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.
Related guides
- Recognised Standards for Queensland Open Cut Coal Mines
- The Mine Record: What Queensland Law Actually Requires
- RS20: Dust Control in Surface Coal Mines
- Blast Fume Management in Open Cut Mining
- All QLD Open Cut Coal guides
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.