Theft, as a consequence of mining equipment and machinery remaining idle for a long period, is an issue for operations on care and maintenance, says law firm ENSafrica mine and occupational health and safety director Pieter Colyn.
In many cases, mining operations retain third-party security personnel for the same duties that they would have had prior to the period of care and maintenance.
As a result, it is important that security and health and safety aspects of a mining operation are properly considered, planned and continually managed during such a phase, Colyn notes.
Care and maintenance does not mean that the mining operation is permanently halted – it is rather a temporary ceasing of mining operations, with a prospect of restarting operations in the future, he explains.
Colyn adds that only the services, work and tasks associated with care and maintenance are conducted at the mining operation, with staff capacity inevitably reduced.
In addition to equipment theft, illegal mining also poses a threat.
“The majority of illegal mining activities take place at mining areas that have been abandoned, or where closure certificates have been issued, for a significant period of time,” says ENSafrica mine and occupational health and safety director Warren Hendricks.
He adds that, if the mining operation is properly managed during the care-and-maintenance phase, and support is provided by security and South African Police Service personnel, the risks associated with illegal mining are well within mitigation.
Hendricks explains that the correct health and safety processes when placing a mine on care and maintenance include ensuring that proper risk assessments are done in accordance with Section 11 of the Mine Health and Safety Act (MHSA).
The mining company must ensure that these assessments are undertaken in relation to the tasks, work and operations that will be conducted under care and maintenance.
While mining operations are temporarily idle during this time, there will be a change of working environment and organisation of work. It is important that the hazards associated with work and operations are identified, and that the associated risks are assessed, controlled, mitigated and/or eliminated.
“The risk assessment process will constitute the blueprint for the health and safety measures and management systems to be put in place and monitored during the phase.
“It is important that the employer identifies the statutory obligations in terms of the MHSA that would remain applicable and require compliance with during care and maintenance,” he says.
Hendricks also points out that there are certain statutory obligations according to the MHSA that only apply to an operation that ‘is being worked’.
Mines failing to comply with the risk assessments may result in potential instances of noncompliance in terms of the provisions of the MHSA, and accidents.
“This could result in criminal sancions and costly administrative fines for the employer, which should be avoided, at all times, but especially when a mine is being placed under care and maintenance,” Colyn concludes.