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

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

The HHMP documents what hazardous agents workers are exposed to and provides details of control measures used to eliminate and reduce exposures. It also outlines the methods used to verify that the controls are effective.

All sites are required to have a HHMP or equivalent, including processing plants, supporting infrastructure (e.g. ports, camps etc.), rehabilitation areas and exploration activities.

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).

The HHMP should be revised (note: SRS refers to a revision):

• whenever a significant change occurs to operations that may alter the risk profile and
• five-yearly, if the risk profile or control strategies have not significantly changed.

New and revised HHMPs are submitted to the department in a digital format via the Safety Regulation System (SRS) ‘Approvals’ sub-system. The HHMP submission contains a minimum of three elements:

• Health Risk Assessment (HRA)
• a document which describes how all health and hygiene hazards identified and assessed at the site are controlled or managed to protect the health of all workers.  This management plan (the HHMP) describes the existing and planned control measures relevant to each hazard, and outlines control verification procedures
• sampling program outline 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. In some cases additional information may be requested by the reviewing inspector.

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/carrying out what has been proposed. At this stage the HHMP is under assessment. Relevant inspectors will be notified of the submission and will undertake a review of the quality and relevance of the management plan and sampling strategy. An inspector may request further information or clarification if required.

Based on the relevance and quality of the submission, the reviewing inspector may acknowledge, return for further information, decline or withdraw the submission. A notification will be sent to the HHMP company representatives (and the person who submitted the HHMP) to advise when this occurs. Alerts will also be sent to the HHMP company representatives two months prior to the annual review due date of the HHMP, and three months prior to the expiry date of the HHMP.

An annual review is an opportunity to highlight improvements to the exposure profile of the site including whether controls implemented over the previous year have been successful. It must be completed every 12 months from the date the sampling plan was implemented.

Completing the annual review also provides the opportunity for industry to identify any similar exposure groups (SEGs) exposed to agents above acceptable levels. Where these SEGs are identified, an action plan will be developed to investigate further controls to reduce exposures to these agents. Where there are more than five per cent exceedances for any agent (atmospheric, biological or noise) for the previous sampling plan year or where the 95th percentile is greater than the exposure standard, a control action plan for the next year will become a mandatory attachment to the annual review.

To demonstrate ongoing management and compliance, an annual 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). The annual report will also justify any variations to the sampling plan for the next 12 months.

An annual review submission must include the following documents:

• An annual report
• Noise report (only mandatory for the first annual review submission)
• Control action plan (only mandatory where >5% exceedances, or the 95th percentile is above the exposure standard).

An ‘Annual Report’ is a mandatory document that will be submitted with each ‘Annual Review’.

The following items may be included in the report:

• Details regarding areas that require further efforts to reduce exposures and to control risks
• Justification for meeting or exceeding the number of samples that were committed to in the initial HHMP submission, including justification for any variations to future sample numbers
• Details relating to control measures outlined in the HHMP that may have changed, including the implementation of any additional controls
• Justification for any alterations to the number and frequency of health assessments and/or audiometric tests
• Any other matters relating to a site’s commitment to effectively manage health hazards.

Only company representatives with the Corporate Endorser role may submit ‘annual reviews’ and ‘revisions’. Other company representatives with the relevant SRS security access, can prepare the annual review.

A revision of an existing HHMP is required to be submitted:

• When there is a significant change to the site’s risk profile.
• Every five years from the commencement of the original sampling plan of the HHMP.
• When new health and/or hygiene hazards are introduced.
• When there is a significant change to the workforce.

The following updated documentation must be provided:

• Health and Hygiene Management Plan (HHMP)
• Health Risk Assessment (HRA).

In addition to the HHMP and HRA, management plans and/or control plans such as fibrous mineral management plans or noise control plans, may be included in the submission to provide further detail on how health and hygiene hazards are managed.

New and revised HHMP’s are submitted to the department in a digital format via the Safety Regulation System (SRS) ‘Approvals’ sub-system.

The HHMP submission contains the following three elements that must be included:

• A Health Risk Assessment (HRA).
• The HHMP, which describes how all health and hygiene hazards identified and assessed at the site are controlled or managed to protect the health of all workers.
• The sampling plan for the next 12 months.

Sites using the levy exempt mines template will need to attach the HHMP to the submission twice, as the HRA is embedded within the HHMP – levy exempt template.

Persons responsible for the submission will also need to create at least one Similar Exposure Group (SEG) under the SRS heading “Sampling Plan”. For example, select the agent respirable dust (Res) and select “samples will be provided as required”.

Exposure monitoring is undertaken to quantitatively assess the exposure risk of workers to hazardous agents at work. However as it is not feasible to monitor every individual worker’s exposure that may vary from day to day, samples of daily exposures are taken. When a statistically significant number of samples are collected, the ventilation officer can confidently make inferences about the likely exposures that most workers will experience when they do a specific job.

In SRS, ‘sampling’ refers to randomly selecting individuals believed to have similar exposures to participate in an exposure monitoring program over a selected sampling period. For compliance monitoring, the sampling plan has been nominated to extend across 12 months.

Health and hygiene sampling is conducted for two main reasons:

• Baseline or investigative sampling to identify hazards and assess risk
• Ongoing monitoring to demonstrate compliance with an exposure standard and to verify the effectiveness of health hazard control measures.

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.

Once the hazard is well understood and appropriate controls are implemented, a regular sampling regime is developed to ensure detection of 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. Time-weighted average (TWA), Peak and short-term exposure limits (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. Adjusted eight-hour equivalent noise levels (LAeq8h) and peak noise levels and are submitted through SRS.

The State mining engineer has requested all sites to submit a Health and Hygiene Management Plan (HHMP) via SRS. All mine sites are required to have a live HHMP submitted via SRS by 30 June 2019. Supporting information such as guides and instructional videos are 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
• Submit a HHMP revision
• Submit an annual review of a HHMP
• Receive automated reminders for upcoming or overdue submissions.

New users without a 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.

• Basic statistical analysis of submitted samples
• Compliance status with the number of specified samples
• Functionality that enables users to submit a ‘revision’ of an existing HHMP.

An HHMP must be submitted via the ‘Approvals’ sub-system in SRS 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 and/or 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.

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 

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.

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.

SRS adjusts exposure standards for atmospheric contaminants using the Quebec model, with adjustment categories as defined in the Safety Regulation System (SRS) health and hygiene code index below. The department is also guided by the AIOH paper titled: ‘Adjustment of Workplace Exposure Standards for Extended Work shifts’ (2nd edition 2016).

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.

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?).

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

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.

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.

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.

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