With the many changes and
revisions taking place in the draft documentation being prepared to
complement the Mine Health and Safety Act, we feel that a general comment
in this regard as well as a look at the specific issues is needed.
Noise Issues
With the Act specifying that "significant
risks" be monitored after assessment, we note that the concept is
fine if one can define "significant risk".
The new, or at least the latest revision to the draft regulations has now
defined this "significant risk" as an eight-hour basis exposure
of 82 dBA.
The value has been derived on the basis that the exposure of any person to
this level will reflect about a 10% value of the limit of 85 dBA.
Arguments along the above lines only serve to accentuate the necessity of
ensuring that exposed persons wear hearing protection devices (HPD's) and
that this be enforced using the disciplinary code route if necessary.
The difficulty of reflecting noise exposure values on medical records
could also pose several logistical problems. Dosimetry appears to be
favoured by some inspectors but we point out that dosimeters are not
manufactured to the required class 1 noise instrument accuracy. This has
proved a necessity and thus some sort of workstation assessments are
likely to be favoured in the future.
For more information see out Noise
assessment sections
Gravimetric Dust Sampling
As with noise, a "significant risk"
level of 10% of the dust or pollutant present has now been specified.
Illumination
The draft regulations have a published list of
required illuminance values, which is welcomed as various recommendations
including the Occupational Health and Safety Act list have been applied.
Many of these lists differ from one another, leading to confusion.
While we measure illuminance levels and indicate
these we point out that averaging should be applied in general. We also
consider factors like the actual activity illumination and not the general
area, which the lists ignore at their peril.
The actual illuminance requirements differ from
person to person and with age with the result that any assessment should
be task related and not just a blind interpretation of values indicated on
a list.
For more information see how we "shed
a little light on the subject"
The department of Minerals and Energy have placed
a greater emphasis on ergonomics in recent years and while one has to make
do with existing ergonomics on old equipment, adjustments can do wonders.
Heat & Thermal Stress
The draft regulations have now established
criteria for heat stress in both confined or underground areas as well as
in open exposed pits and quarries.
In addition, emphasis has now also been made on requirements for chill
factors and cold condition exposures.
While this has been defined conveniently as a
"health" issue and thus not an occupational risk, a recent
litigation case resulted in a substantial pay our to a worker who was
infected rendering assistance to an HIV infected co-worker.
With this precedent now set, on the job infection
or cross-infection has effectively become an occupational risk leading to
potential damage claims. We have now added an HIV/Aids section to all our
reports.
This describes the requirements and safety
precautions that should be adhered to when supplying air for divers and
for sandblasting personnel.
