Supporting Telstra and other carrier communication networks

Introduction

Telstra maintains a communication network across Australia that provides the community and industry phone and data coverage and access to essential emergency services through 000 and medical priority.

Nationally this network comprises over seven million worksites including more than 27,000 towers/antennas and thousands of exchange buildings.

Telstra’s communications towers or antennas are visible on tops of buildings, on both public and private land including mines and quarries. These facilities and associated buried cables play an important part in the communications network. The removal or breakdown of any one of these Essential Service Telstra Facilities (ESTF) can result in widespread outages which may also mean the outage of 000.

Table 1 shows the distribution of Telstra towers on mining leases in Queensland. The leases cover a variety of mine types ranging from large coal mines and mineral mines to small mineral mines including opal mines. The operating status of the mines can range from an ‘inactive granted lease, ‘active mine’ or in ‘care and maintenance’ through to closed. Table 1 does not include the Telstra facilities located on quarries.

In some cases the ESTF pre-date the granting of the mining lease.

Table 1 Distribution of Telstra towers on mining leases in Queensland

Communications equipment

Telstra generally owns the masts and towers on which their communications equipment is installed. In some situations the Telstra tower is also used to carry a mine or quarry’s communication equipment. In other situations Telstra install their communication apparatus on a tower or structure owned by a mine or quarry.

While a mine or quarry may derive a service from the ESTF these facilities exist primarily to provide essential communications services to many Telstra customers and communities within range of the facilities.

Telstra’s obligation to provide a continuously functioning essential service capability is enabled by Commonwealth laws that obligate landholders to allow access to Telstra to repair and maintain existing assets, as well as installing new assets in certain circumstances. These rights apply nationally and enables Telstra to access buildings, pastoral leases, rail corridors, and in fact any parcel of land where their facilities are located. This includes exploration and mining tenures as well as quarries.

The ESTF located within the boundaries of a mining lease or quarry are installed, operated and maintained as part of Telstra’s telecommunications network infrastructure regulated under the Telecommunications Act 1997 (Cth) (the Telco Act) and Telstra’s carrier license.

The installation, operation and maintenance of ESTF is not part of a mine’s ‘operations’ as defined in the Mining and Quarrying Safety and Health Act 1999 (the Act) or part of ‘on-site activities’ as defined in the Coal Mining Safety and Health Act 1999 (the Coal Act.)

Telstra is a non-Commonwealth licensee pursuant to the Safety Rehabilitation and Compensation Act 1988 (Cwth), and as such its workers are subject to the Work Health and Safety Act 2011 (Cwth) (WHS Act) and are regulated, for safety purposes, by Comcare.

Health and safety

Telstra has a Global Health, Safety and Environment Management System in place to ensure that it complies with its duties under the Commonwealth safety laws.

Telstra technicians who access and work on ESTF on a mine or quarry are not ‘workers’ as defined by the Act or ‘coal mine workers’ as defined by the Coal Act. Essentially an SSE is not responsible or accountable for activities conducted on ESTF by Telstra technicians.

As an operator of the Mine you don’t have obligations to ensure the structural integrity of the towers and similarly you don’t have obligations to Telstra workers when they are performing work for Telstra apart from ensuring their safe access and egress from Telstra facilities.

An SSE is responsible and accountable for ensuring that Telstra technicians:

• Can travel safely between the entry point of the mine or quarry and where the ESF are located, often accomplished by providing an escort.
• While they are working on the ESF the risk to them from being harmed by mining or quarrying activities is at acceptable level.
• Are provided with an induction that is appropriate for the level of interaction that the Telstra technician will have with the mine or quarry’s activities e.g. visitor’s induction.

To gain access to ESTF Telstra need to use Telstra’s normal operational vehicles and plant. Telstra recognises that the vehicles must be roadworthy and the technicians need to meet fitness for work standards. Telstra technicians will abide by reasonable site access requirements of the mine when accessing or exiting a mine or quarry, however if these requirements are not reasonable Telstra will request that the mines’ inspectorate assist to resolve the dispute.

Access to Telstra facilities

In arranging access to ESTF, Telstra technicians are obliged to consult, co-operate and co-ordinate with the SSE. The nature and urgency of the work required on the ESTF will determine the notice that Telstra representatives will be able to provide to an SSE that access to the ESTF is required.

Generally there are two situations that Telstra technicians will require access to ESTF:

• For scheduled and planned maintenance work - approximately six weeks’ notice to the SSE of such work would be expected.
• For emergency work, often as a result of electrical storms or cyclones - the Telstra representative will give as much notice as possible but in some cases less than one hour notice to the SSE may be provided.

Because of the criticality of ensuring Telstra technicians have access to the ESTF especially for emergency work and acknowledging that communication problems and access issues might arise from time to time it is essential that such matters are resolved promptly. Operators and SSE’s should ensure that they have suitable processes in place to quickly and effectively facilitate Telstra technician’s access to ESTF.

Operators and SSE’s should also note that in some circumstances the ESTF may be the property of a carrier/service provider other than Telstra but the same principles in facilitating access for maintenance and repair should apply.

Where necessary to facilitate resolution of any problem or issue associated with Telstra’s access or activity on a mine or quarry the relevant Regional Inspector of Mines or Regional Inspector of Coal Mines should be contacted for assistance either by the Telstra representative or the SSE. The current contacts for the Regional Inspectors can be found on the DNRM website (https://www.dnrm.qld.gov.au/our-department/contact-us/mines-inspectorate-contacts).

Authorised by Russell Albury - Chief Inspector of Coal Mines and Phil Goode - Chief Inspector of Mines

Contact: +61 7 MineSafetyandHealth@dnrm.qld.gov.au

Issued by Queensland Department of Natural Resources and Mines