Read the Regulations
The duties referred to in this guidance are contained inPart 5.3 Mines of the Occupational Health and Safety Regulations 2017 (OHS Regulations).
You must read the legislation in addition to this guidance.
- This guidance refers to Regulations 418, 419, 420 and 443 of the OHS Regulations, which are duties for operators of prescribed mines.
- Operators of any mine can use this guidance to develop a higher standard of documentation and procedures to control risks at the mine (see Regulation 405).
- For an overview of the relevant OHS Regulations, read Duties for mine operators.
What is a SMS
A SMS is a comprehensive and integrated risk management system that governs how you manage risks to health and safety at the mine.
Operators of prescribed mines must establish and implement a SMS. Specific requirements are found in regulations 418 – 420 of the OHS Regulations.
Your SMS must:
- be documented in such a way that it can be read and understood by everyone who needs to use it
- contain descriptions of the mine's:
- safety assessment, and
- operator's safety policy
- sets out the system, procedures and other risk control measures
- set out ways to measures the effectiveness of the SMS
- set out how performance standards will be met, and
- explain the process, method and frequency for auditing the effectiveness of the SMS
In addition, you must:
- keep a copy of the SMS, available for inspection, at the mine
- use the SMS as the primary means of ensuring safety at the mine
- review the SMS at least once every 3 years, as well as before any mine modifications and after any incident involving a mining hazard
What to include in a SMS
Mine safety policy
This must be a signed policy that describes:
- your safety objectives, and
- how management will resource the work to achieve the safety objectives
Employee roles and responsibilities
This might include role matrices, job descriptions, contract specifications and any other information that clearly identifies the activities and responsibilities of each role.
Employee competency and knowledge
This should include training, competency and knowledge requirements necessary for employees to safely carry out their roles and responsibilities. This may include inductions, professional development, maintaining certification/qualifications and specific on-site training (e.g. safe operating procedures for plant/machinery or hazard identification processes).
Safety roles for employees
You should include a section on how you created safety roles for employees at the mine, which is required under regulation 380 of the OHS Regulations.
Read: Consulting with employees.
Operational procedures or systems of work
This could include permits to work, clearances, work instructions and the following safe work procedures:
- workplace inspections
- machinery/plant inspections prior to use
- design processes
- reporting processes and requirements
- safe operation of fixed/mobile plant
- safe handling and transport of explosives
Maintenance procedures or systems of work
This should include maintenance activities and processes necessary to ensure mobile and fixed plant is fit for purpose and safe to operate. Examples include:
- maintenance procedures
- systems and processes to monitor and record mobile and fixed plant usage
- planned systems for managing routine maintenance activities
Relevant details from your safety assessment
The SMS must include a description of the safety assessment undertaken pursuant to regulation 421 of the OHS Regulations.
For more information, read WorkSafe's guidance on Safety assessments.
How you manage incidents and emergencies
Include your incident response, investigation and review procedures to ensure continuous improvement is made to reduce incident frequency and harm to employees. Procedures for dealing with negative health surveillance reports should also be included along with the mine's emergency plan (i.e. detailed plan identifying possible emergency events, allocated resources and roles for employees).
How you manage change on site
The Management of Change process should include procedures for managing mine modifications or significant change within the operation. This detailed process should identify any resultant level of risk which may be posed to employees, and assess the adequacy of any existing or proposed control measures.
How you inform, instruct and train your personnel
Include the procedures and processes used to identify training needs, define competency and conduct and review employee training/competency. This covers the use of all plant and equipment on site, and should be continually monitored to ensure employee competency is maintained.
How your SMS contributes to continuous improvement
This section could include Occupational health and safety plans, performance standards, procedures for auditing, procedures for management review and indicators for measuring performance, for example: control measure effectiveness/maintenance and achieved levels of auditing.
Most mines follow a 'plan-do-check-act' structure to ensure continuous improvement.
How you review your SMS
The SMS should outline processes to be followed when conducting a review, including:
- when and how reviews are to be conducted
- who conducts each review
- what competency and experience is required to conduct each review
- the scope of each review, and
- who receives the results
You should explain how a review's results will be presented to management and detail how improvement actions will be developed based on the results, along with how evidence will be collected to show recommendations have been followed up or implemented.
Management of contractors
If your contractors follow their own SMS it is important to know how this is different from yours. Good practice is to assess differences between your own SMS and that of any contractor (i.e. carry out a 'Gap Analysis'). Where a contractor’s system is found deficient, any residual level of risk to employee health and safety should be assessed and appropriate action taken to eliminate this risk. At minimum, it is recommended the effectiveness of a contractor's SMS is equal to yours.
What to consider when developing your system
Integrating the supporting elements
A successful SMS includes elements that support each other to control mining hazards.
For example, elements such as maintenance, training and competency, risk assessment, and design of mine roads, should all combine to effectively control mobile plant hazards.
Your SMS should integrate with your business management systems.
For example, purchasing procedures should include requirements to identify hazards associated with new goods, equipment or services.
Incorporating external expertise
If outside expertise has been relied upon to control hazards or develop risk control measures, then it is important that this is effectively incorporated into your SMS.
For example, if a geotechnical consultant has been engaged to assess ground stability and recommends methods to improve stability, does your SMS detail the process by which ground stability is assessed; has the remediation method been adopted as a control measure; and has routine monitoring of ground conditions been included in workplace inspection checklists?
Identification of all control measures
Each of the risk control measures identified in your safety assessment must be documented in your SMS, along with how they are being adopted at the mine. This includes all procedures, work instruction and engineering control measures.
All aspects of risk control management, including the development, use, maintenance, inspection and testing of control measures, should be addressed in the SMS.
Define performance standards
To measure the effectiveness of your SMS, you must develop performance standards and describe them in enough detail for them to be understood by anyone reading your documentation.
For example, a performance standard for a training element could be that personnel are competent to perform tasks assigned to them. This might be achieved through a structured training and assessment program. Performance could be monitored by tracking rates of completion for scheduled training, and the percentage of incidents in which insufficient training is identified as a major contributing factor. Improvement steps may then be identified through regular review of the mine's progress to achieve targets in areas for improvement.