Health & Safety Management System Manual

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1 Health & Safety Management System Manual Document Information Document Number Description HSMSM This manual describes the Health & Safety Management System elements of the Integrated Management System and related documentation. Document Control Reference (electronic) Next Review Date June 2013 Revision Number Issue Date Author Nature of Amendments V0.1 June 2012 Gary Timmins / Rory Graham Draft V0.2

2 Contents 4. OCCUPATIONAL H & S MANAGEMENT SYSTEM REQUIREMENTS General Requirements... 3 Introduction... 3 Scope Occupational Health & Safety Policy Planning Hazard Identification, Risk Assessment and Determining Controls Legal Obligations and Commitments Objectives, Targets and Programmes Implementation & Operation Resources, Roles, Responsibility and Authority Competence, Training and Awareness Communication, Participation and Consultation Documentation Control of Documents Operational Control Emergency Preparedness and Response Checking Performance Monitoring and Measurement Evaluation of Compliance Incident Investigation, Nonconformity, Corrective Action and Preventive Action Control of Records Internal Audit Management Review APPENDICES Figure 1 Site Plan Health & Safety Management System V0.1 Page 2 of 13

3 4. Occupational H & S Management System Requirements 4.1 General Requirements Introduction Wolf Minerals will establish a health and safety management system (H&SMS) broadly in accord with BS OHSAS 18001:2007 and in accordance with relevant UK legislation but specifically the Quarries Regulations The following pages outline what the system will cover, as well as describe some of the details relating to structures, policies and procedures that Wolf Minerals will put in place to implement and maintain that system. It is however the intention that this H&SMS will be incorporated into an Integrated Management System (IMS) and therefore makes reference to documents and specifically policies that will be used across both the environmental and quality management systems Wolf Minerals is committed to continually improving this system and will do so through regular reviews, updates and feedback (plan, do, check and act) Section and paragraph numbering are in accord with the clauses of the OHSAS standard. Scope This H&SMS system relates specifically to the Wolf Minerals Ltd operations at the Hemerdon site; the project includes a two stage open pit and a 3 Mtpa concentrator with associated infrastructure. The Hemerdon Mine is located six miles north-east of Plymouth, near Plympton, in Devon, UK. It lies to the north of the villages of Sparkwell and Hemerdon and adjacent to the large china clay pits near Lee Moor. Figure 1 presents the geographical boundaries for the HTP operations The mining pit will be supported by comprehensive mining infrastructure: upgraded access roads to the site several level earth pads on hilly country to the west of the proposed site of the open cut mine site runoff dams an integrated landfill tailings storage facility to the north of the concentrator an administration office and associated ablutions and sewerage disposal system a gatehouse and associated security systems maintenance and stores buildings a metallurgical laboratory heavy vehicle workshop and fuel storage and metering facility raw water pumping station and pipeline potable water pipeline excess water disposal system high voltage power supply The H&SMS does not include any Wolf Mineral activities outside of the UK other than those related to Top Management decisions, Management Review, Health & Safety Management System V0.1 Page 3 of 13

4 Appointments or purchasing where it relates to Hemerdon. This document will only cover those health and safety responsibilities or duties on contractors, and suppliers where they are directly related to their activities on site, or on a product or service that impacts on anything on site The scope of the H&SMS will be reviewed annually at the management review. Implementation of any system changes will be the responsibility of the Management Team. 4.2 Occupational Health & Safety Policy Wolf Minerals senior management will develop an integrated policy statement covering health, safety, environmental and quality ensuring that it is appropriate to the nature and scale of Wolf Minerals Hemerdon Operation. In particular it will cover the occupational health and safety risks associated with our activities and products as well as express our commitment to continual improvement and prevention of injury and ill health Wolf Minerals is an ASX and AIM quoted company working in the UK and our policy expresses our commitment to comply with applicable legal requirements and with other requirements to which the organization subscribes which relate to its occupational health and safety hazards Building on our commitment to continual improvement, our policy will provide the top-level framework for setting and reviewing health and safety objectives and targets and ensuring that our systems are documented, implemented and maintained. Wolf management will ensure that the policy and the requirements and benefits of the systems are periodically reviewed and communicated to all persons working for or on behalf of Wolf Minerals Our policy will be available to the public through the Wolf Minerals website Planning Hazard Identification, Risk Assessment and Determining Controls Wolf Minerals will establish, implement and maintain a policy that clearly defines the process for hazard identification, assessment of risk, and determining of necessary controls. The policy will specify what methodologies shall be used, when they shall be used, and who has responsibility for compilation, to ensure the process takes into account the human factors (behavior, capabilities), is proactive rather than reactive, follows the hierarchy of controls and covers both routine and non-routine activities. The primary policy will be: Risk Assessment This policy will cover both routine Risk Assessment, as well as specialist assessments such as Manual Handling, COSHH, Fire, Work at Height, Lifting, PPE, DSE, Noise, Dust, etc. However, as this subject is fundamental to H&S and covers all categories of personnel, the infrastructure, plant, equipment as well as the workplace, certain identified and recognized hazards have lead Wolf Minerals to determine Health & Safety Management System V0.1 Page 4 of 13

5 controls should be implemented through the compilation of separate policies such as: Business Continuity Contractor Management Control of Visitors Workplace Management Mobile Plant Management Fixed Plant Management For more details see section below Legal Obligations and Commitments Wolf Minerals will identify its legal obligations and commitments which are applicable to the company and its operations in the UK, and how they apply and are communicated to all relevant persons at the Quarry. This will be achieved by means of a Register. The management of this Register and guidance on the communication methodology will be detailed in the policy: Legal Obligations and Commitments The records will be documented in the: Register of Legal Obligations and Commitments Objectives, Targets and Programmes Wolf Minerals will establish and maintain documented occupational health and safety objectives which will be measurable, have designated responsibilities and defined time frames for each item. When establishing the objectives they will include the commitment to the prevention of injury and ill health, together with compliance to all applicable legal requirements. In support of Wolf Minerals commitment to objectives and targets suitable implementation programmes will be agreed and periodically reviewed in line with the relevant policies covering this subject. 4.4 Implementation & Operation Resources, Roles, Responsibility and Authority Wolf Minerals will take ultimate responsibility for occupational health and safety and will ensure that resources are available to establish, implement and maintain the H&SMS. Roles, responsibilities, accountabilities and delegated authorities will be defined, allocated, documented and communicated to staff via a combination of Job Descriptions IMS Policies, Procedures, Information Sheets and associated documents Health & Safety Management System V0.1 Page 5 of 13

6 The Management Team will be responsible for ensuring the H&SMS is implemented and maintained and in particular that health and safety management is undertaken as an integral part of each and everyone s role. A member of the management team will be given specific responsibility for occupational health and safety to ensure that they report to the Board on the performance of the H&SMS Competence, Training and Awareness Wolf Minerals will ensure that all Directors, management, operatives, suppliers and contractors are aware of the Integrated Health, Safety, Environmental and Quality Policy Statement and the need to conform to its tenets. Wolf Minerals employees (and relevant contractors) that have the potential to cause an impact on occupational health and safety shall be made aware of such and Wolf Minerals shall ensure they have the education, training, experience and other qualities to ensure that they are competent to manage that role. Wolf Minerals will undertake and update a training needs analysis and maintain appropriate training records as defined in the Training Policy. Training documents include: Training Needs Analysis Matrix Individual Employee and Contractor Training Records Wolf Minerals will ensure that all employees and relevant contractors are made aware of: the consequences of their work activities and behaviors as well as the benefits of improved personal performance, as regards occupational health and safety. their roles and responsibilities of conforming to the relevant requirements of the H&SMS; the potential consequences of departures from the H&SMS and in particular task procedures Communication, Participation and Consultation Communication Wolf Minerals recognises the importance of effective communication and will establish and implement a system for: appropriate inductions when first arriving on the mine site. internal communication regarding health and safety matters between the functions and management levels within the company as well as communication with contractors and other visitors to the quarry; receiving, documenting and responding to health and safety communication from stakeholders and interested external parties. Management of communications both internally and externally will be detailed in the Communications policy: Communications and interactions with local communities and other interested parties will be recorded on a communications record and a register maintained: Communications Register; and Health & Safety Management System V0.1 Page 6 of 13

7 Communications Record Participation and Consultation Wolf Minerals will establish a health and safety committee to ensure there is an effective system for worker participation, particularly Safety Representatives and consultation with all matters related to occupational health and safety. Contractors regularly employed on site will also be given an opportunity to participate within this forum. As this will be Integrated Management System it is intended that the health and safety committee will be combined with environmental and will be called a SHE Committee. Management of this will be detailed in the Communications Policy Documentation This H&SMS will be developed by Wolf Minerals in general accord with BS OHSAS18001:2007 and as previously stated will be incorporated into an Integrated Management System. The IMS structure will include: a health and safety policy statement incorporating environment and quality; a description of the scope of the integrated system in relation to Wolf Minerals Ltd and the Hemerdon Tungsten Project; a description of the main elements of the health and safety management system and their interaction and reference to related documents; documents including records, required by the OHSAS Standard and documents, including records, determined by Wolf Minerals to be necessary to ensure the effective planning, operation and control of processes that relate to occupational health and safety risks. The Hemerdon H&SMS documentation structure is described below: Health & Safety Management System V0.1 Page 7 of 13

8 Three Tiers of H&SMS Documentation TIER 1 H&S Policy Statement H&S System Registers TIER 2 H&S Management Policies H&S System Procedures & Management Documents TIER 3 H&S Management Plans (e.g. Emergency) Task Procedures including Safe Systems of Work Tier 1 The Health & Safety Policy Statement and the Required Registers are in Tier 1 due to their relative importance to the documented system and H&S management planning. Tier 2 Includes the Health & Safety System Policies and Procedures and Management Documents. The system policies and procedures are made up of both mandatory requirements of the standard as well as Wolf Minerals methodologies and systems for consolidating, communicating and implementing relevant H&S legislation. Health & Safety Management Documents are all the Information Sheets, Forms, Logs, Lists, Reports, Questionnaires, Programmes and Templates needed to support the above system and the H&SMS in general. Tier 3 Includes dedicated overarching Health & Safety Management Plans such as Site Emergency Plans which in this case will also cover Environmental requirements in one combined document. It also includes more detailed Task Specific Procedures which will include Safe Systems of Work where there is a hazard identified by the risk assessment. As this will be an Integrated Management System it is intended that the Task Procedures will also cover any Environmental hazards and control measures identified, along with any quality requirements so operatives only have one document to refer to for that element of the activity, thus reducing overall risk and improved compliance. They will cover for example, safe handling of chemicals, storage of explosives, use of spill kits, monitoring instructions and waste management all types. It also contains any Records as required by the H&SMS standard and relevant legislation. Health & Safety Management System V0.1 Page 8 of 13

9 4.4.5 Control of Documents Wolf Minerals intends to use an electronic document control software system such as Q-Pulse to maintain all controlled documents within the H&SMS. As this will be an Integrated Management System this policy and system will cover health, safety, environmental and quality requirements. Details of how this process will be managed can be found in the policy; Document Management Operational Control Where the hazard identification and risk assessment process has determined the need to implement operational controls to manage the OH&S risks Wolf Minerals will introduce one of two systems to ideally eliminate or reduce the risk to an acceptable level. Where the principle issues are common across the operation Wolf Minerals will establish, implement and maintain tier 2 policies, procedures and information sheets or tier 3 H&S Management Plans to manage recognized hazards and activities the same way across the site. Examples of these are below: Managers Rules Isolation Work at Height Working On or Over Water Confined Spaces PPE Control of Visitors Workplace Management Mobile Plant Management Fixed Plant Management Where the activity is task specific Wolf Minerals will require the Management Team to ensure documented procedures (which include Safe Systems of Work where a hazard has been identified and explicitly stipulate the operating criteria) are produced, implemented and maintained to cover situations where their absence could result in a deviation from the H&SMS, policy, objectives and targets or lead to an incident. See notes about combined procedures in Section Documentation above. Operational control of goods and services used by Wolf Minerals and provided by external contractors and suppliers is covered by the following policies: Contractor Management Purchasing Health & Safety Management System V0.1 Page 9 of 13

10 4.4.7 Emergency Preparedness and Response Wolf Minerals will establish, implement and maintain a policy that requires the management team to identify potential emergency situations and potential accidents. The policy will also require the compilation of a suite of procedures detailing how the company will respond to emergencies, preventing or mitigating any adverse OH&S consequences. This will be the Site Emergency Plan which will also contain those procedures required by the Environmental Management System on this subject. The policy will also cover the emergency equipment and training requirements, as well as the testing regime and review process to ensure the plan remains effective. 4.5 Checking Performance Monitoring and Measurement Wolf Minerals will establish, implement and maintain a policy that requires the management team to monitor and measure OH&S performance. The policy defines the type of monitoring required, the methods of measuring, recording and reporting as well as the frequency. The process will assist in monitoring conformity with the objectives and targets, assist in monitoring the effectiveness of controls for both health as well as safety, provide both proactive and reactive measures, cover incident management as well as ill health, provide a process for identifying subsequent corrective and preventive action and analyzing all Evaluation of Compliance Wolf Minerals will ensure that a compliance review of the legal obligations and commitments is carried out on an annual basis as a minimum. It is the responsibility of Senior Management to ensure that these reviews are undertaken and recorded. The compliance review includes an evaluation of compliance against the Register of Legal Obligations and Commitments. Records or evidence to support any compliance decision or summary of changes will be recorded in the register and provided for the management review meeting as detailed in the policy: Performance Assessment, Improvement & Review Incident Investigation, Nonconformity, Corrective Action and Preventive Action Incident Investigation In conjunction with the Emergency Preparedness and Response policy Wolf Minerals will establish and implement a policy/procedures for dealing with incidents including near misses. The policy will require incidents to be Health & Safety Management System V0.1 Page 10 of 13

11 investigated in a timely manner, identify the root causes and corrective and preventive action, as well as opportunities for continuous improvement. The policy will also define the recording, reporting and communication processes. As this will be an Integrated Management System this will be a combined policy and system covering both H&S and Environmental. This is detailed in the policy: Incident Management Nonconformity, Corrective Action and Preventive Action Throughout the H&SMS the need to identify and correct non-conformities will be defined in various policies and procedures. However Wolf Minerals will establish and implement an overarching policy/procedures for dealing with potential and actual nonconformities and taking appropriate action which these other systems will have to conform to. As this will be an Integrated Management System this policy and system will cover health, safety, environmental and quality requirements. It is also the intention that the electronic compliance software system will be used to monitor and manage issues raised through to close out as well as provide statistics. Overall performance will be monitored as defined in Full details can be found in the policy: Performance Assessment, Improvement & Review Control of Records Throughout the H&SMS the requirement to maintain records will be specifically defined in the policy related to that subject. However the policy/procedures below will specify that records must be legible, identifiable and traceable. It will also define the retention periods, the retention location and any documentation numbering system. As this will be an Integrated Management System this policy and system will cover health, safety, environmental and quality requirements. Wolf Minerals intends to use an electronic document control software system such as Q-Pulse to maintain certain records with in the H&SMS. Details of how this process will be managed can be found in the document control policy and associated procedures. Document Management Internal Audit Wolf Minerals will ensure that internal audits of the Integrated Management System are conducted in accordance with the policy below. The policy will define the process of setting the scope and frequency of audits as well as the competence and impartiality of auditors. The audits will determine whether the health and safety elements of the management system conform to planned arrangements, they have been properly implemented and are being maintained. The lead auditor will provide the results of the audit to the management team. The full process is defined in the policy: Health & Safety Management System V0.1 Page 11 of 13

12 Performance Assessment, Improvement & Review 4.6 Management Review Wolf Minerals management will review the health and safety management system elements of the Integrated Management System through a combined management review process defined in the policy below: Performance Assessment, Improvement & Review A record of the management review meeting and any outcomes will be recorded and communicated as defined in the policy. Health & Safety Management System V0.1 Page 12 of 13

13 APPENDICES Figure 1 Site Plan Health & Safety Management System V0.1 Page 13 of 13

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