By: Marko Kotze - Chief Technology Officer, IMT (Integrated Mining Technologies)

When the automatic intervention requirements of South Africa’s Mine Health and Safety Act Regulations came into force in December 2022, many expected a relatively rapid shift to full Level 9 capability across the country’s mines. Yet more than three years later, independent industry commentary and Minerals Council South Africa documentation still indicates that many operations remain in the process of verification against the Mining Industry Occupational Safety and Health (MOSH) Collision Prevention Systems Blueprint, an industry guideline that sets the technical and testing requirements for trackless mobile machinery (TMM) collision prevention systems.

The slower-than-expected progress is not primarily the result of missing technology. Sustainable Level 9 performance remains incomplete for a large part of the industry because compliance is an implementation discipline as much as a procurement decision. The gap is one of practice rather than purely of technology.

The implementation gap three years on

South Africa’s Level 9 regulatory requirement goes beyond earlier detection-and-warning stages. Where no action is taken to prevent a potential collision, the TMM must automatically retard to a safe speed and then apply the brakes, failing to a safe state without human intervention. Achieving that functional outcome reliably across mixed fleets, legacy machines and the full range of surface and underground conditions has proved a complex operational task.

A frequently cited constraint is the large population of legacy TMMs still in service. Retrofitting these older assets with the interfaces, sensors and control logic required for reliable automatic intervention is often technically complex and costly, particularly where remaining machine life does not justify the capital outlay. As this reality continues to shape the pace of fleet-wide progress, it becomes even more important that any installation of the technology is fit for purpose and sustainable over the long term.

In practice, the weak spots in a collision prevention system determine whether operators come to trust it and use it as intended, or lose confidence and ignore or circumvent it. These weak spots include operator alarm fatigue from frequent or non-critical warnings, unnecessary alarms during normal operations, sensing inaccuracies, and reduced system availability. Any of these can turn a theoretically capable installation into an operational liability .

An integrated approach to Level 9

 Ensuring that Collision Avoidance Systems (CAS) enhance rather than hinder mining productivity requires a holistic approach, integrating advanced technology with robust site-level controls, comprehensive operator training and effective change management. The technology solution is not a silver bullet, but must be considered in conjunction with people, processes, operating environments, and other key disciplines necessary to ensure the safe functioning of the mine environment.

IMT is the value-added implementation partner for Wabtec Digital Mine collision avoidance systems. In a Northern Cape surface operation, IMT implemented a site-wide Level 9-capable solution across plant and mine areas in July and August 2025. The deployment remains fully operational and has demonstrated the value of disciplined, staged implementation that treats the technology, the human interface and the supporting site controls as equal priorities.

We’ve learnt that deployments that deliver lasting performance share common characteristics: thorough site preparation and infrastructure readiness, machine-specific installation standards, baseline data collection in silent mode (allowing real interaction data to be gathered before intervention is activated), rigorous change management, and ongoing on-site support once the system is live.

From procurement to capability

The MOSH Collision Prevention Systems Blueprint provides the common technical reference the industry needs through its user requirements, functional and technical performance specifications, independent verification regimes and Section 21 frameworks. Adoption of that Blueprint, combined with independent Technology Readiness Level testing, is steadily raising the quality of available solutions. Yet the Blueprint itself does not install, tune or sustain a system on a working mine and that responsibility stays with the mine and its implementation partner.

It is important to distinguish independent verification of technology readiness from legal compliance under the Mine Health and Safety Act. TRL testing confirms that a system can perform the required functions under controlled conditions; actual regulatory compliance remains the employer’s duty and depends on correct selection, installation, integration, training and ongoing management in the specific operating environment.

Treating Level 9 solely as a procurement exercise carries clear risk. Mines that focus only on acquiring a system that claims regulatory capability often discover later that nuisance alarms, incomplete machine interfaces on legacy equipment, or inadequate support have undermined both safety and productivity. The more durable path is to treat compliance as a capability that is built, tested and maintained over time, including realistic assessment of which machines can be retrofitted cost-effectively and which require alternative controls or phased replacement.

Closing the gap

 South Africa remains the only country in the world that has regulated automatic machine intervention for TMMs at this level of specificity. The opportunity is to demonstrate that advanced collision prevention can coexist with, and even enhance, productive mining. The sectoral responsibility is to close the gap between regulatory intent and operational reality without creating new risks through poorly implemented systems.

Level 9 performance remains incomplete for many South African mines not because the required technology is absent, but because translating regulatory requirements into reliable, operator-trusted performance on diverse and often ageing fleets is a multi-layered operational challenge. When implementation discipline is applied with proper attention to silent-mode tuning, human factors, legacy-equipment realities and sustained support, complexity turns into certainty, and the original purpose of the regulation, fewer vehicle interaction fatalities, becomes achievable in practice.

The industry has the regulatory framework, the technical blueprint and increasingly mature technology. What remains is the consistent application of rigorous, human-centred implementation that accounts for both modern systems and the constraints of the existing machine population. That is where the remaining distance to full operational capability will be closed.