TERMS AND DEFINITIONS
Controls mean measures implemented to eliminate or minimize hazards in the workplace. These controls are established as either engineering (first line of defence), administrative, or personal protective equipment (used as the last resort).
COP means Code of Practice;
DMR means the Department of Mineral Resources;
Hazards means source of exposure to danger
Health-threatening occurrences: means occurrence that has or may have the potential to cause serious illness or damage to health
“HEG” means Homogenous Exposure Group
“ILO” means International Labour Organisation
Investigations: means a well-planned analysis of an event that identifies the root cause and recommends corrective action to prevent re-occurrence
Medical Surveillance means planned programme of periodic examination, which may include clinical examinations, biological monitoring or medical tests, of employees by Occupational Medical Practitioner contemplated in section 13;
MHSA means Mine Health and Safety Act, 1996 (Act No. 29 of 1996) as amended;
MOHAC means Mining Occupational Health Advisory Committee
NIHL means Noise Induced Hearing Loss
Occupational Health includes occupational hygiene and occupational medicine
Occupational Health Practitioner includes OMP, OHNP and or Mine Occupational Hygienist
OHNP means the Occupational Health Nurse Practitioner
OMP means the Occupational Medical Practitioner
PLH means Percentage Loss of Hearing.
Risk means likelihood that occupational injury or harm to a person will occur.
Root/basic cause means the real cause of an incident and the reason for its occurrence. The root cause is usually not immediately evident and requires investigation.
Serious illness means any serious illness resulting from occupational exposure that affects the health of a person to the extent that in capacitates the affected person from resuming that person’s normal or similar occupation for 4 days or more.
RISK MANAGEMENT
Section 11 of the MHSA requires the employer to identify hazards, assess the health and safety risks to which employees may be exposed while they are at work, and record the significant hazards identified and risk assessed. The employer must determine how the significant risks identified in the risk assessment process must be dealt with, having regard to the requirement of section 11(2) and (3) that, as far as reasonably practicable, attempts should first be made to eliminate the risk, thereafter to control the risk at source, thereafter to minimise the risk and thereafter, insofar as the risk remains, to provide personal protective equipment and to institute a programme to monitor the risk.
To assist the employer with the risk assessment all possible relevant information such as accident statistics, locality of mine and emergency services, ergonomic studies, research reports, manufacturers’ specifications, approvals, design criteria and performance figures for all relevant equipment, should be obtained and/or considered.
In addition to the periodic review required by section 11(4) of the MHSA, the COP should be reviewed and updated if significant changes are introduced to procedures, mining and ventilation layouts, mining methods, plant or equipment and material.
ASPECTS ADDRESSED IN THE COP
Where serious illness and or health threatening occurrences indicate the need to be investigated by the employer as required by legislation, the following key elements must be addressed in the COP:
SELECTION OF INVESTIGATION TEAM MEMBERS
In order to ensure that the investigation team consist of competent and sufficient persons, the following members are included in the team:
(i) Occupational Medical Practitioner or Occupational Health Practitioner,
(ii) Affected employee(s) and persons
(iii) Line Supervisor(s)
(iv) Section 12.1 appointee,
(v) Full time Health and Safety Representatives
(vi) Health and Safety Representative of the affected area
(vii) Responsible manager
Needs for the investigation Team Members
The incident investigation team will be trained in investigation techniques including:
(i) Gathering information
(ii) Interviewing skills
(iii) Analysing information
(iv) Identifying factors of the incident
(v) Identifying root/basic causes
(vi) Writing recommendations
(vii) Report writing skills
(viii) Knowledge of the layout of the workplace
(ix) Be familiar with work process ,practices and procedure
Roles of investigation team members
The roles and functions of the investigation team are:
(i) Investigation to be conducted as soon as possible after the incident
(ii) Incident investigation procedure are to be followed
(iii) Root cause(s) are to be identified
(iv) All contributing factors are to be identified
Investigation procedure
The investigation procedure will cover the following:
(i) Time frame to commence into serious illness and or health threatening occurrences investigation
(ii) Method to gather information into serious illness and or health threatening occurrences
(iii) Analysis of information to determine root cause
(iv) Basis of making recommendations to avoid similar reoccurrences
(v) The writing of investigation report
(vi) Follow up on the investigation
Time frame to commence into serious illness and or health threatening occurrences investigation
Steps to be taken after serious illness and or health threatening occurrences indicate need for the investigation:
a) eliminate immediate hazards to prevent injuries
b) maintain site until all information is gathered
c) leave the site undisturbed
d) safe guard the scene of the accident/incident
Conducting Interviews
(a) The following will be Interviewed promptly and separately:
-Affected employee,
-Witnesses if any,
-Supervisors,
-Any other person who might provide necessary information to assist the investigation
(b) Notes taken must include:
-Dates and times,
-Names and addresses,
-Information from interviews,
-Description of the site and environmental conditions,
-Measurements if taken,
-Information about evidence gathered.
Information analysis to determine the root cause (see Annex 2, which is attached for information purpose)
Immediate causes and root causes (s) of the incident will be identified in order to prevent similar incidents in the future.
Recommendations
Recommendations will be:
(a) clearly written
(b) as specific as possible- what, when and where
(c) identify target dates or implementation and follow up, and
(d) list resources required for the implementation
Incident investigation reports
The contents of the investigation will:
(a) identify the causes and underlying causes of the serious illness or health threatening occurrences,
(b) identify any unsafe conditions, acts, or procedures that contributed in any manner to the serious illness or health threatening occurrence, and
(c) makes recommendations to prevent similar serious illness or health threatening occurrence
Follow-up on investigation
Follow-up on the investigation will include the following:
(a) implementation of corrective actions with assigned time frames
(b) evaluation of corrective actions for effectiveness
(c) sharing the investigation findings with employees
(d) communicate the effectiveness of the corrective actions to management and employees representatives in the affected work area.
ISSUES TO BE ADDRESSED IN THE INVESTIGATIONS
In order to ensure that serious illness and health threatening occurrences investigations are adequately conducted, the following will be included in the investigation:
(a) Commencement period of investigation into serious illness and health threatening occurrences
(b) Time frame to conclude investigation should be stated and adhered to in line with Section 11(5) of the MHSA
(c) Comparison of individual exposure to HEGs
(d) Employer must conduct investigations in co-operation with the health and safety representative responsible for the affected working place
(e) Employer must conduct investigations in consultation with the health and safety committee (f) Individual past medical history to be considered (g) Where necessary counselling be provided by the Employer before proceeding with investigation
ACTION LEVELS TO INITIATE INVESTIGATIONS
In order to ensure that investigations into serious illness and health threatening occurrences are promptly initiated, the following matters are covered:
Serious Illness
(a) occupational disease, NIHL if there is a shift of more than 5%
(b) Abnormal occupational health related chest X ray observations
(c) Occupational health related complaints from employees
For Serious Illnesses, the investigation will be conducted within ten (10) working days after the incident has been reported.
Health Threatening Occurrences
(when occupational hygiene exposure to health hazards of the employees is above the limits set out in schedule 22.9(2) (a) and (b))
NIHL
NIHL cases where the PLH is 5% or more from the baseline, will be investigated and reported to the Principal Inspector of Mines.
The investigation of these cases will be done within 30 days after the incident has been reported.
Occupational Lung Diseases
For Health-threatening occurrences, the investigation will be conducted within ten (10) working days after the incident has been reported.
TRAINING AND AWARENESS
Measures to be taken to ensure compliance with the employer’s obligations under training and employee’s obligation under employees’ duties for health and safety of the MHSA:
(a) Members of the investigation team are trained in the investigation techniques
(b) The content and frequency of such training (see also section 10(2)(b) of MHSA);
(c) Employees’ right to information kept in terms of sections 12(3) and 13(3)( c) of the MHSA
(d) Comprehensive health training programme to assist employees to recognize any early symptoms of potential occupational diseases before they become permanent conditions
(e) Employees are trained in the importance of reporting incidents
(f) Employees duties for health and safety in terms of section 22 of the MHSA
REPORTING AND RECORDING
Reporting period for health threatening and serious illness investigations:
REPORTING:
HEALTH-THREATENING OCCURRENCES
For the Health-threatening Occurrences, the investigation report must be submitted to the Regional Principal Inspector within thirty (30) days after the incident was reported.
NOISE INDUCED HEARING LOSS
For Noise Induced Hearing Loss incidents, the investigation report must be submitted to the Regional Principal Inspector within thirty (30) days after the investigation process has been completed.
OCCUPATIONAL DISEASES
For the Occupational Diseases, the investigation report must be submitted to the Regional Principal Inspector within thirty (30) working days after the incident was reported.
SERIOUS ILLNESSES
For Serious Illness incidents, the investigation report must be submitted to the Regional Principal Inspector within thirty (30) working days after the incident was reported.
INVESTIGATION REPORT:
The investigation report will include:
(i) Identification of the root and underlying cause of serious illness or and health threatening occurrences
(ii) Identification of unsafe conditions, acts, or procedures that might have contributed in any manner to serious illness or and health threatening occurrences
(iii) recommendations on corrective actions to prevent similar serious illness or and health threatening occurrences
Remedial Actions from investigation reports will be based on the hierarchy of controls, including:
(i) Elimination
(ii) Engineering control
(iii) Administrative controls
(iv) Personal Protective Equipment (PPE)
ROLES OF OCCUPATIONAL HEALTH AND SAFETY COMMITTEE IN THE INVESTIGATION
The OH&S Committee must receive all incident investigation reports. The investigation procedure must outline responsible persons for distributing the reports to the OH & S committee and persons responsible for updating the OH & S committee on the implementation, follow up and evaluation of corrective actions.
As part of the internal responsibility system, the OH&S committee reviews all accident/incident investigation reports to ensure:
Incident investigation procedure are followed,
Root causes are identified,
Recommendations for corrective actions appropriate,
Additional recommendations are developed and forwarded to the employer if appropriate,
Communication procedure for investigations are followed,
Trends in injury, illness and property damage are identified, and
Investigations are an effective part of OH & S program