WHS Management System for VTI Group Mining and Minerals before acquiring coal fields in Western Australia and Queensland
VTI Group Mining and Minerals (VTIGMM) has implemented the Work Health and Safety Management System (WHSMS) to guarantee safety of workers and prevent health risks. This system is suitable in terms of the WHSMS’s inclusion of all required elements, such as WHSMS policy, responsible actors, WHSMS procedures, an emergency response plan, communication principles, training, contingency plans, and record management among others (Safe Work Australia 4). However, the system can be discussed as appropriate only if such aspects as improved safety standards and workplace conditions, improved recordkeeping, guaranteed legal compliance with reference to all VTIGMM locations, integration with the company’s management systems, and demonstrated commitment to WHS are observed.
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Relevant legislation to WHS includes acts, such as Work Health and Safety Act 2011 (WHS Act), which was enacted by the Commonwealth, and adapted state and territory acts (Occupational Health and Safety Act 2004 for Victoria), regulations (Work Health and Safety Regulations 2017 for the Commonwealth and Occupational Health and Safety Regulations 2017 for Victoria), Australian Standards, codes of practice and guidelines. Acts are law statements that provide an overview of how to maintain health and safety in the workplace. Regulations are laws that provide detailed standards to meet in order to comply with acts. Australian Standards represent specific national requirements regarding work health and safety management (Australian Government 12). Codes of practice and guidelines provide practical advice on how to meet laws, standards, and requirements, and they are specific depending on industry.
Changes in WHS Policy and Procedures
After analyzing VTIGMM’s WHS policy and procedures, it is possible to suggest four improvements to the system. Firstly, it is necessary to guarantee that WHS policy complies with WHS legislation across jurisdictions and locations where VTIGMM operates. Secondly, WHS procedures should reflect improving working conditions for workers to make the workplace safe in terms of addressing manual lifting of coal blocks and handling hazardous materials. Thirdly, systematic WHS recordkeeping should be implemented to guarantee integration of VTIGMM’s management systems. Lastly, WHS policy should be improved to demonstrate the company’s commitment through changing action plan records.
Individuals Responsible for WHS
At VTIGMM, individuals responsible for implementing the WHSMS are supervisors and managers, including a WHS officer, who are members of a health and safety committee, as well as workers. The WHS officer and WHS managers at VTIGMM are responsible for providing a safe workplace and working systems, guaranteeing safety of facilities, and providing training and guidance on health and safety in the workplace. Primarily, the WHS officer and supervisors at different facilities are responsible for implementing the WHSMS, controlling its work, ensuring following standards and requirements, maintaining documentation, identifying risks, realizing hazard control activities, reviewing and assessing the WHSMS (Clayton Utz 5-6). In their turn, workers are responsible for complying with safety guidelines and reporting hazards and accidents.
Human and Financial Resources for WHS
Human resources required for implementing a WHSMS include specialists in health and safety management. An organization should appoint a WHS officer to guarantee the implementation of the system and its compliance with WHSMS requirements, assessment of the system’s effectiveness and reporting, and improvement of the WHS. More WHS specialists (supervisors and managers) can be required to work at different locations to control the WHSMS there (“Occupational Health and Safety Act”). Required financial resources are determined with reference to analyzing what equipment is necessary to guarantee safety of employees according to the organization’s policy and emergency plan, including firefighting equipment, for instance.
The Person Conducting a Business or Undertaking (PCBU) is a mining operator (VTIGMM), which is responsible for approving human and financial resources. Specifically, the organization’s Chief Executive Officer, Chief Operating Officer, Chief Financial Officer, Field Manager, and Human Resource Manager participate in selecting and approving the discussed resources. When a WHS officer is appointed, this person participates in selecting and approving other resources required for the WHSMS (Australian Government 212).
WHS Legislation in Western Australia and Queensland in Contrast to Victoria
In Victoria, safety in the mining industry is maintained according to Occupational Health and Safety Act 2004 that applies the majority of the principles presented in the WHS Act. Additional regulations include Occupational Health and Safety Regulations 2007 (Victoria), Dangerous Goods (Explosives) Regulations 2011 (Victoria), and Equipment (Public Safety) Regulations 2007 (Victoria). In Queensland and Western Australia, the mining industry is regulated by specific WHS laws in mining. In Queensland, WHS is regulated according to Work Health and Safety Regulation 2011 (Queensland), Electrical Safety Regulation 2002, Petroleum and Gas (Production and Safety) Act 2004, Mining and Quarrying Safety and Health Regulation 2001, and Explosives Regulation 2003. In Western Australia, similar laws and regulations include Occupational Safety and Health Regulations 1996 (Western Australia), Mines Safety and Inspection Act 1994, and Dangerous Goods Safety (General) Regulations 2007 (Clayton Utz 49-55). Differences are associated with acceptable levels of risk for these three jurisdictions, due diligence of WHS officers, and consultation with employees.
Amendments to WHS Policies and Procedures
To expand operations to Queensland and Western Australia, it is important to adapt the used WHS policies and procedures in accordance with WHS state legislation. Queensland has passed the WHS Act, and the following amendments to the WHS policies and procedures should be done for this area: a) duties should not be transferrable; b) the role of due diligence in WHS officers is accentuated; c) duties of other individuals in the workplace are clearly stated (take care of their health, safety, and actions); d) the nature of consultation should be revised; e) application of the WHS legislation regarding emergency plans is expected (Minister for Education and Industrial Relations 8). Western Australia has not passed the WHS Act, and its regulations are similar to Victoria’s ones, thus, no specific amendments are required (Government of Western Australia).
Meeting Legislative Requirements
The amended WHS management system proposed to be used in Queensland and Western Australia in addition to Victoria will have specific elements to meet legislative requirements in all territories. Thus, there will be changes in describing duties and responsibilities of WHS officers: duties should not be transferrable and the role of due diligence in WHS officers is changed. Furthermore, duties of other individuals, including employees, will be rephrased, and they will take care for their health, safety, and actions. The nature of consultation will be revised to include the focus on providing advice and involving specialists in consultation. Formulation of statements regarding training, reporting, and emergency plans will also be improved.
Ensuring Effectiveness of the WHSMS
To ensure the WHSMS meets legislative requirements, it is necessary to communicate the WHSMS’s principles to employees, conduct required training, and improve reporting and recording procedures in all areas in order to ensure an effective reviewing and monitoring process. Workers need to understand their role in implementing the WHSMS and related outcomes. Recording management is associated with effective monitoring and measurement of the WHSMS in terms of its compliance with WHS legislation across jurisdictions and consistent application of its principles according to the organization’s objectives (Australian Government). Thus, the focus will be on improving recording and assessment procedures across jurisdictions and locations.
WHS Management System for VTI Group Mining and Minerals after acquiring coal fields in Western Australia and Queensland
Hazard Management Procedure for Western Australia and Queensland
The hazard management procedure for operations in Western Australia and Queensland should be based on Work Health and Safety Regulation 2011 for Queensland and Occupational Safety and Health Regulations 1996 for Western Australia (Minister for Education and Industrial Relations 12). The procedure should include the following steps:
- Identifying hazards (principal mining hazards and other risks).
- Assessing risks.
- Assessment of risks.
- Development of risk management plans.
- Controlling risks.
- Development of an emergency plan.
- Communication with workers.
- Reviewing risk controls.
Risk Management Process for Western Australia and Queensland
The risk management process is also based on specific guidelines for Western Australia and Queensland:
- Identification of hazards (finding out hazards in the workplace that can cause harm, including principal mining hazards (e.g., ground instability) and other ones (e.g., electricity)).
- Reviews of data.
- Assessment of risks (evaluating the seriousness of the harm, the potential for happening, and the effectiveness of prevention measures).
- Control of risks (implementing efficient control measures according to the hierarchy of risk control).
- Selecting control measures.
- Implementing control measures.
- Reviews of control measures (guaranteeing control measures work effectively).
- Keeping records.
- Reviewing control measures regarding the necessity of improvements.
Hierarchy of Control
The hierarchy of risk controls includes several stages to be applied at the planning, designing, and evaluation stages of the project implementation. At the highest level, hazards are eliminated to ensure all possible risks cannot be observed in the workplace. At the lower level, hazards are substituted with other safer activities and procedures. At this stage, it is also possible to isolate hazards with the help of remote controlling, for example. Furthermore, at this level, officers use engineering control options (e.g., interlocks) (Safe Work Australia 5-7). At the lowest level, administrative control options and training are utilized along with promoting the use of personal protective equipment to address risks.
It is important to ensure that new hazards cannot be created from the proposed changes. Thus, it is necessary to refer to hazard identification by WHS officers and workers at such stages of the change implementation process as planning, design, and evaluation. In this case, changes are associated with work policies and practices, and it is important to train employees to recognize different types of hazards at each stage of this change implementation process to ensure employees’ safety.
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Selecting and Implementing Risk Controls
The process of selecting and applying risk control measures should be based on the hierarchy of control and associated WHS legislation (Australian Government 28). The following components of the procedure are required:
- Communication and consultation with the staff (human resources).
- Allocating responsibility.
- Preparing a working plan.
- Timeline and schedule.
- Involved human resources.
- Preparing a risk control plan.
- Identifying hazards.
- Assessing hazards and risks.
- Selecting risk management strategies.
- Eliminate hazards.
- Substitute hazards.
- Isolate hazards.
- Engineering controls.
- Administrate actions.
- Personal protective equipment.
- Identifying needed resources.
- Recording controlling procedures.
- Recording timelines.
- Monitoring the implementation of a plan.
The WHS legislative requirements that support the proposed plan are the WHS Act 2011, Occupational Safety and Health Regulations 1996, and Work Health and Safety Regulations 2017.
Inadequacies in the proposed risk control methods applied in Victoria include the lack of focus on identifying and addressing the risks associated with manual lifting of coal bulk blocks, lifting blocks to a conveyer belt, and handling potentially hazardous materials by the staff, including crane and truck drivers. These risks are not reflected in the risk assessment material for principal mining hazards in spite of their high-frequency level. As a result, it is necessary to add these types of risks to the risk assessment material in order to guarantee they are addressed because of being reported by managers.
Resources to Mitigate Loop Holes
In order to mitigate these risks in Western Australia and Queensland, it is important to use human and financial resources. These risks need to be included in the list of principal mining hazards to be effectively assessed and reported. Manual handling procedures should be controlled. WHS supervisors need to provide training for the employees to prevent manual lifting of coal bulk blocks and inappropriate handling hazardous materials by drivers and other staff. Additional equipment should be provided to support manual handling and lifting procedures.
Requirements for expert advice related to the WHSMS at VTIGMM are associated with the necessity of receiving more information about ground instability risks, inrush and inundation risks, winding operations and related hazards, risks associated with using vehicles, risks related to airborne contaminants, and risks associated with fire, explosion, gas outbursts, and radiation. Expert advice is required to organize planning, design, construction activities, and operations (Minister for Education and Industrial Relations 18). The assistance of experts is required to use the most appropriate risk control measures in the listed cases.
Assessment Task 3
WHS Induction and Training Program
The training program for all VTIGMM’s employees should include the following elements:
- Explanation of duties.
- Discussion of hazards, working conditions, and environments.
- Working instructions and requirements.
- WHS principles and risk control measures.
- Emergency response rules.
- Additional and specific training.
- Hazards in mining (coal blocks, manual handling, and lifting).
- Risk control measures.
- Emergency plans.
- Safety awareness and reporting training for supervisors.
- Competence testing.
- Reviewing training.
- Training records.
Methods for WHS Recordkeeping
VTIGMM lacks the effective recordkeeping procedure to identify all possible injuries and diseases. Methods for recordkeeping should be the following ones:
- Supervisors, operators, and employees participate in identifying hazards.
- Hazard checklists and assessment tools are used and stored for several years.
- Supervisors and WHS officers make mine records to document identified risks, used measures, timelines, and outcomes.
- Supervisors document reviewing and assessment procedures.
- All possible incidents and notices of incidents should be recorded.
- High potential incidents should be recorded.
- Training records should be stored.
- WHS decisions and reasons should be recorded.
Methods to Evaluate the WHSMS
In order to measure or evaluate the developed WHSMS, it is necessary to assess whether used risk control measures are efficient to address hazards, whether objectives associated with the WHS policy are met, whether the consistent application of the system is observed, and whether compliance with WHS legal requirements in all jurisdictions is observed. In addition, the WHSMS should be evaluated against VTIGMM’s quality standards. Additional quality standards that should be used to assess the WHSMS are ISO 9001:2008 Quality Management Systems – Requirements, AS/NZS 4801:2001 Occupational Health and Safety Management Systems, and AS/NZS ISO 31000:2009 Risk Management – Principles and Guidelines (Clayton Utz 50-55).
Three specific improvements can be recommended to be implemented into the WHSMS to achieve VTIGMM’s objectives. Firstly, risks associated with manual handling and lifting coal bulk blocks and handling hazardous materials should be reflected in the risk assessment tools, control regarding these procedures should be documented, and additional training should be provided. These changes are necessary for improving working conditions for workers. Secondly, systematic WHS recordkeeping should be implemented according to the previously described methods. Thirdly, new action plan records should be implemented to include areas for improvement, required actions, expected outcomes, responsible persons, resources, and timelines.
Compliance with WHS Legislation
To ensure compliance with WHS legislation across jurisdictions, it is necessary to complete the following steps:
- Determine WHS legislative requirements across jurisdictions that need to be followed.
- Assess observed procedures in terms of following WHS legislative requirements.
- Identify gaps in following WHS legislation.
- Prepare assessment reports.
- Determine corrective actions and recommendations.
- Monitor changes and progress.
- Conduct follow-up assessments.
Australian Government. Work Health and Safety Act 2011. 2011, Web.
Clayton Utz. Work Health and Safety in Australia: A Harmonised Approach. 2015, Web.
Government of Western Australia. “Guidelines for the Development of Industry Codes of Practice for Approval under the Occupational Safety and Health Act 1984.” Commerce WA Government, 2017, Web.
Minister for Education and Industrial Relations. How to Manage Work Health and Safety Risks: Code of Practice 2011, Queensland. 2011, Web.
“Occupational Health and Safety Act and Regulations.” WorkSafe Victoria, Web.
Safe Work Australia. Guide to the Model Work Health and Safety Act. 2016, Web.