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Mine Health and Safety Act, 1996 (Act No. 29 of 1996)

Regulations

Guideline for a Mandatory Code of Practice

Occupational Health Programme (Occupational Hygiene and Medical Surveillance) on Personal Exposure to Airborne Pollutants

Part C : Format and Content of the Mandatory COP

 

1.         TITLE PAGE

 

The COP should have a title page reflecting at least the following:

 

1.1 The name of the mine;

 

1.2 The heading: "Mandatory Code of Practice for the Assessment of Personal Exposure to Airborne Pollutants";

 

1.3 A statement to the effect that the COP was drawn up in accordance with guideline DMR 16/31214-A1 issued by the CIOM;

 

1.4 The mine reference number for the COP;

 

1.5 The effective date;

 

1.6 The revision dates (if applicable); and

 

1.7 The DMR mine code number.

 

2. TABLE OF CONTENTS

 

The COP must have comprehensive table of contents.

 

3. STATUS OF THE MANDATORY CODE OF PRACTICE

 

This section must contain statements to the effect that:

 

3.1 The COP was drawn up in accordance with guideline DMR 16/3/2/4-A1 issued by the CIOM;

 

3.2 This is a mandatory COP in terms of Section 9(2) and 9(3) of the MHSA;

 

3.3 The COP may be used in an accident investigation/inquiry to ascertain compliance and to establish whether the COP is effective and fit for purpose;

 

3.4 The COP supersedes all previous relevant COPs; and

 

3.5 AH managerial instructions, recommended procedures (voluntary COPs) and standards on the relevant topics must comply with the COP and must be reviewed to ensure compliance.

 

4. MEMBERS OF THE DRAFTING COMMITTEE

 

4.1 In terms of Section 9(4) of the MHSA the employer must consult with the health and safety committee on the preparation, implementation or revision of any COP.

 

4.2 It is recommended that the employer should, after consultation with the employees in terms of the MHSA, appoint a committee responsible for the drafting of the COP.

 

4.3 The members of the drafting committee assisting the employer in drafting the COP, should be listed giving their full names, designations, affiliations and experience. This committee must include competent persons sufficient in number to effectively draft the COP.

 

5. GENERAL INFORMATION

 

General relevant information relating to the mine must be stated in this section of the COP, which must include at least the following:

 

5.1 A brief description of the mine and its location;

 

5.2 The commodities produced;

 

5.3 The mining method or combination of methods used at the mine must be listed. This section must discuss the degree of mechanisation, taking care to identify the potential sources of pollutants and possible pathways of exposure, and possible exposure scenarios;

 

5.4 The general controls in place to prevent exposure to airborne pollutants including ventilation arrangements;

 

5.5 Other related COPs and management standards must be reviewed concurrently to avoid conflict of requirements as laid down by the employer. The objective would be to have an integrated system; and

 

5.6 The unique features of the mine that have a bearing on this COP and cross-reference them to the risk assessment conducted.

 

6. TERMS AND DEFINITIONS

 

Any word, phrase or term of which the meaning is not absolutely clear, or which will have a specific meaning assigned to it in the COP, must be clearly defined. Existing and/or known definitions should be used as far as possible. The drafting committee should avoid jargon and abbreviations that are not in common use or that have not been defined. The definitions section should also include acronyms and technical terms used.

 

7. RISK MANAGEMENT

 

7.1 Section 11 of the MHSA requires the employer to identify hazards, assess the health and safety risks to which employees may be exposed while they are at work, record the significant hazards identified and risks assessed. The employer must determine how the significant risks identified in the risk assessment process must be dealt with, having regard to the requirement of Section 11(2) and 11(3) that, as far as reasonably practicable, attempts should first be made to eliminate the risk, thereafter to control the risk at source, thereafter to minimise the risk and thereafter, insofar as the risk remains, to provide personal protective equipment and to institute a programme to monitor the risk.

 

7.2 To assist the employer with the risk assessment with all possible relevant information such as accident statistics, ergonomic studies, research reports, manufacturers specifications, approvals, design and performance criteria for all relevant equipment should be obtained and considered.

 

7.3 In addition to the periodic review required by Section 11(4) of the MHSA, the COP should be reviewed and updated after every serious incident relating to the topic covered in the COP, or if significant changes are introduced to procedures, mining and ventilation layouts, mining methods, plant or equipment and material.

 

8. KEY ELEMENTS TO BE ADDRESSED IN THE COP

 

8.1 Where the employers risk assessment indicates a need to establish and maintain a system of occupational hygiene measurements and a system of medical surveillance, or where such systems are required by regulations, the following key elements must be addressed in the COP:
• Risk assessment and control.
• Personal exposure monitoring.
• Hierarchy of controls.
• Medical surveillance.
• Reporting and reviewing.

 

These key elements are shown in Figure 1 below.

The occupational health programme to be implemented on the mine should be summarised in the COP in a flow chart similar to Figure 1.

 

8.2 Components of an occupational health programme

 

The occupational health programme has two components namely:

8.2.1 Occupational hygiene; and
8.2.2 Medical surveillance.

 

N419 Part C8 clip0001

 

8.3        Occupational hygiene programme

 

In order to prepare the occupational hygiene programme for the mine, the COP should cover the following steps:

 

Step 1: Risk assessment.

Step 2: Determination of HEG.

Step 3: Sampling and analysis methodology and quality control.

Step 4: Personal exposure monitoring.

Step 5: Linking of occupational exposure.

Step 6: Hierarchy of control measures.

Step 7: Reporting and recording.

 

8.3.1 Risk assessment

The COP should set out measures to ensure that a qualitative and quantitative risk assessment process is followed and takes into account all the factors influencing the health of employees.

 

NOTE: Chapter 3 of the handbook published by the Safety in Mines Research Advisory Committee (SIMRAC): "Handbook on Occupational Health Practice in the South African Mining Industry" could be consulted to assist in conducting a risk assessment.

 

The COP should address the following points:

 

8.3.1.1 Baseline risk assessment

 

At the initial commencement of a system of occupational hygiene measurements, as contemplated in Section 12(2) of the MHSA, a baseline risk assessment is to be conducted to assess exposure to airborne pollutants.

 

8.3.1.2 The risk assessment must be described with reference to:
(a) Any airborne pollutant(s) to which employees are being exposed to (refer to Chapter 22 of the MHSA airborne pollutants occupational exposure limits);
(b) The route of entry (where applicable e.g. inhalation, absorption, ingestion, etc.) and health effects that these individual airborne pollutants can have on employees;
(c) Where such pollutants may be present, e.g. welding bay, spray painting booth, battery charging stations, stope face, development end, etc.;
(d) The airborne nature of those pollutants identified, e.g. gases, fumes, vapour mists, fibres, dusts etc.;
(e) The nature of the key workplace operations and activities that pose the greatest potential for exposure with identified airborne pollutants;
(f) The occupations and number of employees who are being exposed to airborne pollutants;
(g) The pattern (e.g. intermittent, continuous, etc.), duration and frequency of employee exposure to the airborne pollutants identified;
(h) The actual exposure levels measured compared to occupational exposure limits;
(i) The control measures in place, (e.g. substitution, engineering, administration, personal protective equipment etc.), the additional control measures required to be instituted in order to reduce or maintain exposures to below the OELs, and if applicable, the planned programme of implementation;
(j) The frequency of any ongoing monitoring to assess the effectiveness of the controls mentioned above; and
(k) The relevant material safety data sheets as contemplated in Section 21(4)(a), (b) and (c) of the MHSA.

 

NOTE:   For the purpose of the risk assessment the commodity codes, activity codes, occupational codes and pollutant codes as set out in Annexure A should be used. Compliance with Annexure A is mandatory.

 

8.3.1.3 Review of risk assessment

 

The COP must address the review of the risk assessment whenever circumstances arise or change at the mine that could have an impact on the original assessments, and at least in the following instances;

(a) When outcomes of medical surveillance programs indicate the need for it;
(b) When a Section 11.5 investigation indicates the need for it;
(c) When new or revised legislation is introduced;
(d) When new mining methods are introduced;
(e) When process changes are introduced (e.g. in process plants); and
(f) When new types of machinery are introduced.

 

8.3.1.4 Post risk assessment

 

The COP must address on an annual basis, the review of the risk assessment (continuous risk assessment and management) based on the personal exposure monitoring data of the previous cycle.

 

Historical data is to be maintained as provided far in Section 15(2)(a).

 

8.3.2 Determination of HEGs

 

The COP should address the following points:

 

8.3.2.1 HEGs should be identified for purposes of personal exposure monitoring. The baseline risk assessment will enable the identification of HEGs, which will be established as follows:

 

Step 1

 

The sub-division of the mine into sampling areas (e.g. surface = sampling area 1, underground section A = sampling area 2, underground section B = sampling area 3, underground section C = sampling area 4, etc).

 

NOTE:   Surface operations proceed to step 3. Underground operations proceed to step 2.

 

Step 2

 

At underground mines, sampling areas should be sub-divided into ventilation districts which are areas of a mine, ventilated independently from other areas with a common dedicated intake and return airways. Any airborne contaminants released in a ventilation district will only affect that particular district and does not circulate through other areas of the mine where people may be exposed.

 

In order for an area to be classified as a ventilation district it must comply with:

• Ventilated independently from other are
• Independent intake and return airways.
• Does not contaminate other areas.

 

Step 3

 

The sub-division of the sampling areas into activity areas as per the activity area code list found in Annexure A (mandatory codes). Annexure A must be complied with.

 

Step 4

 

To ensure that adequate measurements of personal exposures (refer also to paragraph 8.3A below) are taken in line with the identified airborne pollutants for each activity area If insufficient historical personal exposure data is not available regarding the extent of the risk, a personal monitoring survey must be undertaken for each identified airborne pollutant.

 

NOTE:   Acceptable methodologies on personal monitoring as stipulated by NIOSH should be used for this assessment.

 

Step 5

 

A statistical analysis should be conducted. Annexure B could be consulted in this regard. The results of the identified B.

 

NOTE: Annexure B is attached for information purposes only.

 

Plot past data over time to determine whether the exposure trends are higher or lower. If the exposure trends exist, the Section 12(1) appointee should use only the most recent exposure data in the initial assessment.

 

In order to ensure that HEGs are correctly allocated a statistical analysis of the results is to be done. An example of such an approach is shown in Annexure B.

 

NOTE: Annexure B is attached for information purposes only.

Once the personal exposures within each activity area have been compared to their respective OEL values, each activity area can now be categorised into classification bands to determine the various HEGs within that activity area. The classification bands for airborne pollutants are tabled in Annexure C. Annexure C forms part of this guideline and must be complied with.

 

NOTE: An activity area e.g. stoping, is not a HEG. This activity area e.g. sloping, must be subdivided into the classification bands as shown above. These classification bands are the HEGs within that particular activity area.

 

Repeat step 4 for every pollutant identified in the risk assessment process.

 

Step 6

 

In this step were a single pollutant acting independently has been identified in an activity area the following process must be followed:

(a) Once the personal exposures within each activity area has been compared to the respective OEL values of the single pollutant, that activity area can now be categorised into classification bands determined by the various HEGs within that activity area. The classification bands for airborne pollutants are depicted in Annexure C. Annexure C is mandatory and must be complied with.
(b) If an employee is exposed to a number of identified pollutants, which have an additive effect, step 7 must be followed.
(c) Repeat step 5 for every such identified pollutant.

 

NOTE:

(1) Single pollutant - where no additive effects are known or considered likely, the constituents can be regarded as acting 'independently'. It is then sufficient to ensure compliance with each of the individual OELs.

 

(2) Refer to Annexure D with reference to identified pollutant acting independently.

 

NOTE: Annexure D is attached for information purposes only.

 

Step 7

 

When pollutants that have an additive effect have been identified in an activity area where these effects are additive, their combined effects must be used when classifying the activity area into their respective HEGs. The following formula must be used to assess the combined effect.

 

C1/L1 + C2/L2 + C3/ L3     .... for compliance, the combined effect should be < 1

where C1, C2 etc. are the concentrations of constituents in air

and L1, L2 etc. are the corresponding OELs.

 

NOTE:   The OELs for pollutants listed in Schedule 22.9(2)(a) of the MHSA are for single compounds or for pollutants containing a common entity. Workers are however frequently subjected to mixed exposures. lt is therefore necessary to take into account the possible additive or synergistic effects of these pollutants. Due to the difficulty in assessing, if the effects of a mixture of pollutants are either additive or synergistic, the requirements of this COP will be to treat all such cases as if they are additive. With all types of mixed exposures, it is essential that the classification band category assessment should be based on the concentrations of each of the constituents in air to which workers are exposed.

 

Table C1 in Annexure C depicts exposures to the various hazards that can be considered as being additive or synergistic. Annexure C is mandatory and must be complied with.

 

NOTE:   Refer to Annexure D with reference to identified pollutants that have an additive effect. Annexure D is for information purposes only.

 

8.3.2.2 At the end of each cycle (annually; end of calendar year) sampling results for each HEG must be statistically analysed and re-classified when required. Re classification of HEGs should be done by means of statistically recognised principles. 90% confidence limits are to be used to test the homogeneity of HEGs. Refer to Annexure B for an example.

 

NOTE: Annexure B is attached for information purposes only.

 

The total number of exposed employees will be determined at the beginning of annual reporting cycle and would only change if there is an increase in employees during the quarterly reporting cycle (exposed individuals are only counted once in an annual reporting cycle to prevent duplicate counting).

 

Reduction in employees would not reduce the total number of exposed employees during the reporting cycle.

 

NOTE:   The total number of exposed employees will be determined at the start of annual sampling cycle based on the previous year's results in accordance with the HEG classification based on the various exposure bands.

 

8.3.2.3 HEGs must be re-assessed whenever circumstances arise or change at the mine when the following occurs:
(a) Exposure levels change due to controls being initiated and likewise, when controls deteriorate.
(b) Employee complaints are received.
(c) Processes are changed (e.g. change in procedures, mining and ventilation layouts, mining methods, plant, equipment or material), d) Occupational illness occurs,
(e) A change in exposure category occurs.
(f) Other events warranting re-evaluation occurs:
(i) New technological data; and
(ii) New regulatory initiatives.
(g) Should the review f the baseline assessment warrants it.

 

8.3.3 Sampling, analysis methodology and quality control

 

The COP must address the following points:

 

8.3.3.1 Continuing sampling strategy Continuing sampling must be conducted to assess whether significant changes in trends have occurred and should be added to accumulated data during statistical analysis re-classification of HEGs.
(a) Determining sample size

The total number of samples should be evenly spread out over a twelve-month period for all categories, that is A, 13 and C, as below:

A minimum of 5% or five samples (whichever is the greater) per HEG should be taken as per classification bands in Annexure C as per the following:

(i) Category A - 5% or five samples per quarter;
(ii) Category 13 - 5% or five samples six-monthly to be evenly spread biannually;
(iii) Category C - 5% or five samples per annum to be evenly spread annually; and
(iv) Category D - no sampling plan for this category. Measurement results that are below 10% of the OEL will be reported under this category.

 

NOTE: Annexure C is mandatory and must be complied with.

 

(b) Section 12(1) appointees must use their professional judgment to decide whether additional samples need to be taken in order to increase the confidence that HEGs are appropriately categorised.

 

8.3.3.2 Sampling strategy and schedules

 

The COP should address a sampling strategy that includes a monitoring schedule for each HEG. The sampling cycle and records thereof should be kept as required by law (see for example Sections 12(3) and 15(2)(b) of the MHSA).

 

8.3.3.3 Sampling methodology
(a) The COP should address, for each pollutant identified, an appropriate sampling methodology selected and implemented (refer to Annexure E: Background information on particulates; sampling and analysis methodology. Annexure E is for information purposes only),
b) The COP should put measures in place to ensure that a quality control program for the sampling methodology is developed and implemented.

 

NOTE:

(1) Refer to Annexure F: Quality assurance. Annexure F is for information purposes only.
(2) The relevant methodology chosen for each pollutant identified must be stated in the COP,

 

8.3.3.4 Chemical analysis methodology

 

The COP should address th following points:

(a) For each pollutant identified, an appropriate chemical analysis methodology, which complies with internationally accepted good practice, should be selected and implemented. All the selected chemical analytical methods should be listed in the COP e.g. NIOSH methods for silica crystalline respirable: NIOSH 7500 (XRD); NIOSH 7602 (IR).
(b) The sample analysis should be done either by a laboratory that is accredited (accredited to chemically analyse the specific pollutants) in terms of South African bureau of Standards (SABS) ISO/IEC 17025 of the South African National Accreditation System (SANAS), or a laboratory that is participating in a proficiency testing program and is in a process of obtaining SANAS accreditation, which latter laboratory must produce a proficiency test certificate to the client before doing any sample analysis.
(c) A minimum number of samples taken as determined in accordance with 8.3.3.1 (a) of this guideline must each be individually analysed.

 

NOTE:   The results from the analysis obtained in a HEG will be averaged and allocated to the specific HEG in which the samples were taken.

 

8.3.3.5 Gravimetric weighing facilities

 

The COP should contain measures to ensure that gravimetric weighing facilities have a quality control program in place (refer to Annexure E for information on the requirements for a weighing facility and to Annexure F for a quality control program. Annexures E and F are for information purposes only),

 

8.3.4 Personal exposure monitoring

 

The COP should set out measures to ensure that personal exposure monitoring is conducted to obtain reliable estimates of employee shift exposures in a workplace.

Samples taken should be:

(a) Representative of all full working shifts;
(b) Measured and compared to occupational exposure limits per working shift e.g. day shift and night shift;
(c) Randomly spread over the full sampling cycle period for each HEG; and
(d) Randomly spread across all occupations within the HEG.

 

8.3.4.1. Training

 

The COP should set out the training programme in place for:

(a) Storage and maintenance of equipment;
(b) Issuing of the sampling equipment;
(c) Wearer of the sampling equipment;
(d) Handling of the sampling equipment;
(e) Transportation of equipment; and
(f) Pre- and post-calibration of the sampling train checks.

 

8.3.5        Hierarchy of control

 

The COP should address the hierarchy of controls which are going to be implemented to mitigate the risk(s). The following hierarchy of controls should be taken into consideration:

• Elimination;
• Engineering controls;
• Administrative controls;
• Minimising (the risk); and
• Personal protective equipment.

 

8.3.6        Recording and reporting

 

The COP should address the following:

 

8.3.6.1        Record keeping system

 

A record keeping system, which records the exposure history of each HEG at the mine, should be kept and be readily available at the mine, including any reasons for deviation on sample results such as:

(a)        Controls not operating effectively; and

(b) Events or factors which have influenced the results, e.g. air sampling at surface operations after high rainfall or during excessive winds.

 

8.3.6.2        Mandatory reports

 

Reporting to the DMR must be done on a quarterly basis for all categories, that is A, B, C and D (refer to Annexure C: Classification bands and reporting forms. Annexure C is mandatory and must be complied with).

 

NOTE:

(1) For all categories A, B and C, the measurement results on the samples taken at that time must be reported at the end of each quarter. The rolling average results must be reported at the end of each sampling cycle.
(2) The results in a HEG of which 90th percentile equates to less than 10% of the OEL will be classified under D category.
(3) Pollutant(s) that do not have an additive effect on the target organ(s) must be separately reported.

 

8.4 Occupational medical surveillance

 

8.4.1 Occupational medical surveillance programme.

 

The COP should describe:

 

8.4.1.1 The medical surveillance program at the mine as required in terms of Section 13 and Regulations 11.5, 11.6 and 11.7 of the MHSA and any additional medical surveillance required in terms of the employers risk assessment.

 

8.4.1.2 The method used to link the occupational hygiene measurements (e.g. exposures to individual pollutants as well as additive or synergistic mixtures) to each employee's record of medical surveillance as contemplated in Section 12(3) of the MHSA.

 

NOTE: A manual or computerised system could be utilised to link this information. This system may have to be customised in accordance with the employer's specific needs or commercial programs. Effective communication between the Section 12(1) appointee and the occupational medical practitioner is recommended to ensure that the linkages between occupational hygiene exposures' history and medical conditions are identified.

 

8.4.1.3 The procedure on how the following categories of medical surveillance in terms of the MHSA, will be conducted:
(a) Initial examination - in terms of Section 13(2)(c);
(b) Periodic examination - in terms of Section 13(2)(c); and
(c) Exit examination - in terms of Sections 17 and 19(2).

 

8.4.2 Methodological standards for test techniques forming part of medical surveillance

 

8.4.2.1 The COP should set out measures to ensure that chest x-rays:
(a) Are at least 35x43cm in size, even when digital;
(b) Are of a suitable quality for proper identification and classification of pneumoconiosis: and
(c) Show the date, name of individual and any unique form of personal identification used by the mine (e.g. identity number, personnel number, passport number, company number, etc,).

 

8.4.2.2 The COP must set out how lung function testing will be conducted.

 

NOTE:   The occupational medical practitioners Guidance Note for Lung Function Testing (DMR 25/5/P) and the Guidance Note for Occupational Medical Practitioners: Tuberculosis Control Programs (DMR 25/5/P) could be consulted.

 

8.4.3 Inclusive medical surveillance system

 

8.4.3.1 The COP should set out measures to ensure that the system of medical surveillance is designed in consultation with the occupational medical practitioner to avoid duplication where employees are exposed to more than one hazard. A single, similar test could suffice for the medical surveillance of more than one hazard. It could therefore be possible to use the same examination or test for the medical surveillance of more than one hazard, provided that the requirements of medical surveillance for each hazard are achieved.