FAQs on the reporting of health and hygiene sampling through the Safety Regulation System

What is a Health and Hygiene Management Plan?

A Health and Hygiene Management Plan (HHMP) is a systematic process for managing agents that may adversely impact on a workers health at all stages of a mining operation. It forms an integral part of an organisations Safety Management System and compliments other major hazard management plans.

The HHMP documents hazardous agents and provides details of the control measures used to eliminate and reduce exposures as well as methods used to verify that controls are effective. It should demonstrate an understanding of the hazardous agents as a result of suitable investigation and consultation with experts and workers.

Who is required to submit a HHMP?

All mining operations are required to identify hazards, assess risks, detail controls and document the methods by which the effectiveness of those controls are assessed.  Therefore, all sites are required to have an HHMP or equivalent, including processing plants, supporting infrastructure (e.g. ports, camps), rehabilitation areas and exploration activities.

For particular operations, e.g. very small operations that have been exempt by the District Inspector from requiring a Ventilation Officer, an exemption from submitting a formal HHMP (and annual updates) may be requested. In this case, the Project Management Plan must adequately describe the hazards, controls and control validation methods for the operation.

When is an HHMP required?

A new HHMP should be submitted to the Department:

Prior to operations commencing (as the hazards must be identified and controls implemented prior to operations)
whenever a significant change occurs to operations that may alter the risk profile
Five yearly, if the risk profile or control strategies have not significantly changed.

To demonstrate ongoing management and compliance, an annual summary report should be submitted to the Department highlighting key findings and actions undertaken over the previous year (especially any changes to plans outlined with the HHMP submission).

How are HHMPs submitted to the Department?

HHMPs are submitted to the Department online via the Safety Regulation System (SRS). They are lodged through the Approvals sub-system. A HHMP submission contains a minimum of three elements:

  • a Health Risk Assessment (HRA)
  • the HHMP - which identifies all health and hygiene hazards on site, describes the existing and planned control measures relevant to each hazard, and outlines control verification procedures
  • along with an outline of the sampling program for the next 12 months.

Additional supporting documents including a noise report, noise control plan, dust management plan, diesel particulate management plan or any other document relating to the effective control of health and hygiene hazards on site can also be added to the submission, and in some cases may be requested by the reviewing inspector.

What happens to the HHMP once it’s submitted?

Once the HHMP is submitted, a notification will be sent to the HHMP company representatives (and the person who submitted the HHMP) to confirm the submission and inform them to proceed with implementing what has been proposed. The relevant inspectors will also be notified and may request further information or clarification if required.

When an HHMP submission is acknowledged, declined or withdrawn, a notification will be sent to the HHMP company representatives (and the person who submitted the HHMP). Alerts will also be sent to HHMP company representatives 2 months prior to the annual review due date of the HHMP, and 3 months prior to the expiry date of the HHMP.

What is health and hygiene sampling?

‘Sampling' means to measure or observe a small part of something in order to make conclusions about the whole. In the context of health and hygiene, sampling refers to measurements taken to assess workers’ exposure to particular hazards and the risk associated with that exposure.

Health and hygiene sampling is conducted for two main reasons:

  • Baseline or investigative sampling to identify hazards and assess risk - where the health and hygiene hazards that workers are exposed to are unknown or poorly understood measurements of all plausible hazardous agents must be taken in order to conduct a health risk assessment.
  • Ongoing monitoring to demonstrate compliance with an exposure standard and to verify control effectiveness - once the hazard is understood and appropriate controls are implemented, a regular sampling regime is developed to ensure detection changes in exposure profile and provide continuous validation of controls. Smaller sample sizes will be collected for this period but must be large enough to reasonably demonstrate compliance with an exposure standard.

In the SRS health and hygiene module, sampling refers to the results of atmospheric sampling, biological monitoring and noise dosimetry.

  • Atmospheric sampling - measures airborne concentrations of various hazardous chemicals including gases, dusts, fumes and mists. TWA, Peak and STEL measurements are all submitted via SRS
  • Biological sampling - tests for the presence of a hazardous chemical, its metabolites or other biochemical indicators in workers’ biological materials (usually as a blood or urine test) to determine how much has entered the worker’s body (exposure monitoring) or assess the physiological impact of exposure (health surveillance)
  • Noise sampling - uses dosimeters to measure workers’ daily exposures to noise. Peak noise levels and adjusted eight-hour equivalent noise levels (LAeq8h) are submitted through SRS.

What is the Health and Hygiene Sub-system in SRS?

In May 2017, the Health and Hygiene sub-system was introduced in SRS.

The Department is encouraging sites to submit a HHMP via SRS. All mine sites will be required to have a live HHMP submitted via SRS by December 2019. Supporting information such as guides and instructional videos will be available to assist with the transition.

Current SRS functionality enables industry to:

  • Submit sampling results for personal exposure to airborne contaminants, noise and biological agents.
  • Submit a HHMP and other documents that supports effective health and hygiene hazard management.
  • Submit health and hygiene sampling results against sampling plans (or without). Provide further information including contributory factors and proposed actions for samples identified as exceedances.

What if I don’t have access to SRS?

New users without a Department of Mines, Industry Regulation and Safety (DMIRS) ‘ex-account’ should contact an existing SRS company administrator in their organisation and ask to be registered and granted security roles.

If there is no SRS company administrator for a particular SRS sub-system, the person should register themselves via the DMIRS online system.

If you are unsure of who the Company Administrator is for the Health and Hygiene sub-system, contact the Hygiene Manager (see Who can I contact?)

What functionalities are coming soon to the SRS Health and Hygiene sub-system ?

Industry will soon have access to:

  • Basic statistical analysis of submitted samples
  • Readily apparent compliance status
  • Functionality that enables users to conduct an annual review of site specific HHMPs
  • Automated reminders for upcoming or overdue submissions.

Who can submit HHMPs and associated samples?

The HHMP must be submitted by a corporate endorser (registered manager of a mine or delegate). This signifies a commitment to actions described in the HHMP. Other company representatives (such as a hygienist, ventilation officer or noise officer) will be able to access and edit the HHMP but cannot complete the final submission.

Anyone with security access to the health and hygiene sub-system in SRS will be able to submit the results of atmospheric sampling, biological monitoring and personal noise dosimetry. For atmospheric and noise samples, the person submitting the data will be required to specify the details of the registered sampler or approved noise officer who took the samples.

Third parties, such as contractors or consultants, can input data, if granted the relevant SRS security access by the company administrator acting on behalf of the registered manager and principal employer.

How do I submit sample results via SRS?

For information on lodging individual sample results, refer to the SRS help videos

SRS has a bulk lodgement function that allows you to submit multiple sample results using either an XML or Excel file. Further information is available the guidance package 

Who has access to the samples?

Any users with security for the Health and Hygiene sub-system will be able to access all samples for the site they have access to – not just ones they have submitted themselves.

How are exceedances reported via SRS?

Results that exceed the noise action levels, biological indices or adjusted exposure standards are automatically identified and further information/actions will be required.

Industry can optionally provide an exceedance analysis for any noise, biological and atmospheric sample. This functionality allows industry to submit an exceedance analysis in line with:

  • the sampled persons adjusted exposure standard based on shift length, and/or
  • company specified action level (below the exposure standard).

The option to complete an exceedance analysis also applies to bulk lodgement. Users currently using this functionality can do this by clicking <Exceedance Analysis> when viewing the details of an individual sample.

Note: SRS adjusts exposure standards for atmospheric contaminants using the Quebec model, with adjustment categories as defined in the SRS Code Index. The Department's position is also guided by the AIOH position paper ‘Adjustment of Workplace Exposure Standards for Extended Work shifts’ (2nd edition 2016).

What information do I need to provide when there is an exceedance of the exposure standard?

If an exceedance analysis is required (or selected), further information will need to be entered. You will also need to provide details of the contributing factor(s) and any action(s) required to eliminate or reduce the risk of subsequent exposures. When entering the proposed actions in the exceedance analysis step, the hierarchy of controls should be applied.

Hierarchy of Control

Can I add to what I am currently reporting on through the bulk lodgement functionality?

Yes. For instance, if you are reporting atmospheric sampling you can add the results of noise and biological sampling. Please contact the Hygiene Manager to discuss what changes are required (see Who can I contact?).

Do sites still need to keep a Ventilation Log Book?

Yes, a ventilation log book must still be kept in accordance regulation 9.7. of the Mines Safety and Inspection Regulations 1995.

For a noise sample, what is meant by ‘expected attenuation’?

If the person sampled has been fit-tested, the expected attenuation is defined as the individual's fit testing results from the Hearing Protection Device (HPD) used at the time the sample was taken.

If the person sampled has not been fit-tested, enter the lowest level of noise attenuation (reduction) that can be expected from the HPD as highlighted in the table below.

AS/NZS 1269.3 Occupational Noise Management - Hearing Protector Program

Class SLC 80 Range
1 10 to 19 dB
2 14 to 17 dB
3 18 to 21 dB
4 22 to 25 dB
5 at least 26 dB

 

 

Do I need to submit ‘peak’ and ‘STEL’ samples?

Peak and 'STEL' samples may be submitted to the department optionally. However, regulatory requirements still apply if the level of atmospheric contaminant in a workplace exceeds the peak or 'STEL' exposure standard. Measuring peak and 'STEL' levels can be challenging with false positive results common unless rigorous testing methodologies and diligent interpretation of results occurs.

How do I become a registered sampler or noise officer?

To collect atmospheric and noise samples the person is required to be a registered hygiene sampler or an approved noise officer respectively. Details of this process are below.

Who can I contact?

The Hygiene Manger
Email: SRShygienemanager@dmirs.wa.gov.au
Phone: (08) 9358 8001 (then select option 2)