Standard Operating Procedures

Committed to Excellence in Mining Safety Corrective and Preventative Action Systems

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Corrective and Preventative Action Systems

I Purpose
To ensure that corrective actions designed to correct hazards and other HSLP or ESR
issues are properly implemented and effective. These corrective actions may be derived
from a variety of sources including investigations, inspections, audits, HSLP, ESR, and L&D
committee meetings, observations, industrial hygiene monitoring results, MSHA inspections,
environmental assessments, social evaluations, etc, and are typically intended to be preventive
in nature.

2 SCOPE
This procedure applies to all functional areas, operations, offices, including employees, vendors,
visitors and contractors within the scope of the Integrated Management System (IMS).

3 DEFINITIONS AND ACRONYMS

Definitions

Consequence is the outcome/impact of risk events.

Corrective Action is an action prescribed to correct a substandard condition, act, event, or

its potential.

Corrective Actions Register is a database used to record and track the completion of
corrective actions.

Key Performance Indicators are metrics used to measure the effectiveness of the
HSLP Program in the operating areas. Example: One KPI is a score on CAR indicating the
completion rate for corrective actions in each area.

Likelihood is a measure of the probability and/or frequency of a risk event occurring.

Hazard is the inherent characteristic of a material, condition, or activity that has the potential
to cause harm to people, property, the environment or the COMPANY’s reputation.

Preventive Action is a Corrective Action assigned to a condition, act, event, or its potential,
designed to prevent their occurrence or reoccurrence. These actions tend to be long term in
nature.

Risk is the possibility of economic or financial loss, harm to people, processes, property, and
the environment, relations with stakeholders or to reputation. Risk has two elements – the
likelihood or probability of something happening, and the consequences or impacts if it does.

Risk Assessment is the calculation and allocation of priorities to risks for their subsequent
management or treatment.

Site refers to any COMPANY designated location (operational areas, offices, etc.)..

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Acronyms

CAR Corrective Actions Register

ESR Environmental and Social Responsibility
HMR HSLP Management Representative
HSLP Health, Safety and Loss Prevention
IMS Integrated Management System
KPI Key Performance Indictor
L&D Learning and Development

4 ROLES and responsibilities

Document Owner

HMR

Responsible Roles and Position-Holders

Contractors/Vendors are businesses performing a service for the COMPANY. They are
responsible for ensuring their employees working on COMPANY sites understand and comply
with the requirements as outlined in this procedure.

Employees and Contracted Employees are all employees in any position whether
COMPANY or contracted employees working on any COMPANY site. They are responsible for
complying with the requirements as outlined in this procedure.

Visitors are anyone not employed by the COMPANY in any capacity but are traveling or
touring on a COMPANY site. They are responsible for complying with the requirements as
outlined in this procedure.

HSLP /Environmental is any COMPANY employee working under and including the
Regional Director of HSLP/Environmental. They are responsible for periodically auditing for
compliance to this procedure.

A Supervisor/Foreman or Designee can be a COMPANY employee or a contractor/

vendor working or traveling on any COMPANY site. They are responsible for enforcement of all
requirements, rules, and established guidelines as outlined in this procedure.

5 DIRECTION
All employees, vendors, contractors, and visitors traveling/working on site shall comply with
and ensure personnel accountable to them comply with the following requirements of this
procedure.

Supervisor/Foreman or Designee

• Shall identify risks and hazards and concerns in their area of responsibility, through
Inspections, Task Observations, group meetings, Investigation, etc. and promptly assign
a person responsible for implementing the corrective action and the date for completion
of the action.

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• Shall inform the person responsible for the corrective action of the completion date and
the requirements by the end of shift.

• Corrective actions requirements and completion dates shall be submitted to area HSLP/
ESR representative within 48 hours.

• Complete the corrective action as per commitments made and monitor its effectiveness.

General Supervisor/ General Foreman

• Review CAR reports provided to them by HSLP/ESR and COMPANY reports or action
items, then take appropriate actions designed to implement the corrective actions within
the established dates.

• Hazards and deficiencies you are personally accountable for, promptly assign a
corrective action and date for completion of the action.

• Provide this corrective action and completion date to your HSLP/ESR representative
within 48 hours for CAR corrective actions. Enter information for corrective actions and
completion dates in the computer software.

• Complete the corrective action as per commitments made and monitor its effectiveness.

HSLP/Environmental Business Assistant

• Enter corrective action data into the CAR or COMPANY database upon receipt.

• The CAR register will assign a document number once the required information (Date,
Operating Site, and Functional Area) is entered into the system from a series of drop-
down lists.

• Select the check-box labeled “Preventive Actions” in CAR, or choose “Preventative” from
the Action Type for those Corrective Actions that are indicated as preventive in nature.

• Generate CAR reports for area management at the request of your department
management.

HSLP / Environmental / External Affairs Representatives

• Ensure that corrective actions are promptly provided to your HSLP/ESR business
assistant for entry into the CAR system within 48 hours from receipt.

• Generate CAR reports for area management at the request of your department
management.

• Should verify that corrective actions are completed in accordance with the established
deadlines and that they are effective, through audits and according to area needs/
requests.

• Review the CAR compliance percentages with your Department management at least
monthly.

• Ensure that CAR scores are completed in a timely manner and included as part of the
monthly KPI score for HSLP.

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• Ensure that every entry code into CAR is also in the corresponding physical file.

• Ensure that every entry into CAR is properly coded as to its event type.

Manager

• Review CAR reports provided to you by your HSLP/ESR representative and other reports
or action items. Then take appropriate actions as indicated by the reports to insure that
the corrective actions are properly implemented.

• Review CAR reports with your staff at regularly scheduled staff meetings.

• For hazards you are personally accountable for promptly assign a corrective action and
date for completion of the action.

• Provide this corrective action and completion date to your HSLP/ESR representative
within 48 hours for CAR items.

• Randomly review corrective action for completion and effectiveness.)

• Be personally responsible for completing corrective actions as a result of actual major

and high potential accidents and incidents, S&S citations from MSHA, and Catastrophic/
Extreme risks identified from Risk Analyses.

Superintendents

• Review CAR reports provided to you by your HSLP/ESR representative and other reports
or action items. Then take appropriate actions as indicated in the reports to insure that
the corrective actions are properly implemented.

• Review CAR reports with your staff at regularly scheduled staff meetings.

• For hazards you are personally accountable for, promptly assign a corrective action and
date for completion of the action.

• Provide this corrective action and completion date to your HSLP/ESR representative
within 48 hours for CAR items.

• Ensure completion and effectiveness of corrective actions throughout area of

responsibility.

General Guidelines

• Once hazards and issues from a source are identified, corrective actions will be
established which should be preventive in nature and the person responsible for
correcting the hazard will be assigned specific activities for correcting. The issue will be
defined and estimated completion dates for the activity will be established and recorded.

• This information will be provided promptly to your HSLP/ESR Representative within 48

hours for CAR items.

• Once corrected, the information will be provided to your HSLP/ESR Representative for
entry into the CAR system.

• When dealing with a physical hazard which presents an imminently dangerous to life

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and health situation that cannot be immediately corrected without endangering persons,
property or the environment, the following steps shall be followed:
• Secure the area
• Remove all people at risk..
• Provide the person or persons responsible for correcting the hazard with
necessary physical safeguards, e.g. tapes, signs, barricades, etc.

• All items identified will be entered into the departments CAR.

• After the notification that the corrective action has been implemented, the area
superintendent shall monitor the effectiveness of the correction to assure that it has been
corrected properly.

• CAR reports will be provided to Area Managers monthly by your HSLP/ESR

Representative, and are to be reviewed at monthly meetings.

• Area Managers have the responsibility to distribute those reports within their
Departments to ensure the information is reviewed and corrective actions taken.

• HSLP Representatives will ensure that CAR compliance scores are used in the monthly
KPI calculations.

Risk Ratings and the CAR (Corrective Action) Process

• 3, 2, or 1 point has been assigned to each entry into CAR. These points indicate the
relative importance of this activity for preventing harm, and are based on probability and
consequence of loss factors for entri.

• If something is changing please refer to Change Management.

• Points for other activities are assigned based on relative importance of the general
activity. e.g. safety committee activities, safety meetings, 3 W’s etc.

• Points as indicated in the CAR are assigned as follows:

• Accident Investigations extreme and high potential or actual loss (3)
• Accident Investigations moderate potential or actual loss (2)
• Accident Investigations low potential or actual loss (1)
• Incident Investigations extreme and high potential(3)
• Incident Investigations moderate potential (2)
• Incident Investigations low potential (1)
• Inspections A hazard (3)
• Inspection B hazard (2)
• Inspections C hazard (1)
• Risk Assessments Extreme Risks(3)
• Risk Assessments High Risk(2)
• Risk Assessments other risks (1)

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• Observations, Tasks (2)

• Industrial Hygiene Sample > IDLH (3)
• Industrial Hygiene Sample > STEL (2)
• Industrial Hygiene Sample > TLV (1)
• Emergency Equipment Inspection (2)
• Emergencies (2)
• Emergency drills (2)
• Safety Committees (2)
• MSHA Inspections S&S (3)
• MSHA Inspections non S & S (2)
• Audits Environmental (2)
• Audits Other (2)
• Safety Talks (2)
• 3W (1)
• Other (1)

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