ to any of them, then a Dogging Licence will be required:

• Do they choose their slings for each load?
• Do they inspect the slings prior to using them and throughout their shift?
• Do they decide how the slings will be attached?
• Do they direct Crane Operators when the load is outside of the Operator’s view?

Where can I find information on Dogging Licence Courses

Head on over to WAM Training’s Dogging Licence Course Page for more information.