Emergency preparedness at a small operation is a different problem to emergency preparedness at a large one, and QGN 15 is the Queensland guidance note that recognises that. It is written for small mines and quarries: the operations without a standing rescue team, a full time emergency coordinator or a helipad, where the first ten minutes are handled by whoever is on site.

It is also the clearest emergency preparedness checklist the inspectorate publishes, which makes it worth reading regardless of how large your operation is. This guide covers what it asks for and where preparedness usually breaks down.

The problem QGN 15 addresses

Large operations have depth. Someone is trained, someone is rostered, the equipment is checked by a person whose job that is, and the emergency response plan is exercised because there is a function that owns exercising it.

A small operation has none of that structure and exactly the same hazards. The pit is still deep, the plant still has stored energy, the roads are still shared with heavy vehicles, and the nearest ambulance is still an hour away and does not know where the site entrance is. The consequence of an event is often worse at a small operation, not better, because the response depends entirely on the people who are already there.

QGN 15 responds to that by being concrete. It is a list of things that need to exist, be current, and be findable.

What the guidance note covers

The structure runs through purpose and scope, legislative obligations and risk management, and then a substantial section on emergency preparedness itself covering:

• The emergency response plan itself.
• Mine information. The details an external responder needs and does not have.
• Plans and drawings. Current site plans usable by someone who has never been here.
• Risk management. The credible emergency scenarios this operation actually faces.
• Emergency equipment and facilities.
• First aid supplies, with an example kit contents list in the appendices.
• Training.
• Incident control. Who runs the response.
• Communication.
• Contact lists.
• Securing the site.
• Additional procedures.
• Records.

An appendix covers the Emergency Management Queensland rescue helicopter, which is the item most likely to be skimmed and most likely to matter. A remote operation that has not worked out where a helicopter can land, and how to describe that location to someone flying towards it, has a gap it will discover at the worst possible time.

Mine information and plans, for people who do not know the site

Two of the sections deal with what external responders need, and this is where preparedness most often fails in a way nobody notices during an exercise.

The people who arrive have never been on your site. They need the physical address that a navigation system will find, which is frequently not the postal address. They need the gate, and whether it is locked. They need to know the site is a mine, what is stored on it, and what could hurt them. They need a plan they can read at speed, in poor light, showing access roads, the muster point, the location of the emergency equipment and where the incident is.

A site plan drawn for mining purposes is usually the wrong document for this. It shows what a mining engineer needs and omits what a paramedic needs. Preparing a second, simpler plan aimed at responders is a small piece of work with a disproportionate payoff.

And it has to be current. Access changes constantly on an operating site. A road closed by a dozer this week is a dead end for an ambulance.

Incident control at small scale

Incident control is about who is running the response, and the small site version is harder rather than easier. The named coordinator may be on leave, off site, or be the person involved in the incident.

The workable answer is a role that is always filled rather than a person who is usually available: whoever is the senior person on site holds incident control until relieved, with the succession defined in advance. Everyone needs to know how control is claimed and handed over, because the failure mode at small operations is not the wrong decision, it is three people each assuming another person is coordinating.

The same logic applies to accounting for people. A site of twelve people is easy to account for right up until visitors, contractors and a delivery driver are on site and nobody has a list.

Contact lists, communication and securing the site

Contact lists get their own section because they decay faster than any other part of an emergency plan. People change roles, numbers change, contractors change. A list reviewed annually is on average six months out of date at the moment it is needed.

Communication is the other reliable weak point, particularly in a pit. Mobile coverage that works at the office is not coverage at the bottom of a cut, and radio channels that work between operators may not reach an office that has closed for the day. The test is not whether communication exists, it is whether a person alone at the far end of the site at 5pm can raise someone.

Securing the site is the section people forget entirely. After a serious incident the scene may not be disturbed except to make it safe or to help an injured person, and there are notification obligations that run in parallel. Getting that wrong in the confusion is common and consequential. The reporting duties are covered in high potential incident reporting in Queensland and, on the WA side, in notifiable and reportable incidents at WA mines.

Records

QGN 15 finishes on records, and the reason is not administrative. Three record sets decide whether preparedness is real.

• Equipment checks. Extinguishers, first aid kits, eyewash, stretchers, defibrillators and spill kits, each with a date and a person. Emergency equipment that has never been checked is decoration.
• Training and exercise records. Who is trained in what, when it expires, and what the last exercise found. An exercise that generates no findings was not a test.
• The response record itself. What happened, when, what was decided and by whom, which becomes the basis of the investigation and the notification.

Where sites come unstuck

• The plan is written for the auditor. Comprehensive, unusable in an emergency, and never opened by anyone in a hurry.
• It has never been exercised. Small operations skip exercises because everyone is busy, and an unexercised plan is a document rather than a capability.
• Access information is stale. Gate codes, road closures and muster points that changed and were never updated.
• Equipment checks are not recorded. Someone checks the first aid kit occasionally and there is no way to know when.
• Contractors and visitors are outside the plan. Not on the muster list, not inducted into what to do, and present on site.
• One person holds it all. The person who knows how everything works is the single point of failure, and emergencies do not wait for them to be rostered on.

Keeping preparedness current instead of documented

Emergency preparedness is almost entirely a currency problem. Every element decays: contacts, access, equipment, training, plans. The document does not decay, which is precisely why relying on the document is dangerous.

HazView helps with the parts that live on the ground. Emergency equipment is registered where it physically is, so an extinguisher or first aid station has a location and its own inspection history rather than a line on a list. Checks are scheduled and assigned, and overdue ones are visible instead of being found during an audit. Muster points, access routes and current closures sit on the same map everyone already uses for hazards, so the emergency picture is the live picture rather than a plan printed last year.

Because it runs on a phone or tablet and works offline, a person at the far end of the site can record what they are looking at, with photographs and a position, and that record exists whether or not there is coverage at the time. Offline capability on a remote site is covered in offline hazard mapping when reception fails.

The REST API keeps the perishable data honest. Contact lists, personnel and contractor records usually live in systems that are already maintained, and pulling from those beats retyping a list that then quietly ages. Records can go back out to corporate systems the same way.

None of this responds to an emergency. People do that, and the plan and the training are what make them effective. What a system can do is make sure the equipment was checked, the plan reflects today’s site, and the record of what happened exists afterwards.

See how HazView works for everyone on site, or book a demo.

Frequently asked questions

What is QGN 15?

The Queensland guidance note on emergency preparedness for small mines and quarries. It covers the emergency response plan, mine information, plans and drawings, risk management, equipment and facilities, first aid, training, incident control, communication, contact lists, securing the site, additional procedures and records. It is guidance, not law.

Does a small quarry need an emergency response plan?

Yes. The obligation to manage risk does not scale down with the size of the operation, and the consequence of an event is often worse at a small site because the response depends on the people already there.

How often should the plan be exercised?

Frequently enough that people can act without reading it, and often enough to catch decay in contacts, access and equipment. A short, focused exercise on one scenario several times a year is more useful than one full scale exercise that is postponed.

What do emergency services need from us?

A findable address and gate, knowledge that the site is a mine and what is stored on it, a simple current plan showing access, muster point and equipment, someone to meet them, and for remote sites a known helicopter landing area they can be directed to.

Who runs the response at a small site?

Define it as a role rather than a person. The senior person on site holds incident control until relieved, with succession set out in advance, so control is never waiting on someone who is off site or involved in the incident.

Can we disturb the scene after a serious incident?

Only so far as is needed to make the situation safe or to help an injured person. Beyond that the site is to be secured, and notification obligations run in parallel. Deciding this in the moment is how it gets wrong, so it belongs in the plan.

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A safety and health management system that exists is not the same as one that works. QGN 09, the Queensland guidance note on reviewing the effectiveness of the SHMS, is built around that distinction. It covers obligations, acceptable level of risk, workforce involvement, lead and lag indicators, causal analysis, audit findings, contractor performance, and the chronic exposures that never appear in an incident statistic.

This guide covers what an effectiveness review actually has to establish, why the usual metrics answer the wrong question, and how the review connects to the management structure that RS22 requires.

The question the review has to answer

The obligation under the Queensland legislation is to achieve an acceptable level of risk. QGN 09 breaks that into its two established components.

• Risk within acceptable limits. The residual risk sits below the threshold the operation has defined as tolerable.
• Risk as low as reasonably achievable. Beyond being tolerable, everything reasonably practicable has been done.

Both must hold. A site sitting comfortably inside its tolerability threshold while declining a control it could reasonably implement has not met the obligation, and this is the reasoning set out at length in acceptable level of risk and what you can prove.

The effectiveness review is therefore not asking whether the system is documented, audited and current. It is asking whether the risk at this mine is actually being held at an acceptable level by the system as it operates, which is a much harder question and one that document review cannot answer.

Lead and lag indicators, and why lag alone misleads

QGN 09 treats system performance through both lead and lag indicators. The distinction is well known and routinely applied badly.

Lag indicators count what has already happened: injuries, high potential incidents, property damage. They are objective, comparable, and describe a period that is over. Their fatal weakness in a mining context is statistical. Serious events are rare enough that a year without one is entirely compatible with a system that is failing, and everyone knows a site that ran a record year immediately before a fatality.

Lead indicators measure whether the things that prevent events are actually happening: inspections completed on time, critical control verifications performed and passed, actions closed within their due dates, hazards reported and resolved, training current.

The failure mode of lead indicators is different and just as damaging. They are easy to satisfy without effect. A hundred per cent inspection completion rate where the inspections are cursory measures compliance with a schedule, not control effectiveness. The useful lead indicators are the ones that can return bad news: the proportion of critical control verifications that found a defect, the age profile of open actions, the ratio of hazards found by supervisors to those found during audits.

A review that reports only green lead indicators and a clean lag record has usually measured its own reporting rather than its system.

Causal analysis and repairing defences

QGN 09 addresses causal analysis in terms of repairing defences, which is a deliberate framing. When something goes wrong, the question is which defences did not hold and why, not who did the wrong thing.

The practical test of whether a site does this properly is what its corrective actions look like. If the actions arising from investigations are overwhelmingly retraining, toolbox talks and procedure amendments, the site is repairing people rather than defences. Those actions are cheap, fast to close, and almost never change the outcome, which is why the same event recurs with a different name attached.

An effectiveness review should look across a year of investigations at the distribution of control types in the corrective actions. That single view tells you more about the health of the system than any incident rate, and the underlying pattern is explored in why critical controls fail.

Audit and inspection findings as data

Audits and inspections produce findings, findings become actions, and actions get closed. Most sites manage that pipeline adequately and stop there.

The effectiveness question is different. Are the same findings recurring? Are they recurring in the same areas, or under the same supervisors, or in the same part of the system? Is the same non conformance being closed repeatedly, which means the closure is not working? Are findings from external audits materially different from the ones the site generates itself, which means internal assurance is not looking where it should?

Answering those questions requires findings to be structured and located rather than held in a stack of reports. A site that can only read its audit history one document at a time cannot see repetition, and repetition is the signal.

Contractors, and the boundary that is not a boundary

QGN 09 deals with contractor safety performance as part of system effectiveness, not as a separate reporting line. On most open cut operations contractors perform a significant share of the highest risk work: drill and blast, earthworks, maintenance shutdowns, electrical work.

A review that assesses only the operator’s own workforce is assessing a minority of the exposure. Worse, contractor performance data that arrives in a different format, on a different cycle, and is reported separately, cannot be combined with site data to see anything. The principle of one system rather than three is covered in contractor management under one system.

Chronic exposures

QGN 09 explicitly addresses chronic exposures causing incapacity, and this is where most effectiveness reviews are weakest.

Dust, noise, diesel particulate, whole body vibration and hazardous chemicals injure people on a timescale of years to decades. They produce no incident, no investigation and no lag indicator until long after the exposure that caused them. A system judged on incident performance will rate itself highly while accumulating a liability that surfaces after the people involved have left the industry.

Reviewing effectiveness for chronic exposure means looking at exposure monitoring results and trends, at control verification for engineering controls, and at whether monitoring results actually change anything. The dust side of that is covered in RS20 and dust control in surface coal mines.

Workforce involvement

The guidance note treats workforce involvement as part of effectiveness, and there is a diagnostic hidden in it. If hazard reports are declining, that is either a safer site or a workforce that has stopped reporting. Those two look identical in the data and have opposite meanings.

The way to tell them apart is to look at what happens after a report. Time to first response, proportion actioned, and whether the person who reported it ever finds out what happened. Reporting dies where it produces no visible result, and once it dies the system loses its most sensitive early indicator.

Where sites come unstuck

• The review audits compliance instead of effectiveness. Every document current, every audit closed, and no evidence about whether risk is actually controlled.
• Lead indicators that cannot fail. Metrics measuring whether activity occurred rather than what it found.
• The review is annual and disconnected. A once yearly exercise producing a report nobody uses, rather than a continuous reading of the system.
• Actions are counted, not weighted. Ninety closed toolbox talks outrank one unclosed engineering control in the completion statistics.
• Contractors excluded. The majority of high risk work assessed separately or not at all.
• Chronic exposure ignored because nothing has happened yet, which is exactly what chronic means.

Getting data that can answer the question

Almost every failure above is a data structure problem wearing a safety costume. The questions QGN 09 asks are comparative and longitudinal: is this recurring, is it getting worse, where is it concentrated, what changed after we acted. Those questions cannot be answered from documents, only from records that are structured, located and durable.

HazView produces that shape of data as a by product of the work. Hazards, inspections, controls and actions are recorded against the place and the asset they concern, with the person, the time and photographs attached, and kept permanently. That makes the review questions answerable directly: which controls fail verification most often, where do findings repeat, how long do actions actually take to close, whether hazard reporting is holding up in a given crew or quietly stopping.

Effectiveness review also needs data the platform does not hold: exposure monitoring, health surveillance, contractor performance from a contractor’s own system, corporate incident data. The REST API is how those get into the same view rather than into a separate slide. Feeding data in and out, so the analysis happens on one dataset instead of on four exports reconciled by hand, is the whole difference between a review that finds something and a review that reports something.

The judgement stays with people. Deciding whether risk is at an acceptable level is the site senior executive’s call and not a calculation. What better data changes is whether that judgement is made on evidence or on impression.

See how HazView works for managers and SSEs, or book a demo.

Frequently asked questions

What is QGN 09?

The Queensland guidance note on reviewing the effectiveness of the safety and health management system. It is guidance rather than law, and compliance with it is not by itself sufficient to comply with the legislation.

How often should an SHMS be reviewed?

Formal review on a defined cycle, plus review triggered by change: new plans, significant incidents, restructures, new fleets or major contractor engagements. An annual review with no trigger based reviews will always be looking at a system that has since moved.

What is the difference between a lead and a lag indicator?

Lag indicators count outcomes that have already occurred. Lead indicators measure whether the activities that prevent those outcomes are happening. Both are needed, and lead indicators are only useful if they are capable of returning bad news.

Does a clean incident record mean the system is effective?

No. Serious events are statistically rare, so a period without one is entirely consistent with a failing system. It is evidence of an outcome, not evidence of control.

Should contractors be included in the review?

Yes. QGN 09 treats contractor safety performance as part of system effectiveness, and on most open cut operations contractors perform a large share of the highest risk work. Excluding them assesses a minority of the exposure.

How does this relate to RS22?

RS22 asks whether the management structure for developing and implementing the system is defined and competent. QGN 09 asks whether the system that structure runs is actually working. They are the two halves of the same question and are best reviewed together.

The post Reviewing the Effectiveness of Your Safety and Health Management System appeared first on HazView®.

Recognised Standard 10 governs mine surveying and drafting at Queensland coal mines. It is to be followed by all mine surveyors and used for the control of surveying and mapping on site. Its centre of gravity is the Mine Workings Plan, a statutory document required under section 67 of the Coal Mining Safety and Health Act 1999, kept at the mine with a copy supplied to the Chief Inspector annually.

Most people on an open cut never open RS10, and most people on an open cut rely on its outputs every day. This guide covers what the standard requires of survey control and plan accuracy, the rule about old workings that everyone should know, and why the accuracy of a plan is a safety obligation rather than a technical preference.

The Mine Workings Plan

The Mine Workings Plan shows accurately the position of the mine workings. It has a specific legal life of its own.

• It is required to be kept at the mine, with a copy supplied to the Chief Inspector annually under section 67 of the Act.
• It must be prepared by or under the supervision of the mine surveyor.
• It must be prepared within three months of the opening of the mine, or such other time as the Chief Inspector directs in writing.
• It is produced in digital form and in hard copy for presentation.

The mine surveyor is a registered surveyor with the Surveyors Board of Queensland. This is a statutory appointment with personal professional standing behind it, and RS10 addresses the liability of the mine surveyor directly.

Survey control, and why the datum matters

All mine surveys and plans originate from the mine control network. The Mine Workings Plan is referenced to the Map Grid of Australia 1994, based on Geocentric Datum of Australia 1994 values, and the relationship between the mine grid system and GDA94 has to be shown on the plan itself. A datum station is established near the mine for mine surveys, referenced to GDA94 and to the Australian Height Datum.

Connection of the mine control network to the state grid should be to Class B standards of accuracy as defined in ICSM SP1. Levelling on the mine site is propagated from a benchmark assigned an AHD reduced level, surveyed to Class LD spirit levelling or Class B by trigonometric methods.

The reason this matters beyond the survey office is that everything else on the mine inherits it. Pit designs, dump designs, road alignments, geotechnical monitoring positions, tenement boundaries and every hazard anyone drops on a map are positioned relative to that control. A mine grid that is not properly related to GDA94, or a site where two grids are quietly in use, produces the kind of error that is invisible until two datasets are overlaid and disagree by metres.

Old workings: assume water until proven otherwise

RS10 contains a rule that deserves to be more widely known than it is. All mine plans used in compiling the Mine Workings Plan should be regarded with suspicion until their accuracy has been verified, and every effort should be made to obtain all existing information about the extent and location of old workings.

Then the operative part: where old workings exist that may constitute a danger, it shall be assumed, for the purpose of marking the Mine Workings Plan, that the workings contain water or fill, until the contrary is proven.

That is a default assumption of the worst credible case, written into a surveying standard. It exists because historical workings have killed people through inrush, and because the plans that describe them were drawn to standards nobody can now audit. Anyone planning to mine near old workings should treat that clause as the starting position, and the inrush thinking that follows from it is covered in water management, dewatering and inrush.

When accuracy is not practical

RS10 acknowledges that a plan cannot always show everything to the required accuracy, and it handles that honestly rather than pretending otherwise.

If it is not practical for a Mine Workings Plan to show accurately the details required under the Act, the site senior executive must ensure the parts of the plan containing detail whose accuracy is not practical are clearly marked. In addition, the SSE must ensure the information on the plan is sufficiently accurate to achieve an acceptable level of risk for operations at the mine.

Two things are notable. The obligation lands on the site senior executive, not only on the surveyor, which makes plan accuracy a safety management question rather than a technical one. And the test is the same test that runs through the whole Act: sufficient accuracy to achieve an acceptable level of risk. A plan can be imprecise, provided the imprecision is marked and the risk that flows from it is acceptable and understood.

An unmarked area of uncertainty is the dangerous case, because it looks exactly like a surveyed one.

Symbols, layers and the other plans

RS10 specifies symbols and sign conventions, referencing the Australian Standards for mine plan preparation and symbols and for the graphic representation of coal seams and associated strata. It also sets out themes and layers separately for open cut and underground mines, and covers additional plans, endorsement, certification and certification history, old workings and surveys, closing plans, and the cessation of the mine surveyor’s duties.

The standardisation is not bureaucratic tidiness. Mine plans outlive the people who drew them and are read by people who did not draw them, sometimes decades later and often in an emergency. A consistent symbol set is what makes that possible, and it is the same reason the old workings clause exists.

Where sites come unstuck

• Two grids in circulation. A legacy mine grid and a GDA94 dataset both in use, with no documented relationship, and nobody sure which one a given file is in.
• Areas of uncertainty not marked. The plan draws a confident line where the underlying data was a scanned drawing from 1974.
• Old workings treated as empty because nothing is drawn. The absence of information is not evidence of absence, and the standard says to assume water or fill.
• Operational data drifting off the survey control. Hazards, inspections and geotechnical observations captured on devices with consumer grade positioning, then compared to survey data as if the two were equivalent.
• The annual submission handled as a compliance task. The plan goes to the Chief Inspector and the same currency is not maintained for the plans people actually use in the pit.
• Plan currency assumed. The digital plan is authoritative, it was updated last quarter, and three benches have moved since.

Keeping the operational picture on the same ground as the survey

RS10 governs the survey record. The gap it does not address, because it is not its job, is the distance between the surveyed plan and the day to day operational picture: where the hazards are, which berm was inspected, where the crack in the highwall was last month, which road section is closed today.

HazView sits in that gap. Survey and design data comes in as map layers, so the operational record is drawn on the same ground as the survey rather than on a sketch. Hazards, inspections and geotechnical observations are located against that base and keep their position, their photographs, their time and the person who recorded them, permanently. A crack recorded in March can be found again in September and compared, because it has coordinates rather than a description.

Layers are refreshed as the mine moves, and the REST API means that happens from the systems the survey team already runs instead of by manual export and import. It also means the operational observations can be pushed back out to the geotechnical and planning systems that want them. The point is that the survey office and the pit end up looking at one picture, with one datum, rather than reconciling two.

None of that is surveying. The Mine Workings Plan remains the mine surveyor’s statutory document, prepared to RS10, and no operational system substitutes for it.

See how HazView works for geotechnical engineers, or book a demo.

Frequently asked questions

Who can be a mine surveyor in Queensland?

A registered surveyor with the Surveyors Board of Queensland. It is a statutory appointment, and RS10 addresses the mine surveyor’s liability directly.

How often must the Mine Workings Plan be submitted?

A copy is supplied to the Chief Inspector annually under section 67 of the Coal Mining Safety and Health Act 1999. The plan itself is kept at the mine, and must be prepared within three months of the mine opening or as the Chief Inspector otherwise directs.

What datum do Queensland mine plans use?

The Mine Workings Plan is referenced to MGA94, based on GDA94 values, with the relationship between the mine grid and GDA94 shown on the plan. Heights come from a datum station referenced to GDA94 and the Australian Height Datum.

What does RS10 say about old workings?

Existing plans should be regarded with suspicion until verified, every effort should be made to obtain information about the extent and location of old workings, and where old workings may constitute a danger it is to be assumed for plan marking purposes that they contain water or fill until the contrary is proven.

What if part of the plan cannot be accurate?

The site senior executive must ensure those parts are clearly marked, and must ensure the plan is still sufficiently accurate to achieve an acceptable level of risk for operations at the mine. Marking the uncertainty is the requirement. Hiding it is the failure.

Does RS10 apply to open cut mines?

Yes. It sets out themes and layers separately for open cut and underground operations, and the Mine Workings Plan obligation applies either way.

The post RS10: Mine Surveying and Drafting appeared first on HazView®.

Recognised Standard 11 covers training in coal mines. It applies to surface and underground operations alike, on the basis that while the training materials differ, the system and process requirements do not. It runs from induction through to how you prove, years later, that a person was competent when it mattered.

This guide covers what RS11 requires across induction, training needs, assessment and refresher training, and spends most of its time on record keeping, because that is the part sites underestimate and the part auditors go to first.

Induction, and what it is not

Induction establishes the baseline: the hazards of this site, the safety and health management system, the emergency arrangements, and how work is authorised here. It is a starting point and not a competency.

The failure that follows from treating induction as sufficient is familiar. A contractor is inducted, receives a card, and is then treated as authorised for work that induction never covered. Induction says a person knows how the site works. It does not say they can isolate a conveyor.

Establishing training needs by role

RS11 works through training needs and pathways by category rather than issuing one list, which is the right structure because the categories are genuinely different problems.

• Site safety and health management system. What everyone needs to know about the system they work under.
• Senior and statutory positions. Where prescribed competencies exist, and where they run out.
• Trade competencies. Recognised trade qualifications and what the site adds to them.
• Equipment operator competencies. Machine specific, and the largest volume of assessment on most sites.
• Emergency escape and response competencies. Including the people who will be relied on and may not know it yet.
• Site safety and health representative competencies. A statutory role with its own requirements.
• Other competencies. The residual category that carries most of the interesting cases.

That last category is where RS11 meets RS22 management structure. RS22 requires the site senior executive to determine what competencies a delegated position needs, including where the legislation prescribes none. RS11 is the machinery for delivering, assessing and recording whatever RS22 determines. Sites that treat them as two unrelated obligations end up with a competency matrix that does not match the management structure, and two documents that disagree are worse than one that is incomplete.

Assessment, RPL and the trap in recognition

RS11 covers the training and assessment process, including recognition of prior learning and recognition of current competency, and requires trainers and assessors to be appropriately qualified.

Recognition of prior learning is legitimate and necessary in an industry where people move between sites carrying real skill. The trap is that RPL is often applied to the qualification rather than to the site. A person who has operated that machine for fifteen years elsewhere has the operating competency. They do not have knowledge of this pit, this traffic plan, these ground conditions or this trigger action response plan, and none of that is recognised prior learning.

The practical answer is to be explicit about which part of a competency is portable and which part is site specific, and to record them separately so the site specific half cannot be signed off by reference to a previous employer.

Refresher training

The site senior executive is responsible for ensuring refresher training occurs. The regulation requires that each coal mine worker at the mine, including each worker holding a senior management or supervisory position and each worker holding a certificate of competency, is given refresher training under the mine training scheme at least once in every five years.

Two points are worth drawing out. First, the obligation explicitly reaches senior management and certificate holders. Refresher schedules that quietly cover operators and exempt the people running the operation are a common and visible gap.

Second, RS11 is sensible about the form. Refresher training does not necessarily require full training and assessment against the full unit of competency, and may be partially achieved by recorded observations against the standards during routine work. That is a considerable relief operationally, and it comes with a condition: the observations have to be recorded. An observation nobody wrote down did not happen, and five years is exactly long enough for everyone involved to have forgotten.

Record keeping, which is the real obligation

RS11 asks for detailed and accurate records of all training, assessments and appointments, with recording procedures that are auditable and provide for a specific list of things. The list is worth reading closely because most systems fail at least two of them.

• Sufficient and reliable evidence of competencies and qualifications.
• Worker access to their own records, during and after employment.
• Transfer between operations. With the person’s permission, the SSE makes a copy of their training records available to another operation.
• A full copy on departure. A coal mine worker leaving an operation is to be given a full copy of the competencies, tickets and authorisations achieved while employed there, and those documents are placed on the record at subsequent operations to give a ready cross reference to previous experience.
• Confidentiality of personal training records in accordance with the relevant legislation.
• Retention after employment ends.
• Easy determination of the currency of competencies, including refresher dates.

That final item is the one that quietly defeats most training matrices. A spreadsheet can tell you a person attained a competency. Telling you at a glance which competencies across a workforce of six hundred are expiring within ninety days is a different capability, and it is the one the standard actually asks for.

RS11 also suggests trainees be given a means of recording their own training, such as a training log, and that completed logs can form part of the assessment evidence.

Where sites come unstuck

• Attainment is tracked, currency is not. The matrix records what was achieved and cannot answer what is expiring.
• Contractors sit outside the system. Site employees are managed properly and contractor competency is a certificate someone emailed once. The obligations do not distinguish that way, as covered in contractor management under one system.
• Refresher is exempted upwards. Operators are refreshed, supervisors and managers are not, and the regulation explicitly includes them.
• Observation based refresher is used without records. The flexibility is taken and the evidence is not created, which is worse than not using it.
• Records do not survive the worker. Someone leaves, the file is archived or deleted, and the retention and access obligations are quietly breached.
• Training is disconnected from the risks. The matrix reflects what the training provider offers rather than what the site’s hazard profile requires.

Making currency visible

Almost every RS11 record keeping requirement is a query rather than a document. Who is current. What expires this quarter. Which competencies does this position require and does the person acting in it today hold them. What did this person achieve while they were here.

HazView contributes to the operational half of that. Controls and inspections are assigned against positions and people, so the record shows who was responsible and who actually did the work, with time and location attached and kept permanently. Observation based refresher evidence can be captured in the field as it happens, against the person and the task, rather than reconstructed later. Overdue and expiring items surface rather than waiting to be discovered.

It is worth being straight about the boundary. HazView is not a learning management system and does not deliver or assess training. Most sites already run an LMS or an HR system that holds the qualification data properly, and that is the right place for it. What the REST API does is stop those two worlds from being maintained by hand: competency and currency data can be fed in so field records know who is authorised, and HazView’s operational evidence can be pushed back out. Populating a second system by retyping is where training records go stale, and it is entirely avoidable.

See how HazView works for managers, or book a demo.

Frequently asked questions

How often is refresher training required in Queensland coal mines?

At least once in every five years for each coal mine worker, including workers holding a senior management or supervisory position and workers holding a certificate of competency. The site senior executive is responsible for ensuring it happens.

Does refresher training mean redoing the full unit of competency?

Not necessarily. RS11 allows refresher to be partially achieved through recorded observations against the standards while conducting routine work. The condition is that the observations are actually recorded.

Does RS11 apply to open cut mines?

Yes. It applies to both surface and underground operations. The training and assessment materials differ between them, the system and process requirements do not.

What happens to training records when a worker leaves?

The worker is to be given a full copy of the competencies, tickets and authorisations achieved while employed at that operation, and those documents go on the record at subsequent operations as a cross reference to previous experience. The original site also retains records after employment ends and must allow the person access to them.

Can training records be transferred between mines?

Yes, with the person’s permission. The site senior executive may make a copy of a person’s training records available to another operation where the person concerned has consented to the transfer.

How does RS11 relate to RS22?

RS22 determines what competency a delegated position requires. RS11 is how that competency is delivered, assessed, refreshed and recorded. They should describe the same set of positions, and when they do not, one of them is out of date.

The post RS11: Training in Coal Mines appeared first on HazView®.

A tailings storage facility is the largest structure most mines will ever build, it is built incrementally by the people who operate it, and when it fails the consequences are measured in lives and catchments. QGN 29, the Queensland guidance note on surface tailings storage facility management, describes the regime that keeps that from happening: sound design, construction, operation and maintenance, validated through inspection and auditing.

This guide covers why TSFs fail, what the surveillance regime has to catch, what QGN 29 expects around wet season and seismic events, and where the record keeping usually breaks down.

Why TSFs are a different kind of hazard

Poorly designed, operated or maintained tailings facilities have contributed to a number of high consequence accidents and environmental disasters. That sentence appears in the guidance note, and the international record behind it is unambiguous.

What makes a TSF unlike most mining hazards is the time constant. A haul road hazard is created and resolved within a shift. A tailings embankment accumulates its problem over months or years: a slightly steeper lift than designed, a rate of rise faster than the consolidation allows, a decant that has not been moved, a seepage face that has been damp for a while and is now wetter. Every one of those is survivable alone and the combination is not.

The corollary is that the control is surveillance over time, and surveillance over time is a record keeping problem before it is an engineering one. The engineer who assesses the facility can only assess what was observed and written down.

The four phases QGN 29 addresses

The guidance note frames a regime across design, construction, operation, and maintenance or modification, with inspection and auditing validating all four. The separation matters because responsibility moves.

• Design is usually external, by a specialist engineer, and produces the operating envelope: freeboard, rate of rise, beach length, decant position, phreatic surface expectations.
• Construction is often done by the mine, in lifts, over years, sometimes by people who were not there for the previous lift.
• Operation is deposition management, water balance and decant control, done daily by operators.
• Maintenance or modification is where facilities drift, because a change made for a good operational reason can sit outside the design assumptions nobody reread.

The gap that matters is between what the designer assumed and what the operation actually does. That gap is only visible if operational records are legible to the engineer, which is a higher standard than being legible to the operator.

What the surveillance regime has to catch

Routine TSF inspection is looking for change, not for a pass or fail. The items that matter are the ones that mean something different this week than last week.

• Freeboard against the design minimum, and the trend, not just today’s number.
• Beach length and pond position. A pond migrating towards the embankment is one of the clearest warnings available.
• Seepage. Location, flow, clarity and whether it is carrying fines. Clear seepage in a known location is a design feature. Cloudy seepage in a new location is not.
• Cracking, settlement and bulging on the crest and downstream face, with position recorded well enough that the same crack can be found and compared next month.
• Erosion and rilling on the outer face.
• Instrumentation. Piezometers, survey monuments and inclinometers, and whether they are actually working. QGN 29 specifically expects assessment of all monitoring equipment, because a dead piezometer reads as reassuringly steady.
• Decant and spillway condition, including debris and obstruction.
• Rate of rise against what the design permits.

Wet season and seismic triggers

QGN 29 calls out two event driven expectations that routine monthly inspection does not cover.

Wet season preparedness and compliance against plan. In Queensland this is the dominant annual risk cycle. Storage capacity, freeboard, spillway condition, pump capacity and the water balance all have to be in position before the season, and the check has to be a documented one against a plan rather than a general sense that things look right. The equivalent thinking for pit water is covered in water management, dewatering and inrush.

Inspection after regional seismic events. An earthquake felt at the site, or a regional event of sufficient magnitude, triggers an inspection regardless of where it falls in the routine schedule. The trigger needs to be defined in advance, with a magnitude and distance threshold and a named person responsible, because deciding whether an event qualifies while everyone is talking about the earthquake is how it gets skipped.

People and training

The guidance note expects training and education of mine personnel to ensure safe management of the facility. This is less obvious than it sounds.

The person walking the embankment weekly is usually not a geotechnical engineer. They need to know what normal looks like on this facility, which observations are significant, and what to do immediately rather than at the end of the shift. A generic inspection form handed to someone who has not been taught what a developing seepage face looks like produces a complete record of nothing.

Competency for TSF inspection is a good example of the kind of position specific requirement that RS22 management structure asks the site senior executive to determine and document. No ticket is prescribed for it. That does not mean nothing is required.

Where sites come unstuck

• Inspections record a state, not a trend. Twelve monthly forms each saying “satisfactory” contain no information about whether anything is moving.
• Observations cannot be relocated. “Crack on the northern crest” is unfindable next month. Without a position, comparison is impossible and the record is decorative.
• Instrumentation is read but not assessed. Readings are logged, nobody confirms the instrument still works, and a flat line is mistaken for stability.
• The design intent is not on site. Operators manage deposition without knowing the rate of rise limit or the design freeboard, because those live in a report in a consultant’s file.
• Modifications are made without reference back to the design. A pipeline rerouted, a decant relocated, a road built on the embankment. Each is reasonable and each changes an assumption.
• Records are not available to the reviewing engineer. The annual assessment is done from a site visit and a conversation, because a year of operational observation is not in a usable form.

Running TSF surveillance so the trend is visible

HazView runs TSF surveillance on live sites, so this is a use case rather than an analogy.

Every observation is placed on the facility. A seepage point, a crack, a settlement area or an instrument is a located feature with its own history, so the next inspection opens the same point and compares against the last photograph rather than starting a fresh form. That single property is what turns a stack of inspections into a trend, and it is the property paper and spreadsheets cannot provide.

Inspection routines are scheduled and assigned, with wet season and post seismic inspections as their own triggered routines rather than as an item somebody remembers. Overdue inspections are visible. Photographs, timestamps and the inspector’s identity are attached to every entry and kept permanently, which is what the reviewing engineer needs and rarely receives.

Piezometer and survey data usually come from other systems, and they should. The REST API brings those readings in against the same facility, so instrumentation trends and visual observations sit on one map instead of in two reports that get compared once a year. Records can be pushed back out to corporate or consultant systems the same way, which removes the retyping that makes people summarise instead of record.

The platform is not a geotechnical assessment and does not replace the design engineer or the annual review. It makes sure that when those people arrive, the year of observation they need actually exists and can be read.

See how HazView works for geotechnical engineers, or book a demo.

Frequently asked questions

What is QGN 29?

The Queensland guidance note on surface tailings storage facility management, published in 2018. It outlines a regime of design, construction, operation and maintenance or modification, validated through inspection and auditing. It is guidance, not law, and compliance with it is not by itself proof of compliance with the legislation.

How often should a TSF be inspected?

There is no single number, because it depends on the facility, its consequence category and its rate of rise. What matters is that routine frequency is set deliberately, that event based triggers exist for wet season and regional seismic events, and that the regime is actually followed and recorded.

What should a TSF inspection look for?

Change. Freeboard and its trend, beach length and pond position, seepage location and clarity, cracking and settlement on the crest and downstream face, erosion, instrumentation function, decant and spillway condition, and rate of rise against the design.

Does a seismic event require an inspection?

QGN 29 expects inspection after regional seismic events. The threshold that triggers one should be defined in advance with a named responsible person, so it does not become a judgement call made in the middle of the event.

Who is responsible for the TSF?

The site senior executive carries the safety and health obligation, with design and periodic assessment typically from a specialist engineer and daily management from operations. The failure mode is the space between those three, so the accountability for each part belongs in the documented management structure.

Is clear seepage a problem?

Clear seepage at a known location with a stable flow is often a designed part of the facility. Seepage that is new, increasing, or carrying fines is a different matter entirely, because material moving with the water means internal erosion. Which is why location and clarity have to be recorded, not just the presence of water.

The post Tailings Storage Facility Management appeared first on HazView®.

Blast fume is the orange or brown cloud that sometimes rises after a shot. It is nitrogen dioxide, it is toxic, and Queensland treats a cloud that leaves the blast exclusion zone as a reportable event. QGN 20, the guidance note on the management of oxides of nitrogen in open cut blasting, sets out how to manage it and exactly what to record when it happens.

This guide covers why fume forms, what counts as a fume event, the data you have minutes to capture, who to report it to, and why the exclusion zone you already use is not designed for gas.

Why fume forms

Blasting explosives predominantly use ammonium nitrate. Detonated under ideal conditions, the reaction is close to complete and the gaseous products are largely benign. Field conditions are not ideal conditions.

When the reaction runs inefficiently, oxides of nitrogen are produced instead. The most harmful is nitrogen dioxide, and it announces itself with an orange to brown cloud. In QGN 20’s terms, fume means the oxides of nitrogen, particularly NO2 as the most prevalent.

The variables that drive it are the ordinary variables of a blast: the explosive formulation and its oxygen balance, water in the hole and product sleep time, ground conditions and the presence of reactive ground, confinement and stemming, hole diameter and loading practice, and initiation timing. Most fume events trace back to a combination rather than a single cause, which is why investigating them as “someone did something wrong” usually fails.

What counts as a fume event

QGN 20 defines a fume event as an event that generates visible nitrogen dioxide that moves outside the standard blast exclusion zone.

That definition carries a warning inside it that is worth stating plainly. The standard blast exclusion zone is designed to protect people from projections and blast overpressure. It is a distance calculated for flyrock and air blast. It was never designed as a gas exclusion distance, and gas does not behave like flyrock: it drifts, it follows terrain, it concentrates in low ground, and it goes where the wind takes it.

So the fact that a cloud reached the boundary of a zone that was adequate for projectiles tells you nothing reassuring. It is the trigger for a report precisely because the zone was not sized for that hazard. Sites that manage fume well set a separate, meteorologically informed standoff for gas, and adjust it on the day. The general principles of exclusion and clearance are covered in blast exclusion zones, flyrock and clearance.

The exposure standard

The objective of fume management is that nobody is exposed to nitrogen dioxide above the short term exposure limit of 5 parts per million.

Nitrogen dioxide is deceptive in the field. It has a sharp odour, but olfactory fatigue sets in quickly, so the smell disappears while the gas does not. The serious effect is delayed: a person can walk out of a cloud feeling only mild irritation and deteriorate hours later with pulmonary oedema. Anyone with a meaningful exposure needs medical assessment and observation even if they feel well, and the time of the exposure and the symptoms observed at presentation are part of what the clinician needs.

That delay is the reason fume is treated as a reportable event rather than as a nuisance. The consequence is not visible at the time it needs to be acted on.

What you must record, at the time

If a fume cloud travels outside the designated blast exclusion zone, it must be reported to both the Explosives Inspectorate and the Mines Inspectorate. QGN 20 sets out the information to provide, and this is where the practical difficulty sits, because most of it is perishable.

• Time of the event.
• Fume strength rating, 0 to 5, determined when the cloud is at its highest concentration, using the NOx rating scale in the guidance note.
• Percentage of the blast area emitting fume, in 10 per cent increments, or the AEISG A to C rating.
• Size of the NOx cloud in metres, as width, length and height.
• Wind speed and direction.
• Stability class of the atmosphere.
• Temperature.
• Cloud cover.

Read that list again with a stopwatch running. The rating has to be judged at peak concentration, which lasts seconds. The cloud dimensions have to be estimated while it is still coherent. The meteorological conditions are the conditions at the moment of the shot, not the conditions when someone gets back to the office.

A fume report assembled the following morning from memory and a weather website is a reconstruction. It may satisfy the reporting obligation. It will not support an investigation into why the shot fumed, and it is useless for trending across a year of blasts.

Managing fume before the shot

• Product selection matched to ground conditions. Formulations can be adjusted to reduce fume potential within their category, and the product needs to be fit for the purpose it is actually being used for.
• Water management and sleep time. Water in the hole and product left loaded too long are two of the most reliable predictors of a fume event.
• Reactive ground identification. Known reactive ground changes the product, the loading practice and the sleep time limits.
• Stemming quality and confinement. Poor confinement is inefficient detonation, and inefficient detonation is fume.
• Meteorological assessment on the day. Wind direction and atmospheric stability decide where a cloud goes. A stable inversion layer will hold gas at ground level and carry it a long way.
• An adjusted exclusion zone for gas, separate from the projection zone, based on those conditions.
• Accounting for people by name, including anyone downwind outside the projection zone who would not normally be cleared.

Where sites come unstuck

• The gas zone equals the projection zone. The single most common structural error, and the definition of a fume event exists because of it.
• The record is made later. Perishable data reconstructed from memory, which fails both the investigation and the trend.
• Fume is treated as an environmental complaint. It becomes a community relations issue instead of an exposure event, and the health follow up does not happen.
• No trending. Individual events are reported and closed, and nobody looks at 40 shots together to find the pattern in ground type, product, sleep time or season.
• People downwind are not accounted for. The blast crew is cleared. A dozer operator two ridges away, outside the projection zone, is not.
• Nobody records the shots that did not fume. Without the negative cases there is no baseline, and the analysis has nothing to compare against.

Capturing fume data where it happens

Fume is the clearest example on a mine site of a record that has to be made in the field, in the moment, or not at all. It is also a record with real long term value, because the pattern only emerges across dozens of shots.

This is what HazView is built to do. A gas check or fume observation is recorded at the blast, on the map, with the time it was taken, the person who took it, the rating, the conditions and photographs of the cloud attached. It is held permanently, so a fume event from four years ago is still there with its photographs and its meteorological conditions intact when someone asks whether this ground has fumed before.

Because the records are structured and located rather than sitting in a document, they can be trended. Fume ratings against ground type, against product, against sleep time, against season. That is the analysis that changes blast design, and it is impossible when each event lives in its own report.

The REST API matters here too. Blast designs, product and loading data usually live in a drill and blast system, and monitoring data may come from elsewhere. Those can be brought in against the same blast, and the resulting records pushed back out to whatever the business reports from, so nobody is retyping a fume report into a second system at nine o’clock at night.

The platform does not measure gas concentration and does not decide whether a shot is safe to fire. Those are the shotfirer’s and the SSE’s calls, with instruments. What it removes is the gap between the observation and the record.

See how HazView works for blast crews, or book a demo.

Frequently asked questions

What is a fume event?

Under QGN 20, an event that generates visible nitrogen dioxide that moves outside the standard blast exclusion zone. The orange or brown colour is the identifying feature.

Who do I report a fume event to in Queensland?

Both the Explosives Inspectorate and the Mines Inspectorate, with the time, the 0 to 5 fume rating at peak concentration, the percentage of the blast area emitting fume, the cloud dimensions, wind speed and direction, atmospheric stability class, temperature and cloud cover.

What is the exposure limit for nitrogen dioxide?

The objective of fume management is that people are not exposed above a short term exposure limit of 5 ppm. Effects can be delayed by hours, so anyone with a meaningful exposure needs medical assessment even if they feel fine.

Is the blast exclusion zone enough to protect against fume?

No, and that is the point of the definition. The standard exclusion zone is designed for projections and overpressure. Gas drifts with the wind and settles in low ground, so a separate standoff based on the day’s conditions is needed.

Which legislation applies to blasting fume in Queensland?

Three Acts operate on a mine site using explosives: the Mining and Quarrying Safety and Health Act 1999, the Coal Mining Safety and Health Act 1999 and the Explosives Act 1999. All explosives used in Queensland must be authorised under the Explosives Act.

How long should fume records be kept?

Longer than any minimum requires. Fume behaviour correlates with ground conditions that repeat over years, so records that survive only as long as a retention policy demands destroy the only dataset capable of predicting the next event.

The post Blast Fume Management in Open Cut Mining appeared first on HazView®.

Recognised Standard 20 covers dust control in surface mines. It supports the dust provisions of the Coal Mining Safety and Health Regulation 2017 and provides the framework for a dust management plan across the dust generating processes at an open cut coal mine and the surface areas of an underground mine. It applies to all activities at a surface coal mine.

This guide covers the exposure limits that apply, where the dust actually comes from on an open cut, what a dust management plan needs to contain, and why the monitoring result is only half the obligation.

The exposure limits

From 1 September 2020 the occupational exposure limits in Queensland coal mining are 1.5 mg/m³ for respirable dust and 0.05 mg/m³ for respirable crystalline silica, both as eight hour time weighted averages.

The silica limit is the one that changes behaviour. At 0.05 mg/m³ it is low enough that ordinary open cut activities in the wrong material can approach it, and it is low enough that the sampling has to be done properly to mean anything. Overburden with high quartz content, drilling in sandstone, and dry haul road surfaces in the wrong season are all capable of producing exceedances that would not have registered against the older limits.

An exposure limit is a ceiling, not a target. The obligation under the Act is to hold risk at an acceptable level, which means as low as reasonably achievable, not just under the number. A site sitting consistently at 90 per cent of the limit and treating that as compliance has misread the obligation, and this is exactly the reasoning covered in acceptable level of risk and what you can prove.

Where the dust actually comes from

The mental model of open cut dust is usually a haul road on a windy day. Roads matter, and they are not the whole picture.

• Haul roads and light vehicle roads. The largest single source on most operations, driven by surface material, moisture, traffic volume and speed.
• Drilling. Concentrated, close to the operator, and the highest silica risk on most sites depending on the strata.
• Blasting. Short duration, high volume, and the source most likely to leave the lease.
• Loading and dumping. Drop height and material moisture do most of the work.
• Dozer and grader operations. Continuous, close to the cab, and often overlooked because the machine is enclosed.
• Coal handling and preparation. Conveyors, transfer points, stockpiles and reclaim.
• Wind erosion of exposed surfaces. Stockpiles, spoil, and any large area left bare and dry.

The point of listing them is that a dust management plan built around water carts is a plan that addresses one source and reports on all of them.

What a dust management plan needs

RS20 frames the plan around the dust generating processes rather than around the equipment. In practice a plan that survives an audit answers these, source by source:

• What generates dust here, and how much. Based on measurement, not assumption.
• What controls apply, in order of the hierarchy. Elimination and substitution first, engineering controls next, administrative controls after that, respiratory protection last and never as the primary control.
• Who is exposed, and in what similar exposure groups. Sampling a driller tells you nothing about a serviceman.
• What triggers a response and what the response is. A dust TARP with real trigger levels, in the same shape as the one described in building a trigger action response plan.
• How the controls are verified as working. Not whether they exist, whether they are effective.
• How results feed back into the plan. Monitoring that never changes anything is a data collection exercise.

Control measures that carry the load

Water is the default and it has real limits. Over watering a haul road creates a different hazard, degrades the running surface, and produces the corrugations and edge failure that RS19 road design is trying to prevent. The interaction between dust control and road condition is one of the more common places where two control systems work against each other.

• Surface treatment and chemical suppressants on high traffic roads, which reduce water demand and hold the surface together.
• Drill dust collection systems maintained as critical controls, not as an optional extra that gets bypassed when it blocks.
• Enclosed, pressurised and filtered cabs with a filter change regime that is actually tracked. A cab is only a control while its seals and filters are intact.
• Sequencing and scheduling. Not drilling upwind of a crew is free, and it is an engineering control in everything but name.
• Blast timing against meteorological conditions, which also serves fume management. See blast fume management in open cut mining.
• Rehabilitation and surface stabilisation of areas that are no longer active.

Monitoring, and where RS14 fits

RS20 is about control. RS14 covers the monitoring of respirable dust in coal mines. They are different standards addressing different halves of the same problem, and sites regularly cite one when they mean the other.

The practical relationship is that monitoring exists to tell you whether the controls in the dust management plan are working. A sampling programme that reports numbers to a health and hygiene function, with no defined path back into changing the controls, satisfies the monitoring obligation while leaving the control obligation unaddressed.

Health surveillance sits alongside both. It detects the consequence of exposure. It is not a control, and a site that treats clear health surveillance results as evidence that its controls are adequate has the logic backwards by several years, which is the time lag involved.

Where sites come unstuck

• The plan covers roads and little else. Drilling usually carries the highest silica exposure and gets the least attention in the plan.
• Similar exposure groups are wrong. Groups drawn from the org chart rather than from what people actually breathe produce sampling that is technically valid and practically meaningless.
• Controls are listed, not verified. The cab filter regime exists on paper, and nobody can say when the filters in unit 412 were last changed.
• Exceedances are managed as incidents rather than as plan failures. An exceedance says the control set was inadequate for those conditions. Investigating the person is easier and useless.
• Respiratory protection has quietly become the primary control. It is last in the hierarchy for good reasons, and it is the control most sensitive to fit, wear time and discipline.

Making the control evidence visible

The hard part of RS20 is not deciding what the controls should be. It is showing, on any given day, that they were in place and working across a lease measured in square kilometres.

HazView holds that against the ground. Dust controls are recorded where they apply, so a road section, a drill pattern or a stockpile carries its own inspection history with time, person and photographs attached. Verification checks on critical controls such as drill dust collection and cab filtration are assigned and tracked, and overdue ones are visible rather than found later. Conditions that trigger a dust response can be logged in the field by the person who saw them.

Monitoring results usually live in a hygiene system, and they should. The REST API lets those results come across and sit against the areas and activities they were taken from, so exposure data and control verification are looking at the same map instead of at each other across two reports. It also means the data can go back out to corporate reporting without anyone rekeying it.

The platform does not measure dust and does not assess exposure. Those are jobs for occupational hygienists and calibrated instruments. What it changes is whether the control half of RS20 can be demonstrated as readily as the monitoring half.

See how HazView works for managers, or book a demo.

Frequently asked questions

What is the respirable dust limit in Queensland coal mines?

1.5 mg/m³ for respirable dust and 0.05 mg/m³ for respirable crystalline silica, as eight hour time weighted averages, in force since 1 September 2020. Both are ceilings rather than targets.

Does RS20 apply to underground mines?

It applies to surface coal mines and to the surface areas of underground coal mines. Underground dust control is dealt with separately under RS15, and monitoring under RS14.

What is the difference between RS20 and RS14?

RS20 is about controlling dust. RS14 is about monitoring respirable dust. You need both, and satisfying the monitoring standard says nothing about whether your controls are adequate.

Is a dust management plan mandatory?

RS20 provides the framework for one as a way of achieving an acceptable level of risk for dust. As with any recognised standard you can take another approach, provided you can show it achieves at least the same level of control. In practice, no site has produced a more defensible structure than a documented plan.

Where does respiratory protection sit?

Last in the hierarchy of control, as a supplement to engineering and administrative controls rather than a replacement for them. It is also the control most dependent on fit testing, wear time and individual discipline, which makes it the hardest to verify as effective.

The post RS20: Dust Control in Surface Coal Mines appeared first on HazView®.

The mine record is the statutory record of what has happened at a Queensland mine. Section 68 of the Coal Mining Safety and Health Act 1999 requires the coal mine operator to keep one, sets out what goes in it, requires matters to stay in it for at least seven years, and makes it an offence to alter it so that it is no longer a correct and complete record.

Most sites keep one. Fewer can produce it quickly, and fewer again could show that it is complete. This guide covers what the law requires, what the inspectorate’s guidance adds, and what “correct and complete” means when the underlying records live in six different places.

What must be in the mine record

Section 68 lists it directly. The coal mine operator must keep a mine record containing:

• all reports of, and the findings and recommendations resulting from, inspections, investigations and audits carried out at the mine under the Act
• all directives issued under the Act to the coal mine operator and the operator’s agents or representatives
• a record of all remedial actions taken as a result of those directives
• a record of, and reports about, all serious accidents and high potential incidents that have happened at the mine
• any other reports or information prescribed by regulation

Three further obligations sit around that list and they are the ones that do the real work.

• Seven year retention. A matter must be kept in the mine record for at least seven years after it is included.
• Availability. The operator must ensure the record is available for inspection.
• Integrity. A person must not destroy, deface or alter the mine record so that it is no longer a correct and complete record.

Read those three together and the mine record is not a filing requirement. It is an audit trail with a legally protected integrity requirement attached, which is a rarer thing than it sounds.

What the guidance adds

The inspectorate publishes QGN 05, a guidance note on keeping and using the mine record at mining and quarrying operations. It covers both the coal Act and the Mining and Quarrying Safety and Health Act 1999, because both require a mine record.

QGN 05 is guidance, not a guideline as defined in those Acts, and it says so on its own face: in some circumstances compliance with the guidance note may not be sufficient to comply with the legislation. Treat it as the inspectorate telling you how it thinks about the obligation, not as a safe harbour.

It is also an older document. The substance of section 68 has not moved, but the assumptions about how records are physically kept belong to a period when the answer was a bound book in the mine office.

The mine record is not the same as the mine’s records

This is the distinction sites get wrong most often. A mine generates an enormous volume of records: pre starts, checklists, permits, maintenance history, training files, survey plans. Almost none of that is the mine record.

The mine record is the narrower, statutory set: what inspections, investigations and audits under the Act found, what the regulator directed, what you did about it, and what serious accidents and high potential incidents occurred. It is the formal history of oversight and consequence at the mine.

The practical implication is that the mine record has to be assembled from other systems, because the source material is generated elsewhere. An inspection happens in the field and produces a report. A high potential incident is reported through the incident process. A directive arrives from an inspector by email. Each of those has to end up in one place, complete and unaltered, and stay there for seven years.

High potential incidents and the mine record

HPIs sit in both the notification stream and the mine record, and the two obligations are separate. Notifying the inspectorate of a high potential incident does not satisfy the mine record obligation, and recording it in the mine record does not satisfy the notification obligation. The timeframes and duties around notification are covered in high potential incident reporting in Queensland.

The common failure is that the HPI notification is done carefully, because there is a deadline and a person chasing it, while the mine record entry is done later, by someone else, from memory.

What “correct and complete” actually demands

The prohibition on altering the record so that it is no longer correct and complete has an implication that most digital systems handle badly: you need to be able to show what a record said at the time, not only what it says now.

Correcting a genuine error is legitimate. Editing an inspection finding six months later so that it reads more comfortably is not. The difference between the two is visible only if the system keeps a history. A spreadsheet where the current cell value is the only surviving fact cannot tell those two situations apart, and neither can you.

This is the same problem that makes paper based statutory reporting fragile, and it shows up in the same way in digitising OCE reports and statutory inspections.

Where sites come unstuck

• Nobody owns it. The mine record is the operator’s obligation, and in practice it becomes whoever last had the folder. Ownership needs to be a named position in the management structure.
• Remedial actions are not linked to the directive that caused them. The Act asks for a record of remedial actions taken as a result of directives. A closed action in a separate register with no reference back is not that.
• It is complete but not producible. Everything exists, spread over an email archive, a shared drive, a safety system and a filing cabinet. Assembling it takes days, and the request always arrives on the worst possible day.
• Seven years is treated as a maximum. It is a minimum. Records are routinely purged at five years by a retention policy written for a different purpose.
• Edits leave no trace. The system permits changes but keeps no version history, so the integrity obligation cannot be demonstrated either way.

Keeping a record that holds up

A mine record that works has four properties: everything required is in it, each entry is attributable to a person and a time, changes are visible as changes rather than as replacements, and the whole thing can be produced on request without a project.

This is the part of Queensland compliance that HazView is most directly built for. Inspections and hazards are recorded in the field, tied to the location they relate to, with the person, the time and any photographs attached. Every change is kept in the record’s history and attributed, so a correction is visible as a correction rather than silently overwriting what was there. Nothing is deleted on a retention timer.

Because the platform has a REST API, the entries that originate elsewhere can be brought in rather than retyped. Directives that arrive by email, audit findings held in a corporate system, incident records from a group reporting tool: they can be fed in and carried against the same history, and HazView’s own records can be pushed back out to whatever system the business reports from. That matters because the mine record fails at the seams between systems, and the seams are where manual re-entry lives.

What it does not do is decide what belongs in the mine record. That is a judgement about the Act, made by people with statutory obligations. The platform’s job is to make sure that once the judgement is made, the record of it is complete, attributable and still there in seven years.

See how HazView works for OCEs and supervisors, or book a demo.

Frequently asked questions

What is the mine record?

The statutory record a Queensland mine operator must keep, containing reports and findings from inspections, investigations and audits under the Act, directives issued under the Act, remedial actions taken in response, and records of serious accidents and high potential incidents.

How long must the mine record be kept?

A matter must be kept in the mine record for at least seven years after it is included in the record. That is a minimum, not a disposal date, and it is easy to breach with a generic corporate retention policy.

Can the mine record be electronic?

Nothing in the obligation requires paper. What matters is that it is a correct and complete record, available for inspection, retained for at least seven years, and not altered so that it stops being correct and complete. An electronic system with a proper history satisfies the integrity requirement more convincingly than a bound book with pages torn out.

Who is responsible for the mine record?

The coal mine operator carries the obligation. In practice the work is delegated, and that delegation should appear in the management structure required by RS22 rather than being assumed.

Do quarries have to keep a mine record?

Yes. The Mining and Quarrying Safety and Health Act 1999 carries its own mine record obligation, and QGN 05 addresses both sectors. The detail differs, the principle does not.

Is correcting an error in the mine record allowed?

Correcting a genuine error is what keeps the record correct. The prohibition is on altering it so that it is no longer a correct and complete record. The safe approach is a system where the correction and the original are both visible, so the change can be explained rather than merely asserted.

The post The Mine Record: What Queensland Law Actually Requires appeared first on HazView®.

Recognised Standard 22 requires the site senior executive to develop a management structure for the development and implementation of the safety and health management system, to determine what competencies each delegated position actually needs, and to document those competencies in the structure itself. Released in August 2021, it is the standard that asks an uncomfortable question: does your organisation chart describe anything real?

This guide covers what RS22 requires, what a supervisory position is, how competency determination works when the legislation prescribes nothing, and what evidence a structure needs behind it to survive an audit.

What problem RS22 was written to solve

Every Queensland coal mine has a safety and health management system, and every mine has people responsible for parts of it. The gap RS22 addresses sits between those two facts.

A SHMS delegates responsibility for hazard management plans, standard operating procedures and controls to positions across the operation. Those delegations are usually real. What has often been missing is a documented answer to the obvious follow-up questions. Which positions carry which parts of the system? What does a person in that position need to be able to do? How do we know the person currently in the seat can do it? And when the seat changes hands, what changes with it?

RS22 makes those questions the site senior executive’s to answer, in writing, inside the management structure.

What the standard requires

Three obligations sit at the centre of it.

• Develop a management structure for the development and implementation of the SHMS at the mine.
• Determine the competency requirements of positions delegated responsibility under the SHMS.
• Document those competencies in the management structure, not in a separate training matrix that drifts out of step with it.

The competencies themselves are expected to be relevant to the risks actually present at that mine, aligned to the levels of responsibility in the RII training package, consistent with what the position is responsible for, and sufficient to keep operations at an acceptable level of risk.

That last phrase is the connection back to the rest of the legislation. The obligation is not to fill in a matrix. It is to be able to say that the people holding the system together are capable of holding it together, and to have worked that out deliberately rather than by assumption.

The clause that catches people out

The principle that causes the most trouble in implementation is this: the absence of a competency prescribed by the Coal Mining Safety and Health Act does not mean no competency is required.

Queensland prescribes competencies for a handful of statutory positions. Open cut examiners, site senior executives and a few others have defined requirements. For every other position that carries part of the SHMS, the legislation is silent, and silence has often been read as “nothing required”.

RS22 closes that reading. If a superintendent is responsible for implementing a principal hazard management plan, the fact that no ticket is prescribed for superintendents does not mean the role needs no defined capability. The site senior executive works out what it needs, based on the risks at that mine, and records it.

This is a whole of mine, risk based exercise. It cannot be done by copying another site’s structure, because the competencies follow the risks, and the risks follow the operation.

What counts as a supervisory position

RS22 uses a specific definition. A supervisory position is a position at the mine authorised by the site senior executive to be responsible for the implementation of relevant parts of the safety and health management system and the application of plans, in the relevant vocational field. That includes principal hazard management plans, other hazard management plans, standard operating procedures and other controls required to hold risk from coal mining operations at an acceptable level.

Two things follow from the wording that are worth sitting with.

• It is about authorisation, not job title. A position is supervisory because the SSE authorised it to implement part of the system, not because the word supervisor appears on a badge.
• It is tied to a vocational field. Authorisation to implement the parts of the system relating to mobile plant is not authorisation to implement the parts relating to electrical work. The structure has to be specific enough to show which parts.

Getting this right usually shrinks the list rather than growing it. Sites often start by naming everyone with a supervisory sounding title and end up with a structure that says something true about a smaller number of positions.

Building the structure

A workable RS22 structure answers four things for every delegated position.

• What parts of the SHMS does this position implement? Named plans and procedures, not “safety”.
• What competencies does that require? Determined from the risks the position manages, aligned to the RII levels of responsibility.
• Who currently holds the position and do they hold those competencies? With currency, not just attainment.
• What happens when they are not there? Relief, acting arrangements and the competency of the person acting.

The fourth is the one most structures skip and the one operations most often fail on. A structure that is correct on a Tuesday day shift and meaningless on a night shift during a roster change has not really been developed.

Where it interacts with the rest of the system

RS22 does not stand alone. It is the structural half of a pair.

• RS11 training in coal mines supplies the machinery: how competencies are gained, assessed, refreshed and recorded. RS22 says what is required, RS11 says how it is delivered and evidenced. See RS11 and training in coal mines.
• QGN 09 asks whether the system is actually working, which is the natural next question once the structure exists. See reviewing the effectiveness of your SHMS.
• Principal hazard management plans are the things being implemented. If a PHMP does not name the position accountable for each control, the structure has nothing to attach to. See principal hazard management plans explained.

Where sites come unstuck

• The structure is an org chart. Boxes and reporting lines describe who someone answers to. RS22 asks what part of the system they implement, which is a different question with a different answer.
• Competency lives in a separate spreadsheet. The standard asks for the competencies to be documented in the management structure. Two documents means two update cycles and one of them will lose.
• Attainment is tracked, currency is not. A competency achieved in 2019 with a five year refresher due is a different fact in 2024 than it was in 2020, and only one of those facts appears on most matrices.
• Vacancies and acting arrangements are invisible. The structure describes the establishment rather than the actual state of the mine today.
• It was written once. Fleets change, contractors arrive, new plans are written, positions are restructured. A structure that has not been reviewed since it was created is describing a mine that no longer exists.

Making the structure demonstrable

The honest description of the RS22 problem is that it is not usually a knowledge problem. Most sites know who does what. It is a currency and evidence problem: the structure, the competencies, the people in the seats and the plans being implemented all live in different systems, maintained by different people, on different update cycles.

HazView helps with the evidence half of that. Controls and inspections are assigned to positions, so the record shows which role is accountable for what, and completion is tracked against that assignment rather than against a name that left the site last year. Competency currency and overdue items are visible rather than discoverable. Every inspection and every change carries the time, the person and the location, and it stays permanently.

The part that matters most for RS22 specifically is the REST API. Structures, positions and competencies usually already exist somewhere, in an HR system, a learning management system or a training matrix that someone maintains properly. HazView can take that data in and push its own records back out, so the operational record stays aligned with the system of record without anyone retyping it. Populating systems that humans do not want to populate by hand is exactly where these obligations fail, and it is the failure most worth automating away.

To be clear about the limits: no software determines competency requirements, and none of this replaces the site senior executive’s judgement about what a position needs. RS22 is a thinking exercise before it is a documentation exercise. What a platform can do is stop the result of that thinking from going stale the moment it is written down.

See how HazView works for managers and SSEs, or book a demo and we will run it against your own structure.

Frequently asked questions

Is RS22 mandatory?

It is a recognised standard, so it states a way of achieving an acceptable level of risk rather than imposing a regulation. You may achieve the outcome differently, but you carry the burden of showing your approach works at least as well, and RS22 is admissible in evidence if the question is ever tested.

When did RS22 come into effect?

It was released in August 2021. Implementation across the industry took considerably longer than the release, largely because competency determination for non prescribed positions was new work for most sites.

What is a supervisory position under RS22?

A position authorised by the site senior executive to be responsible for implementing relevant parts of the SHMS and applying the plans in the relevant vocational field, including principal hazard management plans, other hazard management plans, standard operating procedures and other controls. Authorisation defines it, not the job title.

Do we need a competency for every position?

For every position delegated responsibility under the SHMS, yes, and the fact that the legislation prescribes no competency for that position does not mean none is required. The requirement is determined from the risks the position manages at your mine.

Can we copy another site’s management structure?

Not usefully. Competencies follow the risks and the risks follow the operation, so a structure lifted from another mine describes that mine. It is reasonable to borrow the format. The content has to be worked out from your own hazard profile and your own plans.

How often should the structure be reviewed?

Whenever the thing it describes changes. New plans, restructures, new fleets, significant contractor engagements and changes to statutory appointments all invalidate parts of it. A fixed annual review on its own tends to miss the changes that mattered.

The post RS22: Management Structure for the Safety and Health Management System appeared first on HazView®.

Recognised standards state a way of achieving an acceptable level of risk at a Queensland coal mine. They are not regulations, and that distinction is the single most misunderstood thing about them. You can depart from a recognised standard. What you cannot do is depart from one and have no answer when an inspector asks why.

There are 23 recognised standards. Roughly half are written for underground operations and will never apply to an open cut. This guide sorts out which ones actually bite on a surface operation, what legal weight they carry, and how they sit alongside guidelines and guidance notes.

Where recognised standards come from

The Coal Mining Safety and Health Act 1999 lets the Minister make a standard for safety and health, stating ways to achieve an acceptable level of risk. That is the whole design intent in one sentence. The Act sets the outcome, which is that risk at the mine is at an acceptable level, and the recognised standard describes a way of getting there.

Two consequences follow, and both matter more than the content of any individual standard.

• A recognised standard is admissible in evidence. If a proceeding turns on whether you achieved an acceptable level of risk, the standard comes into the room with you.
• Following it is one way to discharge the obligation, not the only way. If you do something different, you carry the burden of showing your approach achieves at least the same level of risk control.

In practice this means a departure is a decision that needs a documented rationale sitting behind it in your safety and health management system. A departure nobody can explain is not a technical breach. It is an evidence problem, and it is the one that gets written up.

Recognised standards, guidelines and guidance notes are not the same thing

Queensland publishes three tiers of material and they carry different weight. People use the words interchangeably and then get surprised in an audit.

• Recognised standards (RS). Made under the Act, admissible in evidence, coal mines only.
• Guidelines (QGL). Made under the Act for mineral mines and quarries. Different instrument, different sector.
• Guidance notes (QGN). Published by the inspectorate as practical advice. Not law, and compliance with a guidance note is not by itself proof of compliance with the legislation. They are still the best written advice available on several topics, and inspectors know their content.

If you also run quarry or mineral operations, the equivalent picture on that side is set out in which Queensland recognised standards apply to a quarry. The short answer there is none of them, because quarries run under a different Act, and the confusion between the two is common enough to be worth reading.

Which recognised standards apply to an open cut

Of the 23, these are the ones that do real work on a surface operation.

The rest are underground: explosion protected diesel engines, sealed area monitoring, place change mining, explosion barriers, heat management, polymeric chemicals, incombustible dust and the underground inspection and dust standards. Useful to know they exist. Not your problem on an open cut.

The four that carry the most weight day to day

RS22, management structure

Released in August 2021 and the most consequential of the recent additions. It requires the site senior executive to build a management structure for developing and implementing the SHMS, to work out what competencies each delegated position actually needs, and to document those competencies in the structure itself. It is the standard that asks whether your organisation chart describes anything real. See RS22 explained.

RS19, mine roads

The most detailed road design document published in Australia, covering widths, grades, berms, intersections, signage and inspection. It is also the standard most often audited by physical inspection, because a road either meets the geometry or it does not. See the full RS19 guide to the design and construction of mine roads.

RS20, dust control in surface mines

Supports the dust provisions of the Coal Mining Safety and Health Regulation 2017 and gives the framework for a dust management plan across every dust generating process on a surface operation. It sits alongside RS14, which deals with monitoring rather than control. See RS20 and dust control on a surface coal mine.

RS11, training

Covers induction, training needs by role, assessment, recognition of prior learning, refresher training and record keeping. It applies to surface and underground alike, and it is where the five yearly refresher obligation lives in practice. See RS11 and training in coal mines.

The guidance notes worth knowing on an open cut

Guidance notes carry no legal force, and several of them are the most practically useful documents the inspectorate has published. On an open cut, four earn their place.

• QGN 20, oxides of nitrogen in open cut blasting. Defines a fume event, sets out what to record when one happens, and who to report it to.
• QGN 29, surface tailings storage facility management. Design, construction, operation and the surveillance regime that validates all three.
• QGN 09, reviewing the effectiveness of the SHMS. The natural companion to RS22, because a structure that exists is not the same as a system that works.
• QGN 15, emergency preparedness for small mines and quarries. Written for smaller operations and still the clearest checklist available for anyone.

The obligation underneath all of it

Standards describe methods. Section 68 of the Act describes the receipts. The coal mine operator must keep a mine record holding the reports, findings and recommendations from inspections, investigations and audits at the mine, every directive issued under the Act, the remedial actions taken in response, and the record of serious accidents and high potential incidents. Matters stay in it for at least seven years, it has to be available for inspection, and nobody may alter it so that it stops being a correct and complete record.

That obligation is what turns every standard above from a document into something you have to be able to prove. It is covered on its own in the mine record and what Queensland law actually requires.

Where sites come unstuck

• Treating a standard as a checklist rather than a way of achieving an outcome. Ticking every clause and still carrying an unacceptable risk is a failure, and the Act is written to catch exactly that.
• Undocumented departures. The departure is usually sensible. The absence of the reasoning is what turns it into a finding.
• Assuming the current edition is the one on the shared drive. Standards are revised through tripartite working groups and reissued. RS20 and RS22 are both recent.
• Confusing a recognised standard with a guidance note, in either direction. One is admissible in evidence. The other explicitly is not sufficient on its own.
• Compliance that exists but cannot be shown. The work is done, the road is right, the training happened, and none of it can be produced without three people and a week of searching.

Making compliance visible instead of filed

Every standard above generates evidence: inspections, measurements, plans, competencies, records of change. The common failure is not that the work is skipped, it is that the evidence lands in five systems and a filing cabinet, and nobody can assemble it on the day it is asked for.

HazView holds that evidence against the place it belongs to on the mine. An inspection is logged where it happened, with the time, the person, the photographs and the result attached, and it stays there permanently. Overdue items and expiring competencies are visible rather than discoverable. Because the platform has a REST API, records can be fed in from the systems you already run and pushed back out to the ones that need them, which removes the double entry that makes people stop recording things properly in the first place.

It does not make the site compliant. That remains the site senior executive’s judgement. What it does is make the state of compliance something you can see on a map instead of something you reconstruct after the fact.

If you carry statutory responsibility on an open cut operation, see how HazView works for managers and SSEs or book a demo and put it against your own site.

Frequently asked questions

Are recognised standards mandatory?

No, not in the way a regulation is. A recognised standard states a way of achieving an acceptable level of risk, and it is admissible in evidence. You may take a different approach, but you must be able to show it achieves at least the same level of control, and that reasoning belongs in your safety and health management system.

How many recognised standards are there?

23 at the time of writing. About half apply only to underground operations. Twelve are relevant to an open cut. The register is maintained by Resources Safety and Health Queensland and is the only place to confirm the current list and edition.

Do recognised standards apply to quarries?

No. Recognised standards are made under the coal mining legislation. Quarries and mineral mines run under the Mining and Quarrying Safety and Health Act 1999 and use guidelines and guidance notes instead. Many quarries adopt RS19 voluntarily as a road design benchmark because nothing better exists.

What happens if we do not follow a recognised standard?

Nothing automatically. The question becomes whether the alternative you adopted achieves an acceptable level of risk, and whether you can demonstrate that. The practical risk is not the departure itself, it is being unable to produce the assessment that justified it.

How do I know I have the current edition?

Check the RSHQ register rather than a copy held on site or supplied by a training provider. Older editions circulate widely and cite superseded regulation sections. RS20 and RS22 in particular have been issued or reissued recently.

The post Recognised Standards for Queensland Open Cut Coal Mines appeared first on HazView®.