05 reviewing your SMS
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Reviewing your safety management system
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05 reviewing your SMS
- 1. Small Mines Roadshow October – December 2020 Reviewing your Safety Management System
- 2. Work Health & Safety (Mines & Petroleum Sites) Regulation 2014 Clause 17 Review (1) The operator of a mine or petroleum site must ensure that the safety management system for the mine or petroleum site is reviewed within 12 months of the commencement of mining operations or petroleum operations at the mine or petroleum site and at least once every 3 years after that to ensure it remains effective. (2) In addition, if a control measure is revised under clause 38 of the WHS Regulations or clause 10 of this Regulation, the operator must ensure that the safety management system for the mine or petroleum site is reviewed and as necessary revised in relation to all aspects of risk control addressed by the revised control measure.
- 3. The SMS should also be reviewed: • if a risk control measure is revised • before making a significant change to the mining operations • if a notifiable incident occurs at the mine • if an audit of performance standards indicates a deficiency in a risk control measure • after a worker's task is changed in response to health surveillance results • if there is evidence that a risk control measure does not adequately control the risk • if a health and safety representative at the mine requests the review
- 4. What information can assist the SMS review? Information that can help with the review includes: * results of any internal or system audits * reports on work health and safety performance * incident reports and investigations * hazard identification and risk assessment activities * changes to work health and safety laws * changes to work health and safety standards * Notices issued by the Resources Regulator
- 5. Reviewing a safety management system (SMS) A safety management system (SMS) should include some means for the operator to formally review the system’s performance and develop improvements based on the results of the review. There are many ways to review safety performance, but an assessment commonly consists of reviews by the quarry management in association with health and safety representatives, often with assistance from technical specialists ie electrical tradesperson, shotfirer, mechanic etc The system should also provide a means of prioritising action items and improvements, with higher priority being given to higher risk issues. Progress on action items should be formally tracked. Develop an Action Plan.
- 9. The SMS assessment tool can be used as a general guide for reviewing your Safety Management System.
- 14. Exercise: Safe R Us Quarries Work health and safety policy Goals Safe R Us Quarries is committed to ensuring all its activities are performed in a manner that protects the health, safety and welfare of workers, contractors, host organisations and the public Safe R Us Quarries shall establish objectives and targets to ensure it meets its WHS performance ensuring the elimination of work-related illness and injuries by continually improving it safety management system in a consultative manner. To achieve this we will; • Provide a healthy and safe workplace • Provide inductions and training for people who enter our quarry • Monitor and regularly review our WHS systems to ensure that are appropriate and effective • Ensure that management are held accountable for WHS matters on site and recognising that workers have a duty to ensure they are safe, and they keep others safe • Implement risk management process to ensure safety on site • Consult with workers and contractors for input into the SMS that will impact on their health and safety • Ensure that information relating to WHS is given to all workers, relevant contractors and visitors who come to site • Ensure that the SMS is effectively implement in accordance with this policy Signed by: Management Date Worker representative Date
- 15. Mine Record Work Health & Safety (Mines & Petroleum Sites) Regulation 2014 Clause 133 Mine or petroleum site record The mine operator has obligations to retain mine records. (a) a record of any notices issued, and (b) a copy of any provisional improvement notice, and (c) a record of every incident notified to the regulator, (d) Record of certain reviews of control measures—operator and the PCBU (risk assessment, incident investigations etc) (e) Communication between outgoing and incoming shifts (f) any other record that the operator is required to keep in respect of the mine or petroleum site under the WHS laws, and (g) a record of all first aid treatment provided at the mine or petroleum site.
- 16. Thank you Questions? Reviewing your Safety Management System 2020 Small Mines Roadshow
Editor's Notes
- SMS for the mine must be reviewed within 12 months of the commencement of mining operations at the mine and at least once every 3 years after that to ensure it remains effective. The WHS Legislation came into effect of Feb 2015 and allowed mine operator to have two years (Feb 2017) to implement the new requirements for SMSs. So now it has been over three years. The SMS is due for review.
- When should an SMS be reviewed? The elements of an SMS should be reviewed regularly and, if necessary, revised. A review should be done: if a risk control measure is revised before making a significant change to the mining operations if a notifiable incident occurs at the mine if an audit of performance standards indicates a deficiency in a risk control measure after a worker's task is changed in response to health surveillance results if there is evidence that a risk control measure does not adequately control the risk if a health and safety representative at the mine requests the review What should be considered during the review? The review should consider: the extent to which objectives and targets have been met the continuing suitability of the SMS in relation to any changing conditions and new information stakeholder concerns.
- Review to be conducted by Quarry management, WHS reps, and technical specialists ie electrical tradesperson, shotfirer, mechanic, operators etc An Action Plan is to be developed with issues risk assessed and priorities given on the improvements.
- Self auditing is a useful tool and the Regulator has published a number of Audit Tools to assist in developing and reviewing your Safety Management System.
- Please note that it was published in 2015… some of the recent updates to legislation won’t be included ie new RCS OEL This is a very comprehensive checklist to assist you in meeting your legislative obligations. The Legislation Audit Tool is intended to assist mines and quarries identify legislation relevant to their particular operation and to provide guidance on what could be expected to comply with the legislation. It also serves as reference to material that may assist mine operators establish and implement effective safety management systems (for example, codes of practice, Australian Standards, safety alerts).
- One of the most difficult decisions in regard to auditing is determining what is the scope or objective of the audit. Will the audit be conducted against all questions or will it break the audit into smaller more manageable parts? This audit tool has been formatted to provide auditors the opportunity to target one or more specific topics written in the legislation. Topics are listed in the table of contents starting on page seven. If an audit is to be conducted against specific parts, then plan what questions are to be used that relate to those parts. Detailed tables of contents are included at the commencement of every section. This audit tool identifies specific audit criteria, each with its own check box (denoted by a ), and questions which collectively may indicate the overall extent of legislative compliance.
- We also have this SMS Assessment guide that can be used to assist in SMS review. This is a 16 page document that allows you to see how well you are progressing, how much more needs to be done or if there is anything missing from your SMS. This assessment asks questions about typical programs and procedures you may have in your SMS, it is not a test but a guide to help assess where you are at.
- Safety Management system assessment guide is located in the Small Mines section of the Resources Regulator website. If you don’t have an SMS or want to revamp part or all of your existing SMS you could look at using the safety management kit for small-scale mines, quarries and extractive industries operations
- Examples of reviewing sections of SMS
- Examples of reviewing sections of SMS
- Examples of reviewing sections of SMS
- On the left is a WHS policy, using the SMS assessment tool on policy (right of screen) lets review the WHS policy Obviously the document is not signed so this would be an improvement item that we would have to attend to This review was not an onerous one but still a review. If you find an area of improvement then you could always use a more in depth tool to get a better understanding of the requirements and result in a better outcome
- All mines are required to maintain a ‘mine record’, which is simply a collection of important documents that are required to be kept together or as a minimum easily located in a timely manner. The mine record must be kept available for inspection for seven years and a summary should be easily accessible to workers. Note: In the WHS legislation there are other records that must be kept for longer periods ie Health Surveillance 30 years.