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INCIDENT INVESTIGATION and REPORTING

QP75.WHS.INV.001 Revision 2

Mining Health and Safety

Any PRINTED copies of this procedure are UNCONTROLLED Page: 1 of 31

TABLE OF CONTENTS

1.0 PURPOSE ......................................................................................................................................... 2 2.0 SCOPE .............................................................................................................................................. 2 3.0 LEGISLATIVE MANDATE ................................................................................................................. 2

4.0 REFERENCES .................................................................................................................................. 2 5.0 DEFINITIONS .................................................................................................................................... 3 6.0 SAFETY & ENVIRONMENTAL RISK ANALYSIS ........................................................................... 13 7.0 PROCEDURE .................................................................................................................................. 13

7.1 Arrium Code of Practice Critical Elements .................................................................................... 13 7.2 Safe Systems of Work .................................................................................................................. 13

7.2.1 Initial Response (and Securing the Scene) ............................................................................... 13 7.2.2 Assessment and Notification ..................................................................................................... 14 7.2.3 Investigation .............................................................................................................................. 20 7.2.4 Corrective Actions ..................................................................................................................... 23 7.2.5 Effectiveness Review and Close Out ........................................................................................ 25

8.0 TRAINING AND COMPETENCE ..................................................................................................... 26

8.1 Awareness Training ...................................................................................................................... 26 8.2 Lead Investigator/Investigation Team ........................................................................................... 26

9.0 RESPONSIBILITIES, AUTHORITIES AND ACCOUNTABILITIES .................................................. 26

9.1 OneSteel / Arrium Safety Council ................................................................................................. 26 9.2 OneSteel / Arrium Safety Network ................................................................................................ 27 9.3 Business Unit Lead Teams (eg. Mining Lead Team led by Chief Executive) ................................ 27 9.4 General Manager ......................................................................................................................... 27 9.5 Business Management Team (eg. Mining Operations Lead Team) .............................................. 27 9.6 Business Area/Stream Managers (eg. Manager – Mining Stream) ............................................... 27 9.7 Site / Department Managers (eg. Operations / Maintenance Managers)....................................... 28 9.8 Supervisor / Shift Team Leader (including Contractor supervisors) .............................................. 28 9.9 Contractor Controllers .................................................................................................................. 29 9.10 Investigation Leader ..................................................................................................................... 29 9.11 Workers (including Contractor workers) ........................................................................................ 29 9.12 Health and Safety Representative / Safety Coordinator ................................................................ 29 9.13 Health & Safety Department ......................................................................................................... 29 9.14 Departmental Environment Coordinators/advisors ........................................................................ 30 9.15 Environment Department .............................................................................................................. 30

10.0 MONITORING AND MEASUREMENT ............................................................................................ 30 11.0 DOCUMENTATION ......................................................................................................................... 31

11.1 WORK INSTRUCTIONS .............................................................................................................. 31 11.2 TOOLS ......................................................................................................................................... 31 11.3 FORMS ........................................................................................................................................ 31 11.4 ATTACHMENTS .......................................................................................................................... 31





1.0 PURPOSE This procedure is to ensure that when incidents do occur;

• those injured are cared for and no one else is at further risk of injury; • environmental impacts are minimised • they are reported to those responsible for undertaking investigations within the business

including supervisors and/or managers; • responsible persons immediately investigate, root causes are identified, corrective

actions are implemented and reviewed for effectiveness, learnings are applied and shared to prevent recurrences;

• and that information is communicated to management & relevant statutory authorities when required.

This procedure also gives guidance to Arrium Contractor Controllers to ensure they are aware of their responsibilities in relation to incidents that have occurred by the Contractors they are working with on Arrium sites.

2.0 SCOPE

This procedure applies to all Arrium Mining business sites, railway corridors, Contractors and Visitors.

Arrium Mining Contractors must adhere to the minimum requirements of this procedure within their own controlled approved operations on Arrium Mining sites.

3.0 LEGISLATIVE MANDATE 3.1 South Australian Work Health and Safety Act 2012 3.2 South Australian Work Health and Safety Regulations 2012 3.3 WHS Code of Practice – How To Manage Health and Safety Risks 3.4 Rail Safety National Law (South Australia) Act and Regulations 2012 3.5 South Australian Electricity Act 1996 3.6 The Environment Protection Act 1993, and in particular Section 83 of the Act. Various other legislation also governs environmental incident notification – see below.

4.0 REFERENCES 4.1 Arrium Work Health and Safety Policy 4.2 Arrium Crisis and Emergency Management Policy 4.3 Arrium Code of Practice – Incident Investigation 4.4 Arrium OHS Risk Management Code of Practice 4.5 OST-OHS-INV-FRM-020 - Arrium / OneSteel Incident Form 4.6 OST-OHS-SYS-PRO-050 - Arrium OHS Monitoring and Measurement Procedure 4.7 OST-OHS-RM-PRO-020 & 021 Crisis Management Manuals 4.8 QP29.13 – Safety Risk Management 4.9 PO1.19 - LifeSaver Program Policy





4.10 WI29.541 – Management of Review of Disciplinary Action Arising From Safety Breaches & HPIs 4.11 WI75.WHS.COM.001 – Communication 4.12 Arrium Environment Policy 4.13 QP50.67 Environment Incident Response 4.14 EPA Licence 13109 – Train Loading Activities, Whyalla Port & Pellet Plant 4.15 EPA Licence 13110 – Ardrossan 4.16 EPA Licence 17122 - Concentrator & OBP 4.17 Various EPA Licence Exemptions 4.18 Various Programs for Environment Protection and Rehabilitation (PEPR’s) – Mining 4.19 Various Development Approvals (DAC) 4.20 Environment Protection Act 1993 4.21 Aboriginal Heritage Act 1988 4.22 Animal Welfare Act 1985 4.23 Development Act 1993 4.24 Environment Protection and Biodiversity Conservation Act 1999 4.25 Heritage Places Act 1993 4.26 Mining Act 1971 4.27 Native Vegetation Act 1991 4.28 Natural Resource Management Act 2004

5.0 DEFINITIONS 5.1 Incident Categories

Incidents can be split into three categories: safety, environmental harm/nuisance or quality. Attachment 1 outlines examples of Environment Incidents. QP50.67 also provides examples of various environmental incidents.

5.2 Incident

An unexpected, unplanned occurrence, which: • Resulted in injury/illness or had the potential to result in injury or illness • Resulted in property damage or potential property that exposes a risk to health and

safety of a worker or any other person • Environmental harm or nuisance • Any other incident that exposes a risk to health and safety of a work or any other person.

5.3 Near Miss An event where there was almost injury or property damage. 5.4 Sensitive Incident

Incidents that: • involve the public • are of media interest • are attended by police • are attended by regulatory authorities • are judged to be so by Executive General Manager/General Manager.

5.5 Serious Safety Incident (as per WI29.541)

Includes, but not limited to: • Lifesaver Breaches • Breach of basic safety rules • Safety Breaches involving;

• Potential for serious injury • Repeated or wilful safety breaches • Where formal written disciplinary action is likely





5.6 Environmental Harm Any harm or potential harm to the Environment of whatever degree or duration including an environmental nuisance, caused by pollution. Environmental harm has the potential to be classed as material or serious, as defined by the Environment Protection (EP) Act 1993, Part 1(3, 5), requiring regulator notification.

5.7 Environmental Nuisance

• Any adverse effect on an amenity value of an area that is caused by pollution and unreasonably interferes with or is likely to interfere unreasonably with the enjoyment of the area by persons; or

• Any unsightly of offensive condition caused by pollution.

5.8 Environmental Non-Compliance (NC) An Incident where general environmental legal requirements or specific licence/agreement conditions are breached. Non-Compliances are identified, reviewed, recorded and reported by the Manager, Environment and Sustainability and Mines Environment Assurance Manager.

5.9 Severity Zero Environmental Incident

An incident where a slight change in circumstances could have resulted in an Environmental Effect. Severity Zero Incidents must have a potential impact assigned where possible.

5.10 Pollutant Any solid, liquid or gas (or combination) including noise, waste, smoke, dust, fumes and odours. (Refer to the Environment Protection (EP) Act 1993, Part 1(3) for a detailed definition)

5.11 Pollute To discharge, emit or deposit pollutants, or cause to fail to prevent the discharge, emission, depositing, disturbance or escape of pollutants. (Refer to the Environment Protection (EP) Act 1993, Part 1(3) for a detailed definition)

5.12 FDR Fugitive Dust Rating 5.13 Quality Event / Incident

An event that affects the quality of a product / service, or that impacts on the business area/stream’s ability to provide an acceptable product to a customer, or that impacts on productivity, need to be investigated.

The reason for formally investigating and reporting of these events is to ensure we continually improve our processes. This is achieved by, identifying the root cause and implementing corrective actions to ensure that these occurrences do not happen in the future. This will also provide an historic record for future reference and auditing purposes. In general some examples of events that require a full investigation are:

• Any unsightly or offensive condition caused by pollution. • Equipment failure impacting on supply of product to a customer. • Power failure (electrical trips) causing plant disruption. • Loss of productivity. • Excessive rework or scrap generation. • Product or service outside the agreed customer specifications (Service Level

Agreement). • Major change to operating conditions (Furnace Cooling). • Customer complaints.





5.14 Notifiable Incident (under WHS Act 2012) Means—

(a) the death of a person; or (b) a serious injury or illness of a person; or (c) a dangerous incident.

Refer to FORM75.WHS.INV.001 – SafeWork SA – Notifiable Incident Report Form (for use by Pellet Plant, Whyalla Port and any other notifiable incidents that have NOT occurred on Arrium Mining mine sites / mining operations)

5.15 Notifiable Mining Incident (under WHS Regulations 2012) Means an incident (other than a notifiable) that:

(a) results in illness or injury that require medical treatment within the meaning of 13.2 of Schedule 24 (this includes suturing of a wound, treatment of fractures, treatment of bruises that require drainage of blood, and treatment of 2nd and 3rd degree burns); or

(b) is a high potential incident (which is an incident that would have been a dangerous

incident as stated in 5.16 if a person were in the vicinity at the time of the incident or event occurred and in usual circumstances a person could have been in that vicinity at that time)

Refer to FORM75.WHS.INV.002 – SafeWork SA – Mining Operations Notifiable Incident

and Mining Incident Report Form (for use for any notifiable incident at Arrium Mining mine sites / mining operations)

5.16 Serious Injury or Illness Of A Person (under WHS Act 2012) Means an injury or illness requiring the person to have—

(a) immediate treatment as an in-patient in a hospital; or (b) immediate treatment for—

(i) the amputation of any part of his or her body; or (ii) a serious head injury; or (iii) a serious eye injury; or (iv) a serious burn; or (v) the separation of his or her skin from an underlying tissue (such as degloving or scalping); or (vi) a spinal injury; or (vii) the loss of a bodily function; or (viii) serious lacerations; or

(c) medical treatment within 48 hours of exposure to a substance, and includes any other injury or illness prescribed by the regulations but does not include an illness or injury of a prescribed kind.

5.17 Dangerous incident (under WHS Act 2012) Means an incident in relation to a workplace that exposes a worker or any other person to a serious risk to a person's health or safety emanating from an immediate or imminent exposure to—

(a) an uncontrolled escape, spillage or leakage of a substance; or (b) an uncontrolled implosion, explosion or fire; or (c) an uncontrolled escape of gas or steam; or (d) an uncontrolled escape of a pressurised substance; or (e) electric shock; or (f) the fall or release from a height of any plant, substance or thing; or (g) the collapse, overturning, failure or malfunction of, or damage to, any plant that is required to be authorised for use in accordance with the regulations; or (h) the collapse or partial collapse of a structure; or





(i) the collapse or failure of an excavation or of any shoring supporting an excavation; or (j) the inrush of water, mud or gas in workings, in an underground excavation or tunnel; or (k) the interruption of the main system of ventilation in an underground excavation or tunnel; or (l) any other event prescribed by the regulations, (Regulation 699A) (Note: the unplanned loss of control of heavy earthmoving machinery (including failure of braking or steering) at a mine is a dangerous incident)

5.18 SafeWork SA Business Unit of the Department of the Premier and Cabinet. SafeWork SA is responsible for administering industrial relations (IR) legislation and managing all Work Health and Safety (WHS) functions in South Australia.

5.19 ComCare

Business Unit of the Australian Government. There are certain Contractor organisations performing work for Arrium Mining who are self-insured under ComCare Scheme which provides rehabilitation and workers' compensation and OHS arrangements for their employees. Instead of reporting the required incidents to SafeWork SA, these organisations must follow incident reporting procedures required by ComCare

5.20 Office of the Rail Safety Regulator

The Office of the National Rail Safety Regulator (ONRSR) is an independent body corporate established under the Rail Safety National Law (South Australia) Act 2012. Rail Transport Operators must report to the Regulator all notifiable occurrences that happen on, or in relation to, the Rail Transport Operators railway premises or railway operations.

5.21 Notifiable Occurrence (under Rail Safety National Law (South Australia) Act 2012) Means an accident or incident associated with railway operations –

(a) that has, or could have, caused - (i) significant property damage; or (ii) serious injury; or

(iii) death; or that is; (b) or is of a class that is, prescribed by the national regulations to be a notifiable occurrence or class of notifiable occurrence

Refer to FORM75.WHS.INV.003 – ONRSR Notifiable Occurrences Written Report

5.22 Office of the Technical Regulator

Business Unit of the South Australian Government Department for Manufacturing, Innovation, Trade, Resources and Energy (DMITRE). While the Office of the Technical Regulator is responsible for the administration of the Electricity Act 1996, Gas Act 1997, Energy Products (Safety and Efficiency) Act 2000, its primary objectives are ensuring the safety of workers, consumers and property as well as compliance with legislation, technical standards and codes in the electricity and gas industries. If the incident being notified is related to an electric shock, gas infrastructure, or gas fitting, the Office of the Technical Regulator (OTR) must be also be notified by authorized Arrium persons. This person is the Arrium Electrical Inspector or their delegate.

Refer to FORM75.WHS.INV.004 – OTR Electrical Shock Incident Report Form 5.23 EPA (South Australian) Environment Protection Authority

http://www.safework.sa.gov.au/show_page.jsp?id=2241





5.24 Regulator-Notifiable Environmental Incidents An incident which have caused or has the potential to cause material or serious environmental harm as defined by the Environment Protection (EP) Act 1993, Part 1(3, 5) OR an incident/non-compliance identified by the National Manager Environment and/or Mines Environment Assurance Manager requiring notification.

Refer to TOOL75.WHS.INV.003 – Risk Profiling (Consequence)

5.25 Potential Consequence The most likely health and safety outcome that could have occurred due to an event or near miss. This may be greater than the actual consequence, but cannot be less.

5.26 Actual Consequence The health, safety or environmental outcome that occurs due to an event.

5.27 Maximum Reasonable Consequence The most severe consequence that is considered reasonably believable for the combination of factors which led to the incident. 5.28 High Potential Incident/Injury (HPI) – Consequence (Severity) Level 4 or 5

A high potential incident is any incident with a potential consequence (severity) of 4 or greater. It is an incident that has a Maximum Reasonable Consequence of a serious injury, fatality or multiple fatalities. In addition an incident may be deemed to be a High Potential Incident by the Manager HSE – Mining, Manager, Environment and Sustainability or Mines Environment Assurance Manager through discussion with the General Manager.

These include all major loss/injury events where the following have or could have realistically occurred:

• Near fatality, single fatality, or severe irreversible disability or impairment or short/long term health effects leading to multiple fatalities.

• Financial losses > A$50 Million • Productivity losses > 5 days • Incidents likely result in major health, safety or environmental regulatory investigation (i.e.

Chemical spills, etc) • Electrical Incidents of:

Any electric shock on equipment with a voltage greater than 50V AC or 120V ripple free DC

Exposure or potential exposure to an arc fault event, electrical fire or explosion of electrical equipment

Exposure to a voltage greater than 50V AC or 120V ripple free DC where the hazards/risks have not been identified, documented and controlled.

• Environmental incidents which have caused serious or very serious environmental effects with impairment of ecosystem function (e.g. destruction of conservation rated species of flora community or habitat of a conservation rated species of fauna).

• (Legal) Major breach of legislation with potential major fine and/or investigation and prosecution by authority

• (Corporate Citizenship – community etc) Serious or significant public or media outcry (international coverage). License to operate might be lost or is threatened. Reputation severely tarnished (e.g. very serious widespread social impacts, permanent or irreparable damage to highly valued structures/items/locations of cultural significance) Refer to TOOL75.WHS.INV.003 – Risk Profiling (Consequence)





5.29 Zero Barrier Incident A High Potential Incident is classified as “Zero Barrier” where all barriers or defences have failed and only luck determined the outcome.

5.30 Medium Potential Incident/Injury - Consequence (Severity) Level 3 These include all significant loss/injury events or environmental incidents where the following have or could have realistically occurred:

• Injuries likely to cause a reversible or moderate irreversible disability or impairment. • MTI or LTI • Financial losses of A$10m-A$50m • Productivity losses >12 hours and < 5 days • Environmental incidents which have caused moderate effects on biological or physical environment but not affecting ecosystem function (e.g. oil spill causing impacts on the shoreline) • (Legal) Serious breach of regulation with investigation or report to authority with prosecution and/or moderate fine possible. • (Corporate Citizenship – community etc) Attention from media and/or heightened concern by local community. Environment credentials moderately affected. (e.g. Significant damage to structures/items of cultural significance).


5.31 Low Potential Incident/Injury - Consequence (Severity) Level 1 or 2 These include all minor loss / injury events or environmental incidents where the following have or could have realistically occurred:

• Injuries resulting in first aid treatment only, and potentially incapacity to work on a restricted work basis • Financial losses of <A$10m (EBITDA) • Productivity losses < 12 hours • All electric shocks that are not LV or HV • No lasting effects and/or low level, minor effects on biological or physical environment • (Legal) Up to minor legal issues, non-compliances and breaches of regulations. Minor prosecution or litigation possible. • (Corporate Citizenship – community etc) Local public complaints or adverse media attention. (e.g. From public health issues, damage to social cultural structures etc)


5.32 Report Only Injury This injury classification applies to:

• journey incidents • an injury or condition which occurred at work but is non-works related, such as a seizure,

heart pain, diabetic episode, fainting. • reports of soreness, aches and pains etc but with no specific work incident / discernible

event. • injuries involving customers where Arrium do not have operational control, and did not

directly contribute to the incident

5.33 All Injury (AI) Any work-related injury or illness, regardless of the severity (including any report of pain or soreness).





5.34 Minor Injury (MI) An injury from a specific work incident that may or may not have resulted in First Aid treatment, but is less severe than a MTI.

5.35 First Aid Treatment

First aid treatment is any one time, and any follow up visit for observation, of minor scratches, cuts, burns, splinters and the like, which do not normally require medical care. Such treatment is considered to be first aid even if administered or supervised by a medical practitioner.

Treatment provided by a first aider or professional health care staff (e.g. OH. Nurse) may include giving health care advice as well as any of the following:

• using non-prescription medications at non-prescription strength; • administering tetanus immunizations; • cleaning, flushing, or soaking wounds on the skin surface; • using wound coverings, such as bandages, BandAids™, gauze pads, etc., or using

SteriStrips™ or butterfly bandages. • using hot or cold therapy; • using any totally non-rigid means of support, such as elastic bandages, wraps, non-rigid

back belts, etc.; • using temporary immobilization devices while transporting an accident victim (splints,

slings, neck collars, or back boards). • drilling a fingernail or toenail to relieve pressure, or draining fluids from blisters; • using eye patches; • using simple irrigation or a cotton swab to remove foreign bodies not embedded in or

adhered to the eye; • using irrigation, tweezers, cotton swab or other simple means to remove splinters or foreign

material from areas other than the eye; • using finger guards; • using massages; • drinking fluids to relieve heat stress

5.36 Restricted Work Case/Injury (RWI) A work related injury where, as a result of the injury, a Doctor documents work restrictions for the person. These restrictions could include:

1. the employee was assigned to another job on a temporary basis or 2. the employee worked their permanent job less than their normal hours of work or 3. the employee worked their permanent job but could not perform all of their normal duties

during all or any part of the normal workday or shift including any overtime. The employer or medical professional (other than a Doctor) may institute “precautionary” restrictions immediately following a minor injury with a view to avoiding exacerbation or delaying recovery and these will not be considered to constitute a Restricted Work Case however they can only be in place for a maximum of 48hrs after the injury. After this time, a Doctor should be consulted and if required documented restrictions implemented and a Restricted Work Case recorded or the person should return to full normal duties. Refer to Attachment 2 for further detail on RWI classification and examples.





5.37 Medical Treatment Injury (MTI) Medical Treatment Injury is a work related injury or illness that requires treatment by a medical professional (Doctor, Dentist etc.), which is beyond the scope of normal first aid, including initial treatment given for more serious injuries.

An MTI may include, but is not limited to the following:

• serious injuries (e.g. lacerations that need suturing) • any fractures (this includes fractures to smaller bones, such as fingers and toes) • Physiotherapy or chiropractic treatment requiring more than two sessions as recommended

by a doctor • recurring injuries such as known back or neck strain/sprains where a separate identifiable

incident can be directly related to the injury • taking of medication only available by prescription from a medical provider.

Note: What is not an MTI?

• If a medical practitioner only provides medical advice, which does not include medical treatment of the injury these then should not be classified as a MTI

• If the first aider refers an employee to see a medical practitioner / Hospital and in turn the medical practitioner only administers first aid treatment

• Physiotherapy or chiropractic treatment related to an injury and limited to a maximum of two treatments will not constitute an MTI. When 2 treatments occur the case will be immediately referred back to the doctor to recommend if any further treatment is necessary

• Recurring injuries such as known back or neck strain / sprains etc., should also not be classified as a MTI if referred to a medical practitioner, unless a separate identifiable incident can be directly related to the injury.

• Any treatment prescribed by a doctor as preventative or investigative only will not be counted as an MTI, eg. Tetanus injection, x-ray etc

5.38 Lost Time Injury (LTI)

Lost Time Injury is a work related injury or illness that fulfils at least one of the following criteria; • requires a person to lose a full shift from work as a result of the injury or illness; or • an injury that results in a permanent disability.

Note: The time lost must be due to incapacity to work as a result of the injury or illness. Where

the time lost is related to a pre-existing work related injury or illness it should be determined whether it is an aggravation or a recurrence. The time lost must occur within 12 months of the original injury to be counted as a LTI, unless there has been an aggravation of the original injury within the past 12 months.

5.39 Recordable Injuries (RI)

Work-related injuries and illnesses that is any one or more of the following: • Fatality, LTI, MTI, RWC or • Injury with the following Nature of Injury classification: • Fractures bones • Amputation • Impalement • Head Injury / Loss of consciousness • Nerve damage • Internal injury including Ear Drum puncture • Effects of exposure, eg weather • Poisoning and toxic effects of substances • Disease of nervous system and sense organs





• Skin disease • Infections • Damage to respiratory system • Needle stick injury • Hearing loss that meets the OSHA definition and is based on a baseline hearing level (for

each worker) established in 2014 or later. (Further detailed can be found in the corporate guidelines on WHS Monitoring & Measurement)

5.40 Special OHS Incident Cases

5.40.1 Aggravation A new and separate incident has occurred that has aggravated an existing injury condition, therefore for all intents and purposes it is a new injury and should be counted as a LTI or MTI, if it is that level of injury.

5.40.2 Recurrence Where an injury re-presents but there is no new and separate incident. This should be counted as a LTI or MTI if it is within 12 months of the original injury and has not yet been counted as a LTI or MTI, and is that level of injury. If it is greater than 12 months since the original injury, or has already been counted as a LTI or MTI it should not be recorded as a LTI or MTI.

5.40.3 Inguinal Hernia An inguinal hernia shall be considered a work related injury only if it is precipitated by an impact, sudden effort, or strain, and meets, after investigation all of the following conditions. • There is clear evidence of an accidental event or an incident, such as a slip, trip or

fall, sudden effort or over-exertion. • There was actual pain in the hernia region at the time of the injury or incident. • The immediate pain was so acute that the injured employee was forced to stop work

long enough to draw the attention of their supervisor or fellow employee, or the attention of a doctor was secured within 12 hours.

5.41 Initial Investigator The front line leader responsible for initially securing the incident scene and commencing initial investigation

5.42 Investigation Leader Person responsible for complete the incident investigation to provide to Next Level Up Manager for approval.

5.43 Next Level Up Manager / One Up Manager

The one level up Manager from an Investigation Leader. 5.44 Incident Cause Analysis Method (ICAM) An analysis process (and tool) that looks beyond the errors and violations of individuals and examines the contributing factors leading to an incident.

5.45 Immediate Cause

The final factors in a series of causes leading to an incident. The immediate causes are underpinned by fundamental, or root causes.





5.46 Root Cause The underlying cause, which triggered the chain of events, ultimately resulted in the incident. The cause of the incident that, if rectified, will prevent the recurrence of not just incidents with those exact circumstances, but others with similar causes.

5.47 Contributing Factor A condition, oversight, system failure, act or omission, which contributed to the occurrence of an incident.

5.48 Critical Corrective Action

An action implemented to eliminate or control the identified root cause(s) of a High Potential Incident in order to prevent recurrence. Test Question: If only these Critical Corrective Actions are implemented will they remove or control the root cause?

5.49 Critical Safety Alert

A document used to communicate initial safety information within 48 hours of a High Potential (HPI) or repeat incident.

5.50 Critical Safety Communication

A document used to communicate detailed information and remedial actions following investigation of internal HPI or Serious Safety Incidents and external Safety Alerts or Bulletins.

5.51 Environment Brief (green)

To communication environment information

5.52 Information / Safety Brief (blue) A document used to communicate general safety site / plant information

Refer to QP75.WHS.COM.001 – Communication and Consultation to obtain appropriate communication templates.

5.53 Arrium Mining Businesses

This procedure applies to the Arrium Mining Business Unit led by the Mining Chief Executive which is split in to 2 Businesses managed by their respective General Managers:

1. Operations with main Business Areas/Stream of: • SMR Fixed Plant Ore Processing Operations

- Auxiliary Crushing at Iron Knight and Iron Duke

• Pellet Plant • Mining business

- Iron Baron - Iron Knob - Quartz Quarry - Southern Middleback Ranges (SMR) Mining Leases

• Supply Chain & Logistics - Ardrossan - Port Operations - Rail and Ore Facilities - Supply Chain - Transhipping





2. Development with main Business Areas/Stream of: • Exploration • Mining Projects • Resource Optimisation and Development • Technology Development

6.0 SAFETY & ENVIRONMENTAL RISK ANALYSIS

JOB HAZARD HAZARD CONTROL The incident scene may contain residual hazards related to the initial event or the emergency response.

Complete risk assessment tool (with input from Emergency Response Controller if applicable) prior to entering scene.

Refer Hazard Register for any additional hazards and their control measures.

7.0 PROCEDURE

7.1 Arrium Code of Practice Critical Elements The Critical Elements which must be conveyed and understood at each Arrium site are:

1. Report all injuries and incidents to your leader immediately. 2. Take immediate corrective action to make the area safe and secure. 3. Investigate injuries and incidents to establish root cause and to identify corrective actions. 4. Significant injuries and High Potential Incidents are to be reported to the Site Manager as

soon as possible.

7.2 Safe Systems of Work This procedure outlines systems in place to respond to incidents which includes:

• initial response • assessment and notification • investigation • corrective actions • effectiveness review and close out

7.2.1 Initial Response (and Securing the Scene)

• Report all injuries and incidents (including near miss events) to your leader immediately. • Make the area where the incident occurred safe • The First Responder is the person at the site of the incident/emergency at the time

who shall assess the situation and to the extent necessary initiate an emergency response to contain or control the threat and protect persons, the environment and assets. No action initiated by First Responder/s should endanger any responding personnel.





• Provide treatment to injured persons within level of training and competency.

• The site of serious incidents (actual consequence 3 or greater) will firstly be made safe but shall not be disturbed unless it is for the purpose of saving life, attending to the injured or preventing injury to any person or damage to property or environment both on and off site.

• Notifiable incidents to SafeWork SA and/or the Office of the Technical Regulator (OTR) or the Office of the Rail Safety Regulator requires the scene to not be altered until permission has been granted by an Inspector, however as outlined above, the scene may be altered to prevent any further risk of injury to any person.

• Initial Investigator to secure the incident scene to protect other people and for site

security. Where applicable, Health and Safety Representatives and Safety Coordinators should be notified and assist in initial investigations.

• Initial Investigator to commence Initial Incident Investigation following emergency

response (if required) and securing of scene. Secure scene with a physical barrier, bunting or appointing sentries (watchers).

• Initial Investigator to create a record of incident in BSS within the same shift of

incident, but if they are unable to for valid reasons, then it must be entered within 24 hours. Where applicable, Arrium Safety Coordinators are responsible to create the initial entry and their Team Leader must ensure this occurs.

Refer to Incident Investigation Reporting Tools / Forms for further assistance.

7.2.2 Assessment and Notification 7.2.2.1 Depending on the nature of the incident it may be necessary to undertake drug and

alcohol testing and/or restrict the duties of those involved until the investigation is complete. This is in order to ensure they (or their colleagues) are not placed at further risk. The following should occur to persons involved in:

Type of Incident Stood Down Until Further Investigation Undertaken

Tested For Drugs & Alcohol

Serious safety incident (as per WI29.541)

Yes – stood down from all duties where there is a chance of repeated occurrence

Yes

Mobile plant /equipment or vehicle incidents

Yes – stood down from operating the type of equipment involved Yes

Isolation incidents Yes – stood down from isolation duties Yes

Working at Heights incidents

Yes – stood down from working at heights duties No

Confined Space incidents Yes – stood down from confined space tasks No

Person involved in incident and suspected of apparent intoxication or impairment (drug and/or alcohol)

Yes – stood down from all tasks Yes





If it is necessary to stand personnel down from normal duties the initial investigator shall notify the direct leader (or supervisor) of those involved who shall formally notify and record the details of the duty restrictions. If there are other obvious immediate actions these should be implemented however it is critical that these are sufficiently well constructed and risk assessed that they do not create new hazards. If LifeSaver rules or Safety Rules are deemed to have been breached, refer to the PO1.19 – LifeSaver Program Policy and any other relevant procedures as required. All breaches of LifeSaver rules will be recorded in the Arrium LifeSaver breach database for all workers including contractors.

7.2.2.2 Based on their initial assessment of the incident consequence potential, the Initial Investigator to commence the incident occurrence notification process to appropriate Arrium personnel.

Refer to Incident Investigation Reporting Tools / Forms for further assistance. Refer also to Area/Stream/Site Unplanned Production Loss Escalation Procedures for further assistance.

7.2.2.3 Potential Severity 2 (Low) or greater (Environment)

For environmental incidents with a potential consequence of 2 (Minor) or greater, the following persons or agencies shall be notified by the Department / Site Manager (eg operations or maintenance manager).

7.2.2.4 Potential Severity 3 (Medium) or greater

For incidents with a potential consequence of 3 (Medium) or greater (including MTIs & LTI's), the following persons or agencies shall be notified by the Department Manager / Site Manager (eg Operations or Maintenance manager):

• Business Area/Stream Manager (eg. Manager Mining Stream) who will escalate

to the relevant General Manager • Business Area/Stream Health and Safety Business / Mining HSE Manager • Arrium Mining Environment Assurance Manager who will notify the EPA • SafeWork SA Inspector / Mining Inspector (for notifiable incident under WHS Act

2012 and WHS Regulations) • Arrium Electrical Inspector who will escalate to the Office of the Technical

Regulator if required • Business Area/Stream Transport Manager / Rail Service Provider who will

escalate to the Office of the Rail Safety Regulator if required. • In the event of attendance by external emergency services the Arrium Media

and Communications Manager who will enable media liaison.





7.2.2.5 Resultant / Actual Severity 3 (Medium) or greater

In the event of incidents which: • Result in consequence 3 (Medium) or greater that involve workers including contractors or members of the public; • Are likely to attract state-wide or national media coverage (or attendance by police or representatives of regulatory authorities); or • Are judged by the General Manager as being appropriate, Then refer to 7.2.2.3, 7.2.2.4 and in addition: • The Department/Site Manager or their delegate such as the Health and Safety Business Partner shall notify the Arrium Mining Workers Compensation and Return To Work Coordinator for any Restricted Work Cases, MTIs and LTIs. They will escalate to WorkCover SA if required. • If a worker requires medical assessment/treatment with a General Practitioner and/or at the Hospital, the Site Manager or their deputy plus the Area/Stream Health and Safety Business Partner must attend with the worker. • The General Manager or their delegate shall contact SA Police if there is a death in the workplace. SA Police must also be notified if there is a significant fire. • The General Manager shall verbally notify the: General Manager – Human Resources as soon as practical and in any case within 24 hours if the incident is a consequence 3 (Medium); • The General Manager shall verbally notify the Arrium Legal and the General Manager – Human Resources and must do so within 4 hours if the incident is consequence 4 (Major); • Within 24 hours, a brief written report of the incident shall be sent to the General Manager and other relevant parties.

7.2.2.6 Notifications to Arrium Mining Legal

Arrium Legal is to be advised when: • an incident is required to be notified to statutory authority • an incident is of actual Consequence Level 4 or 5, or a sensitive incident • recommended by Arrium Legal • advice is required for an incident.

Note: If legal advice is sought, the provisions of this procedure relating to written incident notifications, investigation, and communication should not be initiated until confirmation is received from Arrium Mining Legal. Aspects of this procedure may be overridden if advised to do so by Arrium Legal.

7.2.2.7 Seeking Legal Advice and Legal Professional Privilege

Legal advice should be obtained when an incident is of a consequence 4 (major) or 5 (extreme) or where Arrium Legal otherwise recommends that legal advice be obtained. Arrium Legal may be contacted for any other incident. If legal advice is sought provisions of this procedure with respect to incident investigation and communication should not be initiated until confirmation has been received from Arrium Legal.

If a solicitor from Arrium Legal initiates an investigation, then the investigation is subject to legal professional privilege and must not be divulged to any person, including statutory authorities, without the expressed permission of the solicitor.





Any document, including notes, reports, emails, faxes etc to a solicitor who has initiated an investigation must have the following words marked upon it

“Confidential: Subject to legal professional privilege”.

7.2.2.8 Notifications to External Agencies

The type of serious incident will determine which external agency needs to be notified such as SafeWork SA (or Comcare for certain Contractors), The Office of the Technical Regulator, The Office of the Rail Safety Regulator or potentially maritime safety authorities or Environment Regulators such as Department of State Development (DSD) and/or Environment Protection Authority (EPA). SafeWork SA

Incidents such as fatalities, serious injuries and illness, and dangerous occurrences that arise out of the conduct of Arrium business must be notified to SafeWork SA immediately by an authorised Arrium person or Contractor as soon as Arrium become aware of the incident and incident records must still be kept for five years. The notification to SafeWork SA must be by the fastest available means and can be made by phone or in writing (such as fax, email or other electronic means). If the notification is by phone this must be followed up in writing within 48 hours if SafeWork SA requests it. Refer to FORM75.WHS.INV.001 and FORM75.WHS.INV.002. The person with management or control of a workplace must, so far as is reasonably practicable, preserve the incident scene until the inspector attends the site, or direct otherwise. The scene may be disturbed to move a deceased person, assist an injured person, make the site safe, or assist with a police investigation.

The Office of the National Rail Safety Regulator

Notifiable occurrences are categorised under the Rail National Safety Law (South Australia) Act and timelines for reporting by an authorised Arrium person on Contractor are as follows:

• Category A, the most serious, which must be immediately orally reported by phoning the Australian Transport Safety Bureau (ATSB) on 1800 011 034 and following up with a written report to the ONRSR within 72 hours

• Category B, which must be reported to the Office of the National Rail Safety Regulator (ONRSR) within 72 hours

Refer to FORM75.WHS.INV.003 The Office of the Technical Regulator The timelines for reporting electrical accidents to the OTR by an authorised Arrium person (Arrium Electrical Inspector) or Contractor are as follows:

• Death must be reported immediately via the telephone • Any accident where the person requires medical assistance must be reported within

one working day.





• All other accidents involving electricity must be reported to the OTR within 10 working days of the day of the accident.

Refer to FORM75.WHS.INV.004

Environment Regulators

The National Manager Environment and Mines Environment Assurance manager (or delegates in case of absence_ must be notified of any incident which has caused or had the potential to cause Severity 2 Minor to serious effects on the biological and physical environment (or environment consequence category ≥2) as soon as practicable by at the latest within 24hrs of the incident on telephone number: 0408 386 340 and leave a voicemail message if no answer. The National Manager Environment or delegate will review all environmental incidents for its severity and the requirements under relevant environmental legislation, once reported, and inform the relevant regulator(s) if required.

TOOL75.WHS.INV.003 Risk Profiling (Consequence Category)

7.2.2.9 Incidents Attracting Investigation By Statutory Authorities

Incident Investigations are not to be released to any statutory authority without the permission of the Business Area/Stream Manager (eg. Manager of Mining Stream).

For environment incidents, all written correspondence with the relevant Authority(s) must be carried out by or via the Manager, Environment & Sustainability or delegate.

7.2.2.10 Actions on death in workplace

If any person finds a person deceased, then they must immediately ensure that they do not put themselves or others at risk of injury. The scene must be secured and no other person must enter the area. For deaths that have occurred in the Whyalla Steelworks or if specified in Department Emergency Response Plans then OneSteel Security must be immediately notified by telephone on 4000 or 8640 4000 from mobile phones. All other sites must following their site Emergency Response Plan. SA Police must be notified on 8648 8020 by General Manager or their delegate The Arrium/OneSteel corporate Crisis Management Plan shall also be implemented.

7.2.2.11 Complete Internal Preliminary Report

Complete internal preliminary report following all required notifications. Once the appropriate notifications have been made the Arrium Initial Investigator is responsible for raising the BSS incident entry. For sites where Arrium Safety Coordinators are appointed roles, they are responsible for entering the incident into the BSS and their Team Leader must ensure this occurs. This entry should occur as soon as possible the same shift and within 24 hours if that is able to be achieved for valid reasons. For incidents which have occurred on the controlled sites of Arrium Mining’s embedded Contractors, they are responsible for undertaking their own incident investigations. They





are required to provide verbal notification to Arrium Contractor Controllers immediately for Level 3 and above incidents and as soon as possible as per agreements made between the Contractor and their Contractor Controller for Level 1 and 2 incidents.

Contractors are then required to provide written notification with initial investigation information to the relevant Arrium Contractor Controller and any other authorised persons within 24 hours of the incident. The relevant Business Area/Stream Health and Safety Business Partner or where applicable other authorised persons, are required to create an entry into the BSS for Contractor incidents as soon as possible and within 24 hours of incident. Refer to WI75.WHS.INV.001 - Entering Incidents into BSS

7.2.2.12 Communicate HPI and Serious Incident information in a timely manner

HPI and serious incident notifications should be based on the Critical Safety Alert form as out lined in QP75.WHS.COM.001 – Communication and Consultation

Serious Incident and HPI Notifications should be issued with: • consideration of any legal advice • consideration of involved people’s privacy. • consideration to be issued as soon as possible after preliminary investigation if

deemed required

Serious Incident and HPI Notifications should be communicated: • across the relevant Business Units provided there is sufficient cross business

learning opportunity • to relevant networks including the Arrium Mining and Materials Safety Network • as soon as reasonably possible to allow for prompt preventative action and within

48 hours.

Notification requirements including timeframes for distribution of Critical Safety Alerts / Communications are detailed in TOOL75.WHS.INV.002 – Arrium Mining Incident Notification and Investigation Guidelines. The preparation of the communication briefs is the responsibility of the Investigation Leader with support from the Health and Safety Team. Contractors may have their own safety communication format which if it include all the required elements outlined above, then this is also appropriate to distribute across the relevant Arrium / OneSteel networks, and timeframes as per TOOL75.WHS.INV.002 should be adhered to.

7.2.2.13 Determine level of investigation

Incidents are to be investigated according to the level of potential consequence. The Initial Investigator is responsible for making an initial assessment of the potential consequence.

The incident Consequence Level determines requirements for:

• notification • investigation type





• investigation leader • support personnel • investigation completion • documented reporting • completion of corrective actions • effectiveness review and sign off.

Refer to Refer to Incident Investigation Reporting Tools / Forms to assist with determining level of potential incident consequence.

7.2.2.14 Determine Investigation Leader

Investigations are to be led or conducted by a competent person, in compliance with the TOOL75.WHS.INV.002.

Note that investigation leadership and facilitation do not necessarily need to be performed by the same person. Therefore it is possible that the Investigation Leader may nominate a more appropriately qualified facilitator to assist in parts of the investigation (for example the ICAM phase). However the Investigation Leader is not able to delegate the investigation to someone else unless in TOOL75.WHS.INV.002 they are authorised to lead an investigation of the same potential consequence.

7.2.3 Investigation

Incidents shall be investigated according to their level of incident potential consequence as indicated in the TOOL75.WHS.INV.002. For all investigations a competent person will conduct or lead an investigation. Investigations shall commence as soon as practicable after the incident, and be completed with timeframes specified in TOOL75.WHS.INV.002.

Embedded Contractor Incidents For incidents which have occurred on the controlled sites of Arrium Mining’s embedded contractors, they are responsible for undertaking their own incident investigations and will have their own notification, initial investigation and full investigation procedures. The embedded Contractor incident investigation procedures must meet the minimum requirements of this procedure. Contractors will also have their own level of determining an incident severity level. In this case the nominated Arrium leader must make a determination of the incident in terms of Arrium’s procedures and for each consequence level does not need to lead the investigation. However, this person is responsible for, and must be in attendance for Arrium deemed Level 3 and greater consequence level incident investigations and must also ensure all levels of incident investigations are completed to Arrium’s satisfaction (and published) in the timeframe that is required of incident investigations undertaken on Arrium controlled operation sites.

For basic investigations the Investigation Leader must have been assessed as competent in the Arrium Investigation Process. For Severity 3 incidents the facilitator of the investigation shall have received training in ICAM and assessed as competent. Arrium Contractors must also ensure appropriate levels of training are provided to those conducting investigations in their business.





All investigations must review the relevant entry(s) in the department/site Hazard/Risk Register and where the investigation identifies any deficiencies, the corrective actions must include a task to update the register. The final incident report must be completed within timeframes stated in TOOL75.WHS.INV.002. The initial information must be entered into the BSS event recorder within in the same shift or if not possible within 24 hours of the incident. For sites where Arrium Safety Coordinators are appointed roles, they are responsible for entering the initial incident information into the BSS. Refer to WI75.WHS.INV.001 – Entering Incidents into BSS

Investigation Process • Determine the Investigation Leader (TOOL75.WHS.INV.002) • Complete initial investigation with required timeframes (TOOL75.WHS.INV.002) • Obtain approval from site management and relevant authorities prior to entering site • Conduct a site inspection • Interview witnesses / others as soon as possible after the incident, to determine:

• what happened • actions immediately prior to the incident • actions taken to reduce the risk in the task • training which had been provided • safety systems or personal protective equipment (PPE) for the task • any previous incidents or near misses • what could have been done differently to prevent the outcome • what could be done to prevent a recurrence.

FORM75.WHS.INV.005 - Witness Statement Form should be utilised.

7.2.3.1 Collect information and documents from the site

This may include but is not limited to: • procedures • risk assessments/Job Safety Analysis (JSA) • work permits • training records • photographs

TOOL75.WHS.INV.005 – Incident Investigation Tools contains a PEEPO Analysis Template to assist with date collection.

7.2.3.2 Establish the sequence of events

The aim is to capture the people involved, and the events and connect them in a logical sequence. The sequence of events may start some time before the incident (e.g. when a piece of equipment was purchased).





Various methods can be used to arrange information into a sequence (e.g. Investigation Tree, Step Process, Timeline Chart, Cause and Effect Diagrams). TOOL75.WHS.INV.005 provides examples of an Investigation Tree, Simple Timeline Chart, 5 Whys and Cause and Effect Diagrams.

7.2.3.3 Analyse information and determine root causes

It is imperative to identify root cause to implement effective corrective actions and prevent reoccurrence. If root causes are not corrected then the same conditions could happen again. Identify root causes using techniques such as ‘Ask “WHY?” 5 times’, using Cause and Effect Diagrams, and fault trees. TOOL75.WHS.INV.005 provides examples of an Investigation Tree, Simple Timeline Chart, 5 Whys and Cause and Effect Diagrams. For incidents of potential and actual Consequence Level 3-5, Incident Cause Analysis Method (ICAM) must to be used for all Arrium incident investigations. Contractors may utilise an alternate equivalent investigation method that has been approved by Arrium.

7.2.3.4 Identify learnings and determine recommendations

Establish a course of action to address the root causes. Recommendations should address: • existing hazards • gaps in controls, systems and procedures • organizational factors • actions to prevent recurrence.

7.2.3.5 Complete investigation within required timeframes

As per TOOL75.WHS.INV.002

7.2.3.6 Complete and issue draft report to relevant personnel

The incident investigation report for basic investigations can be either entered by the Investigation Leader straight into the BSS system with recommended actions entered and all required evidence attached or initially on the Incident Report Template prior to entering into the BSS as per OST-OHS-INV-FRM-020. Contractors may use their own internal investigation procedure tools and reports, as approved by Arrium. ICAM format or equivalent shall be utilised for Level 3 and above incidents. Refer to FORM75.WHS.INV.006 for the Arrium ICAM Report Template. All ICAM investigation root causes / contributory factors for both Arrium and Contractor incidents must be entered into the BSS. Refer to WI75.WHS.INV.001 – Entering Incidents into BSS





7.2.3.7 Review and approval of report

Once the draft investigation is complete it must be reviewed by the Next Level Up / One Up Manager as per TOOL75.WHS.INV.002 to confirm thoroughness, quality and clarity before approving. This must be conducted by assigning an action to the Next Level Up Manager in the BSS and within timeframes required.

7.2.3.8 Distribute final report

Issue final report when any clarifications have been addressed. If the incident was entered immediately into BSS, then the Investigation Leader needs to adjust any actions if required. If the report was initially entered via the investigation report template, then all approval actions must be entered into BSS and actions assigned by the Investigation Leader. Contractors must provide copies of their final investigation reports to the relevant Arrium Contractor Controller/s in timeframe specified in TOOL75.WHS.INV.002. The relevant Business Area/Stream Health and Safety Business Partner or other authorised persons are responsible for uploading the Contractor report to the BSS and assigning an action to the relevant Arrium Next Level Up Manager to review each incident report to assess the report for thoroughness, quality and clarity. This review should pay particular attention to the suitability and timeframe of the corrective actions. When satisfied they sign off the assigned corrective action as complete in BSS. Refer to WI75.WHS.INV.001 – Entering Incidents into BSS

7.2.4 Corrective Actions

7.2.4.1 Investigation Leader – determine corrective actions

Corrective actions should be specific cost-effective strategies that: • address root causes and contributory factors • are based upon the Hierarchy of Controls, and • are reasonably practicable to implement.

For all High Potential Incidents Critical Corrective Actions must be identified and included in the ICAM report and approved by Manager – Health & Safety. Refer to WI75.WHS.INV.003 – Corrective and Preventative Actions





7.2.4.2 Investigation Leader – assign responsibilities for corrective actions

Allocate and communicate: • people responsible for corrective actions • completion dates • follow up dates.

7.2.4.3 Communicate investigation information in a timely manner

To prevent any further similar incidents occurring the key points of the incident should be communicated throughout the business. This is to be done by using an Information/Safety or Environment Brief.

To maximise the communication and effective implementation of key learning from significant safety or environment occurrences it is critical that the flow of information is controlled and communicated at the appropriate levels. The Information/Safety or Environment Brief should consider any legal advice and the protection of privacy for any person involved. An Information/Safety or Environment Brief should contain a brief description of the incident, any photographs or diagrams that aid understanding, a summary of the key contributing factors and most importantly the key learnings that are of relevance to the Business.





Information/Safety Briefs Environment Briefs should be communicated to the Arrium Mining / OneSteel Safety / Environment Network and other relevant networks. Timeframes for communication should be as per TOOL75.WHS.INV.002. The preparation of Information/Safety and Environment Briefs is the responsibility of the Investigation Leader. They make seek assistance from the relevant Business Area/Stream Health and Safety Business Partner where required. Refer to QP75.WHS.COM.001 – Communication and Consultation to obtain templates of these briefs. Contractors may have their own safety communication format which if it include all the required elements outlined above, then this is also appropriate to distribute across the relevant Arrium / OneSteel networks, and timeframes as per TOOL75.WHS.INV.002 should be adhered to.

7.2.4.4 Verify implementation of corrective actions

An action must be assigned by the Investigation Leader in the BSS to ensure the Next Level Up Manager is responsible for ensuring all corrective actions are completed as per timeframes specified in TOOL75.WHS.INV.002. For Contractor incidents deemed to be an Arrium Level 1 or 2 incidents, the relevant Contractor Controller must ensure they have formal communication processes in place with the Contractors where they are provided regular updates of incident investigation action close out of such actions. This should be conducted on a least a monthly basis and records kept for auditing purposes. For Contractor incidents deemed to be an Arrium Level 3 or above, the Health and Safety Business Partner or other organisation persons must ensure all causes and actions are entered into BSS for any ICAMs and an additional ‘Verification of Incident Action Close Out’ action is added to the BSS and assigned to the Next Level Up Manager with timeframes specified in TOOL75.WHS.INV.002.

7.2.5 Effectiveness Review and Close Out

7.2.5.1 Review effectiveness of implemented corrective actions prior to close out.

An action must be assigned by the Investigation Leader in BSS to ensure the Next Level Up Manager is responsible for ensuring all corrective actions are reviewed for their effectiveness in preventing recurrence as per timeframes outlined in TOOL75.WHS.INV.002. For Contractor incidents deemed to be an Arrium Level 3 or above, the Health and Safety Business Partner or other organisation persons must ensure an additional ‘Effectiveness Review’ action is added to the BSS and assigned to the Next Level Up Manager with timeframes specified in TOOL75.WHS.INV.002.

7.2.5.2 Review of High Potential Incidents

The Arrium Board will be consulted for effectiveness review and close out of potential and actual Consequence Level 4 or 5 incidents (High Potential Incidents). General Managers or each Mining business will undertake reviews against all High Potential Incidents to discuss further with the Mining Chief Executive. Peer reviews





will also be undertaken as determined by the General Managers / Mining Chief Executive. Refer to FORM75.WHS.INV.007 – General Manager – HPI Checklist, Investigation Effectiveness and Review Form.

8.0 TRAINING AND COMPETENCE

The training provided to individuals is to be determined by training needs analysis as outlined in QP29.28 – Health & Safety Training and any additional awareness training outlined below.

8.1 Awareness Training

Incident and near miss reporting awareness training will be provided to all Arrium employees and contractors via Arrium Mining and relevant site inductions. All Arrium Mining employees and Contractors are also required to complete the online Code of Practice Critical Elements awareness induction. For basic investigations the Arrium Investigation Leader must have been assessed as competent in the Arrium Investigation Process for basic investigations. Investigation Leaders may also choose to utilise Root Cause Analysis (RCA) investigation methods if appropriately trained. Site management are responsible for ensuring their nominated Investigation Leaders are trained to the appropriate level. The Mining Health and Safety Team can assist with training in basic investigations. There is online basic awareness training available via Arrium/OneSteel Learning Management System (LMS) for all Arrium Mining Investigation Leaders as outlined in QP29.28. Arrium Contractors must also ensure appropriate levels of training are provided to those conducting investigations in their business.

8.2 Lead Investigator/Investigation Team For a Consequence severity 3 or above incidents Facilitators of ICAM investigations must have also received ICAM Incident Leader Investigation training and assessed as competent.

Arrium Contractors must also ensure appropriate levels of training are provided to those conducting investigations in their business.

9.0 RESPONSIBILITIES, AUTHORITIES AND ACCOUNTABILITIES

Responsibilities for incident investigation activities vary according to the type and potential

Consequence Level of each incident. The Arrium Mining Incident Investigation Guidelines - TOOL75.WHS.INV.002 provide further information on requirements to be fulfilled.

9.1 OneSteel / Arrium Safety Council

Responsibilities include to: • assume overall responsibility for the incident management system including responsibility for

standards, procedures, and training in consultation with the Arrium Safety Network and Arrium Legal

• approve and effectively implement this procedure and revisions





• conduct regular reviews • manage incidents escalated by Business Units in an Arrium crisis situation using crisis

management systems.

9.2 OneSteel / Arrium Safety Network Responsibilities include to:

• develop the incident management system in consultation with Arrium businesses • develop implementation processes and support Arrium businesses in the implementation

activity • audit compliance through the Arrium Assurance Audit.

9.3 Business Unit Lead Teams (eg. Mining Lead Team led by Chief Executive)

Responsibilities include to:

• manage incidents escalated by sites dependent on Consequence Level • review Consequence Level 4 & 5 incidents and near miss reports • review key cross-business incident trend data to identify opportunities for preventative

programs. • Provide a report for CEO / Arrium Board where required.

9.4 General Manager


• review all Level 4 and 5 (high potential) injuries/incidents with Chief Executive utilising FORM75.WHS.INV.007 – General Management – HPI Checklist, Investigation Effectiveness and Review Form.

• follow-up with Business Area/Stream Managers (eg. Manager – Mining Stream) where appropriate.

• authorise corrective actions where appropriate • organise for a HPI Peer Review with other key business leaders where required

9.5 Business Management Team (eg. Mining Operations Lead Team)


• review all safety/environmental incidents that occur in area of responsibility. • follow-up with Business Area/Stream Managers where corrective action is inappropriate. • authorise corrective action where appropriate.

9.6 Business Area/Stream Managers (eg. Manager – Mining Stream)


• review all Level 3 and above injuries/incidents that occur in area of responsibility. • Investigation Leader of Level 4 & 5 incidents • establish, where appropriate, following a Level 4 or 5 (high potential) injury / incident, an

investigation panel to review the investigation. • follow-up with Shift Supervisor / Department Manager where corrective action is

inappropriate. • authorise corrective action where appropriate. • provide a report to the General Manager of all high potential injuries/incidents.





9.7 Site / Department Managers (eg. Operations / Maintenance Managers) Responsibilities include to:

• Investigation Leader of Level 3 incidents • check that injured persons receive appropriate treatment • attend GP / Hospital with injured persons (or arrange for your Deputy to) • escalate incidents dependent on Consequence Level to all required internal parties • perform notifications in a timely manner (Arrium and OHS statutory authority) • notify Arrium Electrical Inspector for all electrical injuries/incidents within 24 hours who will

escalate to the Office of the Technical Regulator if required. • Notify the Manager, Environment and Sustainability (or delegate in case of absence) of

any environmental incident which has caused or had the potential to cause severity 2 minor to serious effects on the biological or physical environment (or environment consequence category ≥2) as soon as practicable but at the latest within 24hrs of the incident on telephone number 0408 386 340 and leave a voicemail message if no answer. The Manager Environment & Sustainability or delegate will inform the relevant regulator(s) if required.

• check injuries/incidents are investigated • review investigation reports • determine and implement corrective actions to prevent a recurrence where required • review incident (and near miss) trend data to analyse root causes and opportunities for

preventative action before incidents occur.

9.8 Supervisor / Shift Team Leader (including Contractor supervisors) Responsibilities include to:

• Shift Team Leader to be Investigation Leader of Level 1 incidents • Operations Coordinators or equivalent to Investigation Leader of Level 2 incidents • Make plant safe, without disturbing the scene if possible. • Immediately initiate first-aid and arrange casualty transport to the medical centre / first aid

room. • Secure the site to ensure it is not disturbed (if safe to do so). Initiate an immediate

investigation. If the incident is notifiable to SafeWork SA, do not alter the site until permission has been given by an Inspector from SafeWork SA.

• In the case of a safety incident/injury notify the relevant Health and Safety Representative / Safety Coordinator of the occurrence.

• Visit the site of the injury / incident and record details. • Immediately notify Shift Supervisor / Department Manager (Operations / Maintenance

Manager / Contractor Controller) of high potential safety injury or incident. • Immediately notify Shift Supervisor / Department Manager (Operations / Maintenance

Manager) / Contractor Controller) of Environment Incidents which has caused or had the potential to cause material or serious environmental harm (or environment consequence category ≥3)

• Contractor Supervisors: If unable to contact Contractor Controller for high potential injuries or incidents and material or serious environmental harm incidents, contact Arrium Shift Supervisor / Department Manager.

• Notify Shift Supervisor / Department Manager / Contractor Controller of all other injuries or incidents as soon as practical.

• Ensure initial information is recorded into the BSS Event Recorder within 24 hours • Refer to WI75.WHS.INV.002 - Incident Investigation – Team Leader / Supervisor

Handbook





9.9 Contractor Controllers

Responsibilities include to: • Immediately notify the Shift Supervisor / Department Manager of any Level 4 and 5 (high

potential) injury/incident involving contractors that occurred on their plant. • Immediately notify Shift Supervisor / Department Manager of Environment Incidents

which has caused or had the potential to cause Severity 2 minor to serious effects on the biological or physical environment (or environment consequence category ≥2).

• Notify Site/Department/Area Manager of all other injuries or incidents as soon as practical. • Ensure the initial information is entered into the BSS Event Recorder database within 24

hours.

9.10 Investigation Leader Responsibilities include to:

• Responsibilities include to complete investigations according to this procedure/CoP requirements

9.11 Workers (including Contractor workers) Responsibilities include to:

• Immediately report any injury or incident to their supervisor • Notify their supervisor prior to seeking medical attention if possible. • Report all injuries to the relevant site Health Centre / First Aid Room even if treatment not

required • Participate and cooperate in incident investigation processes • Provide the person investigating the event with all relevant information regarding the injury or

incident. Where pollution is occurring (if appropriate & practical), and without risk to personal safety, takes action to stop it, or minimise its effects.

9.12 Health and Safety Representative / Safety Coordinator Responsibilities include to:

• Assist with the investigation of safety injury / incident. • Carry out roles and functions as per the Work Health and Safety Act (2012) and WHS

Regulations for Health and Safety Representatives • Maintain confidentiality of medical records (ie details of injuries suffered by any person) • Safety Coordinators, where relevant, to carry out of role and function of a Safety Coordinator

including ensuring the incident is entered into the BSS within the same shift or if this is not possible within 24 hours.

9.13 Health & Safety Department Responsibilities include to:

• Assist in the investigation of Level 3-5 safety injuries/incidents where appropriate or requested

• Assist in the investigation of all other incidents where required or requested • Audit safety injury/incident investigation system. • Provide training in injury/incident investigation. • Maintain records including entering Contractor incidents in BSS • Notify external authorities as required or requested. • Attend GP / Hospital with injured persons and their Manager





9.14 Departmental Environment Coordinators/advisors Responsibilities include to:

• Assist in the investigation of incidents where required. • Assist in the control, rectification or remediation of all incidents resulting in pollution where

appropriate or requested. • Review all departmental Environmental incidents and associated corrective actions and track

corrective actions where required. • Provide reports of all departmental environment incidents to Departmental Management

Team for review at weekly/monthly meetings.

9.15 Environment Department Responsibilities include to:

• The Manager, Environment & Sustainability or deputy will immediately notify the Environment Protection Authority (1800 623 445) and other relevant Authority(s) of all environmental incidents or potential incidents where material or serious environmental harm has occurred or has the potential to occur.

• Facilitates advice in the control, rectification or remediation of all incidents resulting in pollution where appropriate.

• Compliance auditing of incident reporting system • Liaise with Regulator(s) to ensure corrective actions meet requirements. • Reports summaries of environment incidents to Senior Management on a regular basis

10.0 MONITORING AND MEASUREMENT Key Performance Indicators (KPIs) for the Arrium Mining Business Unit have been designed in order to measure the health of the Incident Investigation System. The KPIs are in addition to any Corporate reporting requirements outlined in OST-OHS-SYS-PRO-050 - Arrium OHS Monitoring and Measurement Procedure. No. KPI Why? Target

1 Near Miss / Incident to Injury Ratio

The ratio provides an indication of whether there is a good culture of incident reporting within the site, business area/streams and overall Mining business unit.

10:1

3 Overdue Safety Incident Actions

Measured by the number of actions that are open and overdue for safety incidents. This measure demonstrates the importance of safety actions from investigations being completed in a timely manner.

<10%

Measurement of KPIs should be also undertaken and reported within each Area/Stream level of the Arrium Mining Business and should also include embedded Contractor performance where relevant.





11.0 DOCUMENTATION

11.1 WORK INSTRUCTIONS WI75.WHS.INV.001 Entering Incidents Into BSS WI75.WHS.INV.002 Incident Investigation – Team Leader / Supervisor Handbook WI75.WHS.INV.003 Corrective and Preventative Actions

11.2 TOOLS TOOL75.WHS.INV.001 Incident Management Flowcharts TOOL75.WHS.INV.002 Incident Notification & Investigation Guidelines TOOL75.WHS.INV.003 Risk Profiling (Consequence Category) TOOL75.WHS.INV.004 Key Contacts List TOOL75.WHS.INV.005 Incident Investigation Tools TOOL75.WHS.INV.006 Incident Investigation Basic Awareness Training Presentation TOOL75.WHS.INV.007 Incident Investigation Basic Awareness Training Theory Assessment

11.3 FORMS FORM75.WHS.INV.001 SafeWork SA Notifiable Incident Report Form FORM75.WHS.INV.002 SafeWork SA Mining Operations Notifiable Incident and Mining Incident Report Form

FORM75.WHS.INV.003 ONRSR Notifiable Occurrences Written Report FORM75.WHS.INV.004 OTR Electrical Shock Incident Report Form

FORM75.WHS.INV.005 Witness Statement Form FORM75.WHS.INV.006 Arrium ICAM Report Template FORM75.WHS.INV.007 GM – HPI Checklist, Investigation Effectiveness & Review Form OST-OHS-INV-FRM-020 Arrium/OneSteel Incident Form

11.4 ATTACHMENTS

ATTACHMENT 1 Examples of Environment Incidents (Mining Business) ATTACHMENT 2 Restricted Work Case Expanded Definition & Examples

INCIDENT INVESTIGATION and

REPORTING

QP75.WHS.INV.001.A1 Revision 1



EXAMPLES OF ENVIRONMENT INCIDENTS (Mining Business)

NO INCIDENT

INCIDENT

EXAMPLES OF POSSIBLE LEVEL ≥2 ENVIRONMENTAL INCIDENTS FOR PURPOSES OF REGULATOR

NOTIFICATION REPORT AT LATEST WITHIN 24

HOURS USING ONLINE INCIDENT RECORDER

NOTIFY MANAGER, ENVIRONMENT&

SUSTAINABILITY OR DELEGATE 0408 386 340

AIR

Pollution control equipment (scrubbers, baghouses, precipitators, conveyor covers)

Pollution control equipment downtime during shutdown or non-operational period

Any equipment malfunction resulting in visible emission; Or operating plant without pollution control equipment being potential breach of License condition whether or not visible emissions occur.

Any dark emissions for extended periods (e.g. greater than 3 minutes, or 30 minutes in an 8 hour period)

Dust emissions from material handling / mobile equipment working areas (including mobile crushing/screening plants)

Light emissions with active maximum dust control measures in place FDR0-2 If operating with controls.

Emissions without reasonable & practicable controls in place or emissions that leave the work area. An incident does not have to be reported when wind conditions > 30km/hr except where work has continued in these conditions FDR 2 If operating with no controls FDR 3

Any medium to heavy emissions leaving the Whyalla Steelworks or Arrium Mining site or internal heavy emissions for extended periods (e.g. 30 minutes in an 8 hour period). An incident does not have to be reported when wind conditions > 30km/hr except where work has continued in these conditions

Fugitive dust from stockpiles Light emissions FDR0-2 If operating with controls.

Medium to heavy emissions leaving the work area from stockpiles that have not been paper pulped, watered or otherwise controlled and do not have a restriction on using dust suppressants. An incident does not have to be reported when wind conditions > 30km/hr except where work has continued in these conditions FDR 2 If operating with no controls FDR 3

Any emissions leaving the Whyalla Steelworks or Arrium Mining site, or heavy emissions for extended periods (e.g. 30 minutes in an 8 hour period). An incident does not have to be reported when wind conditions > 30km/hr except where work has continued in these conditions

WATER POLLUTION Uncontrolled discharge of oil, diesel, acid, chemicals or any other pollutants entering drains, , tailings dams, fresh or salt water ponds or the sea

All discharges regardless of volume All discharges to sea or surface water regardless of volume.

LAND Spillage of oil, hydraulic fluid, fuel, acid, chemicals or other pollutants to ground, not able to reach drains

Less than 20L/20kg. Report as near-miss if potential exists for > 20 L (clean-up must still occur)

Greater than 20L/20kg Greater than 500 litres

Uncontrolled dumping / discharge of chemical wastes

All If dumped in or near water or drains that will impact on the environment.

Tank / hose springs a leak but the leak is contained within a bund.

No incident – report as Near Miss

Vegetation is cleared or damaged without environmental permit approval, for example new waste rock dump, haul roads, civil work or to gain access to plant equipment or structure for the purpose of maintenance or repair

• Area <5m2 • Growth immediately

adjacent (< 1m) to structure or equipment

• Identified weed species • Single juvenile tree

<2m

Vegetation >1m from structure or equipment and/or >5m2, or more than one tree <2m height or any tree > 2m height Any Vegetation Clearance at the Arrium Mining Sites without following approval permitting system

Large areas such as a track or lay down area cleared without assessment and approval. Any unauthorized vegetation clearance outside of tenement boundaries (Arrium Mining)


REPORTING




WASTE Waste Disposal not in accordance with WI50.403 Waste Management

Incorrect disposal of waste in non-approved locations

Incorrect disposal resulting in material harm to the environment (air/ground/marine/surface water)

Mixing of waste types including listed waste at project site

Identified by operating department/contractor & rectified before collection and disposal

Mixed waste disposed of in incorrect waste disposal facility resulting in breach of licence conditions

Contamination of waste disposal facility that cannot be rectified, or results in material harm to soil or groundwater

Disposal of liquid waste to solid waste facility

Breach of EPA licence, PEPR, DA Approval conditions

Contamination of, soil or groundwater as per Land (see above)

Non approved offsite transport of waste

Breach of EPA licence, PEPR, DA Approval conditions

Possible offsite contamination or impacts

WATER WASTAGE Uncontrolled discharge or loss of fresh water

< 1,000 litres 1,000 litres over any timeframe

TRAIN LOADING Breach of Licence conditions

Non beneficiated Iron Ore Fines transported other than upon an AHOF or a PHAY rail wagon. AHOF or PHAY wagons loaded with non-beneficiated Iron Ore fines above the side shields.

STOCKPILES Breach of Licence conditions

Material stockpiled in locations other than those identified in the Stockpile Plan without written approval.

NOTE: If an environmental incident has been classed as a Level 1 or 2, the National Manager Environment (or delegate) and Mines Environment Assurance Manager (Mines incidents only) will review these incidents against TOOL75.WHS.INV.003 for legal implications, and will notify the relevant Regulator/Authority, depending on Legal Risk, of possible non-compliances and breaches of regulation(s). (See the legal section of TOOL75.WHS.INV.003).

All Level 3, 4 and 5 Environmental Incidents will result in immediate notification to the relevant regulators and will be reviewed against TOOL75.WHS.INV.003 for legal implication, in order to establish level of non-compliance to environmental legislation and/or approvals/licences.


REPORTING




Restricted Work Case (RWC) A work related injury where, as a result of the injury, a Doctor documents work restrictions for the person. These restrictions could include: 1. the employee was assigned to another job on a temporary basis or 2. the employee worked their permanent job less than their normal hours of work or 3. the employee worked their permanent job but could not perform all of their normal duties during all or any part of the normal workday or shift including any overtime. The employer or medical professional (other than a Doctor) may institute “precautionary” restrictions immediately following a minor injury with a view to avoiding exacerbation or delaying recovery and these will not be considered to constitute a Restricted Work Case however they can only be in place for a maximum of 48hrs after the injury. After this time, a Doctor should be consulted and if required documented restrictions implemented and a Restricted Work Case recorded or the person should return to full normal duties. At all times, the principle is that the employee is cared for by providing the correct treatment in a timely manner. The instigation and subsequent removal of “precautionary” restrictions on a person following a minor injury shall be recorded in the “Initial Treatment” section of the incident management reporting system with dates.

Examples:

1) A person injures their back, they visit a Doctor and the Doctor places a restriction on the person that they are not to lift more than 5kg for the next 2 weeks.

This is a Restricted Work Case.

2) A person has a minor sprain of their arm tightening a bolt. The arm feels OK but the supervisor says “Why don’t you swap with someone else for the balance of this shift”. The next day the arm is fine and the person resumes their normal work.

A ‘precautionary’ restriction should be recorded in the incident management system but this would remain a minor injury. This is not a Restricted Work Case.

3) A tradesperson twists their ankle badly and is not able to walk on it and perform their normal duties.

The person should receive first aid treatment and visit the Doctor for a medical assessment. Based on the doctors assessment this will be classed as a Restricted Work Case if they cannot resume normal duties for the remainder of their shift and possibly for some extended period of time. (Any restrictions that might be applied by the Employer in this situation are not ‘precautionary’, the person is clearly injured and unable to perform their normal duties).


4) A person injures their foot and initially the injury appears to be quite minor. After first aid, the person continues their normal duties however after 3 hours they report that they are now in pain and they don’t think they can continue to work the remainder of their shift.

The person should receive first aid treatment and visit the Doctor for a medical assessment as soon as practicable. If the doctor advises that the person is not able to complete normal duties or


REPORTING




the shift this indicates a more serious injury. The person should not be sent home as a precaution, going home from work is not a “precautionary” restriction.


5) A person receives a burn to their arm and they are treated at the medical centre and the nurse advises that the person should avoid hot work for approximately a week as a precaution to avoid any aggravation/infection.

This should initially be treated as a Minor Injury and ‘Precautionary’ restrictions of no hot work should be implemented and recorded in the incident management system. After the 48hrs has elapsed the person should visit a doctor and determine if restrictions are still required and in the case that they are, this injury would be classed as a Restricted Work Case. If restrictions are no longer required, the person should return to normal duties and this should be recorded in the incident management system and this incident would remain a Minor Injury.

6) A person has sprained their back at work, they receive first aid treatment and return to normal duties. A couple of days later they decide to visit their own physio who advises them not to do any bending or lifting for the next week, whilst they continue treatment. The employee now advises the Company that they have restrictions from their own physio.

Arrangements should be made for the person to visit a doctor to get clarification on any restrictions. Only a Doctor can document work restrictions that would then constitute a Restricted Work Case.

The 48hrs is not to be used as a window to delay treatment or the need for restrictions, for example:

7) A person strains their leg, late on a Wednesday afternoon and it is highly probable the person cannot continue to do their normal duties.

The supervisor should not put in place supposed “precautionary” work restrictions for 48hrs (ie the rest of the week) with an aim to delay any possible assessment to the Monday of the following week (with a view to avoiding a Restricted Work Case). In this case if it is highly probable that the person cannot do their normal duties, they should receive medical assessment as soon as practicable.

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