Workplace health and safety (WHS) implications for farmers hosting unconventional gas (UG) exploration & production

Figures & data

Figure 1. Overview of the CSG Supply Chain (DNRM, 2014).

Figure 2. Author modified image of CSG Supply Chain including the host farmer.

Table A1. Illustrative risk assessment.

Hazard	Impact on host farmer	P&G Act	WHS Act	Jurisdictional response to impact on host farmer
Exposure to Respirable Silica due to UG activities (fracking and dust generated from general UG activities)	Host Farmer is potentially exposed to respirable silica generated by the industry activities in a different way to the Gas industry workers. The farmer lives 24/7 in the environment and instead of task related exposures that UG Workers have, with the advantage of control over the timing of the activity, the work environment and hierarchy of risk controls, the host farmer may be exposed multiple times by multiple company’s activity in the vicinity with no equivalent controls	The P&G Inspectorate is currently undertaking worker health project in collaboration with the Queensland Government’s Safety in Mines Testing and Research Station (SIMTARS)-conducting respirable dust and silica monitoring at hydraulic stimulation ‘fracking’ work sites in the Surat Basin and Bowen Basin. Sites will be divided between the two contractor groups conducting fracking for Queensland CSG operators. Work practice and risk controls employed by contractors will be observed and assessed. Respirable dust exposure levels will be collected. (P&G Safety News, November 2018)	Workplaces supplied with products comprising silica (such as sand) and all workplaces where silica containing dust is generated in a process will be subject to the WHS Regulation. (Worksafe Queensland, 2018)	Host Farmer is not included in the P&G research, the silica is not generated in the workplace that the host farmer is the person in control of but in the UG industry within his property, but the impacts flow out to the host farmers workplace Silica is expressly addressed as a Hazardous substance which is the jurisdiction of WHS Act according to the MOU but Worksafe Qld and the relevant legislation is not included in this research project.
Noise (including low frequency) (Nothdurft & Anor v QGC Pty Limited & Ors (2017) QLC 41.)	Host farmers are exposed to the industry noise 24/7 directly from individual infrastructure on their property and cumulatively from the infrastructure around them. The noise impacts represent a change to their work environment that is a source of mental stress, but in terms of low frequency noise, also a source of physiological stress. In addition to this, it may impact on sleep and concentration, which in turn impacts on the fatigue they carry which impacts their health and safety on the job (Worksafe Queensland, 2012)	P&G act deal with noise as a compensatory effect, and this is then dealt with through the Environmental Protection Act. Noise levels permitted by the administering authority is determined on an arbitrary environmental element, with no health or safety considerations	WHS act does address noise, but in the case of the UG industry it does not prevail.	WHS Duty is owed under the WHS Act, but in terms of the UG Industry impact on host farmers, Noise is not enforced via this path, but environmental licencing is the only avenue that is actively pursued. Host farmers are required to pursue this issue via the Environment department in the form of ‘nuisance’.
Psychosocial Hazards	The presence and forced interaction with the UG industry for the host farmer can produce impacts that can represent the full spectrum of risk factors for work related psychosocial hazards which potentially provides a very high risk for psychosocial injury/ill health/ physical illness for the host farmer. Risk Factors/Stressors as described in Worksafe Qld guidance tool (Worksafe Queensland, 2017) on Work related stress - Work demands Low control Poor support Lack of role clarity Poorly managed relationships Low levels of recognition and reward Poorly managed change Isolated work Organisational justice	P&G Act does not deal with psychosocial hazards. Even so, perhaps the most significant impact on this issue is the CCA that is signed, which in many cases is the source of the WHS impact and the only source of remedy and for which the P&G Act has jurisdiction	WHS Act does deal with work related stress, SafeWork Australia National Guide on Psychological Health and Safety in the workplace explains: A PCBU has the primary duty to ensure, so far as is reasonably practicable, workers and other people are not exposed to psychological health and safety risks arising from the business or undertaking. This duty requires you to ‘manage’ risks to psychological health and safety arising from the business or undertaking by eliminating exposure to psychosocial hazards so far as is reasonably practicable. If it is not reasonably practicable to eliminate them, you must then minimize those risks so far as is reasonably practicable	P&G Act has jurisdiction in this situation, however, the P&G act has no tools to address this impact on host farmer’s WHS. WHS Duty does exist under the WHS Act, but in terms of the UG industry impact on the host farmer, this is not enforced by the P&G Inspectors, nor by any other enforcing agency. The tools in place that remotely touch on this issue lean far away from the WHS legislative element
Rupture of gas gathering pipeline on host farmer property (one of the reported incidents to Worksafe Qld)	Impact on host farmer include exposure to hazardous material (gas/condensate); potential explosion; fire; damage to plant and equipment, injury; hazard that the UG industry has control over, but host farmer is exposed to and by virtue of the industry footprint, may even be instrumental in the initiation of the event through farming practices such as deep ripping, interfacing with buried pipelines	P&G Act deals with this as a prescribed incident and it must be reported to the Chief Inspector.	WHS Act deals with this via multiple codes of practice and guides on excavation and is a reportable incident in relation to excavation	P&G Act has jurisdiction. WHS Duty is owed to the host farmer, although the P&G Act has jurisdiction and there is no requirement in the P&G Act for the UG industry to consider the impact the pipeline has on the WHS of the host farmer specifically
Spill of up to 4000 L of condensate from high point vent (anecdotally this is a frequent occurrence)	There are no measures from the UG industry to contain these spills which occur across the operating area from time to time, they will spill from the vent onto the host farmer property (there is no bunding between UG plant and Host Farmer property). They can be accompanied by a large release of gas, high pitched noise and large quantities of salty water with other unknown contaminants. It has the potential to impact the host farmer through personal exposure to unknown contaminants, non-routine tasks dealing with material that is not under their control or undertaking, required to mitigate and remediate damages	P&G Act does not capture this as an incident, it is dealt with through the Environmental Protection Act	WHS Act deals with this through the duty to others and exposure to hazardous chemicals The WHS Act places a duty on the UG industry to ensure others are not Impacted by their undertaking, but the P&G act does not require the UG companies to address this risk to the host farmer	P&G Act has jurisdiction
Release of gas via highpoint vents on farmers property	Thousands of vents within the extraction system are on host farmer properties releasing unmeasured, unmonitored and unmitigated gas into the host farmers working atmosphere. This has the potential to impact on the health of the farmer and on the safety of the farmer in relation to fire (McKenzie et al., 2018)	P&G Act deals with by defining this event as an authorized activity	WHS Act deals with this as designers of plant and an atmospheric contaminant and emergency procedures	P&G Act has jurisdiction. While a WHS duty is owed to the host famer in relation to a safe occupational atmosphere and to have appropriate information to manage emergency response, the P&G act does not require these issues to be considered by the Industry in relation to the host farmer. In fact, this event is classified an ‘authorized activity’ and has no definition or limitation or recognition as an issue

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