This paper provides an example of how industry can respond to the implementation of new regulatory approaches to mining risk, health and safety by adopting a robust, practical, software-based approach to the management of risk accountabilities in terms of competence, experience and suitability for obligations and responsibilities, as required in Queensland Coal Mining operations due to the introduction of Recognised Standard 22 (‘RS22’; Resources Safety and Health Queensland, 2021).
Based on the authors’ experience from working with several Qld mine operations, it offers a snapshot of the experiences, approaches and reservations faced collectively by industry as a result of the introduction of RS22.
Several challenges exist within the detail of RS22, leading to varied interpretations, implementation strategies and overall compliance between mine sites. Arguably the single biggest challenge identified has been how to find a balance between compliance and practicality – considering cost, operational interruption, available pathways for delivery of competence, ongoing compliance and value adding to the business operations and people.
Software-based solutions are increasingly being relied upon to address the introduction of new regulatory approaches and the significant administrative load placed on mining operation Site Senior Executives (‘SSE’) due to RS22 means this case is no different. This is further complicated given the continuous, ongoing changes with the site management structure witnessed by the authors across each of the mining operations as a result of continuous changes to personnel, the site risk profile and an overall mining industry uncertainty of how to respond to RS22. The stringent reporting/notification requirements under legislation compounds this further.
The approach put forward by the authors is a well-considered rationale and approach to the application of training and skilling; and equally how to ‘future proof’ the coordination of site training needs around changes to the Management Structure, the Risk Register, skilling processes and succession planning.
A brief investigation of other legislative frameworks concluded this approach would likely meet or exceed expectations of jurisdictions across Australia and overseas, making this a highly flexible approach for establishing a competent Management Structure to provide safe systems of work.