TABLE OF CONTENTS 1.0 PURPOSE... 2 2.0 SCOPE... 2 3.0 LEGISLATIVE MANDATE... 2 4.0 REFERENCES... 2 5.0 DEFINITIONS... 3 6.0 SAFETY & ENVIRONMENTAL RISK ANALYSIS... 13 7.0 PROCEDURE... 13 7.1 Arrium Code of Practice Critical Elements... 13 7.2 Safe Systems of Work... 13 7.2.1 Initial Response (and Securing the Scene)... 13 7.2.2 Assessment and Notification... 14 7.2.3 Investigation... 20 7.2.4 Corrective Actions... 23 7.2.5 Effectiveness Review and Close Out... 25 8.0 TRAINING AND COMPETENCE... 26 8.1 Awareness Training... 26 8.2 Lead Investigator/Investigation Team... 26 9.0 RESPONSIBILITIES, AUTHORITIES AND ACCOUNTABILITIES... 26 9.1 OneSteel / Arrium Safety Council... 26 9.2 OneSteel / Arrium Safety Network... 27 9.3 Business Unit Lead Teams (eg. Mining Lead Team led by Chief Executive)... 27 9.4 General Manager... 27 9.5 Business Management Team (eg. Mining Operations Lead Team)... 27 9.6 Business Area/Stream Managers (eg. Manager Mining Stream)... 27 9.7 Site / Department Managers (eg. Operations / Maintenance Managers)... 28 9.8 Supervisor / Shift Team Leader (including Contractor supervisors)... 28 9.9 Contractor Controllers... 29 9.10 Investigation Leader... 29 9.11 Workers (including Contractor workers)... 29 9.12 Health and Safety Representative / Safety Coordinator... 29 9.13 Health & Safety Department... 29 9.14 Departmental Environment Coordinators/advisors... 30 9.15 Environment Department... 30 10.0 MONITORING AND MEASUREMENT... 30 11.0 DOCUMENTATION... 31 11.1 WORK INSTRUCTIONS... 31 11.2 TOOLS... 31 11.3 FORMS... 31 11.4 ATTACHMENTS... 31 Any PRINTED copies of this procedure are UNCONTROLLED Page: 1 of 31
1.0 PURPOSE This procedure is to ensure that when incidents do occur; those injured are cared for and no one else is at further risk of injury; environmental impacts are minimised they are reported to those responsible for undertaking investigations within the business including supervisors and/or managers; responsible persons immediately investigate, root causes are identified, corrective actions are implemented and reviewed for effectiveness, learnings are applied and shared to prevent recurrences; and that information is communicated to management & relevant statutory authorities when required. This procedure also gives guidance to Arrium Contractor Controllers to ensure they are aware of their responsibilities in relation to incidents that have occurred by the Contractors they are working with on Arrium sites. 2.0 SCOPE This procedure applies to all Arrium Mining business sites, railway corridors, Contractors and Visitors. Arrium Mining Contractors must adhere to the minimum requirements of this procedure within their own controlled approved operations on Arrium Mining sites. 3.0 LEGISLATIVE MANDATE 3.1 South Australian Work Health and Safety Act 2012 3.2 South Australian Work Health and Safety Regulations 2012 3.3 WHS Code of Practice How To Manage Health and Safety Risks 3.4 Rail Safety National Law (South Australia) Act and Regulations 2012 3.5 South Australian Electricity Act 1996 3.6 The Environment Protection Act 1993, and in particular Section 83 of the Act. Various other legislation also governs environmental incident notification see below. 4.0 REFERENCES 4.1 Arrium Work Health and Safety Policy 4.2 Arrium Crisis and Emergency Management Policy 4.3 Arrium Code of Practice Incident Investigation 4.4 Arrium OHS Risk Management Code of Practice 4.5 OST-OHS-INV-FRM-020 - Arrium / OneSteel Incident Form 4.6 OST-OHS-SYS-PRO-050 - Arrium OHS Monitoring and Measurement Procedure 4.7 OST-OHS-RM-PRO-020 & 021 Crisis Management Manuals 4.8 QP29.13 Safety Risk Management 4.9 PO1.19 - LifeSaver Program Policy Any PRINTED copies of this procedure are UNCONTROLLED Page: 2 of 31
4.10 WI29.541 Management of Review of Disciplinary Action Arising From Safety Breaches & HPIs 4.11 WI75.WHS.COM.001 Communication 4.12 Arrium Environment Policy 4.13 QP50.67 Environment Incident Response 4.14 EPA Licence 13109 Train Loading Activities, Whyalla Port & Pellet Plant 4.15 EPA Licence 13110 Ardrossan 4.16 EPA Licence 17122 - Concentrator & OBP 4.17 Various EPA Licence Exemptions 4.18 Various Programs for Environment Protection and Rehabilitation (PEPR s) Mining 4.19 Various Development Approvals (DAC) 4.20 Environment Protection Act 1993 4.21 Aboriginal Heritage Act 1988 4.22 Animal Welfare Act 1985 4.23 Development Act 1993 4.24 Environment Protection and Biodiversity Conservation Act 1999 4.25 Heritage Places Act 1993 4.26 Mining Act 1971 4.27 Native Vegetation Act 1991 4.28 Natural Resource Management Act 2004 5.0 DEFINITIONS 5.1 Incident Categories Incidents can be split into three categories: safety, environmental harm/nuisance or quality. Attachment 1 outlines examples of Environment Incidents. QP50.67 also provides examples of various environmental incidents. 5.2 Incident An unexpected, unplanned occurrence, which: Resulted in injury/illness or had the potential to result in injury or illness Resulted in property damage or potential property that exposes a risk to health and safety of a worker or any other person Environmental harm or nuisance Any other incident that exposes a risk to health and safety of a work or any other person. 5.3 Near Miss An event where there was almost injury or property damage. 5.4 Sensitive Incident Incidents that: involve the public are of media interest are attended by police are attended by regulatory authorities are judged to be so by Executive General Manager/General Manager. 5.5 Serious Safety Incident (as per WI29.541) Includes, but not limited to: Lifesaver Breaches Breach of basic safety rules Safety Breaches involving; Potential for serious injury Repeated or wilful safety breaches Where formal written disciplinary action is likely Any PRINTED copies of this procedure are UNCONTROLLED Page: 3 of 31
5.6 Environmental Harm Any harm or potential harm to the Environment of whatever degree or duration including an environmental nuisance, caused by pollution. Environmental harm has the potential to be classed as material or serious, as defined by the Environment Protection (EP) Act 1993, Part 1(3, 5), requiring regulator notification. 5.7 Environmental Nuisance Any adverse effect on an amenity value of an area that is caused by pollution and unreasonably interferes with or is likely to interfere unreasonably with the enjoyment of the area by persons; or Any unsightly of offensive condition caused by pollution. 5.8 Environmental Non-Compliance (NC) An Incident where general environmental legal requirements or specific licence/agreement conditions are breached. Non-Compliances are identified, reviewed, recorded and reported by the Manager, Environment and Sustainability and Mines Environment Assurance Manager. 5.9 Severity Zero Environmental Incident An incident where a slight change in circumstances could have resulted in an Environmental Effect. Severity Zero Incidents must have a potential impact assigned where possible. 5.10 Pollutant Any solid, liquid or gas (or combination) including noise, waste, smoke, dust, fumes and odours. (Refer to the Environment Protection (EP) Act 1993, Part 1(3) for a detailed definition) 5.11 Pollute To discharge, emit or deposit pollutants, or cause to fail to prevent the discharge, emission, depositing, disturbance or escape of pollutants. (Refer to the Environment Protection (EP) Act 1993, Part 1(3) for a detailed definition) 5.12 FDR Fugitive Dust Rating 5.13 Quality Event / Incident An event that affects the quality of a product / service, or that impacts on the business area/stream s ability to provide an acceptable product to a customer, or that impacts on productivity, need to be investigated. The reason for formally investigating and reporting of these events is to ensure we continually improve our processes. This is achieved by, identifying the root cause and implementing corrective actions to ensure that these occurrences do not happen in the future. This will also provide an historic record for future reference and auditing purposes. In general some examples of events that require a full investigation are: Any unsightly or offensive condition caused by pollution. Equipment failure impacting on supply of product to a customer. Power failure (electrical trips) causing plant disruption. Loss of productivity. Excessive rework or scrap generation. Product or service outside the agreed customer specifications (Service Level Agreement). Major change to operating conditions (Furnace Cooling). Customer complaints. Any PRINTED copies of this procedure are UNCONTROLLED Page: 4 of 31
5.14 Notifiable Incident (under WHS Act 2012) Means (a) the death of a person; or (b) a serious injury or illness of a person; or (c) a dangerous incident. Refer to FORM75.WHS.INV.001 SafeWork SA Notifiable Incident Report Form (for use by Pellet Plant, Whyalla Port and any other notifiable incidents that have NOT occurred on Arrium Mining mine sites / mining operations) 5.15 Notifiable Mining Incident (under WHS Regulations 2012) Means an incident (other than a notifiable) that: (a) results in illness or injury that require medical treatment within the meaning of 13.2 of Schedule 24 (this includes suturing of a wound, treatment of fractures, treatment of bruises that require drainage of blood, and treatment of 2 nd and 3 rd degree burns); or (b) is a high potential incident (which is an incident that would have been a dangerous incident as stated in 5.16 if a person were in the vicinity at the time of the incident or event occurred and in usual circumstances a person could have been in that vicinity at that time) Refer to FORM75.WHS.INV.002 SafeWork SA Mining Operations Notifiable Incident and Mining Incident Report Form (for use for any notifiable incident at Arrium Mining mine sites / mining operations) 5.16 Serious Injury or Illness Of A Person (under WHS Act 2012) Means an injury or illness requiring the person to have (a) immediate treatment as an in-patient in a hospital; or (b) immediate treatment for (i) the amputation of any part of his or her body; or (ii) a serious head injury; or (iii) a serious eye injury; or (iv) a serious burn; or (v) the separation of his or her skin from an underlying tissue (such as degloving or scalping); or (vi) a spinal injury; or (vii) the loss of a bodily function; or (viii) serious lacerations; or (c) medical treatment within 48 hours of exposure to a substance, and includes any other injury or illness prescribed by the regulations but does not include an illness or injury of a prescribed kind. 5.17 Dangerous incident (under WHS Act 2012) Means an incident in relation to a workplace that exposes a worker or any other person to a serious risk to a person's health or safety emanating from an immediate or imminent exposure to (a) an uncontrolled escape, spillage or leakage of a substance; or (b) an uncontrolled implosion, explosion or fire; or (c) an uncontrolled escape of gas or steam; or (d) an uncontrolled escape of a pressurised substance; or (e) electric shock; or (f) the fall or release from a height of any plant, substance or thing; or (g) the collapse, overturning, failure or malfunction of, or damage to, any plant that is required to be authorised for use in accordance with the regulations; or (h) the collapse or partial collapse of a structure; or Any PRINTED copies of this procedure are UNCONTROLLED Page: 5 of 31
(i) the collapse or failure of an excavation or of any shoring supporting an excavation; or (j) the inrush of water, mud or gas in workings, in an underground excavation or tunnel; or (k) the interruption of the main system of ventilation in an underground excavation or tunnel; or (l) any other event prescribed by the regulations, (Regulation 699A) (Note: the unplanned loss of control of heavy earthmoving machinery (including failure of braking or steering) at a mine is a dangerous incident) 5.18 SafeWork SA Business Unit of the Department of the Premier and Cabinet. SafeWork SA is responsible for administering industrial relations (IR) legislation and managing all Work Health and Safety (WHS) functions in South Australia. 5.19 ComCare Business Unit of the Australian Government. There are certain Contractor organisations performing work for Arrium Mining who are self-insured under ComCare Scheme which provides rehabilitation and workers' compensation and OHS arrangements for their employees. Instead of reporting the required incidents to SafeWork SA, these organisations must follow incident reporting procedures required by ComCare 5.20 Office of the Rail Safety Regulator The Office of the National Rail Safety Regulator (ONRSR) is an independent body corporate established under the Rail Safety National Law (South Australia) Act 2012. Rail Transport Operators must report to the Regulator all notifiable occurrences that happen on, or in relation to, the Rail Transport Operators railway premises or railway operations. 5.21 Notifiable Occurrence (under Rail Safety National Law (South Australia) Act 2012) Means an accident or incident associated with railway operations (a) that has, or could have, caused - (i) significant property damage; or (ii) serious injury; or (iii) death; or that is; (b) or is of a class that is, prescribed by the national regulations to be a notifiable occurrence or class of notifiable occurrence Refer to FORM75.WHS.INV.003 ONRSR Notifiable Occurrences Written Report 5.22 Office of the Technical Regulator Business Unit of the South Australian Government Department for Manufacturing, Innovation, Trade, Resources and Energy (DMITRE). While the Office of the Technical Regulator is responsible for the administration of the Electricity Act 1996, Gas Act 1997, Energy Products (Safety and Efficiency) Act 2000, its primary objectives are ensuring the safety of workers, consumers and property as well as compliance with legislation, technical standards and codes in the electricity and gas industries. If the incident being notified is related to an electric shock, gas infrastructure, or gas fitting, the Office of the Technical Regulator (OTR) must be also be notified by authorized Arrium persons. This person is the Arrium Electrical Inspector or their delegate. Refer to FORM75.WHS.INV.004 OTR Electrical Shock Incident Report Form 5.23 EPA (South Australian) Environment Protection Authority Any PRINTED copies of this procedure are UNCONTROLLED Page: 6 of 31
5.24 Regulator-Notifiable Environmental Incidents An incident which have caused or has the potential to cause material or serious environmental harm as defined by the Environment Protection (EP) Act 1993, Part 1(3, 5) OR an incident/noncompliance identified by the National Manager Environment and/or Mines Environment Assurance Manager requiring notification. Refer to TOOL75.WHS.INV.003 Risk Profiling (Consequence) 5.25 Potential Consequence The most likely health and safety outcome that could have occurred due to an event or near miss. This may be greater than the actual consequence, but cannot be less. 5.26 Actual Consequence The health, safety or environmental outcome that occurs due to an event. 5.27 Maximum Reasonable Consequence The most severe consequence that is considered reasonably believable for the combination of factors which led to the incident. 5.28 High Potential Incident/Injury (HPI) Consequence (Severity) Level 4 or 5 A high potential incident is any incident with a potential consequence (severity) of 4 or greater. It is an incident that has a Maximum Reasonable Consequence of a serious injury, fatality or multiple fatalities. In addition an incident may be deemed to be a High Potential Incident by the Manager HSE Mining, Manager, Environment and Sustainability or Mines Environment Assurance Manager through discussion with the General Manager. These include all major loss/injury events where the following have or could have realistically occurred: Near fatality, single fatality, or severe irreversible disability or impairment or short/long term health effects leading to multiple fatalities. Financial losses > A$50 Million Productivity losses > 5 days Incidents likely result in major health, safety or environmental regulatory investigation (i.e. Chemical spills, etc) Electrical Incidents of: Any electric shock on equipment with a voltage greater than 50V AC or 120V ripple free DC Exposure or potential exposure to an arc fault event, electrical fire or explosion of electrical equipment Exposure to a voltage greater than 50V AC or 120V ripple free DC where the hazards/risks have not been identified, documented and controlled. Environmental incidents which have caused serious or very serious environmental effects with impairment of ecosystem function (e.g. destruction of conservation rated species of flora community or habitat of a conservation rated species of fauna). (Legal) Major breach of legislation with potential major fine and/or investigation and prosecution by authority (Corporate Citizenship community etc) Serious or significant public or media outcry (international coverage). License to operate might be lost or is threatened. Reputation severely tarnished (e.g. very serious widespread social impacts, permanent or irreparable damage to highly valued structures/items/locations of cultural significance) Refer to TOOL75.WHS.INV.003 Risk Profiling (Consequence) Any PRINTED copies of this procedure are UNCONTROLLED Page: 7 of 31
5.29 Zero Barrier Incident A High Potential Incident is classified as Zero Barrier where all barriers or defences have failed and only luck determined the outcome. 5.30 Medium Potential Incident/Injury - Consequence (Severity) Level 3 These include all significant loss/injury events or environmental incidents where the following have or could have realistically occurred: Injuries likely to cause a reversible or moderate irreversible disability or impairment. MTI or LTI Financial losses of A$10m-A$50m Productivity losses >12 hours and < 5 days Environmental incidents which have caused moderate effects on biological or physical environment but not affecting ecosystem function (e.g. oil spill causing impacts on the shoreline) (Legal) Serious breach of regulation with investigation or report to authority with prosecution and/or moderate fine possible. (Corporate Citizenship community etc) Attention from media and/or heightened concern by local community. Environment credentials moderately affected. (e.g. Significant damage to structures/items of cultural significance). Refer to TOOL75.WHS.INV.003 Risk Profiling (Consequence) 5.31 Low Potential Incident/Injury - Consequence (Severity) Level 1 or 2 These include all minor loss / injury events or environmental incidents where the following have or could have realistically occurred: Injuries resulting in first aid treatment only, and potentially incapacity to work on a restricted work basis Financial losses of <A$10m (EBITDA) Productivity losses < 12 hours All electric shocks that are not LV or HV No lasting effects and/or low level, minor effects on biological or physical environment (Legal) Up to minor legal issues, non-compliances and breaches of regulations. Minor prosecution or litigation possible. (Corporate Citizenship community etc) Local public complaints or adverse media attention. (e.g. From public health issues, damage to social cultural structures etc) Refer to TOOL75.WHS.INV.003 Risk Profiling (Consequence) 5.32 Report Only Injury This injury classification applies to: journey incidents an injury or condition which occurred at work but is non-works related, such as a seizure, heart pain, diabetic episode, fainting. reports of soreness, aches and pains etc but with no specific work incident / discernible event. injuries involving customers where Arrium do not have operational control, and did not directly contribute to the incident 5.33 All Injury (AI) Any work-related injury or illness, regardless of the severity (including any report of pain or soreness). Any PRINTED copies of this procedure are UNCONTROLLED Page: 8 of 31
5.34 Minor Injury (MI) An injury from a specific work incident that may or may not have resulted in First Aid treatment, but is less severe than a MTI. 5.35 First Aid Treatment First aid treatment is any one time, and any follow up visit for observation, of minor scratches, cuts, burns, splinters and the like, which do not normally require medical care. Such treatment is considered to be first aid even if administered or supervised by a medical practitioner. Treatment provided by a first aider or professional health care staff (e.g. OH. Nurse) may include giving health care advice as well as any of the following: using non-prescription medications at non-prescription strength; administering tetanus immunizations; cleaning, flushing, or soaking wounds on the skin surface; using wound coverings, such as bandages, BandAids, gauze pads, etc., or using SteriStrips or butterfly bandages. using hot or cold therapy; using any totally non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc.; using temporary immobilization devices while transporting an accident victim (splints, slings, neck collars, or back boards). drilling a fingernail or toenail to relieve pressure, or draining fluids from blisters; using eye patches; using simple irrigation or a cotton swab to remove foreign bodies not embedded in or adhered to the eye; using irrigation, tweezers, cotton swab or other simple means to remove splinters or foreign material from areas other than the eye; using finger guards; using massages; drinking fluids to relieve heat stress 5.36 Restricted Work Case/Injury (RWI) A work related injury where, as a result of the injury, a Doctor documents work restrictions for the person. These restrictions could include: 1. the employee was assigned to another job on a temporary basis or 2. the employee worked their permanent job less than their normal hours of work or 3. the employee worked their permanent job but could not perform all of their normal duties during all or any part of the normal workday or shift including any overtime. The employer or medical professional (other than a Doctor) may institute precautionary restrictions immediately following a minor injury with a view to avoiding exacerbation or delaying recovery and these will not be considered to constitute a Restricted Work Case however they can only be in place for a maximum of 48hrs after the injury. After this time, a Doctor should be consulted and if required documented restrictions implemented and a Restricted Work Case recorded or the person should return to full normal duties. Refer to Attachment 2 for further detail on RWI classification and examples. Any PRINTED copies of this procedure are UNCONTROLLED Page: 9 of 31
5.37 Medical Treatment Injury (MTI) Medical Treatment Injury is a work related injury or illness that requires treatment by a medical professional (Doctor, Dentist etc.), which is beyond the scope of normal first aid, including initial treatment given for more serious injuries. An MTI may include, but is not limited to the following: serious injuries (e.g. lacerations that need suturing) any fractures (this includes fractures to smaller bones, such as fingers and toes) Physiotherapy or chiropractic treatment requiring more than two sessions as recommended by a doctor recurring injuries such as known back or neck strain/sprains where a separate identifiable incident can be directly related to the injury taking of medication only available by prescription from a medical provider. Note: What is not an MTI? If a medical practitioner only provides medical advice, which does not include medical treatment of the injury these then should not be classified as a MTI If the first aider refers an employee to see a medical practitioner / Hospital and in turn the medical practitioner only administers first aid treatment Physiotherapy or chiropractic treatment related to an injury and limited to a maximum of two treatments will not constitute an MTI. When 2 treatments occur the case will be immediately referred back to the doctor to recommend if any further treatment is necessary Recurring injuries such as known back or neck strain / sprains etc., should also not be classified as a MTI if referred to a medical practitioner, unless a separate identifiable incident can be directly related to the injury. Any treatment prescribed by a doctor as preventative or investigative only will not be counted as an MTI, eg. Tetanus injection, x-ray etc 5.38 Lost Time Injury (LTI) Lost Time Injury is a work related injury or illness that fulfils at least one of the following criteria; requires a person to lose a full shift from work as a result of the injury or illness; or an injury that results in a permanent disability. Note: The time lost must be due to incapacity to work as a result of the injury or illness. Where the time lost is related to a pre-existing work related injury or illness it should be determined whether it is an aggravation or a recurrence. The time lost must occur within 12 months of the original injury to be counted as a LTI, unless there has been an aggravation of the original injury within the past 12 months. 5.39 Recordable Injuries (RI) Work-related injuries and illnesses that is any one or more of the following: Fatality, LTI, MTI, RWC or Injury with the following Nature of Injury classification: Fractures bones Amputation Impalement Head Injury / Loss of consciousness Nerve damage Internal injury including Ear Drum puncture Effects of exposure, eg weather Poisoning and toxic effects of substances Disease of nervous system and sense organs Any PRINTED copies of this procedure are UNCONTROLLED Page: 10 of 31
Skin disease Infections Damage to respiratory system Needle stick injury Hearing loss that meets the OSHA definition and is based on a baseline hearing level (for each worker) established in 2014 or later. (Further detailed can be found in the corporate guidelines on WHS Monitoring & Measurement) 5.40 Special OHS Incident Cases 5.40.1 Aggravation A new and separate incident has occurred that has aggravated an existing injury condition, therefore for all intents and purposes it is a new injury and should be counted as a LTI or MTI, if it is that level of injury. 5.40.2 Recurrence Where an injury re-presents but there is no new and separate incident. This should be counted as a LTI or MTI if it is within 12 months of the original injury and has not yet been counted as a LTI or MTI, and is that level of injury. If it is greater than 12 months since the original injury, or has already been counted as a LTI or MTI it should not be recorded as a LTI or MTI. 5.40.3 Inguinal Hernia An inguinal hernia shall be considered a work related injury only if it is precipitated by an impact, sudden effort, or strain, and meets, after investigation all of the following conditions. There is clear evidence of an accidental event or an incident, such as a slip, trip or fall, sudden effort or over-exertion. There was actual pain in the hernia region at the time of the injury or incident. The immediate pain was so acute that the injured employee was forced to stop work long enough to draw the attention of their supervisor or fellow employee, or the attention of a doctor was secured within 12 hours. 5.41 Initial Investigator The front line leader responsible for initially securing the incident scene and commencing initial investigation 5.42 Investigation Leader Person responsible for complete the incident investigation to provide to Next Level Up Manager for approval. 5.43 Next Level Up Manager / One Up Manager The one level up Manager from an Investigation Leader. 5.44 Incident Cause Analysis Method (ICAM) An analysis process (and tool) that looks beyond the errors and violations of individuals and examines the contributing factors leading to an incident. 5.45 Immediate Cause The final factors in a series of causes leading to an incident. The immediate causes are underpinned by fundamental, or root causes. Any PRINTED copies of this procedure are UNCONTROLLED Page: 11 of 31
5.46 Root Cause The underlying cause, which triggered the chain of events, ultimately resulted in the incident. The cause of the incident that, if rectified, will prevent the recurrence of not just incidents with those exact circumstances, but others with similar causes. 5.47 Contributing Factor A condition, oversight, system failure, act or omission, which contributed to the occurrence of an incident. 5.48 Critical Corrective Action An action implemented to eliminate or control the identified root cause(s) of a High Potential Incident in order to prevent recurrence. Test Question: If only these Critical Corrective Actions are implemented will they remove or control the root cause? 5.49 Critical Safety Alert A document used to communicate initial safety information within 48 hours of a High Potential (HPI) or repeat incident. 5.50 Critical Safety Communication A document used to communicate detailed information and remedial actions following investigation of internal HPI or Serious Safety Incidents and external Safety Alerts or Bulletins. 5.51 Environment Brief (green) To communication environment information 5.52 Information / Safety Brief (blue) A document used to communicate general safety site / plant information Refer to QP75.WHS.COM.001 Communication and Consultation to obtain appropriate communication templates. 5.53 Arrium Mining Businesses This procedure applies to the Arrium Mining Business Unit led by the Mining Chief Executive which is split in to 2 Businesses managed by their respective General Managers: 1. Operations with main Business Areas/Stream of: SMR Fixed Plant Ore Processing Operations - Auxiliary Crushing at Iron Knight and Iron Duke Pellet Plant Mining business - Iron Baron - Iron Knob - Quartz Quarry - Southern Middleback Ranges (SMR) Mining Leases Supply Chain & Logistics - Ardrossan - Port Operations - Rail and Ore Facilities - Supply Chain - Transhipping Any PRINTED copies of this procedure are UNCONTROLLED Page: 12 of 31
2. Development with main Business Areas/Stream of: Exploration Mining Projects Resource Optimisation and Development Technology Development 6.0 SAFETY & ENVIRONMENTAL RISK ANALYSIS JOB HAZARD HAZARD CONTROL The incident scene may contain residual Complete risk assessment tool (with input hazards related to the initial event or the from Emergency Response Controller if emergency response. applicable) prior to entering scene. Refer Hazard Register for any additional hazards and their control measures. 7.0 PROCEDURE 7.1 Arrium Code of Practice Critical Elements The Critical Elements which must be conveyed and understood at each Arrium site are: 1. Report all injuries and incidents to your leader immediately. 2. Take immediate corrective action to make the area safe and secure. 3. Investigate injuries and incidents to establish root cause and to identify corrective actions. 4. Significant injuries and High Potential Incidents are to be reported to the Site Manager as soon as possible. 7.2 Safe Systems of Work This procedure outlines systems in place to respond to incidents which includes: initial response assessment and notification investigation corrective actions effectiveness review and close out 7.2.1 Initial Response (and Securing the Scene) Report all injuries and incidents (including near miss events) to your leader immediately. Make the area where the incident occurred safe The First Responder is the person at the site of the incident/emergency at the time who shall assess the situation and to the extent necessary initiate an emergency response to contain or control the threat and protect persons, the environment and assets. No action initiated by First Responder/s should endanger any responding personnel. Any PRINTED copies of this procedure are UNCONTROLLED Page: 13 of 31
Provide treatment to injured persons within level of training and competency. The site of serious incidents (actual consequence 3 or greater) will firstly be made safe but shall not be disturbed unless it is for the purpose of saving life, attending to the injured or preventing injury to any person or damage to property or environment both on and off site. Notifiable incidents to SafeWork SA and/or the Office of the Technical Regulator (OTR) or the Office of the Rail Safety Regulator requires the scene to not be altered until permission has been granted by an Inspector, however as outlined above, the scene may be altered to prevent any further risk of injury to any person. Initial Investigator to secure the incident scene to protect other people and for site security. Where applicable, Health and Safety Representatives and Safety Coordinators should be notified and assist in initial investigations. Initial Investigator to commence Initial Incident Investigation following emergency response (if required) and securing of scene. Secure scene with a physical barrier, bunting or appointing sentries (watchers). Initial Investigator to create a record of incident in BSS within the same shift of incident, but if they are unable to for valid reasons, then it must be entered within 24 hours. Where applicable, Arrium Safety Coordinators are responsible to create the initial entry and their Team Leader must ensure this occurs. Refer to Incident Investigation Reporting Tools / Forms for further assistance. 7.2.2 Assessment and Notification 7.2.2.1 Depending on the nature of the incident it may be necessary to undertake drug and alcohol testing and/or restrict the duties of those involved until the investigation is complete. This is in order to ensure they (or their colleagues) are not placed at further risk. The following should occur to persons involved in: Type of Incident Serious safety incident (as per WI29.541) Mobile plant /equipment or vehicle incidents Isolation incidents Working at Heights incidents Confined Space incidents Person involved in incident and suspected of apparent intoxication or impairment (drug and/or alcohol) Stood Down Until Further Investigation Undertaken Yes stood down from all duties where there is a chance of repeated occurrence Yes stood down from operating the type of equipment involved Yes stood down from isolation duties Yes stood down from working at heights duties Yes stood down from confined space tasks Yes stood down from all tasks Tested For Drugs & Alcohol Yes Yes Yes No No Yes Any PRINTED copies of this procedure are UNCONTROLLED Page: 14 of 31
If it is necessary to stand personnel down from normal duties the initial investigator shall notify the direct leader (or supervisor) of those involved who shall formally notify and record the details of the duty restrictions. If there are other obvious immediate actions these should be implemented however it is critical that these are sufficiently well constructed and risk assessed that they do not create new hazards. If LifeSaver rules or Safety Rules are deemed to have been breached, refer to the PO1.19 LifeSaver Program Policy and any other relevant procedures as required. All breaches of LifeSaver rules will be recorded in the Arrium LifeSaver breach database for all workers including contractors. 7.2.2.2 Based on their initial assessment of the incident consequence potential, the Initial Investigator to commence the incident occurrence notification process to appropriate Arrium personnel. Refer to Incident Investigation Reporting Tools / Forms for further assistance. Refer also to Area/Stream/Site Unplanned Production Loss Escalation Procedures for further assistance. 7.2.2.3 Potential Severity 2 (Low) or greater (Environment) For environmental incidents with a potential consequence of 2 (Minor) or greater, the following persons or agencies shall be notified by the Department / Site Manager (eg operations or maintenance manager). 7.2.2.4 Potential Severity 3 (Medium) or greater For incidents with a potential consequence of 3 (Medium) or greater (including MTIs & LTI's), the following persons or agencies shall be notified by the Department Manager / Site Manager (eg Operations or Maintenance manager): Business Area/Stream Manager (eg. Manager Mining Stream) who will escalate to the relevant General Manager Business Area/Stream Health and Safety Business / Mining HSE Manager Arrium Mining Environment Assurance Manager who will notify the EPA SafeWork SA Inspector / Mining Inspector (for notifiable incident under WHS Act 2012 and WHS Regulations) Arrium Electrical Inspector who will escalate to the Office of the Technical Regulator if required Business Area/Stream Transport Manager / Rail Service Provider who will escalate to the Office of the Rail Safety Regulator if required. In the event of attendance by external emergency services the Arrium Media and Communications Manager who will enable media liaison. Any PRINTED copies of this procedure are UNCONTROLLED Page: 15 of 31
7.2.2.5 Resultant / Actual Severity 3 (Medium) or greater In the event of incidents which: Result in consequence 3 (Medium) or greater that involve workers including contractors or members of the public; Are likely to attract state-wide or national media coverage (or attendance by police or representatives of regulatory authorities); or Are judged by the General Manager as being appropriate, Then refer to 7.2.2.3, 7.2.2.4 and in addition: The Department/Site Manager or their delegate such as the Health and Safety Business Partner shall notify the Arrium Mining Workers Compensation and Return To Work Coordinator for any Restricted Work Cases, MTIs and LTIs. They will escalate to WorkCover SA if required. If a worker requires medical assessment/treatment with a General Practitioner and/or at the Hospital, the Site Manager or their deputy plus the Area/Stream Health and Safety Business Partner must attend with the worker. The General Manager or their delegate shall contact SA Police if there is a death in the workplace. SA Police must also be notified if there is a significant fire. The General Manager shall verbally notify the: General Manager Human Resources as soon as practical and in any case within 24 hours if the incident is a consequence 3 (Medium); The General Manager shall verbally notify the Arrium Legal and the General Manager Human Resources and must do so within 4 hours if the incident is consequence 4 (Major); Within 24 hours, a brief written report of the incident shall be sent to the General Manager and other relevant parties. 7.2.2.6 Notifications to Arrium Mining Legal Arrium Legal is to be advised when: an incident is required to be notified to statutory authority an incident is of actual Consequence Level 4 or 5, or a sensitive incident recommended by Arrium Legal advice is required for an incident. Note: If legal advice is sought, the provisions of this procedure relating to written incident notifications, investigation, and communication should not be initiated until confirmation is received from Arrium Mining Legal. Aspects of this procedure may be overridden if advised to do so by Arrium Legal. 7.2.2.7 Seeking Legal Advice and Legal Professional Privilege Legal advice should be obtained when an incident is of a consequence 4 (major) or 5 (extreme) or where Arrium Legal otherwise recommends that legal advice be obtained. Arrium Legal may be contacted for any other incident. If legal advice is sought provisions of this procedure with respect to incident investigation and communication should not be initiated until confirmation has been received from Arrium Legal. If a solicitor from Arrium Legal initiates an investigation, then the investigation is subject to legal professional privilege and must not be divulged to any person, including statutory authorities, without the expressed permission of the solicitor. Any PRINTED copies of this procedure are UNCONTROLLED Page: 16 of 31
Any document, including notes, reports, emails, faxes etc to a solicitor who has initiated an investigation must have the following words marked upon it Confidential: Subject to legal professional privilege. 7.2.2.8 Notifications to External Agencies The type of serious incident will determine which external agency needs to be notified such as SafeWork SA (or Comcare for certain Contractors), The Office of the Technical Regulator, The Office of the Rail Safety Regulator or potentially maritime safety authorities or Environment Regulators such as Department of State Development (DSD) and/or Environment Protection Authority (EPA). SafeWork SA Incidents such as fatalities, serious injuries and illness, and dangerous occurrences that arise out of the conduct of Arrium business must be notified to SafeWork SA immediately by an authorised Arrium person or Contractor as soon as Arrium become aware of the incident and incident records must still be kept for five years. The notification to SafeWork SA must be by the fastest available means and can be made by phone or in writing (such as fax, email or other electronic means). If the notification is by phone this must be followed up in writing within 48 hours if SafeWork SA requests it. Refer to FORM75.WHS.INV.001 and FORM75.WHS.INV.002. The person with management or control of a workplace must, so far as is reasonably practicable, preserve the incident scene until the inspector attends the site, or direct otherwise. The scene may be disturbed to move a deceased person, assist an injured person, make the site safe, or assist with a police investigation. The Office of the National Rail Safety Regulator Notifiable occurrences are categorised under the Rail National Safety Law (South Australia) Act and timelines for reporting by an authorised Arrium person on Contractor are as follows: Category A, the most serious, which must be immediately orally reported by phoning the Australian Transport Safety Bureau (ATSB) on 1800 011 034 and following up with a written report to the ONRSR within 72 hours Category B, which must be reported to the Office of the National Rail Safety Regulator (ONRSR) within 72 hours Refer to FORM75.WHS.INV.003 The Office of the Technical Regulator The timelines for reporting electrical accidents to the OTR by an authorised Arrium person (Arrium Electrical Inspector) or Contractor are as follows: Death must be reported immediately via the telephone Any accident where the person requires medical assistance must be reported within one working day. Any PRINTED copies of this procedure are UNCONTROLLED Page: 17 of 31
All other accidents involving electricity must be reported to the OTR within 10 working days of the day of the accident. Refer to FORM75.WHS.INV.004 Environment Regulators The National Manager Environment and Mines Environment Assurance manager (or delegates in case of absence_ must be notified of any incident which has caused or had the potential to cause Severity 2 Minor to serious effects on the biological and physical environment (or environment consequence category 2) as soon as practicable by at the latest within 24hrs of the incident on telephone number: 0408 386 340 and leave a voicemail message if no answer. The National Manager Environment or delegate will review all environmental incidents for its severity and the requirements under relevant environmental legislation, once reported, and inform the relevant regulator(s) if required. TOOL75.WHS.INV.003 Risk Profiling (Consequence Category) 7.2.2.9 Incidents Attracting Investigation By Statutory Authorities Incident Investigations are not to be released to any statutory authority without the permission of the Business Area/Stream Manager (eg. Manager of Mining Stream). For environment incidents, all written correspondence with the relevant Authority(s) must be carried out by or via the Manager, Environment & Sustainability or delegate. 7.2.2.10 Actions on death in workplace If any person finds a person deceased, then they must immediately ensure that they do not put themselves or others at risk of injury. The scene must be secured and no other person must enter the area. For deaths that have occurred in the Whyalla Steelworks or if specified in Department Emergency Response Plans then OneSteel Security must be immediately notified by telephone on 4000 or 8640 4000 from mobile phones. All other sites must following their site Emergency Response Plan. SA Police must be notified on 8648 8020 by General Manager or their delegate The Arrium/OneSteel corporate Crisis Management Plan shall also be implemented. 7.2.2.11 Complete Internal Preliminary Report Complete internal preliminary report following all required notifications. Once the appropriate notifications have been made the Arrium Initial Investigator is responsible for raising the BSS incident entry. For sites where Arrium Safety Coordinators are appointed roles, they are responsible for entering the incident into the BSS and their Team Leader must ensure this occurs. This entry should occur as soon as possible the same shift and within 24 hours if that is able to be achieved for valid reasons. For incidents which have occurred on the controlled sites of Arrium Mining s embedded Contractors, they are responsible for undertaking their own incident investigations. They Any PRINTED copies of this procedure are UNCONTROLLED Page: 18 of 31
are required to provide verbal notification to Arrium Contractor Controllers immediately for Level 3 and above incidents and as soon as possible as per agreements made between the Contractor and their Contractor Controller for Level 1 and 2 incidents. Contractors are then required to provide written notification with initial investigation information to the relevant Arrium Contractor Controller and any other authorised persons within 24 hours of the incident. The relevant Business Area/Stream Health and Safety Business Partner or where applicable other authorised persons, are required to create an entry into the BSS for Contractor incidents as soon as possible and within 24 hours of incident. Refer to WI75.WHS.INV.001 - Entering Incidents into BSS 7.2.2.12 Communicate HPI and Serious Incident information in a timely manner HPI and serious incident notifications should be based on the Critical Safety Alert form as out lined in QP75.WHS.COM.001 Communication and Consultation Serious Incident and HPI Notifications should be issued with: consideration of any legal advice consideration of involved people s privacy. consideration to be issued as soon as possible after preliminary investigation if deemed required Serious Incident and HPI Notifications should be communicated: across the relevant Business Units provided there is sufficient cross business learning opportunity to relevant networks including the Arrium Mining and Materials Safety Network as soon as reasonably possible to allow for prompt preventative action and within 48 hours. Notification requirements including timeframes for distribution of Critical Safety Alerts / Communications are detailed in TOOL75.WHS.INV.002 Arrium Mining Incident Notification and Investigation Guidelines. The preparation of the communication briefs is the responsibility of the Investigation Leader with support from the Health and Safety Team. Contractors may have their own safety communication format which if it include all the required elements outlined above, then this is also appropriate to distribute across the relevant Arrium / OneSteel networks, and timeframes as per TOOL75.WHS.INV.002 should be adhered to. 7.2.2.13 Determine level of investigation Incidents are to be investigated according to the level of potential consequence. The Initial Investigator is responsible for making an initial assessment of the potential consequence. The incident Consequence Level determines requirements for: notification investigation type Any PRINTED copies of this procedure are UNCONTROLLED Page: 19 of 31
investigation leader support personnel investigation completion documented reporting completion of corrective actions effectiveness review and sign off. Refer to Refer to Incident Investigation Reporting Tools / Forms to assist with determining level of potential incident consequence. 7.2.2.14 Determine Investigation Leader Investigations are to be led or conducted by a competent person, in compliance with the TOOL75.WHS.INV.002. Note that investigation leadership and facilitation do not necessarily need to be performed by the same person. Therefore it is possible that the Investigation Leader may nominate a more appropriately qualified facilitator to assist in parts of the investigation (for example the ICAM phase). However the Investigation Leader is not able to delegate the investigation to someone else unless in TOOL75.WHS.INV.002 they are authorised to lead an investigation of the same potential consequence. 7.2.3 Investigation Incidents shall be investigated according to their level of incident potential consequence as indicated in the TOOL75.WHS.INV.002. For all investigations a competent person will conduct or lead an investigation. Investigations shall commence as soon as practicable after the incident, and be completed with timeframes specified in TOOL75.WHS.INV.002. Embedded Contractor Incidents For incidents which have occurred on the controlled sites of Arrium Mining s embedded contractors, they are responsible for undertaking their own incident investigations and will have their own notification, initial investigation and full investigation procedures. The embedded Contractor incident investigation procedures must meet the minimum requirements of this procedure. Contractors will also have their own level of determining an incident severity level. In this case the nominated Arrium leader must make a determination of the incident in terms of Arrium s procedures and for each consequence level does not need to lead the investigation. However, this person is responsible for, and must be in attendance for Arrium deemed Level 3 and greater consequence level incident investigations and must also ensure all levels of incident investigations are completed to Arrium s satisfaction (and published) in the timeframe that is required of incident investigations undertaken on Arrium controlled operation sites. For basic investigations the Investigation Leader must have been assessed as competent in the Arrium Investigation Process. For Severity 3 incidents the facilitator of the investigation shall have received training in ICAM and assessed as competent. Arrium Contractors must also ensure appropriate levels of training are provided to those conducting investigations in their business. Any PRINTED copies of this procedure are UNCONTROLLED Page: 20 of 31
All investigations must review the relevant entry(s) in the department/site Hazard/Risk Register and where the investigation identifies any deficiencies, the corrective actions must include a task to update the register. The final incident report must be completed within timeframes stated in TOOL75.WHS.INV.002. The initial information must be entered into the BSS event recorder within in the same shift or if not possible within 24 hours of the incident. For sites where Arrium Safety Coordinators are appointed roles, they are responsible for entering the initial incident information into the BSS. Refer to WI75.WHS.INV.001 Entering Incidents into BSS Investigation Process Determine the Investigation Leader (TOOL75.WHS.INV.002) Complete initial investigation with required timeframes (TOOL75.WHS.INV.002) Obtain approval from site management and relevant authorities prior to entering site Conduct a site inspection Interview witnesses / others as soon as possible after the incident, to determine: what happened actions immediately prior to the incident actions taken to reduce the risk in the task training which had been provided safety systems or personal protective equipment (PPE) for the task any previous incidents or near misses what could have been done differently to prevent the outcome what could be done to prevent a recurrence. FORM75.WHS.INV.005 - Witness Statement Form should be utilised. 7.2.3.1 Collect information and documents from the site This may include but is not limited to: procedures risk assessments/job Safety Analysis (JSA) work permits training records photographs TOOL75.WHS.INV.005 Incident Investigation Tools contains a PEEPO Analysis Template to assist with date collection. 7.2.3.2 Establish the sequence of events The aim is to capture the people involved, and the events and connect them in a logical sequence. The sequence of events may start some time before the incident (e.g. when a piece of equipment was purchased). Any PRINTED copies of this procedure are UNCONTROLLED Page: 21 of 31
Various methods can be used to arrange information into a sequence (e.g. Investigation Tree, Step Process, Timeline Chart, Cause and Effect Diagrams). TOOL75.WHS.INV.005 provides examples of an Investigation Tree, Simple Timeline Chart, 5 Whys and Cause and Effect Diagrams. 7.2.3.3 Analyse information and determine root causes It is imperative to identify root cause to implement effective corrective actions and prevent reoccurrence. If root causes are not corrected then the same conditions could happen again. Identify root causes using techniques such as Ask WHY? 5 times, using Cause and Effect Diagrams, and fault trees. TOOL75.WHS.INV.005 provides examples of an Investigation Tree, Simple Timeline Chart, 5 Whys and Cause and Effect Diagrams. For incidents of potential and actual Consequence Level 3-5, Incident Cause Analysis Method (ICAM) must to be used for all Arrium incident investigations. Contractors may utilise an alternate equivalent investigation method that has been approved by Arrium. 7.2.3.4 Identify learnings and determine recommendations Establish a course of action to address the root causes. Recommendations should address: existing hazards gaps in controls, systems and procedures organizational factors actions to prevent recurrence. 7.2.3.5 Complete investigation within required timeframes As per TOOL75.WHS.INV.002 7.2.3.6 Complete and issue draft report to relevant personnel The incident investigation report for basic investigations can be either entered by the Investigation Leader straight into the BSS system with recommended actions entered and all required evidence attached or initially on the Incident Report Template prior to entering into the BSS as per OST-OHS-INV-FRM-020. Contractors may use their own internal investigation procedure tools and reports, as approved by Arrium. ICAM format or equivalent shall be utilised for Level 3 and above incidents. Refer to FORM75.WHS.INV.006 for the Arrium ICAM Report Template. All ICAM investigation root causes / contributory factors for both Arrium and Contractor incidents must be entered into the BSS. Refer to WI75.WHS.INV.001 Entering Incidents into BSS Any PRINTED copies of this procedure are UNCONTROLLED Page: 22 of 31
7.2.3.7 Review and approval of report Once the draft investigation is complete it must be reviewed by the Next Level Up / One Up Manager as per TOOL75.WHS.INV.002 to confirm thoroughness, quality and clarity before approving. This must be conducted by assigning an action to the Next Level Up Manager in the BSS and within timeframes required. 7.2.3.8 Distribute final report Issue final report when any clarifications have been addressed. If the incident was entered immediately into BSS, then the Investigation Leader needs to adjust any actions if required. If the report was initially entered via the investigation report template, then all approval actions must be entered into BSS and actions assigned by the Investigation Leader. Contractors must provide copies of their final investigation reports to the relevant Arrium Contractor Controller/s in timeframe specified in TOOL75.WHS.INV.002. The relevant Business Area/Stream Health and Safety Business Partner or other authorised persons are responsible for uploading the Contractor report to the BSS and assigning an action to the relevant Arrium Next Level Up Manager to review each incident report to assess the report for thoroughness, quality and clarity. This review should pay particular attention to the suitability and timeframe of the corrective actions. When satisfied they sign off the assigned corrective action as complete in BSS. Refer to WI75.WHS.INV.001 Entering Incidents into BSS 7.2.4 Corrective Actions 7.2.4.1 Investigation Leader determine corrective actions Corrective actions should be specific cost-effective strategies that: address root causes and contributory factors are based upon the Hierarchy of Controls, and are reasonably practicable to implement. For all High Potential Incidents Critical Corrective Actions must be identified and included in the ICAM report and approved by Manager Health & Safety. Refer to WI75.WHS.INV.003 Corrective and Preventative Actions Any PRINTED copies of this procedure are UNCONTROLLED Page: 23 of 31
7.2.4.2 Investigation Leader assign responsibilities for corrective actions Allocate and communicate: people responsible for corrective actions completion dates follow up dates. 7.2.4.3 Communicate investigation information in a timely manner To prevent any further similar incidents occurring the key points of the incident should be communicated throughout the business. This is to be done by using an Information/Safety or Environment Brief. To maximise the communication and effective implementation of key learning from significant safety or environment occurrences it is critical that the flow of information is controlled and communicated at the appropriate levels. The Information/Safety or Environment Brief should consider any legal advice and the protection of privacy for any person involved. An Information/Safety or Environment Brief should contain a brief description of the incident, any photographs or diagrams that aid understanding, a summary of the key contributing factors and most importantly the key learnings that are of relevance to the Business. Any PRINTED copies of this procedure are UNCONTROLLED Page: 24 of 31