Addressing Culture of Non-conformance with
Over-Inspection Officers (OIO)
Sasol Mining - 2010
Inus Labuschagne
Setting the context
•
•
From various operational inputs it became clear that there is a prevailing
“Culture of Non-Conformance” at Sasol Mining.
These inputs include:
– Stakeholder engagement workshops with EEWG, Safety Officers,
– Safety Committee Members, Ventilation Officers, Audit teams
– Safety Task Team
– Recurring deviations found during Audits and Inspections
•
The result of this “Culture of non-conformance” is a RCR of 0.83 (09/10)
•
The Recordable Cases have increased from 59 (07/08) to 85 (08/09) to 109
(09/10)
•
Following the third fatality for financial year 2009/2010 it became even clearer
that drastic measures had to be taken to arrest the culture of “condoning
unsafe activities” at Sasol Mining
Appointment of Over Inspection Officers
•
An independent view of the level of compliance to safety and health standards
was required.
•
The MD of Sasol Mining, Hermann Wenhold requested the appointment of
sufficient Over-inspection Officers at Sasol Mining to enable an over inspection
of every identified workplace at every shaft during every shift.
•
The role of the Over-inspection Officers (OIO) was to visit every section on
every shift at Sasol Mining, to inspect compliance to standards and statutory
requirements.
•
The OIOs are required to inform the first line supervisor in charge of the
workplace as well as the team working there of the result of his/her inspections
even if no deviation is found.
Appointment of Over Inspection Officers
•
OIOs were trained and aligned on the standards and issued with standardised
inspection report books.
•
Should “Stop and Fix” deviations be found the section is not allowed to start-up
or commence with production unless the “Stop and Fix” deviations have been
fixed. The Miner is required to do the necessary communication in the line of
command relating non-conformances.
•
The process of over inspections commenced on Monday, 5 July 2010
Over Inspections - Checking compliance
Chain of command over - inspections
1.Miner shift report
2. Shiftboss logbook
3.Management audits
4.Internal OSHAS / ISO audits
5.Safety and Ventilation inspections
6.DMR inspections
7.Peer reviews
8.Machine Operational Checklists
Intervention - Over-Inspection Officers
1.Check compliance to key controls
•
•
•
Explosion prevention
Roof support
Emergency preparedness
2. Gather information to draw a
risk profile per work area
Section risk profile indicator
Ventilation requirement deviations
Last 3 months
10
9
8
7
6
5
4
9
8
7
3
6
2
4
4
1
3
3
3
1
1
0
SECTION 17
SECTION 13
SECTION 11
SECTION 16
3
3
0
SECTION 15
SECTION 21
SECTION 22
SECTION 14
SECTION 20
SECTION 12
SECTION 19
SECTION 18
Ventilation requirement deviations
Fire prevention deviations
Last 3 months
8
7
6
5
4
3
7
6
5
5
2
4
3
3
3
1
2
1
0
SECTION 11
SECTION 20
SECTION 19
SECTION 17
SECTION 15
SECTION 22
SECTION 18
Fire prevention deviations
SECTION 16
SECTION 14
SECTION 13
SECTION 12
SECTION 21
Section risk profile indicator
(continued)
Dust supression deviations
Last 3 months
50
45
40
35
30
25
20
45
41
15
10
5
33
25
21
21
17
16
16
13
12
SECTION 11
SECTION 22
SECTION 20
SECTION 19
SECTION 16
SECTION 15
4
0
SECTION 21
SECTION 13
SECTION 12
SECTION 17
SECTION 18
SECTION 14
Dust supression deviations
Total deviations per production section for Mine A
Last 3 months (Aug 2010 to Oct 2010)
60
50
40
54
45
30
39
20
33
29
10
27
27
26
24
16
13
SECTION 16
SECTION 14
0
SECTION 21
SECTION 13
SECTION 12
SECTION 17
SECTION 11
SECTION 22
Total deviations
SECTION 18
SECTION 20
SECTION 19
Over Inspection Officers – What worked well
•
A dramatic flow of energy within the first few weeks to comply to safety
standards
•
Large numbers of deviations identified and corrected within a very short period
•
Increased awareness amongst production team members regarding safety and
compliance standards
•
Complacency was eliminated
•
Knowledge refreshment on safety standards
•
Shortcomings and unclear descriptions were identified in COPs and SOPs.
•
Improvement in standardisation of safety practices
Over Inspection Officers – What did not work well
•
To resource this initiative at short notice was a challenge
•
The manpower primarily came from production units
•
Over-inspections is primarily the task of the supervisors. If that had been done
in the first place, over-inspectors would not have been required
•
This initiative did not address the root cause of non-compliance
•
It was agreed that this was necessary as an intervention but it is not self
sustaining
Over Inspection Officers – Sustainability?
•
The sustainable solution:
– Supervisors must be held accountable for compliance to standards
– Phasing out the OIOs:
Sections would have to demonstrate sustaining compliance for at least one
month. A team from another operation will perform an audit peer review to
validate compliance. If the audit proof successful, the team will celebrate this
achievement and also sign their commitment to the safety pledge.
Check chain of command responsibilities
SH&E Compliance and Recognition
Peer Review to be conducted by Audit
team, Ventilation, Environmental
Management and Mine Safety officer
then if comply should be sign of as
Intensive care unit to Compliance Unit
by all parties
Over-Inspection Officer findings
Workplace compliance to Standards
No
Yes
Maintain Standards.
Peer reviews to
Confirm compliance.
Consequence
Management.
Train and coach
Workplace compliance
to Standards
Yes
Go into contract with team
by signing Safety Pledge
and give Recognition
According to Policy
No
Consequence
Management
Sasol Mining Recordable Cases
Jul05
Aug
-05
Sep
-05
Oct05
Nov
-05
Dec
-05
Jan
-06
Feb
-06
Mar
-06
Apr
-06
May
-06
Jun
-06
05/0
6
RC
R
23
18
19
5
9
8
9
6
3
8
8
8
124
0.93
Jul06
Aug
-06
Sep
-06
Oct06
Nov
-06
Dec
-06
Jan
-07
Feb
-07
Mar
-07
Apr
-07
May
-07
Jun
-07
06/0
7
RC
R
4
2
7
6
3
8
8
8
7
8
13
10
84
0.73
Jul07
Aug
-07
Sep
-07
Oct07
Nov
-07
Dec
-07
Jan
-08
Feb
-08
Mar
-08
Apr
-08
May
-08
Jun
-08
07/0
8
RC
R
6
5
2
3
7
3
6
8
7
5
3
4
59
0.50
Jul08
Aug
-08
Sep
-08
Oct08
Nov
-08
Dec
-08
Jan
-09
Feb
-09
Mar
-09
Apr
-09
May
-09
Jun
-09
08/0
9
RC
R
10
2
11
10
14
6
2
8
6
2
3
11
85
0.73
Jul09
Aug
-09
Sep
-09
Oct09
Nov
-09
Dec
-09
Jan
-10
Feb
-10
Mar
-10
Apr
-10
May
-10
Jun
-10
09/1
0
RC
R
10
6
7
7
7
9
4
10
13
14
10
13
110
0.84
Jul10
Aug
-10
Sep
-10
Oct10
Nov
-10
Dec
-10
Jan
-11
Feb
-11
Mar
-11
Apr
-11
May
-11
Jun
-11
10/1
1
RC
R
4
9
11
4
2
30
0.80
RC rate, LWDC rate and All injury case rate
RCR
LWDCR
Sasol Mining RCR / AICR/ LWDC Rate History
AICR
2.5
2.11
2.02
1.93
2
1.82
1.79
1.53
1.45
1.39
RCR Rate
1.5
0.93
1
0.73
0.73
0.84
0.80
0.50
0.5
Target
0.23
0.25
0.28
05/06
06/07
0.20
0.30
0.25
08/09
09/10
0.30
0
04/05
07/08
10/11