resolution copper mining copper mining hse management system procedures manual uncontrolled copy...

RESOLUTION COPPER MINING

HEALTH, SAFETY AND ENVIRONMENTAL

MANAGEMENT SYSTEM

PROCEDURES MANUAL

Last Updated:

April 2015

TABLE OF CONTENTS

OVERVIEW ................................................................................................................................................... 1

HSE VISION .................................................................................................................................................. 1

RESOLUTION HSE MANAGEMENT SYSTEM PROCEDURES ................................................................ 3

OBJECTIVES ............................................................................................................................................... 3

SCOPE .......................................................................................................................................................... 3

ACCOUNTABILITIES ................................................................................................................................... 3

DEFINITIONS ............................................................................................................................................... 6

MEETING INTERNAL AND EXTERNAL STANDARDS ............................................................................. 9

ELEMENT 1 POLICY .................................................................................................................................. 10

PURPOSE ................................................................................................................................................... 10

DESCRIPTION OF PROCESS ................................................................................................................... 10

1.1. POLICY DEVELOPMENT AND APPROVAL ............................................................................... 10

TRAINING AND COMMUNICATION ......................................................................................................... 10

2.1. INTERNAL ..................................................................................................................................... 10

2.2. EXTERNAL .................................................................................................................................... 10

REVIEW ...................................................................................................................................................... 10

REPORTING ............................................................................................................................................... 11

DOCUMENTATION AND RECORDS ........................................................................................................ 11

LINK TO REFERENCES AND RELATED DOCUMENTS ......................................................................... 11

ELEMENT 2 LEGAL AND OTHER REQUIREMENTS .............................................................................. 12

2. PURPOSE .......................................................................................................................................... 12

3. DESCRIPTION OF PROCESS .......................................................................................................... 12

0.0. IDENTIFYING & UPDATING RELEVANT HSE LEGAL AND OTHER REQUIREMENTS .......... 12

0.1. COMPLIANCE ............................................................................................................................... 13

3. TRAINING AND COMMUNICATION ................................................................................................. 13

4. MONITORING AND REVIEW ............................................................................................................ 14

5. REPORTING ...................................................................................................................................... 14

6. DOCUMENTATION AND RECORDS ................................................................................................ 14

7. LINK TO REFERENCES AND RELATED DOCUMENTS ................................................................ 15

RIO TINTO COMPLIANCE GROUP PORTAL FOR POLICIES AND STANDARDS ............................... 15

RCM HSE LEGAL AND OTHER REQUIREMENTS REGISTER .............................................................. 15

RCM PERMITS REGISTER ........................................................................................................................ 15

RCM LEGISLATION COMPLIANCE REVIEWSELEMENT 3 HAZARD IDENTIFICATION AND RISK MANAGEMENT .......................................................................................................................................... 15

1. PURPOSE .......................................................................................................................................... 16


2.1 RIO TINTO RISK MANAGEMENT FRAMEWORK ....................................................................... 16

2.2 RISK ASSESSMENT METHODS .................................................................................................. 16

2.3 CONDUCTING RISK ASSESSMENTS ......................................................................................... 17

2.3.1 LEVEL 1 RISK ASSESSMENTS ................................................................................................... 18



2.4 MANAGEMENT OF RISK CONTROLS AND ACTIONS .............................................................. 19



5. REPORTING ...................................................................................................................................... 22



SEG LIST .................................................................................................................................................... 22

ELEMENT 4 HSE MANAGEMENT IMPROVEMENT PLANNING ............................................................ 23

PURPOSE ................................................................................................................................................... 23


IDENTIFICATION OF HSE OBJECTIVES AND TARGETS ...................................................................... 23

IMPROVEMENT PLANS ............................................................................................................................ 24

ANNUAL PROJECT PLAN ........................................................................................................................ 24

PERSONAL HSE PLANS ........................................................................................................................... 24


MONITORING AND REVIEW ..................................................................................................................... 25

OBJECTIVES, TARGETS AND IMPROVEMENT PLANS ........................................................................ 25

PERSONAL HSE PLANS ........................................................................................................................... 25

REPORTING ............................................................................................................................................... 25



ELEMENT 5 ORGANIZATIONAL RESOURCES, ACCOUNTABILITIES AND RESPONSIBILITIES ..... 27

1. PURPOSE .......................................................................................................................................... 27


2.1 HSE RESOURCES ........................................................................................................................ 27

2.1.1 FINANCIAL, TECHNICAL AND PHYSICAL RESOURCES ......................................................... 27

2.1.2 HUMAN AND ORGANIZATIONAL RESOURCES ....................................................................... 27

2.1.3 HSE SPECIALIST ROLES AND EXTERNAL SUPPORT ............................................................ 27

2.1.4 HSE COMMITTEE ......................................................................................................................... 28

2.2 ORGANIZATION CHARTS ........................................................................................................... 28

2.3 DESCRIPTION OF ROLES AND RESPONSIBILITIES ................................................................ 28

2.3.1 INDIVIDUAL ACCOUNTABILITIES .............................................................................................. 28

2.3.2 HSE MANAGEMENT SYSTEM ACCOUNTABILITY ................................................................... 29

2.3.3 HSE COMMITTEE REPRESENTATIVES ..................................................................................... 29

3 TRAINING AND COMMUNICATION ................................................................................................. 29

4 MONITORING AND REVIEW ............................................................................................................ 30

5 REPORTING ...................................................................................................................................... 30

6 DOCUMENTATION AND RECORDS ................................................................................................ 30

7 LINK TO REFERENCES AND RELATED DOCUMENTS ................................................................ 30

ELEMENT 6 TRAINING, COMPETENCY AND AWARENESS ................................................................. 32

1. PURPOSE .......................................................................................................................................... 32


2.1 RECRUITMENT AND SELECTION .............................................................................................. 32

2.1.1. GENERAL POSITIONS ............................................................................................................. 32

2.1.2. POSITION CAPABILITY REQUIREMENTS ............................................................................. 32

2.2 CATEGORIES OF TRAINING ....................................................................................................... 33

2.3 PLANNING AND SCHEDULING OF TRAINING .......................................................................... 34

2.4 TRAINING NEEDS ANALYSIS ..................................................................................................... 34

2.5 TRAINING TOOLS ........................................................................................................................ 34

2.6 COMPETENCE .............................................................................................................................. 35

2.6.1 TRAINING ASSESSMENT AND EVALUATION .......................................................................... 35

2.6.2 TECHNICAL ROLES ..................................................................................................................... 35

2.6.3 REFRESHER TRAINING............................................................................................................... 35

2.6.4 INSTRUCTOR QUALIFICATIONS ................................................................................................ 36

2.6.5 TRAINING PLANS AND APPROVALS ........................................................................................ 36



4.1. TRACKING OF TRAINING ............................................................................................................ 36

4.2. PERFORMANCE MANAGEMENT SYSTEM ................................................................................ 37

4.3. TRAINING PROGRAM REVIEW ................................................................................................... 37

5. REPORTING ...................................................................................................................................... 37



ELEMENT 7 SUPPLIER AND CONTRACTOR MANAGEMENT .............................................................. 38

0. PURPOSE .......................................................................................................................................... 38


2.1 EVALUATION ................................................................................................................................ 38

2.2 PROCUREMENT PRINCIPLES .................................................................................................... 39

2.3 EQUIPMENT AND MATERIALS ................................................................................................... 39



4. REPORTING ...................................................................................................................................... 42



ELEMENT 8 DOCUMENTATION AND DOCUMENT CONTROL ............................................................. 44

1. PURPOSE .......................................................................................................................................... 44


2.2.1. HSE NUMBERING AND NAMING CONVENTION................................................................... 46

2.2.2. DOCUMENT REVISION ............................................................................................................ 46



5. REPORTING ...................................................................................................................................... 47



ELEMENT 9 COMMUNICATION AND CONSULTATION ......................................................................... 49

1. PURPOSE .......................................................................................................................................... 49


2.1. INTERNAL COMMUNICATION .................................................................................................... 49

2.1.1. PRE SHIFT MEETINGS ............................................................................................................ 50

2.1.2. NOTICEBOARDS ...................................................................................................................... 51

2.1.3. RECORDABLE INJURIES AND SIGNIFICANT INCIDENTS .................................................. 51

2.1.4. HEALTH, SAFETY AND ENVIRONMENT MEETINGS ........................................................... 51

2.1.5. EMPLOYEE PARTICIPATION .................................................................................................. 52

2.2. EXTERNAL COMMUNICATION ................................................................................................... 52

2.3. EXTERNAL COMPLAINTS ........................................................................................................... 53

2.4. EMERGENCY COMMUNICATION ............................................................................................... 53



5. REPORTING ...................................................................................................................................... 54



RIO TINTO COMMUNITIES STANDARD .................................................................................................. 55

RCM COMMUNITY OBSERVATIONS WORK INSTRUCTION ................................................................. 55

HSE MANAGEMENT SYSTEM INTERNAL COMMUNICATIONS REGISTER ........................................ 55

HSE MANAGEMENT SYSTEM EXTERNAL COMMUNICATIONS REGISTER ....................................... 55

RCM MULTI-YEAR COMMUNITIES PLAN ............................................................................................... 55

COMMUNITY FEEDBACK FORM ............................................................................................................. 56

COMPLAINTS REGISTER ......................................................................................................................... 56

COMMUNITY AND STAKEHOLDER ENGAGEMENT TRACKING SYSTEM DATABASE ELEMENT 10 OPERATIONAL CONTROL ....................................................................................................................... 56

1. PURPOSE .......................................................................................................................................... 57


2.1. IDENTIFICATION OF HSE HAZARDS ......................................................................................... 57

2.2. TYPES OF CONTROLS ................................................................................................................ 57

2.3. PROCEDURE AND WORK INSTRUCTION DEVELOPMENT ..................................................... 59

2.3.1. ORIGINAL EQUIPMENT MANUFACTURER DOCUMENTATION .......................................... 59



5. REPORTING ...................................................................................................................................... 60



ELEMENT 11 MANAGEMENT OF CHANGE ............................................................................................ 61

1. PURPOSE .......................................................................................................................................... 61




5. REPORTING ...................................................................................................................................... 64



ELEMENT 12 BUSINESS RESILIENCE AND RECOVERY ...................................................................... 65

8. PURPOSE .......................................................................................................................................... 65


10. TRAINING AND COMMUNICATION ............................................................................................ 68

11. MONITORING AND REVIEW ........................................................................................................ 69

12. REPORTING .................................................................................................................................. 69

13. DOCUMENTATION AND RECORDS ........................................................................................... 69

14. LINK TO REFERENCES AND RELATED DOCUMENTS ............................................................ 69

ELEMENT 13 MEASURING AND MONITORING...................................................................................... 70

1. PURPOSE .......................................................................................................................................... 70




5. REPORTING ...................................................................................................................................... 76



RIO TINTO HEALTH PERFORMANCE STANDARDS ............................................................................. 77

RIO TINTO WORK CYCLE HEALTH AND MEDICAL MONITORING BUSINESS SOLUTION .............. 77

DMS ............................................................................................................................................................ 77

EDMS .......................................................................................................................................................... 77

RCM GIS DATABASE ................................................................................................................................ 77

RCM MEDICAL SURVEILLANCE PROGRAM .......................................................................................... 77

RCM HEALTH MONITORING EQUIPMENT REGISTER .......................................................................... 77

ELEMENT 14 NON CONFORMANCE, INCIDENT AND ACTION MANAGEMENT ................................. 78

PURPOSE ................................................................................................................................................... 78


2.2. INCIDENT MANAGEMENT ........................................................................................................... 78

INITIAL RESPONSE TO AN INCIDENT .................................................................................................... 79

2.3. INCIDENT NOTIFICATION............................................................................................................ 79

INCIDENT RECORDING ............................................................................................................................ 80

2.4. INCIDENT INVESTIGATION ......................................................................................................... 81

2.5. ACTION MANAGEMENT .............................................................................................................. 82

GENERAL ACTION CREATION ................................................................................................................ 82



REPORTING ............................................................................................................................................... 83



ELEMENT 15 DATA AND RECORDS MANAGEMENT ............................................................................ 87

PURPOSE ................................................................................................................................................... 87




REPORTING ............................................................................................................................................... 90



WTP OPERATION AND MAINTENANCE SYSTEM ELEMENT 16 PERFORMANCE ASSESSMENT AND AUDITING .......................................................................................................................................... 90

PURPOSE ................................................................................................................................................... 91


COMMUNICATION AND TRAINING ......................................................................................................... 94


REPORTING ............................................................................................................................................... 94


LINKS TO REFERENCES AND RELEVANT DOCUMENTS .................................................................... 94

RIO TINTO AUDIT CALENDAR ................................................................................................................. 95

RIO TINTO SAFETY LEADERSHIP DEVELOPMENT PROGRAM .......................................................... 95

COPPER MAJOR PROJECTS HSE MANAGEMENT SYSTEM AUDIT PREPARATION GUIDANCE ELEMENT 17 MANAGEMENT REVIEW ................................................................................................... 95

1. PURPOSE .......................................................................................................................................... 96


2.1 MANAGEMENT REVIEW PLANNING .......................................................................................... 96

2.2 DATA PREPARATION .................................................................................................................. 96



5. REPORTING ...................................................................................................................................... 97



REFERENCES AND RELATED DOCUMENTS ........................................................................................ 99

REVISIONS ............................................................................................................................................... 100

Resolution Copper Mining HSE Management System Procedures Manual

UNCONTROLLED COPY WHEN PRINTED.

REFER TO PROSPECT FOR CURRENT VERSION.

Page 1 of 108

OVERVIEW Resolution Copper Mining, LLC (RCM) has developed and implemented a system to manage the health, safety and environmental (HSE) performance of their activities. This system is based on the Rio Tinto Health, Safety, Environment and Quality (HSEQ) Management System Standard.

The Rio Tinto HSEQ Management System promotes:

Safe and environmentally responsible systems of work

Compliance with regulations

Effective participation and consultation with employees and contractors

Effective management of hazards

Early reporting of incidents and thorough investigation

Measurement, evaluation and continual improvement

The HSE Management System is the framework of processes and procedures used to ensure that RCM can fulfil all of these tasks.

HSE VISION RCM’s vision is to conduct its activities with the goal of achieving zero harm to its people and the environment. This shall be achieved by:

Ownership: demonstrated by commitment, understanding and involvement from employees and stakeholders

Planning of tasks and resources

Allocation of efficient resources

Assigning clearly defined authorities, responsibilities and accountabilities

Support for innovation

Ensuring decisions are followed through and performance assessed against predetermined criteria

Identifying, planning and implementing opportunities for improvement

Communication of The Way We Work throughout the company and stakeholders




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Continual Improvement Cycle of the Rio Tinto HSEQ Management System Elements




Page 3 of 108

RESOLUTION HSE MANAGEMENT SYSTEM PROCEDURES This Manual contains all the system procedures that describe RCM’s HSE Management System.

The foundations of RCM’s HSE Management System are the Rio Tinto “The Way We Work”, the Rio Tinto HSEQ Management System Standard and the International Standards Organization 14001:2004 Environmental Management System (ISO 14001).

OBJECTIVES System procedures have been developed for each individual Element of the RCM HSE Management System.

Each system procedure ensures that the specific requirements of the HSE Management System Standard Elements are met.

The system procedures describe the processes that RCM takes to achieve the outcomes required. The procedures refer to steps, actions or tasks.

SCOPE The RCM HSE Management System applies to all persons working for or on behalf of RCM, including contractors, and covers the HSE management of all RCM’s activities, assets, products and services.

ACCOUNTABILITIES

Senior Leadership Team The Senior Leadership Team (SLT) is accountable for setting the RCM health, safety and environmental direction by:

Communicating the Rio Tinto and RCM HSE vision, formulating a policy and setting goals for safe work and protection of the environment

Promoting a culture of making HSE an intrinsic part of work systems and procedures and encouraging extension of HSE principles to off the job activities

Structuring the Project plan to promote continual improvement in HSE

Articulating the HSE vision through all Managers and behaving accordingly

Ensuring resources are available to support the implementation of the HSE Management System

Ensuring that HSE systems are applied consistently across the Project work areas

Ensuring the Managers are accountable for their work

Managers

Each Manager is accountable for:

Articulating the vision to his/her team members and giving them discretion to consider HSE and act accordingly

Demonstrating their personal commitment to HSE by designing and supporting consistent business systems and allocating resources




Page 4 of 108

Getting personally involved in the identification of workplace hazards in a way that ensures he/she can assess the risk and then initiate controls that are acceptable

Designing and improving processes to minimize risk

Ensuring all Supervisors are accountable for his/her work

Participating in departmental audits

Completing Take 5s and HSE Interactions

Participating in non conformance investigations and notification processes

Developing and implementing his/her personal HSE improvement plan

Participating in HSE Meetings

Superintendents

Each Superintendent is accountable for the implementation of the HSE Management System Elements and HSE Performance Standards within his/her area of control and with demonstrated behavior shall:

Ensure all team members are fully trained and able to perform their duties safely

Ensure all regular HSE checks, inspections and audits are done

Ensure HSE systems are consistently applied across his/her area of control

Complete Take 5s and HSE Interactions

Participate in non-conformance investigations and notification processes

Develop and implement his/her personal HSE improvement plan

Participate in HSE Meetings

Supervisors / Team Leaders

Each Supervisor / Team Leader is accountable for:

Actively observing employees’ HSE behavior through regular supervision and HSE interactions

Ensuring that all team members understand the HSE requirements and perform them accordingly

Behaving in a manner that demonstrates his/her commitment and understanding of HSE

Employees

Each employee is accountable for supporting the HSE vision by:

Understanding and showing commitment to preventing injuries, minimizing damage to the environment and property and avoiding interruption to the business

Following HSE Management System and HSE Performance Standards, RCM Procedures and systems

Accepting personal accountability

HSE Management Representatives




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The Health & Safety and Environmental Manager have been appointed as the HSE Management Representatives.

The HSE Management System Representatives are accountable for:

Ensuring the currency of the HSE Management System and

Ensuring the Management System reflects the needs of the Project




Page 6 of 108

DEFINITIONS Acronym or Description

Definition

Acceptable Risk A level of risk which is considered sufficiently low not to require any additional active management or changes to the situation presenting this risk.

Accident ALARP As Low As Reasonably Practicable - Risk that is ‘tolerable’, on the basis that

the risk is acceptably low, and cannot be cost effectively further reduced. Business Solution Rio Tinto business system for management Control Current Risk The risk as it currently exists considering the effectiveness of the existing

controls. Documents Documents are broadly defined as those types of documentation that have

the ability to change over time. Examples include procedures, management plans, templates, forms, etc.

Environmental Aspect An element of a businesses’ activities, products or services that can interact with the environment” (refer ISO 14001:2004). Within the HSEQ risk management context any reference to the term hazard is inclusive of environmental aspects.

Environmental Impact Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products or services.

Hazard A source of potential harm or a situation with a potential to cause actual or perceived loss or damage to people, the environment, or plant and equipment

Hazard A source of potential harm or a situation with a potential to cause actual or perceived loss or damage to people, the environment, or plant and equipment.

HSE Administrators The Environmental Coordinator and the Safety Coordinator HSE Management Representative

RCM HSE Managers

HSE Management System Documents

System Procedures Manual

Element Procedure Performance

Standard Procedure

Standard Operating Procedure (SOP) or Work Instruction

Whilst a procedure documents the step-by-step detail for the process, an SOP or work instruction defines further details of one or several process step(s) that the business has put in place.

Safe Work Procedure

Incident Inherent (Baseline) Risk

The initial or raw risk rating as originally identified before controls have been considered in the assessment.

JHA Job Hazard Analysis. Example of Level 1 risk assessment Level 1 risk assessment

Pre-task hazard assessment (Task/Activity based) eg Take 5, JHA

Level 2 risk assessment

Qualitative risk assessment - eg Risk Register




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Acronym or Description

Definition

Level 3 risk assessment

Quantitative or semi-quantitative risk assessment eg SQRA

Maximum Reasonable Consequence

The largest realistic or credible consequence from an event, considering the credible failure of controls.

Maximum Reasonable Likelihood

The most realistic or credible likelihood for an event to result in the defined ‘maximum reasonable consequence’.

Maximum Reasonable Outcome

The maximum reasonable outcome for an incident or risk, based on its consequence potential and likelihood.

Non Conformance Predicted Risk The predicted or forecasted risk remaining after controls and risk reduction

(or enhancement) measures have been implemented. Procedure When the HSE Management System Standard requires that a process be

undertaken, sometimes this shall be documented as a written procedure. This is stated in the relevant elements of the Standard. The procedure documents the step-by-step detail for the process activities and actions that the business has put in place.

Process Some elements of the HSE Management System Standard require certain management activities to be undertaken in a particular way – these activities are referred to as requiring a “process”. A process includes a series of activities, actions or functions designed to bring about a specific result. Some of these processes are pre-defined and mandated through the use of “work cycles”. Other processes need to be determined by the individual business.

Prospect Portal for access to SAP based electronic business system Records Records are broadly defined as those forms of documentation that contain

specific information at that point in time. Examples include monitoring results, meeting minutes, completed incident reports, registers, matrices, checklists and check sheets, completed forms, audit reports, etc.

Risk An uncertain event or condition that if it occurs shall affect achievement of one or more objectives (both upside and downside). It is measured in terms of the likelihood of occurrence and its potential consequences, and assigned an overall risk classification.

Risk Assessment An evaluation of the level of risk determined from assigning consequence and probability.

Risk List A list of all the completed risk assessments that have been undertaken. Risk Register The Business Solution contains a database with the risk assessment results

that require ongoing management. SEART Rio Tinto’s Social and Environmental Reporting Tool SEG Similar Exposure Group

A Similar Exposure Group (SEG) is defined as “A group of workers having the same general exposure profile for an agent because of the similarity and frequency of task(s) they perform, the similarity of the materials or the processes with which they work, and the similarity of the way they perform the task(s).”

Significant Risk Rio Tinto definition of significant risk is where the maximum reasonable outcome is High or Critical.

Significant Risk Reference is made to the management of “significant risk” throughout the Standard. Rio Tinto defines significant risk as that which has a risk management classification of ‘High’ (Class III) or ‘Critical’ (Class IV). (refer to Element 3: Hazard identification and risk management).

SLT RCM Senior Leadership Team




Page 8 of 108

Acronym or Description

Definition

SQRA Semi Quantitative Risk Assessment. This is Rio Tinto’s preferred Level 3 risk assessment

Take 5 Example of Level 1 risk assessment Work Cycle Some of the required processes in the HSE Management System Standard

are further specified through work cycles. A work cycle is mandatory and provides the detail for what steps should be taken, and how, in order to ensure the relevant process is undertaken.

Work Practice Each individual step of a work cycle is called a work practice Refer also - http://sesurvey.riotinto.org/hsedefn/search.aspx




Page 9 of 108

MEETING INTERNAL AND EXTERNAL STANDARDS RCM HSE MS Rio Tinto HSEQ MS ISO 14001:2004 OHSAS18001

PLAN

1.Policy 1.Policy 4.2 Environmental Policy

4.2 OH&S Policy

2.Legal and Other Requirements

2.Legal and Other Requirements

4.3.2 Legal and other requirements

4.3.2 Legal and other requirements

3.Hazard Identification and Risk Management

3.Hazard Identification and Risk Management

4.3.1 Environmental Aspects

4.3.1 Planning identification of hazards/risk assessment and control of them

4.HSEQ management improvement planning

4.HSEQ management improvement planning

4.3.3 Objectives, targets & programs

4.3.3 Objectives and targets

DO 5.Organizational

resources, accountabilities and responsibilities

5.Organizational resources, accountabilities and responsibilities

4.4.1 Resources, roles, responsibility and authority

4.4.1 Structure and responsibility

6.Training, Competency & awareness

6.Training, Competency & awareness

4.4.2 Competence, Training & Awareness

4.4.2 Training & Competency

7.Supplier and Contractor Management

7.Supplier and Contractor Management

4.4.6 Operational Control 4.4.6 Hazard identification, hazard/risk assessment & control

8.Documentation and Document Control

8.Documentation and Document Control

4.4.4 Documentation 4.4.5 Document Control

4.4.4 Documentation 4.4.5 Document Control

9.Communication and Consultation

9.Communication and Consultation

4.4.3 Communication 4.4.3 Consultation, Communication and reporting

10.Operational Control 10.Operational Control HSE Performance

Standards

4.4.6 Operational Control 4.4.6 Hazard identification, hazard/risk assessment & control

11.Management of Change

11.Management of Change 4.4.6 Operational Control 4.4.6 Hazard identification, hazard/risk assessment & control

12.Disaster Management and Recovery (DMR)

12.Disaster Management and Recovery (DMR)

4.4.7 Emergency Preparedness and Response

4.4.7 Emergency Preparedness and Response

CHECK 13.Measuring and

Monitoring 13.Measuring and

Monitoring 4.5.1 Monitoring and

Measurement 4.5.1 Monitoring and Measurement

14.Non conformance, Incident and Action Management

14.Non conformance, incident and action management

4.5.3 Non conformity, Corrective Action and Preventive Action

4.5.2 Incident Investigation, Corrective and Preventive action

15.Data and Records Management

15.Data and Records Management

4.5.4 Record Control 4.5.3 Records & Record Management

16.Performance Assessment and Auditing

16.Performance Assessment and Auditing

4.5.5 Internal Audit 4.5.2 Evaluation of

compliance

4.5.4 OHSMS Audit

REVIEW 17.Management Review 17. Management Review 4.6 Management Review 4.6 Management Review




Page 10 of 108

ELEMENT 1 POLICY

Purpose To state the intentions, commitment and principles of RCM in relation to the effective management of HSE. To periodically review the policy and ensure it provides direction for the business.

Description of Process RCM maintains a single integrated HSE Policy that reflects its responsibilities and goals. This Policy is communicated and available to all employees, stakeholders and other interested parties and indicates the commitment of the project towards due diligence and best practice management.

1.1. Policy Development and Approval The RCM HSE Policy was initially developed and approved in 2006.

The Policy recognizes that HSE management is core to business requirements and is used in setting business objectives and targets. The Policy is endorsed by the RCM SLT to ensure they provide direction for the business. The final approval lies with the Project Director.

Training and Communication

2.1. Internal The RCM HSE Policy is made available to all employees and contractors. This is via various methods including posting of the Policy on the RCM HSE Prospect page and notice boards.

The RCM induction program includes elements of the HSE Policy and all employees and contractors are required to be aware of the commitments outlined in the Policy.

2.2. External The RCM HSE Policy is made available externally:

On the RCM external website

As part of the General Conditions of Contract upon contract establishment or renewal

At the West Plant and East Plant Security facilities

At the Phoenix Office, the Superior Office Visitors Centre, the RCM Verde Building Front Desk and upon request by the public

Review The Policy is reviewed and revised annually or as required by the SLT to reflect developing business conditions and/or directions to ensure it continues to meet the needs and priorities of the business.

The review is undertaken with consideration given to the potential changes to the nature, scale, risks / impacts and purpose of RCM’s activities and services and includes the following elements:

HSE aspects that can be controlled and those that RCM can influence




Page 11 of 108

Compliance with legal and other requirements, including international agreements and external requirements to which RCM subscribes including the Rio Tinto standards of conduct

Effective management of HSE risks and promoting employee awareness of the HSE threats and opportunities

Prevention of incidents that may lead to injuries, illnesses, pollution, property and environmental damage, material losses, security threats, business interruption and Company reputation

A commitment to adopting leading practice in key HSE areas through continual improvement

Improving performance by the setting of measureable HSE objectives and targets

Resources that may be required and a commitment to providing and developing those resources

Encouragement of effective employee participation

Recognition of the business value of effective HSE performance, understanding stakeholder expectations and meeting customer requirements

Any planned, new or modified developments or activities

The updated Policy is provided to the RCM HSE Committee and issued via email to the workforce.

Reporting No reporting on the Policy is required.

Documentation and Records An electronic copy of the final approved HSE Policy is retained in DMS.

Following policy re-issue obsolete copies of HSE policies shall be removed from noticeboards and office walls in the workplace and replaced with the new version as appropriate.

Link to References and Related Documents RCM HSE Policy

Rio Tinto Health, Safety and Environmental Policies

RCM Prospect page

RCM External Website

Rio Tinto External Website




Page 12 of 108

ELEMENT 2 LEGAL AND OTHER REQUIREMENTS

2. Purpose To describe how RCM complies with all legal HSE requirements and conforms to internal Rio Tinto Standards, Policies and other obligations.

3. Description of Process

2.1 Management System Certifications RCM currently maintains the following management system certifications:

ISO14001:2004 Environmental Management System Standard Certificate # 12331- 2007 – AE-USA-ANAB

Certification shall be conducted by the Rio Tinto approved certification body, DNV.

Certification to OHSAS 18001 or ISO9001 shall not be obtained at this time.

2.0. Identifying & Updating Relevant HSE Legal and Other Requirements

Relevant HSE legal and other requirements shall be identified and documented. This shall include international, federal, state, regional or local legislation, licenses, codes of practice, Rio Tinto Group policies, standards and external voluntary commitments.

In addition, in the United States of America (USA), the Native Americans are identified as a Sovereign Nation and have specific requirements.

Legal and other requirements that apply to non mining land managed by RCM shall also be identified.

Information may be identified through:

Legal firms or consultancies

Legal subscription services that provide updates on policy and legislation (eg E & E)

Communications with Rio Tinto and the Copper Group

Reference to the Rio Tinto Compliance Group portal – Policies and Standards – which provides information on endorsed Rio Tinto Group memberships / conventions (voluntary commitments) and Rio Tinto global mandates

Direct communications with regulators and attendance at briefings, workshops, etc. held by such agencies

The risk of legal non compliance shall be referenced in the RCM Risk Registers including the Project Business Risk Register and the Business Solution Risk Register to assist in ensuring compliance of current Project development works and planned Project activities.

Any change to legal and other requirements identified as requiring a specific action shall be managed through the management of change (MOC) process and implemented to ensure conformance / compliance with the new requirement.




Page 13 of 108

2.1. Compliance It is the responsibility of each RCM Manager to ensure his / her activities comply with HSE legislation and permits and to retain appropriate records to show evaluation of compliance.

Statutory and permitting requirements shall take precedence over Rio Tinto Standards, except in those cases where the Rio Tinto Standards are more stringent.

Each RCM Manager shall be aware of the Legal and Other Register and the specific legislation and permits that apply to his / her work area and the specific conditions that shall be complied with.

The RCM Project Study Team shall ensure that planning and design of the RCM operations and infrastructure shall comply with the relevant legislation.

Compliance with legal and other requirements is also evaluated during the following activities (refer HSE Management System Procedures for Elements 13, 14 and 16):

HSE measuring and monitoring programs

Internal auditing and inspections

Incident investigation

Corporate reporting

Evaluation of HSE regulatory compliance is undertaken by external regulators including, but not limited to, the Mine Safety and Health Administration (MSHA), Arizona State Mine Inspectors (ASMI) and Arizona Department of Environmental Quality (ADEQ).

RCM conducts a review of the current HSE Permits every two years and of the HSE Legal and Other Requirements Register on an ongoing basis.

3. Training and Communication All RCM personnel and contractors shall receive training in the legal and other requirements required for their role via:

General induction training

Supervisor training

Training/competency programs for high risk tasks eg confined spaces, or for those with specific statutory obligations e.g. electrical

Annual refresher training on regulatory requirements

Communication of legal and other requirements shall be achieved by a range of means including (but not necessarily limited to):

RCM HSE Prospect page with a link to the controlled electronic HSE Legal and Other Requirements Register

Communications to RCM personnel by HSE representatives where appropriate

Reference to legal and other requirements within employee and contractor induction programs

Changes to regulatory and permitting requirements shall be communicated at least annually to the RCM SLT.




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4. Monitoring and Review Assessment of compliance with legal and other requirements shall be conducted as part of the RCM internal audit program (refer HSE Management System Procedure Element 16).

RCM also conducts compliance reviews of the HSE Legal and Other Requirements Register at a minimum of two yearly intervals. Each compliance review considers the following:

HSE legislation that applies to RCM

Currency of Permits and renewal dates

Compliance with permit conditions

All situations where a non-conformance or non-compliance is identified shall be treated as confidential in accordance with Rio Tinto Legal Department requirements.

Actions shall be by managed by the HSE Managers in consultation with legal advice.

5. Reporting Reporting on compliance is required in accordance with the legislation and permits listed in the HSE Legal and Other Requirements Register.

6. Documentation and Records A HSE Legal and Other Requirements Register that details RCMs legal and other requirements is maintained.

As a minimum the register contains:

The name of the legal or other requirement including Rio Tinto Group Policies, Standards and external voluntary commitments

A summary of how the requirement applies to RCM

A description of compliance/conformance with reference to the appropriate evidence of that compliance

Accountability for maintaining compliance or conformance to each requirement

A Permits Register which details the current permits and licenses is also maintained within the HSE Legal and Other Requirements Register.

As a minimum the register contains:

The name of the permit

Where the permit applies to RCM

A description of compliance/conformance with reference to the appropriate evidence

An electronic copy of the register is retained in DMS.

The registers are updated as required by the results of the compliance reviews.




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7. Link to References and Related Documents Rio Tinto Compliance Group Portal for Policies and Standards

RCM HSE Legal and Other Requirements Register

RCM Permits Register

RCM Legislation Compliance Reviews




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ELEMENT 3 HAZARD IDENTIFICATION AND RISK MANAGEMENT

1. Purpose To identify, assess, record and communicate all HSE hazards, aspects and opportunities using a common approach and ensure:

Their resulting risks to people, property, assets and the environment are evaluated

Risks are managed in accordance with the recommended hierarchy of controls to achieve levels that are as low as reasonably practical (ALARP)

Any requirements are implemented ensuring compliance and conformance to mitigate any HSE risks


2.1 Rio Tinto Risk Management Framework All activities at RCM, including planned, new or modified developments or activities, shall follow the requirements of the Rio Tinto Hazard Identification and Risk Management Work Cycle when conducting HSE Risk Management.

The Rio Tinto HSE 5 x 5 Risk Matrix and associated Likelihood and Consequence descriptors shall be used to assess risk levels.

The hierarchy of controls is used to allocate control measures with elimination being the first control considered. Risk controls identified during the risk assessment and their effectiveness shall be monitored. Risk control monitoring for those identified during the Level 2 Risk Assessment process shall be managed using the action management system in the Rio Tinto Business Solution.

2.2 Risk Assessment Methods The risk assessment approach enables the appropriate level of assessment to be used to match the context, nature and scale of the risks. The more severe the risk level, the more complex and formal and ‘methodology driven’ the risk assessment method shall be.

At RCM, the following tools are used:

Level Risk Assessment Type Triggers

Level 1 Pre-Task Hazard Assessment

Informal Hazard Identification / Risk Awareness (e.g. Take 5)

Workgroup Hazard Assessment (e.g. Group Take 5, Job Hazard Analysis, Level 1.5 Risk Assessment)

(Take 5) Prior to all tasks or duties Significant consequences identified from an informal

risk assessment Deviations from standard work procedures Limited knowledge of risks from task or no existing

procedures Where permits are required Change management for minor changes Where there is a change in work scope




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Level 2 Qualitative Risk Assessment

Qualitative Risk Assessment (e.g. utilizing Rio Tinto HSE 5x5 Risk Matrix)

Hardware or Design Reviews (e.g. HAZOP)

High degree of uncertainty remains after Level 1 assessment

Hazards identified without controls from a Level 1 assessment

Change management for major changes Stakeholder concerns (e.g. complaints or adverse

symptoms) Regulatory driven Post incident review of controls from Low, Moderate

and High incident investigations Recommendation from audit or management review Baseline compilation of RCM Level 2 Risk Register

and action priorities

Level 3 Quantitative Risk Assessment

Semi-Quantitative Risk Assessment (SQRA)

Quantitative Risk Assessment (QRA) (e.g. risk and consequence modelling; fault and/or event tree analysis; formalized/quantitative environmental impact assessment techniques)

Hazards with potential major risk outcome Level 2 assessment where the current risk is

assessed as Critical High degree of uncertainty remains after Level 2

assessment Recommendation from audit or management review

2.3 Conducting Risk Assessments Hazards shall be identified, risk assessed, appropriately controlled and reviewed for the following areas:

All tasks

Processes

Changes in procedures or work methods

Changes in legislation

New training

Goods and services

The risk assessment shall consider all HSE social and environmental consequence categories, listed on the Rio Tinto HSE 5 x 5 risk matrix, and detailed as follows:

Health impact

Personal safety

Environment impact

Community impact

Compliance impact

Reputation (Rio Tinto or RCM)




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All risk assessments are conducted by a cross functional team who represent various levels of the organization and work areas. Members include subject matter experts or persons with detailed knowledge of the process / situation and are aware of the situation being assessed or may be impacted by the situation.

All contributors to a risk assessment shall be documented on the risk assessment template.

Completed risk assessments are reviewed by the relevant Manager of the area where the risk assessment applies.

2.3.1 Level 1 Risk Assessments Personnel are required to conduct a Take 5 risk assessment before undertaking any task. If a task is identified as one for which personnel cannot identify adequate controls, the employee shall contact his / her supervisor for further instructions. A Job Hazard Analysis (JHA) may be required involving more persons in order to identify ways to adequately control the risk or change the process of the work required. Level 1 Risk Assessments must be re-evaluated if there is change in work scope or environment mid-process, including changes to people, equipment or environment, or changes to hazards or controls. After it has been completed, the need for a higher level of assessment should be evaluated if hazards remain inadequately controlled or a higher degree of uncertainty remains.

A. Take 5

A Take 5 is conducted and documented by individuals or small teams immediately prior to commencing a task, including whenever the environment has changed, which will require the task to be reassessed.

B. Job Hazard Analysis (JHA) (also known as Level 1.5 Risk Assessment)

A JHA is conducted and documented in workgroups involving people who are skilled and knowledgeable in performing the task and are conducted a close to the commencement of the task as reasonably practicable. These assessments are often used for the development of a work instruction or procedure. If an existing JHA or workgroup hazard assessment is to be used, it must be reviewed in detail by the work group prior to being applied to a task.

2.3.2 Level 2 Risk Assessments Hazard based risk assessments (Level 2) are facilitated by trained personnel and recorded in the RCM Level 2 Risk Assessment Template, which follows the Rio Tinto required fields and formatting. Events or conditions initiating a Level 2 risk assessment may include identification of major work area, Project implementation, or Safe Work Practice development. The risk register shall be developed for work areas and Similar Exposure Groups (SEGs). The relationship of the SEG or work area(s) to their hazard(s) forms the individuality of the risk assessment.

SEGs have been defined for occupational health hazards that may occur at RCM.

At RCM, the primary factors that determine the composition of a SEG may include but are not limited to:

Job task(s) / work process(es)

Task / process frequency and/or duration




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Environmental stressor(s)

Job classification (description)

The SEGs that are applicable to the activities currently undertaken by RCM are documented in the HSE SEG Monitoring Program. Each SEG has had a risk assessment completed and controls identified.

An annual assessment, such as medical examination or monitoring, shall be required where there is exposure to known and suspected carcinogens and reproductive toxicants to ensure that the risk is ALARP.

Level 2 Risk Assessments shall be transferred by the H&S Department to the Risk Register and stored on the I: drive. The Risk Register is maintained and updated so that it remains a current working system. Each department shall undertake an annual review of hazard and risk registers, with support from the HS&E Departments. All risk assessments shall have a risk owner. The risk owner is accountable for the overall management of the risks and their contributing risk scenario(s).

2.3.3 Level 3 Risk Assessments SQRA (Level 3) are facilitated by trained personnel. SQRAs may be initiated by significant risks from Level 2 risk assessments that cannot be adequately controlled or where current risks have an evaluated maximum reasonable outcome (MRO) of Critical, legislative requirements, high consequence but low likelihood events identified, or new Project works.

Level 2 Risk Assessments must be updated with relevant information from the Level 3. Where Level 3 has determined the risk class is higher or lower than identified through the Level 2, the qualitative risk class in the Level 2 should be reviewed and amended as required.

2.4 Management of Risk Controls and Actions A completed risk assessment includes identification of significant hazards, existing controls and action plans where additional controls are required.

The risk response for the control of risks that shall be applied is detailed through the risk classifications in the following table:

Rating Risk management response

HSE focus

Action Implementation Time Frame

Critical Class IV Risks that significantly exceed the risk acceptance threshold and need urgent and immediate attention.

Immediate action required.

High Class III Risks that exceed the risk acceptance threshold and require proactive management. Includes risks for which proactive actions have been taken, but further risk reduction is impracticable. However active monitoring is required and the latter requires the sign-off from Business Unit senior management.

Short term action required.

Improvement items shall be included in the Annual Improvement Plan to reduce risk level.




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Moderate Class II Risks that lie on the risk acceptance threshold and require active monitoring. The implementation of additional measures could be used to reduce the risk further.

Medium term action required.

Improvement items should be included in the Annual Improvement Plan to reduce risk level.

Low Class I Risks that are below the risk acceptance threshold and do not require active management. Certain risks could require additional monitoring.

Manage by routine processes.

Control measures shall be selected in accordance with the most effective control mechanisms of the hierarchy of controls to reduce the risk to an acceptable level:

Elimination – Removing the hazard from the workplace. For example, replacing a chemical process with a mechanical or physical one, or replacing the need to handle drill rods by the use of an automated rod-handler. However, the removal of the hazard may not always be a practicable alternative as elimination may require the removal of an essential part of a process or essential item of a plant.

Substitution – Replacing a hazard with something that may still be a hazard but a hazard to a much lesser degree. For example, using water-based paint in place of a solvent-based paint.

Engineering and process control – Minimizing the creation of the hazard at its source or controlling the hazard’s potential risks by limiting its effective range. There are many examples of engineering controls, but one is the use of localized extraction systems to remove gases, fumes or dusts from the work environment. Another example is a guard protecting the hand from contact with rotating drill rods.

Administration – Whereas the above mentioned control stages address the hazard, administrative controls address the person in the workplace. Administrative controls include use of safe work practices, limiting the exposure of persons to a hazard to particular times only, e.g. when prevailing weather conditions are favorable.

Personal protective equipment (PPE) – Equipment worn by a person to isolate them him/her from a hazard present in his/her surrounding workspace. The use of PPE should be restricted to situations where other control measures are not practicable, for example, emergency situations, or where PPE is used in conjunction with other control measures to provide the required level of protection.

It must be stressed that the use of PPE is to provide protection from a hazard and should never be considered as the primary form of protection. Many employers are under the misapprehension that by providing PPE, they have met their duty-of-care responsibilities. This is not the case as the limited protection offered by PPE is governed by a number of factors.

Control measures shall reduce the risk to ALARP.

All existing controls shall have a control owner. Planned controls or actions are assigned a responsible person for implementation.

For Level 2 risk assessments, actions are managed via the RCM Level 2 Risk Register, in accordance with the Rio Tinto Action Management Work Cycle. Actions are reviewed by the work area of responsibility on an annual basis when the risk register is reviewed. Actions may be moved to current controls and risk levels re-assessed at those times.




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For Level 1 and 3 risk assessments, actions are managed via spreadsheets, in accordance with the Rio Tinto Action Management Work Cycle.

3. Training and Communication All employees and contractors complete training in the Take 5 risk assessment process.

All significant hazards and their controls are identified and communicated to all persons potentially exposed to the risk.

Other methods of communicating hazards, risks and controls are pre shift meetings, HSE meetings, shares, posters and interactions.

4. Monitoring and Review Risk assessments that have actions that shall be implemented in order to lower the current risk shall be monitored until completion of all actions. Monitoring of the actions progress shall occur through the HSE SLT review meetings, and risk register reviews, as well as by departments’ regular meetings.

When all actions associated with a risk assessment are completed, the risk assessment shall be reviewed with the current controls in place and a current risk noted. Implementation of controls shall also be verified during regular inspections.

Risks with a current classification of high (class III) or critical (class IV) must be reviewed and updated at least annually. Risks with a current classification of low (class I) or moderate (class II) must be reviewed and updated at least three yearly.

The risk owner is accountable for ensuring the risks are reviewed prior to expiry of the review date.

In addition to reviewing significant HSE risks, RCM shall periodically, after an incident, upon identification of hazard or when processes change, undertake reviews of the hazards related to the Rio Tinto HSE Performance Standards and hazards related to:

Biodiversity

Closure

Raw materials (resources)

Energy

Climate change

Products

Communities

Process safety hazards

Business continuity




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5. Reporting All current risks that remain classified as critical (class IV) after completing quantitative risk analysis (Level 3) must be reported to Rio Tinto. Reporting requirements are included in the Rio Tinto Social and Environment Reporting and Definitions Work Cycle.

RCM currently has no Critical (Class IV) risks identified in the SQRA, therefore there are no Rio Tinto reporting requirements.

6. Documentation and Records Take 5s shall be documented and retained in the relevant work area.

Level 1 risk assessments (e.g. Take 5s and JHAs) shall be documented and retained and managed in the relevant work area.

Level 2 risk assessments shall be entered into the RCM Level 2 Risk Assessment Template and sent to the H&S Department for retention and inclusion in the RCM Level 2 Risk Assessment Master and Risk Register, which is readily accessible to all risk owners and relevant internal stakeholders on the RCM HSE Prospect page.

Level 3 risk assessments (SQRA) are recorded in Microsoft Access and any risk identified as critical after completion of the SQRA shall be entered into SEART.

7. Link to References and Related Documents Task Based Risk Assessment Form

List of Task Based Risk Assessments

List of Hazard Based Risk Assessments

Completed Task Based Risk Assessments

Completed Hazard Based Risk Assessments

Business Solution Risk Register

Project Business Risk Register

SEG List

SHEA Form

Rio Tinto HSE 5 x 5 Risk Matrix




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ELEMENT 4 HSE MANAGEMENT IMPROVEMENT PLANNING

Purpose To describe how RCM establishes processes and plans to manage HSE performance and provide for continual improvement.

Description of Process

Identification of HSE Objectives and Targets Objectives and targets shall be in place for RCM each year. The objectives and targets may be short term (annual) or longer term (up to 5 years).

The aim of the objectives and targets is to facilitate continual improvement in HSE performance. They shall be based on both lagging and leading indicators.

Objectives and targets shall be measurable and consistent with the Group, product group, business unit and RCM’s HSE policies. The objectives and targets shall take into account:

RCM HSE Policy

Copper Major Projects HSE Policy

Rio Tinto Group HSE objectives and targets

Project risk register in particular SQRA’s and other significant HSE risks and impacts

Prevention of HSE incidents

Legal and other requirements

Key stakeholder expectations

Commitments to continual improvement

Commercial and Project objectives including technological options, financial, operational and business requirements

Previous years objectives and targets

Note: When developing new objectives and targets the SLT may also review the previous year and consider which were the most successful and effective and why they were.

The H&S Manager and Environmental Manager shall identify Project HSE objectives and targets for performance management.

Where possible, targets shall be measurable against a quantifiable performance indicator and include a specific time frame. It is recognized that some objectives and targets may not be quantifiable in terms of a numeric value but add value from an environmental or reputation aspect.

The SLT shall review the proposed objectives and targets and provide feedback on additions, deletions or corrections.




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Improvement Plans Once the objectives and targets have been finalized, annual improvement plans shall be developed. The annual improvement plans include:

The current and target condition

The agreed actions to be achieved (these shall be achievable and measurable)

The designation of accountability for each specific improvement program

The designation of responsibility for each task to be completed

The timeframe by which tasks are to be achieved

The planned timetable for improvement work start and completion

Annual Project Plan The Annual Project Plan shall be developed with consideration of the following:

RCM HSE objectives and targets

RCM risk register and the results of risk assessments

Available resources

Addressing known legal non-compliance

Commitments made in the RCM HSE Policy

Relevant community and stakeholder concerns

Improvement ideas including new technological opportunities.

Personal HSE Plans All employees shall have a personal or team based HSE improvement plan with documented objectives and targets that reflect RCM’s objectives and targets and support the goal of continual HSE improvement for the Project.

Training and Communication The RCM HSE objectives and targets shall be made available to all employees and contractors. This may be achieved by communicating in newsletters, emails, team meetings, posting on the RCM HSE Prospect page or notice boards.




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Monitoring and Review

Objectives, Targets and Improvement Plans Review of performance against HSE objectives and targets occurs via various mechanisms throughout the year including:

Review by the HSE Committee of progress and effectiveness of actions

Review by the SLT every six months to ensure the objectives, targets and management continue to be suitable, adequate and effective for the stage of the Project as well as confirming progress is being made on the actions

The following circumstances may also trigger an interim review of objectives and targets:

Changes to Project activities

The identification of a new significant HSE risk

Results from monitoring, inspection, audit, management review or a non-conformance report which indicate that a review is necessary

When there is a change to the activities, products or services of the business or significant changes in operating conditions

Feedback from key stakeholders

Findings from improvement projects focused on HSE objectives and targets

Findings from a regulatory or legal agency

Any changes to HSE objectives and targets shall be documented as part of the RCM annual planning process.

Personal HSE Plans All employees shall meet with their supervisor to agree on appropriate objectives and targets for their personal or team HSE Improvement Plan.

A formal meeting between Supervisors and team members occurs at least once a year to discuss RCM’s performance against HSE objectives and targets as well as appropriateness of personal or team plans.

Reward and incentive scheme shall be designed so that HSE performance is not compromised in order to maximize financial reward.

Reporting Internal reporting on RCM’s HSE performance includes the following:

Monthly reports to Copper Group and partners

Six monthly Rio Tinto Social and Environmental (S&E) reports

External reporting on RCM’s HSE performance is through:




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RCM external webpage

S&E Report

The Rio Tinto Sustainable Development Report

Documentation and Records Records of objectives, targets and HSE improvement plans shall be maintained to provide a history of the continual improvement of the business.

RCM’s objectives and targets and improvement plans shall be stored in DMS.

Personal HSE plans shall be retained by each employee.

Team plans shall be retained by the Supervisor.

Link to References and Related Documents RCM Annual Objectives and Targets

RCM Annual Improvement Plans

RCM Annual Project Plan

Personal and Team Based HSE Improvement Plans




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ELEMENT 5 ORGANIZATIONAL RESOURCES, ACCOUNTABILITIES AND RESPONSIBILITIES

1. Purpose To ensure that resources, responsibility and accountability are appropriately allocated for the maintenance and continual improvement of HSE management.


2.1 HSE Resources

2.1.1 Financial, Technical and Physical Resources

Financial, technical and physical resources shall be provided to enable RCM to meet the requirements of any permits, ensure employees and contractors may meet their accountabilities and present or report relevant information to the government authorities and community.

Technical and physical resources may include:

Computer hardware and software

Monitoring equipment (water monitors, dust monitors etc)

Vehicles

Documentation and references (books, journals, reports)

2.1.2 Human and Organizational Resources

Human and organizational resources shall be provided to enable RCM to fulfill the requirements of legislation, permits and the HSE Management System.

As part of the annual planning process staffing levels are reviewed by the SLT as part of the project planning process to ensure legislative and corporate requirements and operating conditions continue to be met. Appropriate staffing levels are then determined by each Manager and approved by the Project Director.

Requests for new employees are facilitated through the Business Solution ServU-New Hire Notification ticket request.

2.1.3 HSE Specialist Roles and External Support

RCM has dedicated HSE personnel to support the Project. Where specific HSE expertise is not available in-house, RCM has access to specialist HSE advisors through the Copper Group and Rio Tinto or may access external providers of the required services.




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2.1.4 HSE Committee

A HSE Committee has been established to support the management of HSE performance and oversee the implementation of improvement plans.

The RCM HSE Committee comprises a representative from most of the main work areas along with a member of the SLT and a HSE Management System Representative. Each member shall be requested to participate by members of the SLT and shall sign a letter that acknowledges the Charter of the Committee.

The HSE Committee meetings are held at least 4 times a year.

All HSE Committee meetings shall be undertaken in accordance with the Charter with an agenda prepared, minutes taken and any actions assigned clearly identifying the owner and due date for completion.

HSE sub-committees may be established to facilitate improvement initiatives in specific areas of risk.

2.2 Organization Charts The RCM organization chart describes the various levels of the organization.

The RCM organization chart and details of incumbents in the roles are available through the Business Solution – Rio Tinto Organization Chart and RCM Organization Chart. RCM Human Resources Department (HR) shall be accountable for contacting the service desk to update the organizational structure details as required.

2.3 Description of Roles and Responsibilities At RCM, responsibility is described as the undertaking of a task by specified personnel in accordance with prescribed processes.

The RCM Project Role Database lists the active and potential positions that may be required during the Project and provides a summary of those roles that have specific HSE responsibilities and those that only have general HSE responsibilities.

In general, RCM professionals and supervisors have specific HSE responsibilities. These responsibilities are documented in role descriptions.

RCM non professional roles, operators and administrative roles have general HSE responsibilities. These are communicated to all employees through the HSE Accountability and Responsibility Policy.

RCM shall develop and maintain role descriptions for all Supervisor roles. Each position shall have a basic description of the functions of his / her role and the associated role outputs.

Where particular Project activities have the potential for HSE impacts the employees or contactors shall be advised during the Level 1 risk assessment process.

Employees are informed of their HSE responsibilities during the RCM new hire induction and refresher courses.

2.3.1 Individual Accountabilities

At RCM accountability is described as the acknowledgement and assumption of responsibility for actions and decisions, including the administration, governance and implementation within the scope of the role and encompasses the obligation to report, explain and be answerable for the resulting consequences.




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All employees and contractors are accountable for the HSE consequences of their own actions and have a duty to carry out their work in a manner consistent with the HSE Policy, the requirements of the HSE Management System and legislative requirements.

2.3.2 HSE Management System Accountability

The SLT has appointed the Health & Safety Manager and Environmental Manager with the overall accountability for the adequacy, effectiveness, implementation and certification of the HSE Management System. Letters of appointment detail the responsibilities.

Accountability for the HSE Management System is important to ensure:

The HSE Management System is maintained in accordance with relevant standards and certifications

Performance against the system and standards is reported to management for review, including analysis of measuring and monitoring data and recommendations for continual improvement

Management plans contain designated responsibilities for achieving HSE objectives and targets at relevant levels of the organization. Targets and objectives are reviewed during the annual planning process and progress reviewed by the HSE Committee

The role of the HSE Management System Advisor is to provide support to the Management System Representatives.

2.3.3 HSE Committee Representatives

The role of the HSE Committee Representative is to provide advice and make recommendations to the senior management team in its oversight of the following:

HSE risks

RCM’s compliance with applicable legal and regulatory requirements associated with HSE matters

RCM’s HSE Management System implementation and performance to ensure the commitments made in the HSE Policy are being met and that HSE related risks are being assessed, eliminated, avoided or controlled

Reviewing objectives, targets and improvement plans for HSE performance and assessing progress toward achieving those targets

HSE Committee members shall also encourage employees and contractors in their work area to provide HSE suggestions for review at HSE Committee Meetings.

A Committee Charter has been developed for the HSE Committee and letters of appointment provided to the Committee representatives.

3 Training and Communication Employees and contractors shall be advised of their roles, accountabilities and authorities when they commence employment with RCM.

HSE accountabilities and responsibilities shall be communicated via:

HSE Accountability and Responsibilities Policy




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Role descriptions

Inductions (Project Site and Work Area as required)

Performance Reviews

Annual HSE Personal Improvement Plans

Level 1 risk assessments

All contractors shall be advised of their roles, accountabilities and authorities as required for the contract work during the Pre-Bid Meeting and Pre-Job Meeting via the Scope of Work; Safety, Health and Environmental Analysis (SHEA); HSE Performance Standards; and the contractor contract requirements.

Each Supervisor shall be responsible for ensuring that all direct reports have received the necessary training required to fulfill the requirements of the accountabilities of their roles. These requirements are identified through a ‘Training Needs Analysis’ and documented in a matrix. The requirements of the Training Needs Analysis matrix are communicated to all Supervisors.

All employees and contractors shall be advised by their Manager of any changes that occur to their role, accountabilities or authorities.

4 Monitoring and Review All Supervisor responsibilities shall be reviewed annually as part of the Performance Review process to ensure the requirements for each role are still appropriate and changes are made as required.

Staffing levels shall be reviewed by the SLT as part of the annual planning process to ensure legislative and corporate requirements may continue to be met.

5 Reporting No reporting is required for this Element.

6 Documentation and Records Copies of Role Descriptions shall be maintained by the HR Department.

Induction and training records shall be maintained by the HR Department.

7 Link to References and Related Documents RCM Organization Chart

RCM Project Role Database

HSE Accountability and Responsibility Policy

HSE Management System Representatives Letter of Appointment

HSE Committee Charter

HSE Committee Letters of Appointment

RCM Training Needs Analysis Matrix




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ELEMENT 6 TRAINING, COMPETENCY AND AWARENESS

1. Purpose To ensure processes are established to provide the requisite training, competency and awareness to effectively manage HSE risks.


2.1 Recruitment and Selection

2.1.1. General Positions

RCM shall utilize established standards governing the selection and recruitment of employees. Effective standards ensure that employees do not endanger themselves or their co-workers as a result of an inappropriate match with the requirements of the position. Selection and recruitment standards also help improve quality, efficiency and employee morale.

Selection criteria shall be developed prior to interviews for each position to be filled. These selection criteria include questions for each individual to answer in relation to his / her knowledge and skills, competence, personal capabilities, health and physical requirements and psychometric abilities as applies to the HSE aspects of the position to be filled.

The tools used to assist in the site recruitment and selection process are:

Pre-employment Medical Assessment – all external candidates shall undergo a medical assessment to ensure they are fit for the role and meet the requirements of the RCM medical criteria

Pre-employment Reference Checking – before hiring new employees, the HR Department or their representative shall check with former employers and/or associates to verify that the person has the skills for the role

The RCM recruitment process outlines all the steps / requirements for appointment of personnel to roles on site. The process is maintained by the HR Department.

2.1.2. Position Capability Requirements

Some RCM roles may have specific capability requirements that must be met. The recruiting team shall be responsible for ensuring the requirements needed for each occupation are included in the selection process. This capability analysis shall identify the core requirements of a position that may include physical demands that a job places on a person. This information shall be provided to the medical person conducting the physical examination.

The duties of the role shall be explained to the applicants during the recruitment process to ensure they are aware of the requirements and could fulfill them.

The RCM Project Role Database lists the active and potential positions that may be required during the Project and provides a summary of the HSE responsibilities and accountabilities. This database is referenced during the selection process and development of training requirements.




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Where particular RCM activities have the potential for HSE impacts the capabilities and competence of employees or contactors shall be determined during the Level 1 risk assessment process.

2.2 Categories of Training The areas of training include both general awareness and competency based.

Individual role classifications may include some or all of the following training categories:

General – This category includes all courses that are specifically required for all employees. Such courses may be required by Legislation, Standards or the Company and are often compulsory for specific positions eg inductions, risk assessment and HSE interactions

Department – This category includes recommended courses for all employees within a Department. Such courses are relevant to the occupation or a designated area

Role – This category includes the courses needed to provide individual managers and employees with the skills and knowledge applicable for their specific area and responsibilities eg role specific work skills and trade skills. Specific HSE training applies to this category.

Business training includes:

Rio Tinto business training such as The Way We Work and Careful Communications trainings

RCM and Departmental work skills such as Business Solution and DMS

Personal development such as negotiation skills

Career planning such as Rio Tinto Leadership Development Programs

General HSE training is provided for all personnel. It shall include, but not be limited to:

General induction training to Rio Tinto and RCM’s approach to managing HSE

Awareness of the Rio Tinto HSE performance standards via Employee Induction and HSE Meetings

Understanding of the Rio Tinto HSE management system processes implemented at RCM

Significant HSE risks, activities and controls via Visitor Induction, Employee Induction, New Miner and Refresher

Specific controls required for all activities undertaken by the role

Accountabilities of specific HSE roles and their responsibilities via Employee Induction

Consequences of departure from specified procedures or Rio Tinto standards

Emergency response procedures and the BRRP via Visitor Induction, Employee Induction, New Miner and Refresher

How to identify change

How to conduct HSE interactions

Competency based HSE training may include, but not be limited to:

Appropriate risk assessment processes such Level II risk assessment facilitator training

HSE training such as MSHA, Taproot or Rio Tinto Auditor training




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Role specific work skills/competencies such as electrician, equipment operator and HazWOPER

BRRP training as required for those with defined roles

Inspections, monitoring or maintenance activities where required by the role

Incident management and investigation required by the role such as emergency response and Taproot

Some specific operational controls such as required for the Water Treatment Plant

Work area specific training as specified by MSHA 5000-23

2.3 Planning and Scheduling of Training As part of the annual project planning process, representatives from every Department are able to identify additional training needs for the coming year and inform HR. Employee feedback is also reviewed. The courses shall be scheduled for delivery based on organizational and/or department needs, number of employee requests, course availability and other related factors. Employees shall be selected for courses based on their training needs and their Supervisors approval.

The Training Coordinator shall inform all personnel of the proposed training course schedule for the upcoming year through email, notice boards and via the Site Training Calendar.

Management of training is outlined in the RCM Training Plan.

2.4 Training Needs Analysis Review of training needs by each Department Manager and HR may include the identification of areas of training that are available for personal development which encompasses job-role competencies, succession planning and personal growth. The annual HR performance review system captures this process.

A training needs analysis (TNA) shall be completed for all role types. The TNA identifies the training that is required to ensure that the person in that role is competent to handle tasks to which he / she is assigned including normal, planned and unplanned duties or emergency situations.

Roles requiring compliance with legal obligation, for example licensing or certification, shall be identified and documented in the TNA.

The TNA is available to Managers and Supervisors to assist employees in developing their Personal Development Plan within the Business Solution.

2.5 Training Tools Formal and refresher training programs shall be conducted via any, or a combination, of the following:

Written lesson plans and materials

Task analysis and procedures

Visual aids and tests of knowledge

Online / computer-based modules




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Practical skills proficiency

Numerous training modules are available for use by teams and contractors. The RCM Training Plan contains a complete index.

Individuals who successfully complete programs may receive a certificate in recognition of achievement of a given competency level in their occupation. Records of completion are maintained in the Personnel Training Tracking Database or with the Health & Safety Department.

2.6 Competence

2.6.1 Training Assessment and Evaluation

All training programs shall have some form of assessment including on the job assessment to ensure the participants have understood the content of the program. Competence also includes education, skills and experience so these shall be considered part of the process of determining competence.

Where significant HSE risk exists for particular tasks, employees / contractors shall be assessed as competent before commencing such tasks without supervision. For example, the Water Treatment Plant operators must be assessed as competent after receiving the training.

Assessment shall only be performed by the appropriate competent person with the necessary skills who have themselves been assessed as being competent to assess others and, where required, accredited by a Registered Training Organization.

This assessment may be in the form of:

Verbal assessment

Written assessment

Practical assessment (off-the-job)

Performance assessment

On-the-job work assessment

General work observation

Recognized Prior Learning

Training and assessment materials shall also be regularly evaluated to ensure that they are meeting the objective of this element.

2.6.2 Technical Roles

Project roles that require technical certification, registration or licensing are listed in the TNA. Copies of certificates shall be retained within the work area and relevant certification and expiration dates communicated to HR for tracking to ensure currency of the competency.

2.6.3 Refresher Training

Employees and contractors shall receive refresher training when required to ensure they remain competent (dependent on mandatory recertification requirements and risk assessment recommendations).




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Dependant on the requirements of the course, such refresher training may involve both theory and practical components to ascertain competency.

Refresher training is specifically available for MSHA accreditations, First Aid, electrical and other regulatory requirements.

Individuals who change jobs or require a different application of their skills shall be retrained as necessary.

2.6.4 Instructor Qualifications

All training shall be conducted by personnel with appropriate skills and, where required, accreditation from a Registered Training Organization. Instructors shall be able to demonstrate formal training qualifications or have attended “Train the Trainer” or equivalent sessions in presentation skills. In addition instructors shall be selected based on their experience and expertise in the specific topics and their potential capability as trainers.

Trainees may give feedback on instructor effectiveness and competency upon completion of any training.

2.6.5 Training Plans and Approvals

Approval of all training required by roles shall be maintained as part of the Personal Development Plan in the Business Solution. Training plans are documented for the future year and completed training is reviewed and recorded.

All elective external training courses shall be approved by the Department Manager.

3. Training and Communication Implementation of training shall be supported by Department Managers and Supervisors to ensure that employees are allowed to undertake required training.

Contract Superintendents shall recommend and support specific training to be undertaken by contractors as detailed in Element 7 (Contractor Management).

Communication of training programs shall be through the standard communication channels outlined in Element 9 (Communication and Consultation) but generally include:

Email

Training Calendar on noticeboards

Management and Departmental meetings

4. Monitoring and Review

4.1. Tracking of Training HR maintains a Personnel Training Tracking Database.

Each Department Manager retains records for any task training that is required for the work area.

The H&S Manager retains a list of all MSHA 5000-23 training that is required.




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4.2. Performance Management System Annual performance reviews are conducted for all employees. The review identifies areas for improvement or individual development, and may be utilized to assess and monitor competencies that individuals have achieved. Records of training may be reviewed with HR.

4.3. Training Program Review Each individual training program or module shall be reviewed annually. Updates shall occur as a result of feedback on the training program and changes to training requirements.

Evaluation of feedback collected on the training program shall include the delivery of required training on the quality of training techniques and on the skills achieved.

5. Reporting Reporting of the completion of the Rio Tinto Compliance Training is undertaken annually.

6. Documentation and Records Records of training and assessment shall be maintained by HR for all employees.

RCM uses the Personnel Training Tracking Database as a repository for electronic training and assessment records. Records of assessment, showing the elements of competency against which assessment has occurred, are kept by the Health & Safety Department in hardcopy form.

MSHA audits relevant training records during their inspections as well as following any incident.

7. Link to References and Related Documents Training Needs Analysis Matrix

RCM Personnel Training Tracking Database

RCM Training Plan

Training Feedback Form

RCM Training Calendar

RCM Training Modules

Business Solution Personal Development Plan




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ELEMENT 7 SUPPLIER AND CONTRACTOR MANAGEMENT

0. Purpose To ensure products and services undertaken by RCM are effectively managed for HSE risks and other stated requirements such as legal compliance.

1. Description of Process RCM recognizes that all employees and contractors have a responsibility to assist in management of HSE issues. This is communicated upon employment, reflected in role descriptions and contained in service agreements.

An evaluation process is undertaken when sourcing and procuring equipment and materials to assess any potential HSE risks to the Project.

The sourcing and management of contractors is undertaken in accordance with the RCM Contractor Management System.

A list of approved suppliers and contractors is documented in a procurement database known as BROWZ.

A Chemical Inventory Register and MaxCom Database are maintained by the HSE Department.

2.1 Evaluation The following systems ensure that the procurement of materials, equipment, services and labor to be used at or by RCM do not cause an unacceptable HSE risk to the Project:

RCM Contractor Evaluation template, pre-qualification process and Browz Register

RCM Contractor Management System

The RCM Contactor Evaluation template is based on the Rio Tinto Procurement (RTP) 5 Phase Strategic Sourcing Process. Assessments are as per the RTP Evaluation Criteria Template. Evaluation Criteria are grouped under “Technical”, “Commercial”, “Contractor Capability”, and “Health, Safety & Environment”. The template is populated prior to a tender being floated with input from end users, HSE and RTP.

The RCM Contractor Management System describes the processes for:

Pre-qualification

Pre-mobilization

Mobilization

Contractor Performance Monitoring

Contractor Performance Evaluation

The RCM Contractor Management System is based upon the requirements in the Rio Tinto Contractor Management Work Cycle as well as Rio Tinto’s The Way We Work and The Way We Buy.

At this point in time RCM is not producing a product therefore the downstream implications of purchasing materials or equipment are not applicable.




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2.2 Procurement Principles Goods and services are procured in accordance with the Rio Tinto Group Procurement Policy document as well as RTP’s 5 Phase Strategic Sourcing Process. The Rio Tinto Business Solution provides the procurement systems.

Goods and services provided under the purchase / service order system are all supplied in accordance with Rio Tinto’s purchase / service order terms and conditions.

Goods and services supplied under the contract system are all supplied in accordance with Rio Tinto’s contracting terms and conditions.

Contractors are managed through the RCM Contractor Management System.

2.3 Equipment and Materials

2.3.1 Purchasing Requirements

Purchasing is undertaken in accordance with the RTP 5 Phase Strategic Sourcing Process to ensure products or services procured to the Project meet specified HSE requirements.

2.3.2 Hazardous Materials

Before any type of chemical or dangerous good may be used at the Project by an employee or contractor the RCM Chemical Product Approval Request form shall be completed and reviewed by the HSE representatives.

This form requires the following aspects to be assessed:

What is the need for a new or an alternative chemical?

Is an MOC required?

What are the MSDS details such as the hazards and disposal requirements?

HSE representatives shall then determine if the product is approved or disapproved for site use. If approved the order may be placed. The MSDS shall accompany any delivery of chemical or dangerous good.

The details of the material shall be entered into the Chemical Inventory Register and MaxCom Database.

MaxCom is available to all employees and contractors at http://www.maxcomonline.com, which is also accessible via a link on the RCM Prospect page.

2.3.3 Delivery, Storage and Disposal Requirements

All items are delivered to the West or East Plant Security Gate prior to distribution to the relevant storage area. Due to the current stage of the Project there is no warehouse facility. Goods are stored by the relevant department in appropriate storage facilities. Storage facilities are inspected as part of regular area inspections.

Disposal of surplus, used materials, chemicals, equipment and hazardous waste is undertaken by approved, licensed contractors.




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2.4 Supply of Labor The process for the management of contractors is described in the RCM Contractor Management System and includes the following phases:

Development of contract scope

Risk assessment

Contractor selection

Contractor preparation

Contractor award

Orientation and training

Mobilization and equipment inspection

Managing contractors

Post-evaluation

2.4.1 Contractor Categorization

Contractors are categorized as per the Rio Tinto Contractor Management work cycle WCMS0701.

Contractors are defined as follows:

Category 1 – Individuals on temporary contracts working within existing operations

Category 2 – Companies engaged for a discrete project

Category 3 – Companies or individuals engaged under contract to carry out specific tasks or provide specified services within existing operations areas.

2.4.2 Contractor Risk Assessment

An assessment of the risks is conducted for each Scope of Work using the Safety Health and Environment Analysis (SHEA) form. This completed document is provided to contractors at the pre-bid meeting. The contractors then develop their Safety, Health and Environmental Action Plan (SHEAP) which is reviewed by HSE representatives and the designated manager to ensure it is complete. The SHEAP is used as an evaluation tool for contractor selection and award.

Once the bid is awarded, the successful contactor, designated manager and HSE representatives complete a Level 1.5 task-based risk assessment of the work to be completed by the contractor. Following the risk assessment, the contractor is required to develop a comprehensive HSE Engagement Plan for the Scope of Work.

2.4.3 Accountabilities

A RCM employee shall be assigned as Designated Manager for every contractor. This individual is accountable for ensuring a contractor’s HSE performance is acceptable with regard to the work to be undertaken as part of a contract and ensuring the effectiveness of a contractor’s HSE system and processes in relation to the scope of work and responsible for the task/activity the contractor will perform.




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The designated manager shall develop the contractor’s HSE Engagement Plan and ensure it is implemented.

All work involving more than one person shall have full-time contractor supervision. This may vary from a lead person for minor, localized work to dedicated, full time supervision for larger, more complex or distributed work. Visitors may not “work” at any time.

All work performed by contractors on site shall have appropriate authorization / permits and documents including but not limited to:

Permits to Work (Induction, Hot Work, Confined Space, Working at Heights, etc)

JHA risk assessment

Incident Reporting / Investigation

Change Management

Tool inspection and pre-start checks

These documents shall be accessible to all working on the job.

2.4.4 Contractor Training

Prior to commencement of work, the designated manager shall verify that all regulatory required training is completed and training certificates are available for inspection. The designated manager shall verify that the contractor has undertaken a documented training needs analysis for its employees to determine which training each role will need. Where one has not been completed, the designated manager, with assistance from HSE representatives, shall create a training needs matrix on their behalf. The designated manager shall arrange for all contractors to attend RCM Contractor HSE Induction which includes a RCM orientation, overview of HSE risks and controls, emergency procedures and an introduction to site and Rio Tinto HSE Management System and Performance Standards. Additionally, the designated manager shall arrange for leaders from the contractor’s team to attend a HSE Leadership Workshop, organized and facilitated by HSE representatives. Evidence of induction and workshops shall be documented and made available upon request.

2.4.5 Contractor Tools and Equipment

Tools and equipment used by contractors are identified during the Pre-Mobilization process, and are ensured to be in a safe condition. Pre-Mobilization inspections are generally conducted by a third party evaluator using a prescribed checklist. Records are maintained by and available for inspection with the designated manager.

2. Training and Communication Requirements for purchasing and contractor management are included in the RCM Contractor HSE Induction.

Designated Managers shall undertake specific contractor management training.

Business Solution training is available for all employees who are required to enter purchase requisitions.




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3. Monitoring and Review

4.1 Suppliers Suppliers are pre-qualified and required to enter the BROWZ system. HSE representatives conduct a monthly status review and provide a feedback report to the designated manager or responsible person. The contract owner or responsible person verifies the ongoing qualification of the supplier or works with them to ensure they recover from any identified deficiencies.

4.2 Contractors Contractors are pre-qualified and required to register into the BROWZ system. BROWZ provides a monthly report indicating whether or not the contractor has maintained minimum qualification requirements. HSE representatives conduct a monthly contractor status review and provide a feedback report to the designated manager. Designated managers verify the ongoing qualification of the contractor or works with them to ensure they recover from identified deficiencies.

4. Reporting Contractors provide a monthly scorecard to RCM indicating leading and lagging indicators. Contractors provide legal reporting as required by local, state and federal regulations.

5. Documentation and Records Records relevant to the approved RCM supplier and contractors are maintained by RCM Procurement and the HSE Departments.

Current controlled copies of documents required to be used by contractors are to be obtained from their designated manager and are linked to the RCM HSE Prospect page and on the contractor portion of the external RCM website. Refer to Element 8.

6. Link to References and Related Documents RCM Contractor Management System

RTP 5 Phase Strategic Sourcing Process

RCM Contractor Evaluation Template

List of Approved Suppliers and Contractors

Chemical Inventory Register

MaxCom Database

Chemical Request Form

SHEA Form

SHEAP Template

Permit to Work Forms




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JHA Risk Assessment




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ELEMENT 8 DOCUMENTATION AND DOCUMENT CONTROL

1. Purpose To develop, implement and maintain a documented system of manuals and procedures required for the effective operation of the management system.


2.1. HSE Documentation HSE documentation is required for:

Operational activities assessed to contain significant HSE risks/impacts (the procedures and/or work instructions shall include operating criteria)

Ensuring HSE policy, objectives, targets and requirements are met (where their absence could otherwise cause deviations)

The maintenance, inspection, testing and modification of plant and equipment (that has the potential to impact on HSE performance) to ensure that it meets the design description and specification

Addressing risks in the Rio Tinto HSE Performance Standards to ensure they are identified and controlled in accordance with these standards

Addressing appropriate permit, license, regulatory, and /or legal requirements to ensure their compliance

Revision of drawings, operating procedures and work instructions, and maintenance and emergency procedures impacted by any change process

Planning, developing, controlling and training in relevant operational. procedures and or work instructions

Documents are broadly defined as those types of documentation that have the ability to change over time. Examples include procedures, management plans, templates, forms, etc.

Records are broadly defined as those forms of documentation that contain specific information at that point in time. Examples include monitoring results, meeting minutes, completed incident reports, registers, matrices, checklists and check sheets, completed forms, audit reports, etc.




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RCM HSE Documents

Description

Policy Describes the intent of RCM for the effective management of HSE and how the Company shall protect its employees, contractors and the environment in which they work.

Strategy Describes the methodology used to accomplish an objective or target as prescribed by a policy. It is a high-level approach to an issue that is designed to deliver change by implementing policy.

Rio Tinto HSE

Performance

Standards

Describe the minimum requirements for particular hazards. RCM complies with the requirement of those Standards.

Standards set the measure for the way work is to be undertaken. Standards complement policies. Standards provide the minimum requirements towards attaining policies.

Rio Tinto HSE Work

Cycles

Provide a second level of mandated detailed requirements expanding upon the requirements of a standard and provide detailed process steps on how the requirements are achieved or met. The work cycle is integral to the Rio Tinto HSEQ risk framework and covers the core steps within the process.

Rio Tinto HSE Work

Practices

Provide a sequence of structured requirements of process activities within the work cycle. Work practices relate to the Rio Tinto Business Solution processes.

HSE Manage

ment System Procedu

res Manual

Describes what RCM does to comply with the minimum Rio Tinto HSEQ Management System requirements as well as any specific legislative requirements.

There are 17 System Procedures to cover each of the 17 elements of the HSE Management System http://calbbayproxy/Intranet/default.asp?s=HSEQ%20Management%20System&t=2524&p=0&type=menu&navst=1

HSE Manage

ment System Procedu

res

Provides additional procedures for those Elements that are more complicated and therefore require more detailed explanation on the processes to be undertaken.

HSE Perform

ance Standar

d Procedu

res

Describe how RCM complies with the minimum requirements of the Rio Tinto HSE Performance Standards.http://calbbayproxy/Intranet/default.asp?s=HSEQ%20Management%20System&t=2524&p=0&type=menu&navst=1

Registers,

Databases and

Provide formats to collect information and organize it so that it may be easily accessed, managed, and updated They are generally a spreadsheet or table for information including hazards, risk assessments, complaints, equipment or chemicals.




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RCM HSE Documents

Description

Matrices

Management

Plans

Where required address specific Rio Tinto and RCM aspects. A Management Plan is an operational guide that sets out current and projected performance, planned activities and planned achievements and outcomes over a given period of time.

A Management Plan can be developed to cover any aspects of the environment. Rio Tinto has 9 Environmental Performance Standards of which 6 specifically require Management Plans.

Manuals Describe a document that collates information such as policies and procedures pertaining to a particular area.

Guide, Guidelin

e and Guidance Note

Provides general information on recommended practice that allows some discretion or leeway in its interpretation, implementation, or use.

Monitoring

Programs

Describes a planned sequence and combination of activities designed to achieve specified goals. A Monitoring Program normally includes location (of monitoring), frequency (of monitoring), details of equipment and materials required and responsibilities

Application

Forms and

Permits

Where required provide strict controls of specific high-risk activities are required including hot work, operation of vehicles, excavations, etc as detailed in relevant Performance Standard Procedures.

A Form is a document that allows users to input and submit data, such as applying for approval for a new chemical. A form is usually paper based.

Checklist and

Check Sheet

A Checklist is a comprehensive list of important or relevant actions, or steps to be taken in a specific order. It may be a list of items to be noted, checked or remembered.

A Check Sheet relates to quality and is a simple data recording device, custom designed to enable a user to readily interpret the results of an activity or process. One of the seven tools of quality, it presents a sequence of steps or events that is marked off (checked off) by the user, in a specific order or as the anticipated events occur.

Templates

Describes documents created to be utilized in the creation of the documents for the HSE Management System that include the unique identifiers required.

2.2. Document Creation Requirements All documents shall be created in the appropriate version of the RCM HSE templates. These templates display on each page the HSE Management System and company logo, the type of document and title of the document, the page number, approving manager and effective date. The templates, created for Microsoft applications also have basic formatting and headings to guide the initiator in completion of the document.




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2.2.1. HSE Numbering and Naming Convention

RCM HSE documents and records shall be assigned the appropriate name that applies to the type of document that shall be used in the header of the document. The RCM Document Management System (DMS) has a naming convention that applies to document management criteria. See HSE Management System Element 8 Procedure.

2.2.2. Document Revision

Document initiations and revisions shall be reflected in DMS and on the document. It is a requirement to complete the Revision Table at the initiation of a document and all subsequent major revisions. The document templates to be used for documents under the RCM HSE Management System are available on the RCM HSE Prospect page.

2.3. Document Approval Process Only documents required to be controlled as a requirement of the HSE Management System shall be reviewed using the following process:




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HSE Document Approval Workflow

2.4. Controlled Documents Only HSE documents accessed via DMS and the RCM HSE Prospect page are considered valid, controlled and current by the HSE Management System. These are the only approved locations with the current version of the controlled document.

All documents that are required to be controlled have the following statement in the footer of the templates “Controlled Document – Check with HSE for Current Version”.

3. Training and Communication New or revised procedures that undergo a major revision require the initiation of the Management of Change (MOC) process, in order to notify Supervisors whose employees or contractors may be affected. After MOC approval is obtained, the procedure shall be formally communicated to employees and contractors as needed by email with a link to the document in DMS.

New procedures or those with significant changes may require formal competency-based training and assessment. New procedures or those with significant changes may require compliance auditing.

4. Monitoring and Review The review periods are entered into the HSE Document Register by the HSE Management System Advisor and into the document metadata in DMS by the document importer. The HSE Management System Advisor shall notify the HSE Management System Representatives when a document is due for review.

The official review periods are as follows:

HSE Management System Documents

Every two years, beginning from the effective date, noted in the document header

HSE Management Plans

Every four years, beginning from the effective date, noted in the document header

HSE Registers None, as these documents are updated on a continual basis

5. Reporting No reporting is required for this Element.

6. Documentation and Records All HSE documents that are required by the Management System shall reside in DMS.

All HSE documents shall be accessible, legible (with a clear document title), readily identifiable.

The HSE Management System Advisor shall ensure that HSE documents required for the operation of the HSE Management System are current and final versions are stored in DMS.

Document Initiator

HSE Management System Advisor and Element / PS

Champion Validation

SLT Approval, if needed

HSE Management System Representative

Approval

HSE Document Register

Document Importer into DMS




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All controlled HSE documents shall be archived and retained as per the RCM HSE Management System Procedure E15 Records.

Obsolete documents shall be removed from all points of issue and use.

7. Link to References and Related Documents HSE Management System Procedure E08

HSE Management System Procedure E15

HSE Management System Procedure Template

Health Performance Standard Procedure Template

Safety Performance Standard Procedure Template

Environmental Performance Standard Procedure Template




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ELEMENT 9 COMMUNICATION AND CONSULTATION

1. Purpose To describe the process of how RCM ensures and facilitates the involvement and participation of all employees, contractors, customers and relevant stakeholders in the management of HSE issues.

2. Description of Process At this stage of the Project RCM shall communicate the management and performance of its significant HSE risks for current and planned activities to external parties through RCM’s public website and S&E Report.

RCM does not currently produce a product so no communication occurs in relation to product risks.

Communication is exchanging (giving and receiving) information. Communication is dialogue between a business, its employees and its neighbouring community and other stakeholders. It enables a business or site to learn about its employees, local community and other stakeholders.

Consultation is purposeful and deliberately seeks input from stakeholders in order to shape decisions, relations and the development of programs. Consultation involves the business or site, key individuals, organizations and groups affected by or interested in the development and outcomes of the activity/process being discussed.

2.1. Internal Communication Information on the RCM HSE Management System shall be provided to all employees, contractors and visitors that access the RCM property. This information shall include:

The RCM HSE Policy

RCM’s significant HSE risks

How to initiate emergency response

How to report an incident

RCM’s HSE performance as displayed at the West Plant security gate that is updated daily

In addition employees and contractors shall be provided with information through training, awareness sessions or other various communication methods on:

The key components of the HSE Management System

How they can contribute to HSE management and continual improvement in HSE performance

The specific operational processes, procedures and permits in their work area and for the activities they undertake

The legislation that applies to their work area and work and their own responsibilities

The risks in their work area and related to their work and the associated controls

How and when to conduct a Level 1 and 2 risk assessment

What objectives and targets are established in their work area




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How they can contribute to RCM’s HSE performance and have objectives and targets that are complimentary to RCM’s business plan

That contractors shall follow the same rules as employees

What documents they shall complete and how they are managed

Who their HSE representative is

How to submit HSE suggestions

What is classified as a change and how to initiate an assessment of change

What inspections and monitoring activities are to be undertaken in their work area

What to do if they are audited

Internal communication to staff and contractors shall use the most appropriate method for the situation. There are a variety of processes available including HSE Meetings, Pre-shift meetings, Notice boards, HSE Alerts, emails, team Supervisor/team member discussions, and “RCM Drill Bits”.

Employees shall be consulted as appropriate on HSE plans, objectives and targets, changes and modifications, introduction of PPE and any other matter which directly affects their Health, Safety and the Environment.

The major internal communication method within RCM for HSE issues is the RCM HSE Prospect page. Employees can access relevant information and data from the page including:

HSE Policy

RCM HSE Procedures and legal requirements

HSE Permits and Forms

HSE Management System Internal Communication Register provides a summary of the Internal Communication tools at RCM.

The HSE Management System Internal Communication Register includes the following details:

Communication mechanism

Description of communication

Communication accountability

Intended audience

Recommended communication frequency

Communication documentation

The HSE Management System Internal Communication Register is reviewed annually to ensure all communication mechanisms are valid and in use.

The HSE Management System Internal Communication Register is available on the RCM HSE Prospect page.

2.1.1. Pre Shift Meetings

Supervisors shall conduct pre-shift meetings with the purpose to:




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Reflect previous shift safety performance

Share safety information

Share status of work

2.1.2. Noticeboards

RCM has notice boards located near each main work area that display HSE information which may include:

RCM HSE Policy

Significant Incidents

Status of objectives and targets and annual improvement plans

HSE Committee contacts

Specific HSE information

2.1.3. Recordable Injuries and Significant Incidents

HSE Alerts shall be prepared on significant HSE incidents and distributed to all employees and contractors.

HSE Alerts are emailed to all employees as soon as the incident information has been received and reviewed. The incident information is supplied by the HSE representatives and the Safety Coordinator creates and distributes the form.

Contractors are emailed a pdf of the HSE Alert so that it may be communicated to their employees at pre-shift meetings.

Each Department Manager shall ensure that relevant HSE Incidents are communicated to all employees and contractors.

2.1.4. Health, Safety and Environment Meetings

All Departments shall hold regular HSE Meetings where information on HSE management and performance is provided to employees and contractors. Information includes leading and lagging indicators of HSE performance.

The following regular HSE meetings are held:

West Plant

Contractor Management Meetings

Geology Team

Study Team

Maintenance Team

Water Treatment Plant Team

Shaft Development Team

H & S Team

Environmental Team




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A HSE Committee has been established to support the SLT in developing and overseeing HSE initiatives and improvement ideas. Refer Element 5 for details on HSE Committee responsibilities.

Contact details for the current HSE Committee members shall be available on notice boards. Employees and contractors are encouraged to provide HSE suggestions to the HSE Committee representatives.

2.1.5. Employee Participation

In order to promote improvements in HSE employees are encouraged to participate in activities including:

Hazard identification, risk analysis and determination of controls

Incident reporting, which also allows suggestions to be submitted

Incident investigation

Providing feedback on the HSE Management System

Improvement programs

Project awards and milestones

Emergency Rescue Team participation

Involvement in working groups to review site processes

Visits to other mine sites

Further HSE training

Special projects

All employees and contractors have the opportunity to provide suggestions at any time including:

During team meetings or on the job

During a routine job or activity

During maintenance work

If prompted by supervisors

Supervisory staff shall actively seek suggestions when speaking to the workers, including during team meetings and one-on-one discussions.

Suggestions may be logged in the Rio Tinto Business Solution.

All suggestions shall be reviewed and either implemented or discarded. The outcome shall be recorded in the Business Solution and feedback provided to the employee.

2.2. External Communication The method of External Communication on HSE issues depends on the nature of the issue.

RCM has a deliberate and strategic approach to community engagement that is focused on the Land Exchange legislation which includes Community Forums. The Rio Tinto Communities Standard sets out the requirements for this consultation process.

HSE information shall be communicated external to RCM as appropriate including:




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Details of recordable diseases, recordable injuries, significant HSE Incidents

Executive Committee report

Sustainable Development Report

The Community Relations Team is responsible for all external communications, including community complaints. Refer RCM Community Observations Work Instruction.

No employee shall comment to the Media on RCM related business.

Community Relations shall maintain a database of interested parties (stakeholders) including those with environmental interests.

The Environmental Manager in co-ordination with the Communications Manager shall ensure routine external communication (formal or informal) of environmental issues.

All data provided for publications on RCM for external distribution shall be reviewed by the appropriate HSE representatives and the SLT.

RCM shall actively communicate relevant local activities to employees and contractors and participate where appropriate.

The HSE Management System External Communications Register and the Multi-Year Communities Plan provide a summary of the external communication methods undertaken by RCM.

The HSE Management System External Communication Register includes the following details:

Communication mechanism

Description of communication

Communication accountability

Intended audience

Recommended communication frequency

Communication documentation

The HSE Management System External Communication Register is reviewed annually to ensure all communication mechanisms are valid and in use.

The HSE Management System External Communication Register is available on the RCM HSE Prospect page.

2.3. External Complaints In the event that a stakeholder has a concern or complaint relating to RCM’s activities the details shall be recorded as described in the RCM HSE Management System E09 Procedure – Recording Stakeholder Concerns.

2.4. Emergency Communication Guidelines for communication with emergency services and the public are detailed in the site Emergency Response Plan and site Business Resilience and Recovery Plan.

Mechanisms of emergency communication available at RCM include:




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Two way radios

Mobile and Satellite Phones

Alarms / Loud speaker

Area Wardens or Person to Person

Media – local radio, TV etc

3. Training and Communication The promotion of continual improvement in HSE performance is facilitated within the workplace through a continual awareness process. This is comprised of but is not limited to:

Newsletters

Provision of health and safety

Regular promotional activities

Health and Wellness initiatives

Mechanisms of receiving communication include:

Electronic eg: email, internet

External and internal training

Industry forums

Postal mail

Industry journals

4. Monitoring and Review The effectiveness of internal and external communication processes is evaluated through feedback received from surveys, meetings and HSE interactions.

Surveys, community meetings, receipt of community concerns and complaints are a mechanism by which RCM may monitor the success of communication and consultation processes.

Feedback forms are provided at all community forums. A Complaints Register is maintained by Community Relations in the Superior Office.

5. Reporting Details on the HSE information that is communicated to stakeholders is contained in HSE Management System External Communication Register. For internal stakeholders this includes S&E reporting data, for external stakeholders this includes Sustainable Development reporting and government reporting.

6. Documentation and Records Records of all communications are retained by Community Relations.




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The Community and Stakeholder Engagement Tracking System (CSETS) Database shall be utilized to record all external communications. This database is being implemented and shall provide a repository for all planned and actual meetings with any external stakeholder.

Emails may be sent to CSETS to automatically record meeting dates, notes from meetings and actions required.

Community concerns and complaints are recorded in a Register located at the Superior Office until the CSETS is implemented. Records of the communication or complaint include, where possible:

Name, address and contact telephone number of the complainant

Nature of concern or complaint

Details of the concern or complaint

Date and time that the concern or complaint was received

Time of the event that led to the concern or complaint

Method by which the concern or complaint was lodged (eg. phone / personal / email / fax/ letter)

Assurances given/action taken

Any relevant conditions at the time of the concern or complaint (eg. weather conditions)

Where minutes are required they shall be securely filed and if appropriate, published on the intranet. Minutes should be approved by the person accountable for chairing the meeting and shall be kept available for auditing purposes. At a minimum, minutes shall contain the following:

The date of the meeting

Those present

Topics raised

Actions agreed upon with name of person to perform action and expected completion date

7. Link to References and Related Documents Rio Tinto Communities Standard

RCM Community Observations Work Instruction

RCM Noticeboards Register

HSE Management System Internal Communications Register

HSE Management System External Communications Register

RCM Multi-Year Communities Plan

RCM HSE Management System Procedure E09 – Recording Stakeholder Concerns

Emergency Response Plan

Business Resilience and Recovery Plan




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Community Feedback form

Complaints Register

Community and Stakeholder Engagement Tracking System Database




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ELEMENT 10 OPERATIONAL CONTROL

1. Purpose The purpose of this system procedure is to:

Ensure potential hazards associated with RCM are identified and controlled.

Ensure RCM develops, implements and maintains controls that address hazardous tasks of significant risk.

Develop procedures for the activities and equipment with potentially significant HSE hazards to prevent potential deviations.

Provide processes for maintenance of plant and equipment that have the potential to impact HSE performance.


2.1. Identification of HSE Hazards RCM conducts risk assessments, as defined in Element 3, for all the early works undertaken for the Project to define those activities that shall be controlled in order to reduce or eliminate associated HSE hazards.

All the Rio Tinto HSE Performance Standards and HSEQ Management System Elements shall be implemented at RCM unless a variance or non implementation request has been submitted and approved. All current variances and non implementations are documented in SEART.

2.2. Types of Controls Controls shall be implemented to manage HSE hazards. A control is the activity of managing or exerting control over something. Controls may be placed at the source (where the hazard "comes from"); along the path (where the hazard "travels"), at the worker (last line of protection) and after the event or incident (to reduce/mitigate the consequences).

Preventive controls are controls that prevent an event from occurring while mitigative controls are controls that reduce or mitigate the harm from an event after it has occurred.

The general hierarchy of control is:

1. Eliminate the hazard.

2. Substitute the hazard.

3. Isolate the hazard.

4. Control the hazard by engineering means such as constructed design, passive design, active design or engineered protection such as warning devices.

5. Control the hazard by administrative means.

Types of Engineering Controls




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Type of Engineered

Control Examples for Environmental Engineered Controls

Design Controls

Engineered designs by competent personnel that contain detailed maintenance and inspection regimes.

Passive Controls

Walls, fences, barricades, dust guards, sprinkler systems, lightning rods, ground fault circuit interrupters, and pressure relief valves etc.

Active Controls

Manual shut downs systems, emergency stop buttons and chords, temporary barricading. (PPE controls are not as appropriate for environmental hazards)

Warning Devices

Alarms, sirens, flashing / strobe lights, air quality monitors, color coding, signs,

Administrative Controls

Procedures, work permits, policies, guidelines, training manuals, registers, operating manuals, all types of skills training, pre-start checklists, risk assessments, PPE

The main non engineered mitigative control methods used by RCM are:

Management System documents

Maintenance, Housekeeping, Inspections and Monitoring

Purchasing and Contract controls

Communication, Training and Reporting

Summary of RCM Controls:

Type of Control

Description Further Information

Management System Documents

RCM uses the following HSE Management System documents as controls:

Policies

Procedures and Work Instructions

Forms and Permits

Checklists and Check Sheets

Definitions of these documents are provided in Element 8.

Housekeeping All work areas have minimum standards for housekeeping. Further details are contained in Element 13.

Maintenance Plant and equipment shall be maintained, inspected and tested to ensure it meets design descriptions and specifications. A register of all equipment requiring maintenance, inspection or testing is contained in the Rio Tinto Business Solution and provides information on:

Equipment identification

Information of all activities undertaken

Identification of statutory requirements

Identification of critical equipment The system is managed and maintained by the Maintenance Department.

Further details are contained in Element 13.

Inspections All plant and equipment operated on site shall be subjected to an Further details are




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Type of Control

Description Further Information

inspection, testing and maintenance program to ensure the integrity of the plant and equipment over the lifecycle of the processes, plant and equipment.

contained in Element 13.

Monitoring Environmental and health monitoring is undertaken Further details are contained in Element 13.

Purchasing and Contract Controls

New products and services shall be assessed prior to their purchase to ensure they are safe and environmentally acceptable to the Project. All equipment or services provided by third parties, shall be inspected, and have the controls verified to ensure the safe operation and adherence to health, safety, environment performance objectives

Purchasing and contractor management HSE requirements are detailed in Element 7.

2.3. Procedure and Work Instruction Development Procedures and/or work instructions have been developed for the operation and maintenance of plant and equipment that have a potential to impact HSE performance (as defined through risk and criticality analysis).

The plant and equipment that RCM has identified as requiring procedures or work instructions during this stage of the Project are:

Plant/Equipment Area for Potential Significant Impact

Controls

Water Treatment Plant

Environment – water quality Maintenance; Inspections; Procedures

Shaft construction equipment

Safety - working at heights Maintenance; Inspections; Procedures

Batch Plant Safety Health - noise

Maintenance; Inspections; Procedures

Drilling equipment Environment - water quality Safety – hand injuries

Maintenance; Inspections; Procedures

Project construction works

Safety Procedures; Inspections

These documents are developed and controlled as set out in Element 8 of the RCM HSE Management System Procedures Manual.

Documentation has also been developed that addresses control measures for the Rio Tinto HSE Performance Standards. These documents are listed in the RCM HSE Roadmaps.

2.3.1. Original Equipment Manufacturer Documentation

When equipment has been bought, original equipment manufacturers’ documentation shall be retained to ensure adequate operation and maintenance of the equipment.

Risk assessments shall be conducted on new equipment prior to purchase and involve persons with adequate knowledge of the equipment and site usage.




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3. Training and Communication The RCM Induction and Site Specific Task Training include details on the plant and equipment that have a potential to impact HSE performance (as defined through risk and criticality analysis). RCM employees are issued a MSHA 5000-23 for undergoing Site Specific Task Training. Visitors are issued a Site Hazard Recognition Certification for undergoing RCM Site Induction.

Where specific procedures and work instructions are required these are communicated as part of the JHA undertaken.

The RCM HSE Prospect page and Employee and Contractor HSE Booklet contain information on the procedures and work instructions that are required to be followed.

4. Monitoring and Review All operational controls shall be verified periodically to review their effectiveness.

RCM performs a variety of risk reviews, inspections and audits to ensure operational controls are verified. Details are outlined in Elements 13 and 16.

5. Reporting Requirements for reporting on operational controls are detailed in Element 13.

6. Documentation and Records HSE Management System documentation requirements for addressing significant HSE risks are outlined in Element 8. The list includes documentation requirements relating to:

Permit, license, regulatory, and/or legal requirements compliance

Maintenance activities (including drawings, inspections, plant and equipment modification)

Critical process(es), plant, equipment and services and product specifications.

7. Link to References and Related Documents RCM Safety Standard Procedures

RCM Health Standard Procedures

RCM Environmental Standard Procedures

RCM Induction

RCM Site Specific Task Training

MSHA 5000 – 23 Forms

RCM HSE Roadmaps

SEART




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ELEMENT 11 MANAGEMENT OF CHANGE

1. Purpose To manage proposed changes to business processes in a manner that does not give rise to an unacceptable risk of:

Injury or illness to people

Damage to the environment or physical assets

Disruption to the organization and operation of the business

Loss of reputation, community concern or other adverse impact on relevant stakeholders


2.1. Defining and Identifying Change Changes are identified and assessed to determine if they shall be subjected to the change management process. Change does not occur when variations to plant, equipment, processes and people are within designed or agreed boundaries / tolerances. This includes normal repairs or other activities to restore original functionality.

The RCM HSE Management System Procedure E11 - Management of Change (MOC) – Process / Physical lists all classes of change that shall be subjected to the complete change management process.

Change management shall be applied to planned or unplanned, sudden or gradual, temporary or permanent changes.

2.2. Change Management Systems RCM has a number of systems for managing specific changes including:

Project purchases that are managed through the Approval for Expenditure (AFE) process. The AFE process includes a requirement for the HSE risks to be assessed by competent persons and reviewed by HSE. A formal Post Implementation Review (PIR) process is undertaken for items assessed as high risk.

Project management tools including Pre-Feasibility Study (PFS) processes and Engineering Drawing Approval System

Minor changes raised at pre-shift meetings may be managed through the use of “Take 5” and discussion at pre-shift and safety meetings. Supervisors and HSE Professionals leading these meetings shall be aware of the need to initiate the full change management process when the risk assessed is greater than “low” on the Rio Tinto HSE 5 x 5 Risk Matrix.

Changes of plant or equipment, operating or maintenance procedures, site layout, mine planning, start-up of a new facility or the handover of responsibility from a contractor to RCM are examples requiring the MOC process and use of the Process or Physical Change MOC Form. All these types of changes are initiated, approved and tracked.




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The assessors of changes that are processed through the above systems shall be aware of the need to consult with potentially affected parties and/or initiate a change request in the formal change management process as outlined below.

2.3. Creating and Recording Change Management Requests Where the assessment has determined that the change is subject to the change management process, the proposed change shall be described in detail on the relevant MOC form.

2.4. Assessing Change Requests Change requests shall:

Be evaluated by "Technical Assessors" selected on the class of the change and its likely impacts. The HSE Management System Procedure E11 – MOC – Process / Physical lists the roles required for Technical Assessment based on the class of the change.

Involve the workforce or representatives of the workforce impacted by the change.

Technical Assessors shall consider the items listed on the MOC form, which includes the following:

The risks and hazards associated with the change

The hierarchy of control mechanisms to eliminate or minimize the risk

The standards to be used and controls to be required

Further studies to be carried out

Legal and other requirements i.e. compliance with respect to legal, statutory, license and permitting obligations.

Significant changes (i.e. those ranked with a potential impact of high or critical) and Organizational Changes are reviewed at the SLT meetings and may be reviewed at HSE Committee meetings.

2.5. Authorizing Change Requests After assessment of the change, the relevant RCM Departments shall be notified of the change by the Outlook email system that includes a process for documenting acknowledgement and approval by the recipients. In addition all completed MOC forms shall be routed to the Safety Coordinator to ensure proper recording of documentation and completion of a post implementation review (PIR).

As a minimum the Rio Tinto HSEQ Management System Standard requires an approval of the change by at least the same level of authority as those who control the existing process or item being changed.

In emergency change situations the most senior manager at RCM who is accountable for the managed activity shall approve the change.

2.6. Implementing Change Requests Following approval the change shall be implemented as outlined in the MOC document. The MOC shall detail any essential training required prior to implementation.




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For changes that involve engineering design or modifications that requires new engineering drawings or significant modifications to existing documents then the person accountable for implementation of the change shall ensure that a qualified person has verified that the proposed change meets the requirements of the relevant Engineering Standards.

2.7. Trials and Temporary Change Where a change is to be subject to trial, the change request shall include:

The preparation necessary for the trial

The measure for the trial

The start and finish dates / times for the trial

The review process to evaluate the trial

The actions required to communicate the conclusions from the trial.

Where a change is temporary, the change request shall include:

The preparation necessary for the change

The start and finish dates / times for the temporary change

The actions required to return to the previous state

2.8. Emergency or Contingency Change Procedure An “emergency change” is a change that would normally require the use of the Change Management System, but is made without being subjected to the full process due to adverse weather, fire, power outage and because of the immediate threat to:

A person’s safety, health and/or wellbeing

Piece of equipment

The environment, or

Process stability and the ongoing viability of the plant

An emergency change may proceed with a reduced number of steps prior to the change being implemented but at a minimum shall include an assessment of the risk.

3. Training and Communication Information about the change shall be communicated to all those affected. Where the target audience is large or physically dispersed the use of email is appropriate. Communication shall occur prior to the implementation of the change, but if this is not possible the communication shall be as soon as practical after the change.

All MOCs shall be communicated to the SLT.

Where a change is rejected, the reason for rejection is to be clearly detailed on the Change Management database record and the initiator advised.




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All employees and contractors shall be trained and competent to identify what constitutes a change and how to initiate the relevant change management process. This training is provided during New Hire Orientation and is available on the RCM HSE Prospect page.

4. Monitoring and Review The MOC form identifies controls needed to facilitate the change and the people responsible for each of those controls.

The Safety Coordinator is responsible for tracking all MOC activity and shall be notified of all MOCs. The Safety Coordinator is also responsible for implementation and management of the system for ensuring MOC requests are acted on and closed out in a reasonable time period.

Prior to closing out a change proposal a PIR shall be carried out to ensure:

The change(s) have been implemented in accordance with the authorized change proposal

All required actions and controls have been satisfactorily completed

The actual change impact against the intended change impact, and any reasons for deviation were assessed

The physical change has not introduced any unforseen risks

Any lessons learned are documented

The MOC shall not be closed out until the Safety Coordinator receives documentation that the PIR is complete.

5. Reporting The results of PIRs for significant changes (i.e. those ranked with a potential impact of high or critical) may be reported to the HSE Committee.

6. Documentation and Records Completed MOC forms shall be collated by the Safety Coordinator and filed in DMS.

7. Link to References and Related Documents RCM HSE Management System Procedure E11 - Management of Change

RCM Outlook MOC System

RCM MOC Process Form

Post Implementation Review Process




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ELEMENT 12 BUSINESS RESILIENCE AND RECOVERY

8. Purpose To ensure that appropriate resources, effective plans, and procedures are in place to identify potential emergency scenarios and to plan an appropriate response for the control and recovery from emergencies and business disruption.


9.2. Major HSE Event A major HSE event is an event that may impact the business activities of the Project and may include:

Natural disasters

Terrorist acts

Major fire/explosions

Aircraft incidents

Murder/suicide in the workplace

Accidental fatality

Kidnap for ransom

Hostage taking

Bomb threats

Toxic chemical release or theft

Major vehicle incident

Major transport incident

Workplace violence

Loss of communications/information systems/technology

Health issue/widespread illness or pandemic

Scandal/public relations issue (reputation)

Major asset/property damage

Major market disruption

Loss of utilities

A major HSE event shall be declared by the SLT when a workplace or external incident, event or issue occurs that is not under control and poses a significant risk of damage to RCM employees, activities or RCM’s reputation.




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A major HSE event shall be managed as defined in the Business Resilience and Recovery Program (BRRP).

9.3. Business Resilience and Recovery Program RCM shall have a BRRP that includes:

Business resilience management

Emergency response (incorporating first aid and emergency evacuation requirements)

Business continuity

Information and technology disaster recovery

The process and requirements for the development and integration of these plans are defined in the Rio Tinto Work Cycle: Preparing for Business Resilience and Recovery.

The plans incorporated in the BRRP shall be based upon the Rio Tinto incident escalation protocols for activation and deployment of resources.

In addition MSHA, OHSA, ASMI and ADEQ requirements need to be addressed including:

Emergency Response Plan

Escape and Evacuation Plan

Immediate notification of 12 specific types of mine accidents

The H&S Manager is accountable for the development and implementation of the BRRP.

9.4. Business Resilience Management The BRRP Plan describes the processes for managing the response to incidents classified as major HSE events or disasters.

The plan provides details of the key threats and provides guidance on their management including details on:

The RCM Business Resilience Team (BRT) members and support staff, as well as external support agencies and their contact details

Roles and responsibilities of the BRT

Disaster management tasks, roles and activities

The facilities available (location and equipment) for managing an event

Legal requirements and regulatory authority contacts

Notification and communication systems and requirements for both internal and external stakeholders

Guidelines for media management

Guidelines for the provision of counselling services




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9.5. Emergency Response The Emergency Response Plan (ERP) provides guidelines for the initiator of emergency response through procedures and contact lists. The guidelines cover injury response, natural disasters, environmental incidents, bomb threats and evacuation. RCM maintains an Emergency Response Team (ERT) utilizing employees and contractors.

The call-out protocols for the ERT shall include digital telephone intercoms, email, site radio and mobile phone call-out systems.

2.4.1 On Site Emergencies

RCM shall manage on site emergencies to the capability of the ERT with assistance as required from external services. Transport of injured persons off site shall be via a suitable service provider and vehicle.

2.4.2 Off Site Emergencies

Off site emergencies shall be managed by external services, with assistance available from RCM personnel and equipment if requested. RCM has no recognized jurisdiction outside of the RCM property and shall not attend off-site emergencies unless specifically requested by the Police or Officer in Charge of the Emergency Service on the scene.

External emergency services include:

Ambulance

Fire Brigade

Police

County Search and Rescue Service

Helicopter emergency services

Phoenix Hospitals

Various counselling service providers

9.6. Emergency Facilities, Equipment and Systems RCM maintains the following to ensure any major event is able to be handled appropriately. Requirement Details

Control and Command Center

In the event of an emergency a Control Center shall be designated. This shall nominally be the Verde Building Conference Room for West Plant events or East Plant Bull Pen meeting room for shaft development incidents. The emergency shall be managed in accordance with the RCM ERP.

Protective Equipment and Warning Systems

Warning systems shall be inspected and maintained regularly to ensure they are operational. These checks shall occur through planned inspections and the maintenance system.

Rescue Equipment

Emergency rescue equipment shall be maintained using site maintenance systems.

Hazardous Materials

Details of the storage locations of hazardous materials including chemicals and fuels shall be available at Security Stations. This shall be prepared and updated annually.

Escape Plan An Escape Plan shall be prepared for the site with specific detail on the underground environment. This plan includes the location of self contained self rescuers, escape ways, ventilation fans and




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doorways, .first aid equipment, mobile equipment, fire fighting equipment and contact information for the ERT.

Confined Spaces

Specific procedures for confined spaces shall be developed. The procedure shall state the maximum distance allowed before an alternate secondary means of egress or a refuge chamber is required.

9.7. Debrief and Investigation At the completion of any emergency situation the H&S Manager shall coordinate activities to ensure all information is collected and is factual and prepare a full report, which includes:

Ensuring all key personnel involved in the emergency have documented their actions during the critical period

Reviewing all documentation produced including logs of actions, telephone communications and notifications

Developing a chronological list of key events, decisions, actions, notification and communications

Interviewing relevant personnel as required to complete any areas where information is missing

Conducting a debrief of the ERT personnel to clarify all activities carried out during the emergency

Conducting a debrief with the BRT to clarify all activities as carried out during, and immediately after, the emergency

10. Training and Communication Training is provided in the following areas:

BRT members and backup team members

First Responder

EMT – Basic and Paramedic

Fire Fighting

ERT training

Underground Mine Rescue

Exercises shall be coordinated by the H&S Manager and undertaken as follows:

Annual desktop exercise

Surface and underground evacuation drills

Full-scale BRRP exercise at least every 2 years

The H&S Manager is responsible for ensuring that site drills and area exercises for employees, contractors and ERT members are undertaken.

The requirements of the BRRP shall be communicated to employees and contractors. The Plan shall be available on the RCM HSE Prospect page.




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11. Monitoring and Review A full investigation shall be conducted into the cause of an incident as per the requirements of Element 14.

Emergency response documentation shall be reviewed regularly to ensure it is kept up to date.

After any exercise the performance shall be evaluated, considering the views of the participants and observers.

Opportunities for improvement shall be identified and the relevant plan shall be updated to reflect the lessons learned from the exercises and actual incidents.

The BRRP shall be reviewed at least annually and updated where necessary, unless there are changes to the BRT membership or BRRP requirements that necessitate more frequent updating.

MSHA undertakes bi-annual inspections of drills that have been undertaken.

12. Reporting Reporting shall be undertaken as required by Rio Tinto and government requirements.

In particular MSHA requires immediate notification of 12 specific types of mine accidents.

13. Documentation and Records The BRRP shall be a controlled document with the following copies:

One hard copy at the BRRP Centre

A copy for each BRT member

An electronic copy

14. Link to References and Related Documents Rio Tinto Work Cycle: Preparing for Business Resilience and Recovery

RCM BRRP

RCM ERP

RCM ERT Call out Protocols

RCM Contaminated Sites Register

RCM Escape Plans

RCM Confined Space Entry Procedure

RCM Muster Location Figures




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ELEMENT 13 MEASURING AND MONITORING

1. Purpose To describe how RCM consistently monitors and measures its workplace, community and ambient health, safety and environmental performance to the required standards. These requirements may be legislation based or be contained in a recognized standard or code, from an external or organizational source.


2.1 Regulatory and Other Requirements RCM undertakes monitoring in accordance with all relevant legislation, operating conditions, corporate, USA and International standards and commitments to stakeholders as outlined in RCM HSE Legal and Other Requirements Register.

Procedures for measuring and monitoring occupational health exposure and environmental impact shall conform to the processes defined in the Rio Tinto Work Cycle Environmental and Health Exposure Monitoring.

2.2 Identifying Areas to be Monitored HSE monitoring programs shall be identified through consideration of the following:

Government permits, legislation or evidence of compliance

Rio Tinto requirements or relevant International Standards

HSE hazards / risks or impacts as identified in risk assessments

Controls that have been implemented and need monitoring

Project activities

HSE data, standards and procedures

Management of incidents

HSE objectives and targets

Commitments made to stakeholders

2.3 Requirements for HSE Monitoring Programs All RCM HSE monitoring programs are undertaken for employees and Level 1 contractors and the surrounding environment and shall be designed, implemented and conducted by competent personnel.

Individual monitoring programs have been established for health, safety and environment.

Health monitoring comprises a RCM Medical Surveillance Program which is based on the stage of the Project and current activities undertaken. As a result, the program shall reflect the activities planned for the current year or project milestone.




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Safety monitoring is undertaken to ensure employees and contractors are following specified processes and procedures that comply with both Rio Tinto, local and federal regulations.

Environmental monitoring is undertaken to ensure compliance with permit conditions, collect baseline data and ensure activities do not result in impacts on the environment are in full compliance with legislative requirements.

Development of the monitoring programs considers:

Monitoring objective (assess exposure, compliance monitoring, etc)

The legislative requirements and areas to be monitored

The parameters that need to be monitored, the data collection and analytical methodology

The variability in the process / activity to be monitored. E.g. consideration should be given to sampling frequency, interval, season, size of sample population and potential to emit, etc

Training and competency requirements for employees and contractors who shall be conducting monitoring and reviewing HSE monitoring data

Methods for collection and analysis of data and current best practice and quality control requirements and survey type (preliminary, detailed or follow-up)

The accuracy and precision of data collected from HSE monitoring ensuring that data is verifiable, appropriate and reproducible

Acceptable operating limits and occupational exposure limits (OELs)

HSE monitoring equipment that requires calibration

How the results are to be recorded and where they are to be filed / archived

How the results are to be analyzed, by whom and statistical validation requirements

Reporting requirements (what, how, to whom)

Process for corrective action

The potential risks to personnel associated with (performing or receiving) the monitoring or testing

Where contractor or consultants are employed for the purposes of measuring or monitoring, their systems and procedures shall conform to Rio Tinto requirements.

Notification requirements / timeframes for contractors conducting HSE monitoring shall be detailed in contract documentation.

Any analytical laboratory service used shall have an active quality assurance or control program in place.

2.4 Monitoring Equipment RCM shall ensure all inspection, monitoring, measuring and test equipment demonstrates compliance to specified legislative requirements and standards.

Due to the changes in the Project scope there are regular fluctuations and variations in activities. As a result monitoring requirements and the associated equipment shall vary.

There is a Health Monitoring Equipment Register that contains a reference to the relevant requirements such as maintenance, calibration, storage location, and responsible person.




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The main HSE monitoring equipment used by RCM is listed below:

Monitoring Area Equipment Monitoring

Health Sound level meter Instantaneous noise

Dosimeter Noise

Sampling pumps Diesel particulate matter Respirable dust

Fixed gas meter CO, CO2, O2, NH4

Electret Radon

Safety Gas meters O2, NH4, CO, CO2 H2S, SiO2

Lightning detectors Lightening

Environment Flow meters Water quantity

In-Stream meter Water Quality-pH conductivity

Monitoring, measuring and test equipment shall be:

Appropriate with regard to precision, accuracy, reliability, data output, backups, standards and availability of servicing

Identified and maintained

Controlled / safe guarded from unintentional adjustments

Stored and protected from damage

Calibrated or verified against a traceable standard at specific intervals and the calibration status known and recorded.

Monitoring equipment required by permits or legislation is listed in the relevant Health or Environmental Monitoring Manual.

2.4.1 Equipment Calibration

All HSE equipment that requires calibration shall be calibrated to the relevant Standard or equipment specifications. Calibration details are included in the HSE Monitoring Equipment Register. This includes details on important monitoring equipment that requires calibration. Where possible, information may include details on equipment type, make model, date of purchase, supplier, previous calibration date and when the next calibration is due.

2.5 Data Quality Assurance Data quality and assurance is critical for the following areas:

Medical surveillance and hygiene monitoring

Water quality and discharge quantity

Smelter soil quality

To ensure data quality and assurance the following processes are utilized:

Contracts established with appropriate conditions that specify QA/QC eg certified laboratories




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Sample collection methodology is established which includes sample size, frequency and blanks

Equipment is calibrated

Sample analysis is undertaken in accordance with the contract

Results are reviewed by competent personnel and trends and statistics analyzed where required

Records are collected on sampling conditions

Reject criteria is established

2.6 Safety Monitoring Safety monitoring is undertaken for:

Personal safety eg HSE interactions

Personal safety equipment eg W65 self rescuers, Drager BG4, lanyards, lifelines, safety harnesses, self contained self rescuers

Plant and equipment eg vehicles, hoists, rope, sheave, pressure vessels, grounding continuity, cranes, wire rope NDT

Work environment eg lighting

Facility and infrastructure eg ground control monitoring, shotcrete quality testing

Incidents and statistics eg LTFR, AIFR

Leading indicators eg number of HSE interactions

Regulatory compliance eg MSHA 30CFR

2.7 Medical Surveillance All persons employed by RCM shall be deemed fit for the work duties for which they are to be or have been employed, in accordance with RCM’s employment standards. Medical standards shall be developed, maintained and applied for each Similar Exposure Group (SEG) and medical monitoring data shall be assessed by competent persons.

The RCM Medical Surveillance Program includes personal health and hygiene monitoring for all employees and Category 1 contractors and is consistent with local regulatory requirements, the Rio Tinto Health Performance Standards and Health and Medical Monitoring Work Cycle as well as with consideration of the Project health risks and objectives and targets.

The Medical Surveillance Program shall be based on the outcome of health risk exposure assessments and, as appropriate, employee health surveillance information.

Where a possible increased health risk is identified, employees shall be encouraged to participate in the program.

Personal monitoring shall be employed in preference to ‘static’ fixed-place or area monitoring for defining potential exposures. Static monitoring may be employed for measuring exposures where prior programs have demonstrated good correlation with personal monitoring data.




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Where health risk assessment indicates the possible presence of levels of gas or vapour sufficient to cause significant adverse health effects in less than one shift, continuous monitoring is required as long as the potential for harm exists.

Competent persons and appropriate equipment shall be available for conducting any special air samples (e.g. tank entry, incident investigations, etc.).

For carcinogens and reproductive toxicants and for progressive chronic conditions with a known cause, exposure data shall be statistically valid on an annualized basis.

For progressive chronic conditions with a known cause (requiring long-term exposure for an effect to manifest; excluding noise), exposure data shall be statistically validated on an annual basis. Time weighted average measurements over several shifts, and consistent with the work-day period, shall be used. If three or more years data are low (<50% of the mean OEL), then the monitoring period may go out to three years, provided the process does not change.

Shorter monitoring periods shall be required (in the order of seconds or minutes) for substances that manifest toxic effects after short-term exposures (eg carbon monoxide and some substances causing occupational asthma).

The Medical Surveillance Program at RCM is dependent on Project activities and may include:

Pre employment health assessments eg medicals

Voluntary wellness assessment with annual review

Annual health assessments

Personal (audiometry) and work environment noise monitoring

Personal and work environment dust monitoring

Respiratory protection

Radiation dose monitoring (as appropriate)

Review process for employees who change roles

Other health monitoring as appropriate

The results of monitoring shall guide actions and decisions for accurately assessing exposures.

2.8 Environmental Monitoring Environmental monitoring is undertaken as required for the stage of the Project.

In particular during the Project pre-feasibility stage monitoring is undertaken to collect baseline data and meet Rio Tinto requirements.

Permits and legislative requirements require specific monitoring of:

Meteorological data

Discharge water quality and quantity

Soil quality

Hazardous waste

Contaminated land




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Details of all monitoring that has been undertaken and is currently in progress is included in the RCM Environmental Monitoring Program available via the Environmental Data Management System (EDMS).

All environmental monitoring is undertaken by competent employees or approved consultants. Contracts detail the approved sampling and analysis methods.

Environmental data is managed via the Environmental Data Management System (EDMS).

2.9 HSE Inspections Activities, equipment and facilities across Project shall undergo inspections, testing and condition monitoring to ensure they are operational, safe, minimize harm to the environment and are working correctly.

Inspections shall be conducted to:

Identify and correct unsafe HSE conditions, hazards, risks and non conformances

Identify and correct unsafe behavior and unacceptable environmental impacts

Identify and correct unsafe or unacceptable work procedures

Maintain an awareness of and ensure compliance with RCM processes and procedures

Recognize examples of good conditions and methods of work

Maintain compliance to regulatory standards

Planned inspections shall be performed at established frequencies for all areas and identified equipment. Inspection schedules are managed at the Departmental level. The H&S and Environmental Departments undertake inspections on a regular basis in accordance with permit and legislative requirements.

3. Training and Communication RCM monitoring programs shall be designed and reviewed by persons competent in the relevant area.

RCM employees undertaking monitoring shall be trained and tested as competent.

Results from HSE monitoring programs shall be communicated externally or internally as defined by Element 9.

Avenues for communication of HSE monitoring information include:

HSE statistics reported at weekly meetings

Display of data on notice boards

Incident Reports and SEART report

Government reporting

Relevant information shall be provided about the potential risks to personnel associated with (performing or receiving) the monitoring or testing.

Medical assessment and occupational hygiene monitoring results shall be reported back to the individual concerned as soon as possible. Results shall be explained along with any potential risks to the individual.




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4. Monitoring and Review Monitoring programs shall be reviewed regularly to ensure:

Permit conditions, legislation and Rio Tinto requirements are being met

Procedures are followed and up to date

Adequate levels of staff competency to conduct the monitoring programs

Modifications are made where required

Review of data from monitoring programs shall be carried out through the review of results, reports, and statistical analysis. Monitoring data from laboratories and reports from consultants shall be reviewed as soon as practicable upon receipt for potential exceedances and trends.

Statistical analysis may include but is not limited to mean, standard deviation, maximum, minimum, median and confidence intervals.

SEGs shall be periodically reviewed and data shall be periodically checked statistically for outlier results.

Unexpected exceedance of operating criteria (eg OELs, emission limits etc) shall be recorded, investigated and reported as appropriate.

Actions resulting from monitoring results shall be documented in the Business Solution, assigned accountability and tracked until completion.

An incident shall be raised in the Business Solution when a non-conformance / exceedance is detected.

Review of monitoring programs and HSE data shall be included as a standard agenda item in HSE SLT Review Meetings.

Changes or new monitoring programs shall be approved by the H&S Manager or Environmental Manager.

5. Reporting HSE monitoring results are reported by HSE personnel via:

Safety Statistics

Rio Tinto HSE 6 monthly report

Rio Tinto S&E Surveys

Rio Tinto SD Report

Rio Tinto Incident Alerts

Government reporting is undertaken in accordance with legislation and permits and is detailed in the HSE Management System Legal and Other Register.

Any legal or standard non-conformance or unexpected OEL exceedance shall be reported within 24 hours upon receipt and confirmation of analysis results to the Manager of the department in which they occurred and an incident report raised in the Business Solution (refer E14).




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6. Documentation and Records Monitoring records shall be maintained and provide sufficient process and operation detail to allow an assessment of sampling and control effectiveness.

Retention requirements for HSE monitoring records are described in E15.

EDMS and the RCM GIS database and Document Management System (DMS) are utilized for storing and managing the majority of the environmental monitoring data.

The Business Solution and DMS are utilized for storing and managing the majority of health, hygiene and safety monitoring data.

7. Link to References and Related Documents

Rio Tinto Health Performance Standards

Rio Tinto Work Cycle Environmental and Health Exposure Monitoring

Rio Tinto Work Cycle Health and Medical Monitoring Business Solution

DMS

EDMS

RCM GIS Database

RCM HSE Management System Legal and Other Requirements Register

RCM Medical Surveillance Program

RCM Health Monitoring Equipment Register

Rio Tinto HSE 6 monthly report

Rio Tinto S&E Surveys

Rio Tinto SD Report

Rio Tinto Incident Alerts




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ELEMENT 14 NON CONFORMANCE, INCIDENT AND ACTION MANAGEMENT

Purpose To ensure all incidents and lessons learned are recorded and corrective actions identified, closed and communicated.

This procedure is written to comply with MSHA, OSHA, and Arizona regulations as well as the various Rio Tinto Incident Management Work Cycles.


2.2. Incident Management Incidents include injuries, illnesses, harm to the environment or property and potential harm to persons, the environment and property (near miss/near hit).

Non conformances include any findings resulting from HSE Management System audits.

All employees and contractors shall:

Report all incidents to their Supervisor and / or the Work Area Owner immediately after the event has occurred

Understand incident reporting procedures (relevant information is provided in the RCM induction)

All Supervisors shall:

Involve the workforce in reviewing incidents where applicable

Report and share the findings of incident investigations

Analyze incident causes and identify preventive measures

Incident Process Flow Diagram

Incident Review Process

Reporting

Requirements

Incident

notification

Initial response

Incident

Recording

Incident

Investigation & Documentation

Recording Actions




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Initial Response to an Incident

Always check for DANGER to self and others. Consider activation of the Business Resilience and Recovery Program (BRRP).

Immediate actions shall be taken in the event of an accident or incident to prevent (further) harm to people, process or environment. Immediate actions may include first aid, spill containment, plant shutdown or other forms of incident control or containment.

Initial response shall depend on the type of incident:

If persons are involved in the incident, initiate the RCM First Response including First Aid

Call x3999 for immediate assistance

In an underground emergency the ERP is initiated with Mercaptan (Stench Gas)

If there is a spill of material, initiate spill response

For any incident involving an electric shock, the victim shall be taken immediately to Security for medical assessment. The victim is to be taken to a hospital. Do not allow the victim to walk any substantial distance when seeking medical assistance

In the case of a fire, explosion, rescue, motor vehicle accident or chemical / hydrocarbon spillage, water supply contamination initiate the ERP. The First Responder is accountable for calling out the Emergency Services. Procedures for dealing with emergencies are detailed in the RCM ERP

Immediate action shall be taken to eliminate or minimize risk associated with the incident. This may include barricading the incident scene, isolating equipment, preventing the spill from entering drains etc

Ensure adequate containments are in place to prevent an immediate re-occurrence

For cause testing shall be undertaken in accordance with the RCM Alcohol and Other Drugs Policy.

Preserve and protect the scene as much as possible so that it cannot be interfered with and allow for the investigation process – particularly if the incident is reportable to statutory authorities. This shall ensure valuable information is not tampered with or destroyed and ultimately improve the outcome of the investigation process. Preservation shall include not moving any evidence, taking photos, measurements, and gathering immediate witness statements.

2.3. Incident Notification Report all incidents to your Supervisor and / or the Supervisor of the work area immediately after the event has occurred.

The H&S Manager and Environmental Manager shall be notified where appropriate or if necessary.

The RCM Security Hut shall be notified and the incident light turned on.

RCM employees shall be notified by email on the same work day for serious incidents.

The appropriate notification requirements shall be based on the Actual Consequence and / or the Maximum Reasonable Outcome (MRO) for a particular incident.

Actual Consequence and MRO are determined by using the Rio Tinto HSE 5 x 5 Risk Matrix. Refer to E3 for additional detail.

The table below details the minimum Rio Tinto reporting expectations:




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Outcome By Whom Who is notified

When

Report only

Actual and MRO low / moderate

Person involved Supervisor As soon as possible

Leader Department Manager

As soon as possible

First Aid

Actual and MRO moderate

Person involved / Security

Supervisor As soon as possible / on presentation to the Security Station for treatment


As soon as possible

Department Manager

Project Director

First working day following incident

Medical Treatment

Person involved / Security

Supervisor As soon as possible / on presentation for treatment


Immediately

Department Manager

Project Director

As soon as possible and by end of Shift

Significant incidents

Actual consequence – serious, major or catastrophic

and/or

Maximum Reasonable Outcome high / critical

Refer Rio Tinto Risk Matrix

24 hour reporting incidents shall be reported through to the Managing Director – Copper Major Projects immediately who shall notify the Chief Executive and Global Practice Supervisor – HSE within 24 hours of occurrence. The Project Director shall release the information on the incident to the Copper Group and statutory authorities (refer to Compliance and Conformance Register.

Immediate reporting to MSHA and ASMI for the 12 mine accidents.

Notes:

24 hour reporting requirements for Major and Catastrophic incidents are included in this procedure.

For additional detail refer to the Rio Tinto 24 Hour Reporting Work Cycle 140101 for major and catastrophic incidents.

Incident Recording

A Rio Tinto Business Solution incident record shall be generated on the same shift the event occurred. Refer to Rio Tinto Report and Record Incident Work Practice for additional detail, instruction and context.

The following information shall be formally captured for each impact associated with an incident. This shall occur within 48 hours of the incident being logged.

Actual Consequence

MRO




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Maximum Reasonable Likelihood

Process Type (under general tab)

Process (under general tab)

If an incident has multiple impacts, each impact shall be evaluated independently, with the most significant classification forming the main rating of the incident.

Near miss events shall be reported as an incident.

All incidents resulting in personal injury or occupational illness shall have injury / illness detail captured in the incident report. Due to the confidential nature of this information, there is limited authorization to view and complete this work. These records shall also include any lost or restricted work days accumulated as a result of the incident.

This activity shall be completed within seven days of an incident being recorded where detail is known. In the case of shift / days lost, this information shall be updated on a monthly basis. Refer to Rio Tinto Record Injury – Illness Information Work Practice for additional detail and the procedure for completing this process.

2.4. Incident Investigation Incident investigations involve the methodical examination of an undesired event that did, or could, result in physical harm to people, damage to property or the environment, or loss to process. Facts and circumstances related to the event need to be identified to determine the causes and develop remedial actions to control the risks.

The accountability for investigation rests with the ‘involved persons’’ Supervisor (involved persons may be ‘injured persons’ or ‘involved persons’). Where no person is identified as involved or injured (eg a gear box failure spilling oil), the accountability for investigating the incident results with the Work Area Owner.

The appropriate investigation methodology shall be based on the type of incident, non conformance and actual consequence and / or MRO for a particular incident.

The investigation shall establish:

The basic event

Causal factors

The root cause of the incident

The controls that would have prevented the event from occurring

Corrective and preventive actions to avoid recurrence

All audit findings shall be investigated by the Element or Performance Standard Champion, HSE Management System Advisor, HSE personnel and, if needed, personnel from the work area in which the finding was identified. These investigations may be documented on the RCM Non Conformance Root Cause Form. Upon identification of the audit findings’ root cause(s), action item(s), and responsible person(s), the HSE Management System Representative shall sign off on their approval.

The following table details the necessary level of investigation and recording.

Maximum Reasonable

Level of Investigation and Recording Investigator Competence




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Outcome

Low Business Solution record Completion of RCM Incident Investigation / Management Training Moderate Business Solution record

High Business Solution record (released to SEART) TapRooT Incident Investigation summary RCM HSE Alert

Persons trained in Taproot® Investigation facilitation (five day course)

Critical Business Solution record (released to SEART) TapRooT Incident Investigation summary RCM HSE Alert

2.5. Action Management Corrective actions are considered an integral part of an incident investigation and reflect the recognized need for action to mitigate or treat an identified hazard or risk to prevent the incident from re-occurring.

Incidents of high and critical shall have at least one action assigned to it.

If progress against Project Objectives or Targets is not being met, the non-conformance is evaluated and corrective or alternate actions assigned during the SLT HSE Management System Review meetings. The Objectives and Targets are reviewed during this meeting at least twice a year and recorded in the Meeting Minutes.

General Action Creation

Corrective and preventive actions may also be identified through:

Risk assessments

Management of Change (MOC)

Identification of non-conformance and/or non-compliance

Internal or external complaints

HSE monitoring programs

Management reviews

HSE meetings

Internal and external audits

Risk register reviews

HSE interactions

Inspections

HSE improvement ideas / innovations

To initiate the corrective action system within the Business Solution employees may create a stand alone action against a work area or create an action which is linked to:

An incident




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A HSE interaction

An audit / review

Actions entered in the Business Solution shall be:

Approved by appropriate management representatives

Considered to determine if MOC applies

Documented in the Rio Tinto Business Solution, referencing the Incident Report

Communicated and assigned to a person who has authority to complete the action. The person assigned the action shall assess the resources required, including financial and human, to complete the action

Given a completion date set based on the priority of the action and the availability of resources

Reviewed at HSE Committee meetings

Updated in the Business Solution to include any additional comments and the actual completion date.

Refer to the Rio Tinto Action Management Work Cycle which details the management of actions from identification through to completion.

Actions identified during the Level 1 Task Based Risk Assessment process shall be tracked via the risk assessment form, including the responsible person. Follow through on those actions shall be monitored by the Safety Coordinator.

Training and Communication All employees and contractors shall be trained in the requirement to report incidents immediately as part of the RCM Induction.

HSE representatives and RCM Supervisors shall be trained in incident investigation techniques.

Incidents and associated actions shall be communicated to relevant personnel.

Monitoring and Review The SLT and the HSE Management System Representative(s) shall review the progress of actions particularly in relation to the due date for completion. Wherever unexpected circumstances delay the completion of actions, actions shall be reviewed and dates reassigned with comments about the reason for the delay.

When an action has been completed, the effectiveness of the action shall be verified to ensure a risk reduction and the absence of increased risk. The verification should be conducted by the Supervisor of the person assigned the action.

Verification of the action shall be recorded in the Business Solution.

Reporting Incident notification is as per section 2.2.




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Below is a summary of reports required on incident details to meet Project, Copper Group and Rio Tinto expectations:

Data Report Timing / Frequency

Details Audience Relevant Reference

MSHA Immediate for 12 Regulated Accidents

Any safety incident that constitutes a breach of MSHA or OSHA regulations.

MSHA ASMI

Legislation

MSHA Within 10 days for MTC


MSHA ASMI

Legislation

MSHA Quarterly Report of all Injuries


MSHA ASMI

Legislation

ADEQ Within 24hrs of the incident

Any environmental incident that constitutes a breach of permit conditions shall be reported

Government Legislation

ADEQ Within 24 hours of becoming aware

Any release of contaminants outside the Project boundary

Government Legislation

Investigation Interim Report

Within 21 days of the incident.

An interim investigation report should be completed

RCM Management

Investigation Findings

Within 7 days of the incident

Investigation findings using Taproot should be entered into the Rio Tinto Incident Investigation System

RCM Management

Incident Report to SEART

Within 7 days of the incident

Post all significant incidents to SEART and Knowledge Sharing portal, after approval from the H&S Manager

Corporate reporting requirement.

WPMS 1401-02 Monthly HSE Reporting Requirements Refer H&S Manager

SPI’s Within 21 days of SPI

. RCM Management, Copper Group and Rio Tinto

Refer H&S Manager

HSE Incidents As required Summary of site HSE incidents On-going maintenance of Rio Tinto Business Solution records. Relevant communications from other sites

All site personnel

Refer H&S Manager

RCM Monthly HSE Data

Monthly Summary of monthly chart data taken from the Rio Tinto Business Solution including incident/ action progress, root cause/ actual & MRO not assigned and SEART action tracking for incidents, reviews and audits

All site personnel

Refer H&S Manager

RCM HSE Alerts

As required HSE Alerts are completed and distributed for significant incidents HSE Alerts may be completed and distributed for Moderate and Low risk incidents and incidents of interest at the discretion of the H&S Manager

All site personnel

Refer H&S Manager

SEART Monthly Number employees/ contractors, hours worked, LTI’s, days & shifts lost Note: data is taken directly from records maintained in Rio Tinto Business Solution Significant incidents are released into

Corporate reporting requirement

WPMS 1401-02 Monthly HSE Reporting Requirements




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Data Report Timing / Frequency

Details Audience Relevant Reference

SEART through the Rio Tinto Business Solution Upon completion of the entry into SEART, the incident needs to be published. Upon clicking on the PUBLISH button, all necessary information is fed in to the Rio Tinto Knowledge Sharing System template

Refer H&S Manager

Knowledge Sharing

Quarterly The H&S Manager reviews entries in the Knowledge Sharing System and approves notifications for publication to Rio Tinto Knowledge Sharing subscribers. This allows the details of the incident to be available to the wider Rio Tinto community

Rio Tinto Refer H&S Manager

Six monthly HSE review and report

July Update on status of significant incidents and associated actions, outstanding review and audit findings


WPMS140103 Six monthly HSE review and report Refer H&S Manager

End of year reporting requirements

January HSE data entered into workbooks covering a number of key HSE areas


WPMS140104 Annual HSE reporting requirements Refer H&S Manager

Documentation and Records All incident reports shall be stored in the Business Solution.

Where possible, associated documents such as the field investigation report, photographs, chain of events report, Taproot, Witness Statements etc shall be attached to the relevant Business Solution record or stored in DMS.

Link to References and Related Documents MSHA

OSHA

Arizona regulations

Rio Tinto Incident Management Work Cycle

Rio Tinto Action Management Work Cycle

Rio Tinto 24 Hour Reporting Work Cycle

Rio Tinto Report and Record Incident Work Practice

Rio Tinto Record Injury – Illness Information Work Practice




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Business Solution

TapRoot

Document Management System

RCM HSE Prospect page

RCM Alcohol and Other Drugs Policy

RCM Non Conformance Root Cause Form

Incident Reports




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ELEMENT 15 DATA AND RECORDS MANAGEMENT

Purpose To ensure all HSE data and relevant records required for the management system are maintained, accurate, current and, where necessary, secure in accordance with the Rio Tinto Data and Records Management Work Cycle.


HSE Data and Records HSE data and records are:

Documentation that is not subject to change over time and therefore does not require document control (eg: monitoring laboratory reports, training records, meeting minutes)

Documentation stating results achieved, providing evidence of activities performed in relation to HSE performance (eg: waste certificates)

Completed forms indicating conditions at a particular moment in time (eg: Job Hazard Analysis, Permits)

HSE data and records include, but are not restricted to the following sources:

Records of compliance with HSE legislation

Company emails containing information or evidence that may be required for legal purposes

Tables, matrices, registers and lists

Monitoring result records (including personal medical files)

HSE objectives and targets

HSE inspection reports

Injury and incident reports

HSE aspects of equipment maintenance ie. Inspections and calibrations

Training records

Audit reports

Complaints

Meeting minutes

Emergency management records

Tables, Matrices and Registers

Tables, matrices and registers are designated as “records”, therefore, unless otherwise specified, do not require document control authorization.




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Where appropriate roles / persons authorized to modify HSE registers are specified in each register.

Each time a HSE register is modified it shall be updated with the modification date. This date may be in the document header or footer.

Engineering Drawings

Engineering and technical drawings required for the Project shall be managed in accordance with RCM Project processes.

Where information is relevant to current Project activities that may result in HSE impacts, copies of that information shall be available as required.

Analytical Data

Analytical laboratories shall be selected to ensure that they have an active quality assurance / quality control program in place. Where circumstances prevent this, a reference, including appropriate context, shall be made in the analytical results.

Data and Records Creation and Management

Creating HSE Records HSE records shall be prepared in a manner that is legible, permanent, identifiable, and traceable to the activity, product or service involved. For example references to standard methods used and identification and type of instrument used for measurement.

The means of identifying and assuring traceability shall be dependant on the type of record but shall include the appropriate combination of:

The date the record was last updated

The period (month, quarter, year etc) that the record includes

The identification number, or name, of the related authorization

The retention time and method for archiving and/or disposal

Storage and Retrieval of Data and Records

Data and records maintained as paper copy shall be stored by relevant personnel in a manner that the records are:

Protected from damage, deterioration or loss

Easily located and accessible to personnel who need them for their work

Disposed of when appropriate

Care shall be exercised if hard copies are kept on recycled paper, particularly if the data and records have to be maintained for an extended period of time eg: 30 years.

Archived data and records shall be readily accessible.

Electronic data is to be maintained so that it has regular back up of information eg: server, CD copies etc.




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Records retained in the Business Solution (eg. risk registers, incident reports, improvement actions) do not need to be additionally retained on the RCM server.

Records kept electronically for RCM shall be maintained on the RCM network in appropriate folders as designated by the person accountable for their storage and disposal.

Electronic records of critical records / documents (e.g. as required for Business Continuity) shall also be retained on alternative electronic media (eg. CD, PDA). In addition, physical copies of critical records / documents shall also to be maintained.

RCM IS&T Personnel shall back up electronic records on the public shared environments on a daily basis.

HSE records controlled by the Water Treatment Plant (WTP) shall be maintained as per WTP Operation and Maintenance System for records management.

Health Data and Personal Medical Records

All health and hygiene risk assessments and surveillance results shall be recorded, reported and maintained in a database and/or hardcopy in a medical file. Each employee’s SEG personal monitoring data shall be maintained in a database.

Each medical examination report shall be dated and signed by the examining physician or nurse and include either a printed name to identify (electronic signature is acceptable).

Confidentiality

Confidentiality of personal data shall be maintained according to the privacy laws and Rio Tinto information management standards.

In particular personnel files, including those related to personal data, employment conditions, training and health and medical records shall be securely stored and maintained so that the privacy of the individual and confidentiality of the information is secured. Only authorized persons may access this information.

Closure or Divestment

Responsibility for the management and retention of records shall be agreed with the Rio Tinto HSE Global Practise Supervisor upon closure or divestment of the Project.

Record Retention Retention periods for HSE data and records shall be as specified in the Rio Tinto Retention Schedule.

Training and Communication The importance of records and data management shall be included in the RCM induction.

Basic training in DMS shall be provided to all RCM employees and any contractor who log into the RCM internet public page as part of the induction.

Specific records management and document control training shall be available to those roles that are required to manage records.




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Monitoring and Review Review of data from monitoring programs shall be carried out through the review of results, reports, and statistical analysis. Statistical analysis may include but is not limited to mean, standard deviation, maximum, minimum, median and confidence intervals.

The HSE Management Representatives shall ensure that:

Monitoring data and reports from consultants are reviewed as soon as practicable upon receipt for potential exceedances and trends

The quality and integrity of data and records are checked for completeness prior to filing or recording

All records are legible

Quality assurance of data is to take place where appropriate to ensure:

Completeness

Comparability

Representativeness

Defensible methods are used

Accuracy and precision

Reporting Reporting on data and records is as per Element 13.

Documentation and Records HSE data and records management is tracked via DMS.

Link to References and Related Documents Rio Tinto Data and Records Management Work Cycle

WTP Operation and Maintenance System




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ELEMENT 16 PERFORMANCE ASSESSMENT AND AUDITING

Purpose To regularly evaluate and measure HSE performance to assess:

The implementation and effectiveness of RCM’s HSE Management System

Whether RCM continues to meet the requirements of the Rio Tinto HSE Management System Elements

Compliance with legal and other requirements

Employee awareness of the HSE Management System


Performance Assessment Methods RCM reviews HSE performance through the following methods:

Project data review and reporting

Inspections and interactions

Project reviews and audits

Metrics include both quantitative and qualitative data as well as leading and lagging indicators such as:

The extent to which objectives are being met

Progress against targets

The effectiveness of controls

Proactive conformance measures

Reactive or historical performance measures

Performance metrics are reviewed regularly through the following forums:

SLT Meetings

HSE Committee meetings

Reports to the Copper Group and Rio Tinto

Project HSE Metrics Review and Reporting Various documents are produced by RCM to report on HSE performance metrics.

Project Monthly Report to Copper Major Projects




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Injury frequency rates – All Injury Frequency Rate (AIFR) and Lost Time Injury Frequency Rate (LTIFR). This is presented as an overall figure as well as being broken up to compare employees and contractors

LTI severity rate

Summary of injuries, illnesses, significant incidents

Leading indicators, including interactions, inspections, near miss reporting, audit action item close out

MSHA Quarterly Reports

Report on all injuries

OSHA Quarterly Reports

Report on all injuries

Social & Environment (S&E) Survey

The S&E Survey measures environmental, social and economic aspects in order to identify Rio Tinto’s contribution to sustainable development


The Sustainable Development Report outlines the annual performance of Rio Tinto Businesses and includes an overview of RCM activities, including HSE

Inspections and HSE Interactions Workplace Inspections shall be performed on a regular basis to ensure that the work environment is maintained to minimize HSE risks.

Inspections shall be recorded.

HSE Interactions shall be conducted with persons performing work (including contractors) to ensure that work is being performed in accordance with RCM systems, procedures and instructions. The Rio Tinto Safety Leadership Development Program provides guidance on conducting HSE Interactions. Each employee at RCM shall undertake HSE interactions every month.

HSE Interactions shall be recorded in the Business Solution.

Auditing Requirements

HSE Business Conformance Audits

Rio Tinto requires all Group Businesses to implement the Rio Tinto HSEQ Management System Standard and the HSE Performance Standards.

Rio Tinto’s appointed global certification provider shall audit annually against the HSEQ Management System and issue certificates relevant to the defined scope of the business’s management system.




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Internal audits of the HSE Management System shall be conducted biennially.

ISO 14001 – Environmental Management System Audits

RCM shall maintain certification to ISO14001:2004 – Environmental Management System. This requires annual external audits to be undertaken to ensure ongoing compliance with the requirements of the management system. Recertification audits shall be conducted after three years. These audits shall be undertaken by the global certification provider.

HSE Performance Standard Audits

The Rio Tinto HSE Performance Standards are required to be audited annually but on an internal / external rotation.

The internal audit of these Performance Standards is called a first party audit and may use competent Rio Tinto auditors who work for the Project provided they are independent of the activity.

The external audit is called a third party audit and shall be undertaken by Rio Tinto employees trained as auditors who do not work for or on behalf of RCM.

The third party audits shall be aligned to the process detailed in the HSEQ Business Conformance Audit Work Cycle and utilize the HSEQ Business Conformance Audit Protocols.

Legal and Other Requirements Audits

Legal and other requirements compliance is required to be audited at least once every three years. These audits shall be undertaken as an internal audit and conducted by external or internal personnel.

Applicable legal and other requirements are also included in inspection programs of the workplace.

Audit Schedule and Planning

RCM commenced the external audit process in 2010 with an audit of the Rio Tinto HSEQ Management System Standard (excluding Quality) and the Rio Tinto HSE Performance Standards.

After this the audit cycle shall be as follows:

Odd years – External audit of HSEQ Management System (ISO14001)

Even years – External audit of HSEQ Management System (ISO14001) and HSE Performance Standards

The Copper Major Projects HSE Management System Audit Preparation Guidance provides detailed information on how to plan and prepare for an audit and the tools that are available.

RCM conducts internal audits of the Rio Tinto HSE Management System Standard and the Rio Tinto HSE Performance Standards on a biennial rotating basis as follows:

Odd years – Internal audit of HSE Performance Standards

Even years – Internal audit of HSEQ Management System (ISO14001)




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Communication and Training The outcomes from the audits shall be communicated to the HSE Champions and Senior Leadership Team for review of results and proposed actions.

Internal and external audit training is available to employees who have been identified as having the relevant skills and experience.

Monitoring and Review The HSE Management Representatives shall ensure that HSE monitoring, interactions and audits are completed as per the requirements and schedule.

Any non conformances or findings identified during the audits shall be classified according to nomenclature defined in the Rio Tinto Business Conformance Work Cycle and entered into the Business Solution Audit Management Tool.

Corrective actions shall be assigned to responsible RCM positions. The HSE Committee shall review the status of corrective actions and the Safety Coordinator shall track the actions until completion.

Reporting Reporting is undertaken in accordance with Rio Tinto’s Group reporting requirements and frequency as defined in the Rio Tinto Social and Environmental Reporting and Definitions Work Cycle.

All audit reports are provided to the SLT and the HSE Committee.

External audit reports are provided to the SLT and Rio Tinto Corporate HSEC. Findings shall be entered into SEART with six monthly reporting on the status of actions until the actions are closed.

Documentation and Records Audit tools and templates are provided in the Copper Major Projects HSE Management System Audit Preparation Guidance.

All audit reports shall be stored in DMS.

Links to References and Relevant Documents RCM Monthly Report

MSHA Quarterly Reports

OSHA Quarterly Reports

SEART Six Monthly Report

Social & Environment Survey


Workplace Inspections

HSE Interactions (in Business Solution)




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Audit Reports

Business Solution

Rio Tinto Social and Environmental Reporting and Definitions Work Cycle

Rio Tinto HSEQ Management System Standard

Rio Tinto HSE Performance Standards.

ISO 14001:2004 – Environmental Management System

HSEQ Business Conformance Audit Work Cycle

HSEQ Business Conformance Audit Protocols

Rio Tinto Audit Calendar

Rio Tinto Safety Leadership Development Program

Copper Major Projects HSE Management System Audit Preparation Guidance




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ELEMENT 17 MANAGEMENT REVIEW

1. Purpose To ensure the effectiveness of the HSE Management System through:

Evaluating the need for changes

Establishing actions to improve the system

Ensuring planning and implementation of audits

Providing resources to ensure the required changes, improvements and audits are carried out effectively and efficiently


2.1 Management Review Planning The RCM SLT shall review its HSE Management System at least annually. The review shall include HSE performance and management system effectiveness.

Generally, HSE performance is assessed using statistics and checking progress against targets. This is usually undertaken throughout the year as part of SLT meetings.

The review of the management system effectiveness may be undertaken in segments and occur during SLT meetings or specific review sessions may be planned.

There shall be one specific management review meeting to check that all of the Elements of the system have been covered to ensure completeness.

At least five members of the SLT shall participate in the review.

The reviews shall consider management system processes, performance, feedback and opportunities for improvement.

2.2 Data Preparation The following information shall be collated to assist with the review process:

Current Policies

RCM HSE Management System Procedures Manual

RCM HSE Registers (legal and other; significant risks)

Incidents and non conformances and status of compliance

Status of HSE Objectives, Targets, and Performance Indicators

Findings of internal and external HSE audits and reviews

Monitoring results and statistics (health and environment) and feedback (employees, contractors and community including complaints)

Status of corrective and preventative actions




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Minutes from previous management reviews and status of actions

Lessons learned from incidents (Knowledge sharing)

The SLT shall consider this data during the review to assist with evaluating the effectiveness of the HSE Management System.

Other aspects to consider during the review include:

o Changes in RCM activities

o Changes in RCM structure

o Expectations of external parties

o Shared best practice

The review shall provide an opportunity to identify the need for changes to the HSE Management System or other areas where improvements may be made to activities and processes that may result in reduction of risk across the Project. These outcomes may feed into the Project’s objectives, targets and annual improvement plans.

3. Training and Communication The outcomes from the Management Review shall be communicated to the HSE Committee and the minutes shall be available on DMS.

4. Monitoring and Review The HSE Management Representatives shall ensure that all of the Elements and processes required by the system as well as information on RCM’s HSE performance have been covered by the review to ensure completeness.

5. Reporting Significant outcomes from the review of the HSE Management System processes shall be communicated to Copper Group and Rio Tinto to provide feedback on the requirements of the Rio Tinto HSEQ Management System Standard.

6. Documentation and Records SLT Review Meetings shall have recorded minutes and include the following:

Date and attendees

Data reviewed that influenced discussion

Discussion, decisions and actions relating to possible changes of policies, objectives, targets and other elements to the HSE Management System

Effectiveness of the system and opportunities for improvements to the overall system or individual processes

Actions, responsibilities and required resources

The SLT Review Meeting Minutes shall be provided to all the members of the SLT and filed in DMS.




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Actions from minutes shall be tracked by the responsible person and reported against at the next SLT Review meeting.

7. Link to References and Related Documents HSE SLT Review Agenda

HSE SLT Meeting Minutes




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REFERENCES AND RELATED DOCUMENTS

Rio Tinto Corp HSEC Prospect Page

RCM HSE Prospect Page

RCM HSE Roadmaps

Rio Tinto documents

External documents (ISO)

Internal documents – listed per Element

Internal documents – listed per HSE Performance Standards

Templates




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REVISIONS

Version #

Description Manager Approval (HSE) Date

0 Created M Wegleitner August 2011

1 Updated: MS06, 11, 14 T Fox October 2012

2 Updated: MS03, 04, 07, 16 T Fox March 2014

3 Updated: MS16 T Fox April 2015