Implementing Recognised Standard 14 - Monitoring of Respirable Dust in Coal Mines
Since May 2015, when the first re-appearance of coal workers pneumoconiosis (CWP) was detected, the Regulator, Industry and Unions have all taken up the challenge to reduce worker exposures to Respirable Coal Dust.
Following completion of the Sims review, tripartite groups collaborated to produce the findings within this report. Interim and ongoing changes have since been made to the health surveillance system.
Regulatory changes to the way Industry assesses and controls the risk of coal dust exposure has remained unchanged.
Until now that is…
A new Recognised Standard 14 (QLD), Monitoring Respirable Dust in Coal Mines has been released. A standard for the Queensland Coal Industry to adhere to in the monitoring, reporting and investigation of worker exposure to respirable coal dust.
This article seeks to explain some of the key initiatives that the Recognised Standard 14 (‘the Standard’) has introduced to the QLD Coal Mining sector.
So what has changed?
As a whole, the Standard has formalised the requirements that the vast majority of QLD mines have already put in place. This has been a progressive journey for the sector over the last 10 years while Occupational Hygiene programs have matured.
During that time, industry specialists have helped to shape what has since become industry practice for managing occupational hygiene risks.
The Standard is a useful tool to clarify that approach for assessing exposures, enabling mines to focus on the most important thing, controlling exposure to mine workers.
The Standard (available here) outlines the accountabilities that the Site Senior Executive (SSE) holds. It applies to all underground coal and surface coal operations and is inclusive of all activities on the mine lease. Although it focuses heavily on monitoring respirable coal dust exposures, the Standard strongly promotes the programs to be control focused.
The purpose of the Recognised Standard 14: Monitoring of Respirable Dust in Coal Mines (‘the Standard’) is to provide the coal mining sector minimum requirements that shall be included in the site safety and health management system to manage the risk of exposure to mine workers.
The standard is based on a risk management model similar to the principles currently in place at your operation.
GCG undertook a high-level gap analysis on the new standard against current industry practices, where the below changes were identified as the most significant changes for industry to be aware of:
Table 1 – Significant changes from industry practice
|Risk based exposure monitoring plans||Personal exposure monitoring programs are to be designed to a specified model and reviewed by a competent person (i.e. COH).|
|95% Upper Confidence Level (UCL) for exposure assessment||The UCL 95% is to be used for assessing the risk for each relevant SEG onsite. This metric is derived from statistical analysis and should be reviewed annually as a minimum. For help with the UCL, see our help article.|
|Single exceedance re-testing 14 days||Each single exceedance for respirable coal dust is to be re-sampled within 14 days. There’s a specific reporting and actioning protocol for this.|
|Controls||The Standard is for monitoring respirable dust, however, there is a clear requirement to monitor the performance of controls. Gathering evidence to feed into any investigations will be highly beneficial.|
It is important to note that this standard has not clarified how to determine compliance with the occupational exposure standard for respirable coal dust. However, it is clear that each site is required to measure their own performance against the 95% UCL.
Considering the context of the document, the pathway to success clearly lies in controlling worker exposures.
To enable this, a documented control program should be running parallel to your monitoring program. This should be accessible at any time to pro-actively seek and document failures in your dust control systems that could lead to non-compliance with the 95% UCL and/or single exceedances. Supporting this through realtime monitoring can be hugely successful.
Should you require any assistance during the transition of this standard, we would be delighted to help.
Feel free to contact us to talk with a Senior Occupational Hygiene Consultant.
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