AIOH Submission – Draft Health and Safety Risk Management of Tunnels and Shafts in Construction Code of Practice

Description

We welcome the opportunity to provide feedback on the draft Code. We acknowledge and commend the many positive inclusions within the proposed Code, particularly the recognition of ventilation officers and certified occupational hygienists as essential
components of best-practice tunnelling operations. The strengthened requirements for ventilation and the clear emphasis on managing respirable crystalline silica (RCS), being the most significant health risk faced by tunnel workers, represent important and long overdue advancements in protecting worker health.

This Code provides a much-needed instrument for an industry where the health risks are both acute and increasing. We thank the NSW Government for undertaking this critical work and for inviting the AIOH to contribute. In preparing this submission, we
have consulted with experienced occupational hygienists currently working on tunnelling projects across NSW, and the feedback presented reflects their consolidated expertise and insights.

Association number: A0017462L
ABN: 50 423 289 752
Approved by Council: 26 November 2025
Prepared by: AIOH External Affairs Committee
Date: 26 November 2025

Acknowledgements
The AIOH Council acknowledges the work of members who contributed to this submission from the External Affairs Committee, and the many occupational hygienists who work in tunnelling in NSW.