The document summarizes issues the presenter has observed with Electrical Engineering Control Plans (EECPs) at mines in NSW from 2016-2018. Many EECPs were developed by adapting older Electrical Engineering and Safety Management Plans (EESMPs) rather than starting with a new risk assessment. This can lead to EECPs that do not fully comply with legislation, apply the hierarchy of risk controls, or ensure risks are managed as far as reasonably practical. Standards are also limited and sometimes incorrect, so should not be solely relied upon. The presenter recommends EECPs undergo a new risk assessment process focused on the legislative requirements to develop improved electrical safety controls.

1. ‘THE CART BEFORE THE HORSE’ SYNDROME
- How legacy EEMSPs negatively impact EECPs at Mines -
Presenter: Bernard Gittins
Electrical Engineering Safety Seminar: 2018

2. ABOUT THE PRESENTER
A RETIRED INSPECTOR
OF ELECTRICAL
ENGINEERING AT
NSW MINES
With opinions which may or may
not represent the Department’s
position.

3. BACK TO BASICS !

4. BACKGROUND TO THIS PRESENTATION
EECPs assessed ranged in size:
from: a glossy published multi volumed document
to: a 4 page , double spaced, large font document
EECPs were variously written by:
- Mine Electrical Engineers
- Consultants who sometimes utilised a fairly generic plan across a number of sites
- Electrical contractors …. Who struggled somewhat
- To Quarry managers with no ‘formal’ electrical qualifications – (no polite description of quality available)
- last two examples come from a sample of small quarries
Consequently, the EECPs assessed ranged in quality:
from: plans solidly grounded in legislation with extensive risk based controls
to: “Really?”
But most EECPs were fairly good, although common ‘potential improvement areas’ were observed ….. Thus this
presentation.
Assessment of the EECPs at Metal Mines and large Quarries across NSW
2016-2018

5. SO WHAT DOSE A HIGH QUALITY EECP LOOK LIKE?
1. It complies with legislation
2. It identifies and controls the risk of the use of electricity at the mine utilising the HRC
& SFAIRP principles
3. It is accessible readily understandable for all the ‘stake holders’ – from Engineers
through to operators
Aside: EECP assessment interviews – electrician, welder & operator
• generally had a good understanding of electrical safety controls relevant to their work
• But also often were prepared to ignore those requirements
• Needs further investigation …. Human factors issues

6. SO WHAT DOES THE LEGISLATION SAY ABOUT EECPS ?
• WHS(MP)R Clause 26(5)(a)
The mine operator must:
‘prepare and implement an electrical engineering control plan for the mine or
petroleum site that sets out the means by which the operator will manage those risks in
accordance with clause 9’
This is where the ‘Back to basics ‘ principle come in ….
What is the risk? &
What are the controls?
Although when you start applying clause 9 of WHS(MP)R it becomes a little more
complex…

7. WHS(MP)R CLAUSE 9 (SUMMARISED)
1 Risks to be managed in accordance Part 3.1 of WHSR including:
• Duty to identify hazards
• Manage the risks
• Utilise Hierarch of Risk Control (HRC)
• Maintain the controls
• Review the control measures
2 Competent person to conduct the RA
3 Hazard, Likelihood, Severity
4 …. etc
5 …. etc
6 …. etc
7 RA record keeping
That is, it requires more than a basic BBRA.
Note:
The expression ‘So Far As Is Reasonably Practical’ (SFAIRP) does not appear
in Clause 9 but it does occur in the following Subdivision of the Regulation

8. IN THE OPINION OF THIS RETIRED INSPECTOR:
• EEMPs developed under the older legislations did not have the same rigor at the risk
assessment stage that is now becoming more common at mines.
• Indeed the older legislation even appeared to be less demanding:
‘A health and safety management system for an operation must provide:
• (a) the basis for the identification of hazards, and of the assessment of risks arising from
those hazards, by the operator of the operation, and
• (b) for the development of controls for those risks, and
• (c) for the reliable implementation of those controls.’
• The reality was that it was experience / mistakes & accidents which often provided the
impetus for the development of Safety Standards and Codes of Practice which in turn
formed the basis of many EEMPs at mines.
• Risk assessments were carried out, but the controls nominated largely consisted in
nominating a portion of standards
• The reality was, as an industry we were not developing effective risk assessments

9. ‘THE CART BEFORE THE HORSE’ SYNDROME
BBRA Standards Based EESMP
Inadequate EECP

10. THE LIMITATION OF UTILISING ENGINEERING
STANDARDS & COPS TO DEVELOP EESMPS
1. Do not necessarily apply the HRC
2. Do not necessarily apply SFAIRP
3. Sometimes just get it wrong
Note:
One Australian Standard that clearly applies systematic RA, the HRCs & SFAIRP principles
is the HV Standard AS2067:2016 ….
In my opinion, they got it right 

11. THE LIMITATION OF ENGINEERING STANDARDS
1. Do not necessarily apply the HRC
2. Do not necessarily apply SFAIRP
3. Sometimes just get it wrong

12. THE LIMITATIONS OF ENGINEERING STANDARDS & HRC
Example:
In many risk assessments touch voltage is identified as a hazard.
Installation to AS/NZS 3000 is identified as the control
• But what about elimination (eg IT earthing), substitution (eg use ELV
supply on field devices) Isolation (use a class II device)
• The reality is that AS/NZS 3000 does not utilise the HRC

13. THE LIMITATIONS OF ENGINEERING STANDARDS CNTD
Engineering standards:
1. Do not necessarily apply the HRC
2. Do not necessarily apply SFAIRP
3. Sometimes just get it wrong

14. THE LIMITATIONS OF ENGINEERING STANDARDS & SFAIRP
Most safety standards stop at ‘acceptable risk’ levels eg
• AS/NZS 3000
• Clause 5.7.2 touch voltages clearance times accepted ‘where it can
be shown that people are not exposed to touch voltages that exceed
safe values.’ …..
• Fig B4 ‘Normal Curve L’ indefinite contact time for touch voltage up to
50 V
• AS 60204.1 ‘Safety of Machinery’
• Clause 4.1 ’This will determine the acceptable level of risk …’
• AS 61508 ‘Functional Safety of electrical ….’
• Clause 3.1 Functional safety ‘is freedom from unacceptable risk…’
• ie Closer to ALARP solutions than SFAIRP solutions

15. THE LIMITATIONS OF ENGINEERING STANDARDS & SFAIRP CNTD
• AS/NZS 3010 ‘Electrical installations – Generating sets’ does not apply
SFAIRP in that it does not recommend / mandate the use of screened
leads or armoured cables in hostile environments
• well established practice at mines (EES014: Stand Alone Generators)
• the cost of their use is not ‘grossly disproportionate’
• In my time as an inspector I have investigated several electric shocks
incidents which could have been prevented by the use of such cables
• AS/NZS 3012 ‘Electrical Installations – Construction & demolition sites’
• The use of screened leads in hostile areas not required accept for
relocatable alternative supply systems (ACSs) -> SFAIRP

16. THE LIMITATION OF ENGINEERING STANDARDS CNTD
Engineering standards:
1. Do not necessarily apply the HRC
2. Do not necessarily apply SFAIRP
3. Sometimes just get it wrong (In my humble opinion)

17. STANDARDS SOMETIMES JUST GET IT WRONG
AS/NZS 3760:2010 ‘In-service safety inspection and testing of electrical equipment’&
AS/NZS 3017:2017 ‘Electrical Installations – Verification guideline’ re RCD testing
Both utilise the following testing criteria:

18. Fig 20 AS/NZS 60479.1 – Zones of Effect of a.c. currents
Type 2 RCD Compliant to AS/NZS 3190:2011
protecting the effect of a 230Vac shock voltage
Max Body currents

19. Fig 20 AS/NZS 60479.1 – Zones of Effect of a.c. currents
5% Chance
of fibrillation

20. 5% Chance
of fibrillation
Permitted ‘Pass Level’
of AS/NZS 3017 & 3760
Unnecessary
Risk
Fig 20 AS/NZS 60479.1 – Zones of Effect of a.c. currents
Possible trip speed a 30 mA Type 2 RCD compliant to AS/NZS 3190:2011
Unnecessary
Increased
Risk

21. ENGINEERING STANDARDS ARE NOT ‘HOLY WRIT’
SFAIRP -> 30-40 mSec test time based on extensive field experience

22. THEREFORE
EECPs based primarily on legacy EESMPs with a prepended BRA….
1. May not adequately address risk identification and subsequent control
as specified in Legislation
2. Do not necessarily apply the HRC
3. Do not necessarily apply SFAIRP
4. Sometimes just get it wrong
This is my opinion based on many EECP assessments.

23. BUT WAIT,
THERE’S MORE!
WHS(MPS)Regulation
Clause 32 ‘Electrical Safety’
…. like a ‘safety net’ fall back
position of a legislator who
does not trust the industry to
‘get it right’
A wise operator would map
their EECP against this
legislation.
‘Mr Demtel’ – Tim Shaw

24. OTHER COMMON ISSUES
• LV Rescue kits?
• ‘live work’?
• time to death
• other controls higher in the HRC
• Use of powered hand-tools
• sometimes still the default expectation
• still being used in wet areas
• Use of AC welders
• more dangerous than DC welders
• Use of Isolated Power Supplies often poorly managed
• Particularly with isolated Generator and UPS sources

25. RECAP
From my assessment of many EECPs I have formed the following
opinions:
If your EECP was developed from your previous EEMSP with a
prepended RA than:
• You may have not complied with all of the requirements of
Legislation; specifically re having a risk based control plan to
satisfy Clause 26(5)(a) of the Regulation.
• You may not have identified and controlled all of the risks of the
use of electricity at the mine SFAIRP
• You may not have fully utilised the HRC in your controls
• You are vulnerable to excessive dependence on Engineering
Standards which may apply lesser safety criteria than legislation
Further…
• Clause 32 gives a good summary of the main controls which are
to be addressed in the EECP
• Isolated Supplies in Generators and UPS’s are often missed in
EECPs

26. RECOMENDATIONS
Put the horse in front of the cart…. If it not already there.
ie at your next EECP review….
Start with a rigorous risk assessments to WHS(MP)R Clause
26(5)(a) to develop your electrical safety controls. The HRC
& SFAIRP principles must be applied to each control.
Utilise recognised standards and codes of practice to
facilitate the selection of controls but do not assume they will
fully satisfy the full legislative requirements of your EECP.
Map your EECP against WHS(MP)R Clause 32 … it is legislated
and a good cross check.
DONE WELL, THIS WILL PRODUCE A SUPERIOR EECP

27. QUESTIONS NOT ALLOWED