This is the third in a series of six columns exploring traditional principles of safety. Previous parts were entitled: “Safety First” and “Safety is Just Common Sense.” – Ed.
The typical box is made up of six panels – top, bottom and four sides. That same structure can be applied to the figurative box often referenced when one is advised to “think outside of the box.” This is the third of six columns focused on expanding our approach to safety beyond each of those six panels.
Compliance = Safety
In mining, we understand that we must play by a set of safety rules. The most prominent of those rules are produced by and enforced by the Mine Safety and Health Administration (MSHA). Failure to comply with those rules can result in a citation, an injury or (in many cases) no adverse consequence at all.
These are not the only set of safety rules under which we operate. At the national level, OSHA, DOT, ATF and other agencies demand compliance. There may be state or local regulations for which you must comply. And where there are gaps, we create our own corporate or site-specific safety rules. Combined, a significant part of our safety effort is focused on compliance with rules and regulations.
- Some safety rules require that we create and maintain a safe environment: 30 CFR § 56.4602 Gauges and regulators used with oxygen or acetylene cylinders shall be kept clean and free of oil and grease.
- Some direct us to perform: 30 CFR § 56.4201 (a)(1) Fire extinguishers shall be inspected visually at least once a month to determine that they are fully charged and operable.
- Others ensure that miners are properly informed or trained: 30 CFR § 46.7 (a) You must provide any miner who is reassigned to a new task in which he or she has no previous work experience with training in the health and safety aspects of the task to be assigned …
- Still others require verification through recordkeeping: 30 CFR § 56.14100 (d) Defects on self-propelled mobile equipment affecting safety, which are not corrected immediately, shall be reported to and recorded by the mine operator. The records shall be kept at the mine or nearest mine office from the date the defects are recorded, until the defects are corrected. Such records shall be made available for inspection by an authorized representative of the Secretary.
So can we truly say that full compliance with this multitude of safety rules will actually produce safety?
Certainly safety rules are important to safety, but they do not reflect your site conditions and the level of skill and experience of your personnel. Nor do they account for the specific safeguards you employ to mitigate risks that are unique to your operation.
Compliance and Injury Incidence
Some question whether a strong correlation exists between compliance (as measured in enforcement) and injury incidence. MSHA M/NM injury and enforcement data from 2007 through 20131 may confirm that supposition.
During that time period, MSHA reportable incident rates dropped steadily from 3.02 to 2.11 (incidents per 200,000 man-hours). During that same time frame, the number of citations per mine rose steadily from 4.67 in 2007 to a high of 5.97 in 2010. It then dropped steadily to a low of 4.60 in 2013.
Incident rates dropped steadily whether enforcement increased or decreased. Could it be that we’ve reached (or nearly reached) maximum benefit from compliance enforcement?
Compliance may effectively protect miners from ordinary hazards and compliance with established safety rules and regulations should be viewed as an important component in defining safety in mining operations.
However, compliance will not necessarily protect miners from the extraordinary – the unusual. These are the types of incidents we must learn to prevent if we are to improve. We cannot hope to produce a rule for each and every possibility. While we’ve made astonishing progress in institutionalizing safety, safety is ultimately very personal. Only when we create, nurture and operate within a true safety culture will we begin to approach our ultimate objective.
1 Based on preliminary data for calendar year 2013.