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Compliance alerts

April 2015

Fatigue and fatigue management have long been an area of concern.  The Guideline for a Mandatory Code of Practice for Risk Based Fatigue Management at Mines, which was published on 19 December 2014, describes fatigue as "…more than simply feeling tired or drowsy.  It is caused by prolonged periods of physical and/or mental exertion without enough time to rest and recover", and describes the consequences as including an individual's capacity to function, decreased performance and productivity, and increased potential for injuries to occur. 

The fatigue guideline is aimed at assisting employers to achieve the objectives of risk-based fatigue management at the relevant working places.  An extensive amount of work (primarily based on hazard identification and risk assessment), is required in order to comply with the fatigue guideline, and to prepare the required code of practice. Aspects to be addressed includes the shift system and the shift rostering.  This may also therefore impact on existing collective agreements, production schedules and upcoming wage negotiations, particularly in the coal and gold commodities.

The fatigue guideline concludes that fatigue is underreported in incident investigations and requires employers to actively consider whether fatigue contributed to any incidents or accidents. It is likely that fatigue and related consequences will be interrogated by the Mine Health and Safety Inspectorate in any investigations conducted in terms of section 60 and/or inquiries in terms of section 65 of the Mine Health and Safety Act 29 of 1996.

Conveyor belt installations have also been a constant source of concern.  The Guideline for a Mandatory Code of Practice for the Safe use of Conveyor Belt Installations for the Transportation of Mineral, Material or Personnel, published on 19 December 2014, requires the implementation of a comprehensive code of practice in support of the management of all activities associated with conveyor belt installations, including design, installation, extension, dismantling, transportation, re-installation, maintenance and repairs.  Understandably, there is a strong focus on the guarding of conveyor belt installations. 

Trackless mobile machinery, and in particular, collisions between trackless mobile machines and other trackless mobile machines and between trackless mobile machines and persons, is extensively addressed in the amended Regulations relating to machinery and equipment, published on 27 February 2015.  The Trackless Mobile Machinery Regulations come into effect on 27 May 2015.  The new Regulations are comprehensive and, in addition to interaction between machinery and persons, address safe operations of trackless mobile machines, refuelling, wheels, tyres and rims, access of persons, roadway conditions and related aspects.  Existing codes of practice, procedures, standards and instructions should therefore be reviewed, in light of the new Trackless Mobile Machinery Regulations, and where appropriate, amendments should be made. 

The team

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