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Occupational Health and Safety Regulations 2007

SA-2 Managing Risk Control MeasuresA Self Assessment Tool for Prescribed Mines

WorkSafe Victoria / SA-2 Managing Risk Control Measures Edition 1 April 2008

Occupational Health and Safety Regulations 2007


Table of Contents1. About this Tool........................................................................................................................2

1.1 Relevant OH&S Regulations for Managing Risk Control Measures.................................21.2 References Relevant to Managing Risk Control Measures..............................................31.3 Adopting Risk Control Measures – Supporting Information.............................................4

2. Adopting Risk Control Measures to Eliminate or Reduce Risk...........................................52.1 Eliminating Risk................................................................................................................52.2 Using Substitution, Isolation or Engineering Controls to Reduce Risk.............................62.3 Using Procedures and Personal Protective Equipment to Reduce Risk..........................7

3. Reviewing and Revising Risk Control Measures..................................................................9

4. Testing Risk Control Measures............................................................................................11

5. Safety Role for Employees...................................................................................................13

6. Prohibitions..............................................................................................................................15

WorkSafe Victoria / SA-2 Managing Risk Control Measures Edition 1 April 2008


1. About this Tool

SA-2 Managing Risk Control Measures is part of the Self Assessment Toolbox. This specific tool has been prepared to assist operators of prescribed mines to explore their risk control measures and identify opportunities for improvement. It can be used as a stand alone document or alternatively the content contained within this tool can be used to supplement existing site procedures.

The Self Assessment The Self Assessment Toolbox is made up of core and supporting tools. The core tool section of the toolbox covers processes which are an essential part of day to day safety management. The supporting tools were written to assist operators to:

- further explore their identified hazards,

- identify risk control measures for adoption, and

- develop safety management systems.

The scope of the supporting tools is intended to grow and change over time as needs within the industry are identified.

SA-2 Managing Risk Control Measures is based on part 5.3 of the Occupational Health and Safety Regulations 2007 and covers topics such as adopting, testing and reviewing risk control measures, as well as, employee involvement. There is space within each section of the tool to record your observations and reference documents used to form your opinion. A compliance statement is also contained within relevant sections of the tool to compare your findings against the regulatory standard. If you identify opportunities for improvement there is space at the end of each section to record these, assign responsibilities and propose a completion date.

The Self Assessment Toolbox

Core tools Supporting toolsSA 1 – Risk Management SA 6 – Managing Geotechnical Hazards

SA 2 – Managing Risk Control Measures SA 7 – Ventilation and the Working Environment

SA 3 – Emergency Management SA 8 – Contractor Management

SA 4 – Safety Management Systems SA 9 – Mining Plant

SA 5 – Consultation, Information, Instruction and Training

1.1 Relevant OH&S Regulations for Managing Risk Control Measures

Regulation Title

5.3.8 Control of risk

5.3.9(1)(c) and 5.3.9(2) Review by operator of risk control measures

5.3.24 Testing risk control measures for major mining hazards

5.3.33 Prohibitions

WorkSafe Victoria / SA-2 Managing Risk Control Measures Edition 1 April 2008 2


1.2 References Relevant to Managing Risk Control Measures

Reference Relevant to Location

National Minerals Industry Safety and Health Risk Assessment Guideline, Minerals Industry Safety and Health Centre, 2005

Section 4Identification of controls and performance measures

Minerals Industry Health and Safety Centre, University of QLDwww.mishc.uq.edu.au

Guidance note MPV-GN-03 Risk Assessment and Control, Victorian Department of Primary Industries

Risk control measures – general DPI Websitewww.dpi.vic.gov.au

Guidance note MPV-GN-05 Safety Assessment Victorian Department of Primary Industries

Selection, evaluating and testing control measures

DPI Websitewww.dpi.vic.gov.au

AS 4360:2004 Risk Management, Standards Australia

Risk management overall (systems focused)

Standards Australia www.standards.com.au

HB 436:2004 Risk Management Guidelines Companion to AS/NZS 4360:2004

Risk management overall (systems focused)

Standards Australia www.standards.com.au

Minerals Industry Safety Handbook – NSW Department of Minerals Resources 2004

Section 1.5Risk control measures – general

DPI NSW Website www.dpi.nsw.gov.au

General duty of care in Western Australian mines- Guideline

Information on control hierarchy and monitoring reviewing control measures.

Department of Consumer and Employment Protection (DOCEP)www.docep.wa.gov.au/resourcessafety

Guide to positive performance measurement

Section 4.2 Inspection, testing and monitoring

The Chamber of Minerals and Energy WA www.cmewa.com.au

Major Hazard Facilities Guidance note 10 - Control measures and performance indicators WorkSafe Victoria

Selection, evaluating and testing control measures

WorkSafe Website www.worksafe.vic.gov.au

Controlling OHS hazards and risks – A handbook for workplaces

Information on effectiveness and reliability of controls and review of controls.


How WorkSafe appliesthe law in relation toReasonably Practicable

Information on applying Division 20(2) of the OH&S Act 2004




1.3 Adopting Risk Control Measures – Supporting Information

Hierarchy of controlsA key aspect of this regulation is that in adopting appropriate risk control measures you must have considered that some risk control measures are more effective than others. In other words, ways of controlling risks can be ranked from the highest level of protection and reliability to the lowest. This approach is known as the ‘control hierarchy’, is illustrated in the accompanying diagram.

So far as is reasonably practicable (SFARP)You must have regard for the following matters in determining what is reasonably practicable when adopting risk control measures. Division 20(2) of the Occupational Health and Safety Act 2004 defines reasonably practicable as:

a) The likelihood of the hazard or risk concerned eventuating;

b) The degree of harm that would result if the hazard or risk eventuated;

c) What the person concerned knows, or ought reasonably to know, about the hazard or risk and any ways of eliminating or reducing the hazard or risk;

d) The availability and suitability of ways to eliminate or reduce the hazard or risk;

e) The cost of eliminating or reducing the hazard or risk.

For more information, refer to How WorkSafe applies the law in relation to Reasonably Practicable.

Layers of protectionIn some instances a number of different controls can together provide the best reduction in risk. As illustrated by the diagram below.



2. Adopting Risk Control Measures to Eliminate or Reduce Risk

2.1 Eliminating Risk

Regulation Title

Regulation 5.3.8 (1) The operator of a mine must adopt risk control measures that–(a) eliminate so far as is reasonably practicable risks to health or safety

associated with any mining hazards at the mine; or; (b) if it is not reasonably practicable to eliminate those risks, reduce those

risks so far as is reasonably practicable.

Before you begin Do you have access to all the relevant information you need? Some key examples include: register of existing adopted control measures, hazard register, and documents which list the reasons for the adoption or rejection of control measures.

Do you intend to consult about the adoption of risk control measures with employees at the mine who are likely to be directly affected and their Health and Safety Representatives (HSR)’s? (Refer to Self-assessment tool 5 – Consultation, information, instruction and training for more information.)

Adopting control measures to eliminate risk Have you considered that the best control option is to remove a mining hazard completely so that its associated risks to health and safety are eliminated? An example of this would be eliminating the risk associated with Load Haul and Dump (LHD) equipment operators being exposed to broken and unsupported ground in draw points by using remotely controlled LHD equipment.

Have you adopted risk control measures which eliminate risk? If so, have you considered what systems you need to have in place to ensure these control measures survive and are reliable? Control measures include: management sign off of design standards and management of change systems.

Have you recorded who was involved and who you consulted with?

Relevant Documents & Records

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2.

Observations and Comments

Compliance Information All reasonably practicable means have been taken for eliminating mining hazards or risks to health and safety.

RatingMeets requirement

Does not meet requirement

Opportunities for improvement identified Person responsible Proposed completion date



2.2 Using Substitution, Isolation or Engineering Controls to Reduce Risk

Regulation Title

Regulation 5.3.8 (2) For the purpose of complying with sub regulation (1), the operator must, so far as is reasonably practicable, use one or any combination of the following risk control measures–(a) the substitution of a new activity, procedure, plant, process or substance

for that which is related to the relevant mining hazard; (b) the isolation of persons from the mining hazard; (c) engineering controls.

Before you begin Do you have access to all the relevant information you need? Some key examples of this include: register of existing adopted control measures, hazard register, documents which list the reasons for the adoption or rejection of control measures.

Do you intend to consult about the adoption of risk control measures with employees at the mine who are likely to be directly affected and their HSR’s?

Using Substitution, Isolation or Engineering Controls to Reduce RiskIf you are unable to eliminate the risk, have you considered that the next best control option is to change the risk using substitution, isolation or engineering controls?

Substitution - That is, if you can’t eliminate the hazard or risks, have you substituted the hazard with a new activity, procedure, plant, process or substance that is less of a risk? An example of this would be substitute the use of electric detonators by using NONEL detonators. Isolation - That is, if you can’t reduce the risk by substitution, have you separated the people from the hazard? An example of this would be isolating underground workings from potential inrush of water or inflow of mine gases from old workings.Engineering Controls - That is, if the risk cannot be substituted or isolated, have you reduced the risk by engineering methods such as using mechanical or engineering devices or changing work processes? An example of this would be engineering fit for purpose backfill bulkhead seals to dam waters.

Have you adopted risk control measures which change the risk? If so, have you considered what systems you need to have in place to ensure these control measures survive and are reliable? Some key examples of this include: maintenance systems, performance monitoring systems, inspection systems.





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Compliance Information There are mining hazards for which a risk remains and all reasonably practicable substitution, isolation or engineering controls have been adopted for mining hazards.ANDThe risk control measures adopted are effective at reducing the risk of the identified mining hazards.




2.3 Using Procedures and Personal Protective Equipment to Reduce Risk

Regulation Title

Regulation 5.3.8 (3) If an operator has complied with sub regulation (1) so far as is reasonably practicable and a risk to health or safety remains, the operator must, so far as is reasonably practicable, use administrative controls.

(4) If an operator has complied with sub-regulations (2) and (3) so far as is reasonably practicable and a risk to health or safety remains, the operator must provide appropriate personal protective equipment to persons at risk.

Before you begin Do you have access to all the relevant information you need? Some key examples of this include: register of existing adopted control measures, hazard register, documents which list the reasons for the adoption or rejection of control measures, and material safety data sheets which detail relevant PPE.

Do you intend to consult about the adoption of risk control measures with employees at the mine who are likely to be directly affected and their Health and Safety Representatives (HSR)’s? (Refer to Self-assessment tool 5 – Consultation, information, instruction and training for more information.)

Using administrative controls to reduce risk

If risk still remains after consideration of higher level control strategies, have you considered reducing exposure to a hazard through procedural approaches? For example, developing a mining procedure which specifies the requirements for effective tolerances required for support of underground workings.


Have you adopted administrative risk control measures which change the risk? If so have you considered what systems you need to have in place to ensure these control measures survive and are reliable? Some key examples of this include: supervision, accessible work instructions, auditing systems, job cycle checks, training, instruction, and competency testing.

Using personal protective equipment to reduce risk

If the risk to health and safety remains after consideration of higher level control strategies, have you considered the use of personal protective equipment to reduce the risk? Some key examples of this include: use of self rescuers, mandatory issue of safety helmets for personnel working in the risk zone.

Have you considered that identifying personal protective equipment for use will depend on, the type of work or process and what you know about an injury or disease that can be caused by doing the work or process?

Have you considered that this type of control will only be effective if you have chosen suitable protective equipment, and if it is fitted and maintained correctly, and used at all times when needed?

What type of systems do you have you in place to ensure these control measures survive and are reliable? Some key examples of this include: Manufacturer or supplier specifications, supervision, training, and signage.



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Compliance Information There are mining hazards for which a risk remains and all reasonably practicable administrative and personal protective control measures have been adopted for mining hazards.ANDThese risk control measures adopted are effective at reducing the risk of the identified mining hazards.





3. Reviewing and Revising Risk Control Measures

Regulation Title

Regulation 5.3.9 (1) In order to ensure that an operator of a mine is complying with regulation 5.3.8 (1) by adopting appropriate risk control measures, the operator must review and, if necessary, revise – (c) the risk control measures adopted.

(2) A review under sub regulation (1) must be conducted–(a) before any mine modification is made; or(b) after any incident involving a mining hazard occurs at the mine; or(c) if the operator has removed a person from the person's work or assigned

the person to alternative work in the circumstances described in regulation 5.3.16(2); or

(d) after receiving a request from a health and safety representative - and in any event at least once every 3 years.

Before you begin Have you clearly defined what you want to review and by when?

Do you have a copy of all the information you may need. Some key examples of this include: control measure registers, incident reports, management of change registers, health surveillance reports and break down reports.

Have you considered where you will store the data from the review? Is there space in your control measure register?

Does your procedure for managing control measures define when, how and who will complete a review? At a minimum, does it list the circumstances specified in the regulations?

Does you procedure for managing change prompt a review of the adopted risk control measures for all mine modifications?

Does a report of a detrimental health effect in relation to a specific employee result in an incident report or review of control measures?

Does the incident reporting system trigger a review and revision of control measures following an incident involving a mining hazard?

Do you intend to complete the review with employees at the mine who are likely to be directly affected and their HSR’s?

Mine modification – some additional information about SMS management of change Mine modifications at a mine may be triggered by or required because of changes to: mining methods, technology, licence conditions, expectations and requirements of stakeholders, legislation or standards, or as a result of risk assessments, accident investigations, the findings of an audit, a senior management review of operations or the SMS, safety alerts or safety suggestions, or updating of manufacturers advice for plant and equipment. If not managed correctly, mine modifications can introduce new hazards into the mine or can even invalidate previously adopted risk control measures.


Reviewing and revising risk control measures Have you reviewed and revised your risk control measures under the specific circumstances listed in the regulations?

Have you documented the outcome of the review?

Have you recorded if a HSR requested the review, who was involved and who you consulted with?


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Compliance Information The mine operator can provide evidence that revision of the adopted risk control measures has taken place in the circumstances required by the Regulations.





4. Testing Risk Control Measures

Regulation Title

Regulation 5.3.24 The operator of a prescribed mine must, in relation to the control of risk associated with major mining hazards, test all risk control measures documented under regulation 5.3.21(3)(f) as often as necessary to ensure compliance with regulation 5.3.8 in relation to those hazards.

Before you begin Do you have access to all the relevant information? Some key examples of this include: parts of your safety management system which list the adopted control measures, maintenance registers, records of performance monitoring of control measures and training records.

Does your SMS list the adopted risk control measures, define the frequency of testing, include rationale for the chosen testing regime, define performance indicators and define who is responsible for the testing, monitoring and review of the testing process?

Do you provide training in inspection and maintenance procedures for employees?

Does your SMS define competencies and training for personnel undertaking or supervising maintenance and inspection tasks?

Does your SMS contain testing, operation and isolation procedures for critical equipment/ processes?

Does your maintenance system record whether inspection tasks have been undertaken and does it detail “as found” condition and required actions?

Testing risk control measures For all risk control measures adopted have you determined how frequently you will need to test them to ensure that they remain effective at reducing risk?

For all risk control measures adopted how do you know if you are testing them at your specified frequency?

How have you considered that different controls require different methods for testing and monitoring?

For example:

Hazard Control measure Performance monitoring method Frequency and justification

Air blast loading and hauling ore from unsupported stopes

1. Use automated remotely controlled LHD face equipment

Pre start up checks, routing maintenance, equipment condition monitoring

To manufacturer’s specification

2. Supervisory - clear areas checked before working at the face

Job production cycle check by Mine Manager

As per management audit schedule

3. Monitoring equipment installed

Testing/ calibration At beginning of new production cycle and annual as per manufacturer’s specification



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Compliance Information All risk control measures associated with major mining hazards, and documented under regulation 5.3.21(3) (f), are tested.ANDAre tested as often as necessary to ensure they remain effective at reducing risk.





5. Safety Role for Employees

Regulation Title

Regulation 5.3.25 (1) The operator of a prescribed mine must develop a role for the operator's employees, including the specific procedures employees are required to follow to assist the operator to–(c) adopt, review and test risk control measures under regulations 5.3.8, 5.3.9

and 5.3.24;(2) The operator of a prescribed mine must review the role of the employees

developed under this regulation if there is any change of circumstances, including a mine modification, that would require additional or different knowledge or skills on the part of employees to perform the role.

Before you begin Do you have access to all the relevant information? Some key examples of this include: position descriptions, organisational charts, responsibility/role matrix, contract specifications and the list of maintenance routines.

Do you have a copy of the procedure(s) which defines how your employees assist you in adopting, reviewing and testing risk control measures?

Do these procedure(s) define what will trigger a review? Some key examples of this include: change in legislation, mine modification, changes to the control measure register, change in organisational structure.

Do you intend to develop and review safety roles in consultation with employees at the mine who are likely to be directly affected and their HSR’s?

Developing and reviewing a safety role Do you have safety role descriptions for your employees? Some key examples of this include: Senior management, technical personnel, supervisory personnel, operators, contractors, other employees.

Do these descriptions detail the types of safety related activities that the role undertakes and where relevant do these mention adopting, reviewing and testing risk control measures?

If you use contractors to test risk control measures are these tasks clearly defined?

Do you review the skills and knowledge required to do the role when there has been a modification to the mine?

Have you recorded who was involved in the development and/or review of the safety roles?

Have you recorded who you consulted with during the development/review?



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Compliance Information Safety roles have been defined and include statements on adopting; reviewing and testing risk control measures for all relevant personnel at the prescribed mine. ANDSpecific procedures have been developed regarding safety roles, including procedures for adopting, reviewing and testing risk control measures. ANDA review of the skills and competencies required occurs when modifications are made to the mine. ANDThere is evidence that employees are participating in adopting, reviewing and testing risk control measures as defined by their role.





6. Prohibitions

Regulation Title

Regulation 5.3.33 The operator of a prescribed mine must not allow the following to be used underground–(a) an internal combustion engine (other than a compression ignition engine); or(b) polyurethane foam

Before you begin Do you have access to the relevant information? Some key examples of this include: control measure registers, onsite equipment registers, and technical specifications of equipment, purchasing procedures, and underground inspection checklists and induction or training material.

Have all employees and contractors been instructed in the risks associated with internal combustion engines and polyurethane foam used underground?

How do you inform your employees and contractors who work or buy equipment for use underground about this prohibition?

Does your purchasing procedure contain information on these prohibitions?

Prohibitions Do you prohibit the use of polyurethane foam or internal combustion engines underground?

What risk control measures have you adopted to ensure that polyurethane foam and internal combustion engines are not used underground? Some key examples of this include: purchasing specifications, induction/ training, targeted underground inspections, and random checks of contractors’ equipment.


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Compliance Information No internal combustion engines and polyurethane foam are underground.





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