1.0 PURPOSE & SCOPE
The purposes of this Minimum Mandatory Standard are as follows:
- To ensure that Environmental, Health, and Safety (EH&S) risk analyses (consisting of the identification, assessment, and prioritization of EH&S risk, including hazards and environmental aspects) are conducted both for the entire mine and specific levels within the mine;
- To require that management acknowledge the risks and eliminate or mitigate unacceptable risks identified by risk analyses;
- To require that management prioritize the findings, recommendations, and action items resulting from audits, inspections, incident and near-miss investigations, management reviews, EH&S change management procedures and other EH&S-related reviews/analyses in a consistent manner;
- To help identify and eliminate or reduce risk of hazards that could impact the ability to implement early science on specific requested levels within the mine that may or may not have been levels that were identified as levels of interest in the Conceptual Design Report; and
- To help establish an access map after risks have been identified, reviewed, mitigated or eliminated.
Upon full implementation of this requirement, South Dakota Science and Technology Authority (SDSTA) will have documented procedures in place that will meet the requirements of any regulatory requirements covering risk or hazard evaluation (e.g., the process safety management [PSM] requirements codified in 29 CFR 1910.119 for US sites, the risk management plan [RMP] requirements codified in 40 CFR 68 for US sites, the Seveso II Directive [Seveso] for EU sites, 30 CFR MSHA for US sites, etc.).
This Minimum Mandatory Standard applies to SDSTA.
SDSTA Executive Director and Lab Director – Ensure the implementation and documentation of the elements of this standard are completed as appropriate.
SDSTA EH&S Director – Approves changes or exceptions to this standard; without such approval, no changes or exceptions are allowed. The EH&S Director also conducts periodic audits to ensure compliance with this standard.
The following personnel and/or teams also have responsibilities under this Minimum Mandatory Standard:
Engineering Director (Engineering Personnel, Geologist, Mechanical, Civil, and Mining, but not limited to)
Science Liaison Director
Science Liaison Supervisor
Environmental Senior Specialist
Operations Safety Officer
EH&S Director – This is the staff person with responsibility for environmental compliance management at SDSTA. This person typically reports to the Executive Director and/or Lab Director.
Environmental Aspect – Element of SDSTA’s activities, products, and services that can interact with the environment. This interaction can result in either an adverse or beneficial change to the environment.
Environmental Impact – Any change to the environment, whether adverse or beneficial, wholly or partially resulting from SDSTA’s environmental aspects.
Hazard – Element of SDSTA’s activities, products, and services that has the potential to cause harm to employees, contractors or other personnel in the workplace.
Likelihood – A judgment of the chances that a hazard will result in an adverse impact or that an environmental impact will occur.
OSHA Process Safety Management (PSM) – A regulation that potentially applies to US sites, which is intended to prevent or minimize the consequences of a catastrophic release of toxic, reactive, flammable or explosive highly hazardous chemical from a process. It is codified in 29 CFR 1910.119. The term “PSM” can also more generically refer to the management program for process safety at a site.
Risk – For safety and health risks, the combination of the probability that a hazard will result in an adverse impact and the consequences of the hazard occurring and for environmental risks, the combination of the probably that an adverse environmental impact will occur, and the consequences of the environmental impact.
Risk Assessment – A process of analyzing the level of risk, considering those in danger (the impacted population both on and off-site) and/or the environmental receptors (e.g., air, water, soil, biota, etc.), and evaluating whether hazards and environmental aspects are adequately controlled, taking into account measures already in place. A graphic representation of a generic risk assessment procedure is included as Figure 1.
Figure 1. Generic Risk Assessment Procedure
Identification of hazards and environmental aspects
Identification of scenarios associated with these hazards and environmental aspects
Probability of an adverse impact from a hazard occurring or of an adverse environmental impact
Consequence of hazard or environmental impact
Acceptance of risk?
Build or operate system/process
Modify system operation/design such that an acceptable level of risk is achieved
Risk Management Plan (RMP) – The primary requirement of a regulation that potentially applies to US sites, which is intended to prevent or minimize the consequences of a catastrophic release of flammable or toxic substances from a process. It is codified in 40 CFR 68.
Severity – A judgment of the gravity of a possible outcome from a recognized hazard or of an environmental impact (i.e., a qualitative assessment of the scale of impact if an event occurs).
Seveso II Directive (Seveso) – A regulation that potentially applies to European Union (EU) sites, which aims to prevent major accidents involving dangerous substances and to limit the consequences of such accidents should they occur.
4.1. Enterprise-Wide (Homestake Mine) Risk Analyses
The EH&S Director, with assistance from personnel listed in Section 2.0 of the document, shall conduct enterprise-wide (Homestake Mine) risk analyses. Homestake Mine risk analyses shall consist of identifying, assessing and prioritizing the significant risks associated with each Level that can be controlled or influenced by SDSTA. Identified risks shall be ranked and prioritized using a severity and likelihood matrix according to the requirements in Requirement 4.3 for prioritization. The EH&S Director shall establish documented plans to eliminate or mitigate unacceptable risks to submit to upper management for direction on how to use such plans.
The results of the risk analyses from all Levels shall be combined to assess enterprise-wide risks. The purpose of analyzing risks across the Homestake Mine is to allow the management team to identify the most significant risks for the mine, determine if the risks have been controlled to an acceptable level and prioritize the direction of SDSTA’s resources in eliminating or mitigating unacceptable risks to SDSTA’s resources, including people, environment and capital.
The EH&S Director shall maintain a written list of the most significant risks for SDSTA and approved elimination and/or mitigation plans from upper management to manage identified risks. The EH&S Director shall maintain the schedule for which the elimination/mitigation of a risk shall be appropriate to the relative priority of the risk and immediate action shall be taken on all high priority items to reduce risk to an acceptable level.
Elimination of risk shall be the preferred option for all unacceptable risks. If elimination is not an option, risks shall be mitigated according to a risk control hierarchy where design andengineering controls are preferred. A minimum of two layers of control is required for all significant risks. Significant risks shall not be controlled through procedures or other systems that rely solely on people.
The Executive Director / Lab Director shall incorporate the risk elimination/mitigation plans into the overall business plan for SDSTA and is responsible for the ultimate implementation of the risk elimination/mitigation plans.
The Executive Director / Lab Director shall track to completion any action items necessary to eliminate or mitigate unacceptable risks (see EHS500-MMSR – document management).
Homestake Mine risk analyses shall be reviewed and updated once every three years. In addition, after any significant incident, the SDSTA Management shall conduct an updated risk analysis for the specific Level and possible contributing Levels located in the region the incident occurred. The EH&S Director, together with the personnel listed in Section 2.0, shall review the results of the updated analysis to determine if any SDSTA’s priorities require revision.
Procedures used to conduct all Homestake Mine risk analyses shall be documented. The results from all enterprise-wide risk analyses, including assumptions made and the risk ranking approach used, shall also be documented.
4.2. Specific Level Risk Analyses
The EH&S Director shall establish, implement and maintain a documented procedure that requires each Level of the mine to have a risk analysis conducted that is appropriate to the nature and scale of the need for each Level and its continued operation or use. Level risk analyses shall be reviewed and updated once every year, after any significant incident and after any known significant change. The specific level procedure will apply detailed steps that take the Level as part of a region within the mine, or the entire mine as it relates to risk analysis, or it can require each specific Level to have their own procedure with specific details as needed, as long as those level procedures meet the standards in this document.
Specific Level Risk Analysis procedures shall include the identification and assessment of risks that it can control and influence, including the following:
- Ground Control Systems
- Rock Formations – Geology
- Bolting and Support
- Primary and Secondary Egress (Escape Routes)
- Oxygen deficiency
- Air composition affected by water or old timber
- Ponded Water
- Catastrophic events (acts of God)
- Drainage patterns
- Mine Infrastructure Deterioration
- Transportation risks – tracks, ladders, pipelines
- Stopes – condition, age, volume if possible
- Wall Integrity (retaining)
- Environmental aspects of the level’s activities, users, equipment, operations, including those associated with normal operations, abnormal operations, and emergency conditions;
- Health and safety risks for routine as well as non-routine activities;
- Risks associated with new equipment (installation) and processes (risks should be identified for new equipment and processes as part of change management, see EHS220- MMSR);
- Risks associated with changes to existing equipment and processes (risks should be identified as part of change management, see EHS220-MMSR); and
- Risks associated with legacy disposal practices.
- Back fill
- Shaft Systems
Specific level risk analysis procedures (or other separate documented procedures, which already exist) shall include the effect of equipment on that Level (old/new), including operating procedures to process information.
Specific level risk analysis procedures shall detail the techniques to be used to identify and assess hazards and environmental aspects. These procedures must meet any applicable regulatory requirements covering risk or hazard evaluation (e.g., the PSM requirements codified in 29 CFR 1910.119 for US sites, the RMP requirements codified in 40 CFR 68 for US sites, Seveso for EU sites, 30 CFR MSHA, etc.), but shall not be limited to processes with such regulatory requirements.
Specific level risk analyses shall be conducted by a team with expertise in engineering; mine operations; personnel listed in Section 2.0; and shall include one employee who has experience and knowledge specific for the process or operation being reviewed. The team shall also include at least one member knowledgeable in the specific technique(s) being used to identify and assess risks.
A risk-ranking based system shall be used to quantitatively prioritize all risks identified and assessed. The risk-ranking based system shall include a severity and likelihood matrix according to the requirements in Requirement 4.3 for prioritization.
Specific level risk analysis procedures shall include the documentation of the risk analysis results, assumptions made, identification and assessment techniques used and risk-ranking approach used.
The EH&S Director or representative shall maintain a written list of the most significant risks for SDSTA and shall establish documented recommendations to eliminate or mitigate risks deemed unacceptable by the Executive Director and/or Lab Director. These recommendations are submitted to the Board for approval. Upon approval the Executive Director or Lab Director will delegate any follow-up, if applicable, to appropriate representatives. The schedule for elimination/mitigation of a risk shall be appropriate to the relative priority of the risk and immediate action shall be taken on all high priority items to reduce risk to an acceptable level. Elimination of risk shall be the preferred option for all unacceptable risks. If elimination is not an option, risks shall be mitigated according to a risk control hierarchy where design and engineering controls are preferred. A minimum of two layers of control is required for all significant risks. Significant risks shall not be controlled only through procedures or other systems that rely solely on people.
The Executive Director and Lab Director shall incorporate the risk elimination/mitigation plans into the overall business plan for SDSTA and is responsible for the ultimate implementation of the risk elimination/mitigation plans. The EHS Director or representative shall track to completion any action items necessary to eliminate or mitigate unacceptable risks (see EHS500-MMSR).
4.3. Prioritization of Findings, Recommendations, and Action Items
SDSTA shall prioritize all findings, recommendations, and action items resulting from EH&S risk analyses (see Requirements 4.1 and 4.2), audits, inspections, incident and near-miss investigations, management reviews, EH&S change management procedures, and any other EH&S-related reviews/analyses.
All findings, recommendations, and action items (or in the case of a risk analysis, all identified risks) shall be ranked and prioritized using a severity and likelihood matrix. Severity scores shall take into account legal issues and the concerns of internal and external interested parties. The product of the severity and likelihood scores represents the risk. The resulting risk values must be divided into at least three priority categories (e.g., high, medium, and low). Note that this Minimum Mandatory Standard does not specify that a particular ranking and prioritization scheme be used; therefore, any procedure that meets the intent of this Minimum Mandatory Standard to have each finding, recommendation, and action item ranked and prioritized using a severity and likelihood matrix is satisfactory. Other factors, beyond severity and likelihood (e.g., an injury factor), may be considered in the matrix, if deemed appropriate. Appropriate qualified employee participation is required in assigning severity and likelihood values.
The ranking methodology used by SDSTA shall be documented and available for review. The methodology used shall be communicated to all staff involved in the prioritization prior to initiation of the process so that it can be assured that all likelihood and severity judgments will be made using the same basis (i.e., the analysis will compare “like to like”, e.g. “apples to apples”). The results of the ranking shall be documented and available for review.
The priority of a finding, recommendation, or action item as well as the need for timely access shall be considered when developing a schedule to address the finding, recommendation, or action item. Items with higher priorities shall have a more aggressive schedule for completion, if and when access is needed, than items with lower priorities. Tracking of all action items shall meet the requirements in EHS500-MMSR.
The EH&S Director or representative is required to ensure that Personnel listed in Section 2.0 are trained on conducting site-level risk analyses and risk ranking methodologies, including specific techniques for risk identification and assessment, as necessary. Having been involved in a specific level risk analysis may be sufficient to ensure the necessary training for personnel.
The EH&S Director or representative will conduct an audit to ensure compliance with this standard once every three years.
5.0 REFERENCE AND RELATED DOCUMENTS
Minimum Mandatory Standard (MMS) for Change Management (EHS220-MMSR)
MMS for Identification, Investigation, and Corrective and Preventative Actions (EHS500- MMSR)
Risk analysis studies to include the following records:
- Reports & Studies (previous risk reviews, recommendations, closure reports).
- Drawings and Diagrams (Maps).
- Inspection Reports (Historical and within 3 weeks of review start date).
- Previous Risk Recommendations.