GHANA INSTITUTE OF MANAGEMENT AND PUBLIC ADMINISTRATION

(GIMPA)

TOPIC:
HEALTH, SAFETY AND ENVIRONMENTAL MANAGEMENT PLAN FOR
SOUTH TREATMENT PLANT (STP)-ANGLOGOLD ASHANTI

BY
ISAAC ASANTE-AMPONSAH
(12025374)

A THESIS SUBMITTED TO THE GIMPA PUBLIC SERVICE SCHOOL IN PARTIAL

FULFILLMENT FOR THE AWARD OF A POSTGRADUATE DIPLOMA IN
OCCUPATIONAL SAFETY, HEALTH AND ENVIRONMENTAL MANAGEMENT

DECEMBER 2013

DECLARATION

I, the undersigned, Isaac Asante-Amponsah, do hereby declare that, except for the references
to other researched works and publications which have been duly cited, this work is entirely
my own original ideas, thoughts, formulation and research work.
Furthermore, I submit that this project work has neither in whole nor in part been presented to
any institution nor examination board nor credited to anyone for any academic qualification
in this institution or elsewhere.

...................................................................
ISAAC ASANTE-AMPONSAH

DATE: ......................................................

..................................................................
MRS. FLORENCE AGYEI-MARTEY
(SUPERVISOR)

DATE: .....................................................

DEDICATION
2

I dedicate this thesis to my lovely wife, Kezia Serwaa Appiah, who supported me from the
beginning to the end to the program.
This thesis is dedicated to my parents, Mr. Joseph Asante who taught me that the best kind of
knowledge to have is that which is learned for its own sake. It is also dedicated to my mother,
Mrs. Regina Asante who taught me that even the largest task can be accomplished if it is done
one step at a time.
I also dedicate this to all my friends and colleagues who in one way or the other helped and
supported me through this program.

ACKNOWLEDGEMENTS
3

Mrs. Florence Agyei-Martey has been the ideal thesis supervisor. Her advice, and patient
encouragement aided the writing of this thesis in innumerable ways. I would also like to
thank Mr. Kenneth Yeboah whose steadfast support of this project was greatly needed and
deeply appreciated.
Above all I give glory and thanks to Jehovah God for his guidance and support.

ABSTRACT

With the plan-do-check-act approach being applied to health safety and environmental
management, there have been the development of individual standards such as ISO 14001
and OSHAS 18001. In each of these standards, there is much that is common. As a results
many organizations are merging the fragmented management systems into a single integrated
management systems.
This paper identifies the benefits of HSE plan and the effects of not having HSE plan. It also
identifies all legal requirement for health, safety and the environment.
Finally this paper outline the merit and demerits of using integrated management systems in
the development of HSE plans.

TABLE OF CONTENTS

CHAPTER ONE..1-2
1. Introduction1
1.1. Background.....2
1.2. Objective of the Health, Safety and Environmental Plan... 2
CHAPTER TWO..... 3-12
2. Importance of HSE Plan.... 3
2.1. Consequences of Not Having HSE Plan......... 5
2.2. Regulatory Plan... 8
2.2.1. The Labor Act, 2003 (Act 651) ... 9
2.2.2. Workmens Compensation Law...11
2.2.3. International Conventions....... 12
2.3. Procedures for Preparing HSE Plan.... 12
CHAPTER THREE..... 14-20
3. Methodology / Conceptual Framework...14
3.1. Overview of the Standards...14
3.1.1. ISO 14001..14
3.1.2. ISO 18001..14
3.2. Advantages of Integrated Systems....15
3.3. Disadvantages of Integrated Systems...16
3.4. The Deming Cycle..17
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CHAPTER FOUR.......21-30
4. Health, Safety and Environmental (HSE) Plan..21
4.1. Aim of the HSE Plan.......21
4.2. Objectives21
4.3. Responsibilities and Authorities..22
4.3.1. Managers...22
4.3.2. Supervisors....23
4.3.3. Employees.24
4.3.4. Safety Officers..25
4.3.5. Contractors...25
4.3.6. Safety Representatives..26
4.4. HSE Management System...26
4.5. Health...27
4.5.1. First Aid....27
4.5.2. First Aid Representatives..27
4.5.3. Accidents and Incidents...27
4.5.4. Accident/Incident Reporting and Recording...28
4.5.5. Injury Management...28
4.5.6. Personal Protective Equipment.29
4.5.6.1. Selection and Use of PPEs.. 29
7

4.5.7. Material Safety Data Sheet (MSDS).. 30

4.5.8. Medical Examination. 30
4.6. Safety.30
4.6.1. Communication.. 30
4.6.2. Safety Meetings Site Wide. 30
4.6.3. Safety Toolbox Meetings... 30
4.6.4. Safety Awareness... 31
4.6.5. Dispute Settlement..31
4.6.6. Safety Inductions....32
4.6.7. Managerial and Supervisor Staff32
4.6.8. Safe Work Procedures....................................................................33
4.6.9. Hazard Identification and Control..33
4.6.10. Job Safety Analysis..33
4.6.11. Hazard Reporting and Identification33
4.7. Environmental Awareness.35
4.7.1. Protection of the Environment........35
4.7.2. Storage and Disposal of Non-Toxic Waste Materials....35
4.7.3. Spillage Contingency Plan......35
4.7.4. Reporting Requirements.36
4.7.5. Spillage Control Requirements...36
8

CHAPTER FIVE.......3739
5.1. Introduction..37
5.2. Conclusion.37
5.3. Recommendations.37
5.4. References.38

LIST OF TABLES
2.1. The average estimated cost of accidents or occupational disease to employers ...8
3.1. Summary of the actions involved in delivering effective arrangements...18
4.1. HSE activities for supervisors

.24

4.2. Contractors HSE activities....26

10

LIST OF CHARTS
3.1. The Deming Cycle...20

11

CHAPTER ONE
1.0 Introduction
Historically mining has been one of the industries with the highest fatal and non-fatal injury
rates. Labor protection that is the prevention of occupational diseases and reduction in the
frequency of accidents, has always been a matter of great concern to the industry. It is
imperative that management promote and maintain high safety standards through applicable
measures to reduce frequency of accidents and occupational disease.
One of the major tools to prevent and reduce the frequency of accidents and occupational
diseases is the health and safety management plan
Health and safety management plan (HSMP) is a working document designed to take all
practicable steps to provide and maintain a safe work environment (health and safety
management plan, by Greg Davis)
Occupational health and safety management plan can also be defined as a plan that
demonstrates an organizational commitment to health and safety in the work place by
providing a clearly written statement of intent and plan of action for the prevention of
accidents and occupational illness and injury. (Developing an OHS plan for small businesses
and organizations by organization for victims of violence and human rights violations pg. 4).
Furthermore, according to the South Africa Labor Guide, a health and safety plan means a
documented plan which addresses hazards identified and includes safe work procedures to
mitigate, reduce or control the hazards identified.
1.1. Background

Keeping employees safe from risk and danger should be a priority for all employers and
employees. A safe, healthy working environment is good for business. It is not only essential
for the well-being of employees, but also for ensuring that the organization is successful and
sustainable.
Effective health safety and environmental management systems result from leadership and
commitment. Everyone has a duty to work safely and report hazards, but overall health and
safety plan is still needed.
A good SHE plan shows the employer is serious about making health and safety a core value
in the organization and building it into all operations throughout the organization. It also
provides both an internal and external motivation to continuously improve.
1.2. Problem Statement
As mentioned above, the nature of work and the number of hazardous substances used in the
gold processing industries have brought with its accompanying health, safety and
environmental issues. If theses health, safety and environmental issues are not managed
properly, it could give a bad image to the socio-economic importance of the gold processing
industry.
Though Anglogold Ashanti as a company has a general HSE management plan, there appears
to be virtually no documented HSE management plan for its processing plant to deal with the
specific hazards associated with the processing industries.
In order to address these shortfalls, this paper seeks to develop a Health and Safety
management Plan that conforms to the Anglogold Ashanti Health, Safety and Environmental
policy
1.3. Objective of the Health, Safety and Environmental Plan
2

The objectives of the HSE plan is to;

Explain the rules, monitor and improve the performance regarding health and safety
of employees at work and environmental protection.

Describe some of the tools to analyze, advice and review on health, safety and
environmental issues.

To describe the allocation of responsibilities at all levels of works,

satisfy the conditions of various legislation, such as the Mining (Health and Safety)
Regulations, 2012 (LI 2182)

1.4. Significance of Study

The reason why this study is significant can be explained from these aspects;

This study investigates the consequences of not having a Health Safety and
Environmental management plan. It identifies all the regulatory requirements, both
national and international, of managing health, safety and environment.

This study will also serve as a guide for the management of health safety and
environment at the work premises of the South Processing Plant (STP).

Finally, the study investigates why integrated system of health, safety and
environmental management is the ideal method of centrally identifying, evaluating
and managing risk across the processing plant as often risks are inter-related.

1.5. Scope of the Study

The scope of this project is limited to the gold processing plant and more specifically, to the
bio-oxidation (BIOX) method of gold recovery. The gold processing plant is undergoing
3

rapid infrastructural changes. This leads to the introduction of new hazards at the workplace.
The study seeks to investigate these new hazards and the existing ones. From the information
gathered a Health, Safety and Environmental management plan is developed.
1.6. Study Methodology
The study uses two sources of information for the collection of data. This includes interviews
and site visits. The data collection through interviews and site visits has been very important
because at South Processing Plant, which is used in the case study, issues concerning HSE
management plan is virtually non-existent.
The interviews were conducted in both English and Twi (local language in Ghana) depending
on the preference of the interviewee. In all, five (5) interviews with twenty (20) interviewees
(3 managers and 17 employees) were conducted. In order to ensure increase in validity of the
interview, notes were taken during the interview.
Site visits have been used as a way to examine the health, safety and environmental problems
on the ground. Being an engineering supervisor at the South Processing Plant and knowing
the plant well contributed to the site visits. The site visits part has contributed to the validity
of data from interviews. Moreover photographs were taken in all visits in to addition notes.
1.7. Limitation of the Study
The South Processing Plant runs 24hrs a day due to production demand. This has made most
of the employees of South Processing Plant have work schedules which is unstable or
unfavorable. This made the conduction of the interviews very difficult.
Some of the employees were not willing to disclose information. This was because the
workers have the view that the information gathered will be divulged to third parties and
could be used against them.
4

Another limitation of this study is time. In a study of this nature, time is of the essence. The
researcher had to combine the exercise with other academic and work activities at the same
time. Due to this limitation, the collection of information on the subject could affect the
outcome.

CHAPTER TWO
2. Importance of HSE Plan
Good HSE plan in the workplace can be positive for the entire company. Addressing health
and safety should not be seen as a regulatory burden. It offer a lot of benefits to both the
employer and the employees. Benefits include;

Improves workers morale

Increase productivity

Increase retention

Reduces replacement costs

Better working Conditions

Lower Insurance Costs

Increase Compliance

Improves Morale
A good HSE plan at work means that employees feel that management cares about their wellbeing. Offering comprehensive health insurance, an adequate amount of sick time, and a
range of health services that include counseling for mental health issues and savings accounts
for expenses not covered by insurance can help to raise employee morale. Higher employee
morale means less unscheduled time off taken by disgruntled employees.
6

Increased Productivity
A comprehensive HSE plan works with employees to help reduce accidents in the workplace,
and it also works to help speed up recovery times if an accident does happen. Accident
prevention through a safety program will increase employee productivity.

Increase Retention
Employees consider health and safety to be an essential part of their employment package. A
comprehensive HSE plan can be an incentive for employees to remain with the company and
reduce employee turnover.
Reduce Replacement Costs
Part of a HSE plan is proper maintenance and use of company equipment. When the
equipment is kept and used properly, it will last longer and cut down maintenance and
replacement costs.
Better Working Conditions
A HSE plan works to keep the workplace clear of hazards such as blocked hallways that can
be tripping hazards, overstocked shelves that can fall and other potential hazards. A focus on
a clean workplace can reduce the spread of disease and help to improve the overall health of
the company.
Lower Insurance Costs
7

Focusing on workplace safety through a HSE plan can help reduce insurance costs, according
to the Rochester Institute of Technology. Discussing the companys HSE plan with your
insurance agent to see what steps should be taken to lower the cost of the companys liability
insurance, and if offering a safer workplace can help lower the cost of health insurance
premiums

as

well.

Increase Compliance
A company that creates an HSE plan focuses on following internal and external workplace
safety laws. Focusing on workplace safety laws ensures that measures will be taken to be in
compliance with them. This not only helps to raise the level of safety in the workplace, it also
lowers the probability of lack of compliance fines. A focus on workplace safety can also help
protect a company in case an employee is hurt on the job and the employee sues. A company
is less likely to be held responsible if the HSE plan has brought the company in compliance
with safety laws.
2.1. Consequences of Not Having HSE Plan
The cost to employers of workplace injuries, work-related ill health and accidental damage
events has been estimated to be between 3.5 billion and 7.3 billion a year (HSE, 1999a).
These figures have been highlighted in a number of campaigns designed to demonstrate the
business case for improving health and safety performance.
The ILO constitution sets forth the principle that workers should be protected from sickness,
disease and injury arising from their employment. Yet for millions of workers the reality is
very different.
Gold processing plants are one of the areas of employment where hazardous conditions are
part of the everyday working environment. Safety is important in processing plant because of
8

the many risks to worker health. Understanding the consequence of poor health and safety in
the workplace can help in deciding where to make improvements. Below are some of the
consequences of not having HSE plan;

Reduced productivity

Increased premiums

Morale Problems

Corporate manslaughter and gross negligence manslaughter

Costs of accidents

Reduced productivity
When workers are calling out of work with illnesses or injuries, it can reduce the overall
productivity of the business. When a worker is out, someone else has to his job or a
replacement has to be brought in and trained. Each of these options will cost the company
time and money because it will slow productivity down.
Increased premiums
When there is a high rate of workers' compensation claims filed against a company, it may
find its premiums going up. Workers' compensation is like any other insurance-styled
program. The more claims a company have, the more the company is charged for the
coverage. Not having an HSE plan in place at your business can create an unsafe atmosphere
that can cause accidents and drive the numbers of claims through the roof.
Morale Problems

Employees who work together every day can become friends. When the work environment is
unsafe because of a lack of safety or health precautions and workers become affected, it can
cause the morale of the entire staff to plummet. Low overall morale is a natural consequence
of poor health and safety in the workplace. Low morale can decrease productivity and
increase employee turnover rates.
Corporate manslaughter and gross negligence manslaughter
If a breach of health & safety law causes a death, the organization responsible may be
prosecuted for corporate manslaughter and, even more serious still, an individual responsible
prosecuted for gross negligence manslaughter. The penalties on conviction for corporate and
gross negligence manslaughter are severe. Organizations convicted of corporate manslaughter
are liable to unlimited fines and remedial orders and individuals convicted of gross
negligence manslaughter can face up to life imprisonment.
Costs of accidents
Many employers believe that the insurer will pick up the costs of an accident, and that's why
they pay their insurance. However the costs of an accident can be broken down into the
direct costs and indirect (uninsured) costs.
Direct costs of an accident
Direct costs are those costs that are accrued directly from the accident. They are quite easy to
calculate, and include the medical costs incurred and the compensation payments made to the
injured workers. Direct costs are usually insurable by businesses.
Indirect costs of an accident

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Indirect costs are the less obvious consequences of an accident that can be costed. While the
indirect costs created by accidents are hidden, they too must be paid from profits from the
sale of products. They are more difficult to calculate and tend not to be insured. Indirect costs
include:

Time away from the job not covered by workers' compensation insurance;

Payment of other workers who are not injured, for example those who stopped work
to look after or help the injured worker and those who require output from the injured
in order to complete their tasks;

The cost of damage to materials or equipment involved in the accident;

The cost of overtime imposed by the accident (lost production, additional supervision,
and additional heat, light, etc.);

The cost of wages paid to the supervisor for time spent on activities related to the
accident. This includes caring for the injured, investigating the accident, and
supervising the activities necessary to resume the operation of business. All of these
activities will disrupt the supervisor's productivity;

Costs associated with instructing, training, and repositioning employees in order to

resume production. In some cases, it might even be necessary to hire a replacement
with all the associated hiring costs;

Medical costs paid by the employer that are not covered by the insurance. This may
include treatment facilities, personnel, equipment and supplies;

11

Cost of managers and clerical personnel investigating and processing claim forms and
related paperwork, telephone calls, interviews, etc.

Wage costs due to decreased productivity once the injured employee returns to work.
This is due to restricted movement or nervousness/cautiousness on the part of the
injured employee and time spent discussing the accident with other employees etc.

Costs brought about from any enforcement action following the accident such as
prosecution fines and costs of imposed remedial works.

The table below shows the average estimated cost of accidents or occupational disease to
employers
Human Cost

Lost Output

Resource Costs

Total

Fatality

991,200

520,700

900

1,500,000

Major Injury

18,400

16,200

5,200

40,500

Other Reportable Injury

2,700

100

500

5,800

Minor Injury

200

100

50

350

Average case of ill health

5,800

2,300

800

8,900

Table 2.1. The average estimated cost of accidents or occupational disease to employers
(HSE, 2006)
2.2. Regulatory Plan
Gold processing plant in the mining industries must commit to compliance with all legal and
other requirements that are applicable to their activities, products and services.
Section 24(1) of the 1992 Constitution states that Every person has the right to work under
safe and healthy conditions. This fundamental human right has been upheld by the Labor
Act, 2003 (Act 651).
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2.2.1. The Labor Act, 2003 (Act 651)

The Labor Act, 2003 (Act 651) established a National Tripartite Committee made up of five
representatives each of the Government, employers associations and organized labor with the
Minister for Labor as the chairperson (Section 112) and charged it, among other functions to
advise on employment and labor market issues, including labor laws, international labor
standards, industrial relations and occupational safety and health (Section 113 (1) (b)).
Section 115 (1) stipulates that the committee may set up sub-committees of the Committee in
such regions and districts as it considers necessary for the performance of its functions.
Section 118 (1) places a duty on the employer to ensure that every worker employed by him
or her works under satisfactory, safe and healthy conditions. Subsection (2) of the Section
118 specifies that:
Without limiting the scope of subsection (1), an employer shall
a) provide and maintain at the workplace, plant and system of work that are safe and
without risk to health;
b) ensure the safety and absence of risks to health in connection with use, handling,
storage and transport of articles and substances;
c) provide the necessary information, instructions, training and supervision having
regard to the age, literacy level and other circumstances of the worker to ensure, so far
as is reasonably practicable, the health and safety at work of those other workers
engaged on the particular work;
d) take steps to prevent contamination of the workplaces by, and protect the workers
from, toxic gases, noxious substances, vapors, dust, fumes, mists and other substances
and materials likely to cause risk to safety or health; supply and maintain at no cost to
the worker adequate safety appliances, suitable fire-fighting equipment, personal

13

protective equipment, and instruct the workers in the use of the appliances and
equipment;
e) provide separate, sufficient and suitable toilet and washing facilities and adequate
facilities for storage, changing, drying and cleansing from contamination of clothing
for male and female workers;
f) provide adequate supply of clean drinking water at the workplace; and
g) prevent accidents and injury to health arising out of, connected with, or occurring in
the course of work, by minimizing the causes of hazards inherent in the working
environment.
Subsection (3), however, obligates every worker to use the safety appliances, fire-fighting
equipment and personal protective equipment provided by the employer in compliance with
the employers instructions. The Act, in subsection (4), further absolves the employer of
liability for injury suffered by a worker who contravenes the provisions of subsection (3)
where the injury is solely due to non-compliance of the worker.
The Act in Section 119 protects the rights of a worker to remove himself or herself from any
situation in the workplace which he or she has reasonable cause to believe presents an
imminent danger to his or her life. In such cases, the Act forbids the employer terminating
the employment of a worker or withholding his or her remuneration. An employer cannot
require a worker to return to work in circumstances where there is a continuing imminent and
serious danger to the life, safety or health of the worker. The Act also requires an employer to
report occupational accidents and diseases which occur at the workplace as soon as
practicable as and not later than seven days from the occurrence to the appropriate
government agency (namely the Factories and Mines Inspectorates respectively. Diseases
should in addition be reported to the MOH / GHS).
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Finally the Act mandates the conduct of labor inspection to:

a) secure the enforcement of the provisions of the Act relating to conditions of work and
the protection of workers at their workplaces, including the provisions relating to
hours of work, wages, safety, health and welfare of the workers and the employment
of young people;
b) provide technical information and advice to employers and workers concerning the
most effective means of complying with the provision of the Act;
c) bring to the notice of the Labor Department or the Commission any defects of the
Act; and
d) report to the Labor Department or the Commission other unfair labor practices or
abuses not specifically provided for by the Act.
2.2.2. Workmens Compensation Law
The Workmens Compensation Law, 1987 consolidates, with amendments, the law relating to
compensation to workmen for personal injuries caused by accidents arising out of and in the
course of their employment. It brings together the law on compensation to workmen.
The basic provision is the principle of compulsory payment by an employer of compensation
in respect of death or disablement of a workman as a result of an accident occurring in the
course of his employment independently of negligence on the part of the employee or
fellow worker.
The Law deals with the liability of employers for the payment of compensation to workmen
as defined in the Law in respect of injuries resulting from accident, the amount of
compensation to be paid in the various cases which can arise, the method of calculating the
workmens earnings for the purpose of determining the compensation payable and the
persons to whom it is to be paid. The position with regard to occupational diseases is dealt
with by a legislative instrument under Section 31 of the Law. Thirteen of such diseases are

15

listed in the Third Schedule to the Workmens Compensation Regulations, 1967 (L.I. 546),
for workmens compensation purposes. The Law empowers the Minister responsible for
Labor to extend the provisions of the Law to incapacity or death certified as caused by any
disease specified in an instrument made under this section.
2.2.3. International Conventions
International declarations to which Ghana is a signatory also provide frameworks for
effective promotion and enforcement of OHS standards. Examples of such international
declarations ratified by Ghana include the following conventions of the International Labor
Organization (ILO):
I.

Convention 81 - Labor Inspection (02/07/59)

II.

Convention 115 - Radiation Protection Convention (07/11/61)

III.

Convention 119 - Guarding Machinery (18/03/65)

IV.

Convention 120 - Hygiene (Commerce and Office) (21/11/66)

V.

Convention 148 - Working Environment (Air Pollution, Noise and Vibration)

(27/05/86)

The provisions on occupational safety and health within Labor Act 651 are consistent with
ILO Conventions 155 of 1981 on Occupational Health and Safety and the Working
environment, and Convention 161 of 1985 on Occupational Health Services, which Ghana is
yet to ratify.
2.3. Procedures for Preparing HSE Plan
The following reference standards were used during the development of this HSE Plan:

Ghana standards for Environmental Protection Authority (EPA)

ISO 14001 Environmental Management Systems

16

Occupational Safety and Health Assessment Series 18001

The structure of this HSE Plan is similar to that of the above standards, which are
representative of SHE management systems. Similar to these Standards, the Plan-Do-CheckAct continual improvement framework have been adopted for this HSE plan.

17

CHAPTER THREE
3. METHODOLOGY / CONCEPTUAL FRAMEWORK
STP must not only achieve legislative compliance but produce gold which represent the best
practices in HSE performance. With this in mind, the project will utilize the integration of
ISO 140001 and OHSAS 180001 OHS management systems.
3.1. Overview of the Standards
3.1.1. ISO 14001
ISO 14001 is also based on the PDCA cycle.4 Top management sets the vision for an
organization in its environmental policy; the EMS is then designed to support the policy. An
organization must develop procedures to identify the ways it affects the environment, identify
relevant legal and other requirements, and set objectives and targets that will continually
improve the management system and prevent pollution. An organization uses the planning
information to develop operations that manage the environmental impact of its activities,
products or services. Then top management reviews the performance of the EMS to
determine the need to change the system to ensure it supports the organizations
environmental policy.
3.1.2. ISO 18001
OHSAS 18001 was developed by registrars and organizations to fill a market demand to
manage OHS issues. While it is not officially an international or national consensus standard,
it is being adopted by many organizations as a logical and complementary approach. This
specification recognizes the similarities between environmental and OHS issues and is
patterned after ISO 14001. Though it is organized like ISO 14001, it has been modified to

18

reflect the different parties associated with OHS issues. An organization can get a high return
on investment by taking advantage of the similarities between the three standards and
integrating their quality, environmental and OHS management systems.
Some organizations that have successfully integrated portions or all of their management
systems include those in the chemical, automotive, technology, steel, service, pulp and paper,
and medical products industries. Each has experienced significant returns from reduced
operating costs, management system complexity and time required to manage the process.
These organizations have also discovered employee satisfaction often improves once an
integrated approach to job descriptions, work instructions and priority setting is implemented.
3.2. Advantages of Integrated Systems
Simplified systems.
Employees working for an organization with an integrated management system can perform
their jobs using one set of work instructions rather than multiple, sometimes conflicting,
documents from different management systems. Confusion is minimized when employees
know when to use each document and under what circumstances. The chance that documents
from different systems conflict is also reduced. A single training process for new employees
typically minimizes contradictions.
Optimized resources.
One system that meets the requirements of all three standards minimizes the resources
required to develop, implement and maintain separate systems. Maintaining single processes
for employee training, document control, management review, and corrective and preventive
action requires fewer resources than developing and maintaining multiple processes to
accomplish similar goals.
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Improved organizational performance.

A formal system that helps identify potential problems, risks or hazards can reduce or
eliminate workers complaints, product nonconformities, accidents, illnesses or environmental
incidents in the workplace. In addition to reducing quality related risks, it can also reduce
costs associated with environmental cleanups, workplace injuries, illnesses, fatalities and
fines from regulatory compliance organizations
Integration of environmental and OHS objectives into the overall business strategy.
This eliminates the idea that quality, environment and safety are separate or nonessential parts
of the business. An established framework for continual improvement of quality,
environmental and OHS systems. Management not only establishes goals and objectives for
quality, environmental and OHS systems, but it also reviews them at regular intervals to
ensure progress is being made. Management also identifies opportunities for improvement. A
formal corrective and preventive action system identifies ways to improve the system and
ensures all actions are verified as being effective before they are closed out.
3.3. Disadvantages of Integrated Systems
A tendency to develop over-documented, bureaucratic processes.
This is true for single management systems and increases for systems intended to meet the
requirements of multiple standards. Organizations tend to write lengthy, complex procedures
and work instructions that gather dust because they are rarely used. This causes employees to
grumble about the bureaucratic management system that doesnt let us do our business.
Turf battles.

20

If a QMS already exists, environmental and OHS professionals often resist tacking their
requirements onto the existing quality system. Likewise, quality professionals often resist
contaminating the system with requirements that do not relate to the quality of the product.
Limits on degree of integration.
ISO 14001: 1996 and OHSAS 18001:1999 are highly compatible and can be readily
integrated. However, some OHS and EMS requirements do not easily integrate with existing
quality systems. For example, aspect identification and significance determination, as well as
legal and other requirements, do not readily fit with an existing QMS.
3.4. The Deming Cycle
This is also known as the PDCA- Plan, Do, Check, Act. The Plan, Do, Check, Act approach
achieves a balance between the systems and behavioral aspects of management. It also treats
health and safety management as an integral part of good management generally, rather than
as a stand-alone system.

21

Plan, Do,

Conventional health and safety

Process safety

Check, Act
Plan

management
Determine your policy/Plan for

Define and communicate

implementation

acceptable performance and

Profile risks/Organize for health

resources needed
Identify and assess risks/Identify

and safety/Implement your plan

controls/Record and maintain

Do

process safety knowledge

Check

Measure performance (monitor

Implement and manage control

before events, investigate after

measures

events)
Act

Reviews performance/act of lessons Measure and review performance/Learn

learned

from measurements and findings of

investigations

Table 3.1. Summary of the actions involved in delivering effective arrangements. (HSG65
2013))
Plan

Think about where you are now and where you need to be

Say what you want to achieve, who will be responsible for what, how you will
achieve your aims, and how you will measure your success. You may need to write
down this policy and your plan to deliver it

Decide how you will measure performance. Think about ways to do this that go
beyond looking at accident figures - look for leading as well as lagging indicators.
These are also called active and reactive indicators

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Consider fire and other emergencies. Co-operate with anyone who shares your
workplace and co-ordinate plans with them

Remember to plan for changes and identify any specific legal requirements that apply
to you

Do

Identify your risk profile Assess the risks, identify what could cause harm in the
workplace, who it could harm and how, and what you will do to manage the risk

Decide what the priorities are and identify the biggest risks

Organize your activities to deliver your plans

In particular, aim to: Involve workers and communicate, so that everyone is clear on
what is needed and can discuss issues - develop positive attitudes and behavior

Provide adequate resources, including competent advice where needed

Implement your plan Decide on the preventive and protective measures needed and
put them in place

Provide the right tools and equipment to do the job and keep them maintained

Train and instruct, to ensure everyone is competent to carry out their work

Supervise to make sure that arrangements are followed

Check

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Measure your performance Make sure that your plans have been implemented,
paperwork on its own is not a good performance measure

Assess how well the risks are being controlled and if you are achieving your aims. In
some circumstances formal audits may be useful

Investigate the causes of accidents, incidents or near misses

Act
Review your performance Learn from accidents and incidents, ill-health data, errors
and relevant experience, including from other organizations
Revisit plans, policy documents and risk assessments to see if they need updating.

Fig 3.1. The Deming Cycle

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CHAPTER FOUR
4. HEALTH, SAFETY AND ENVIRONMENTAL (HSE) PLAN
4.1. Aim of the HSE Plan
The STP HSE management plan has been developed to document the Safety & Environment
Management systems to be implemented and maintained by STP in accordance with the
scope of works that has been detailed for the processing plant.
4.2. Objectives
The Objective for this includes:

Anglogold Ashantis HSE policies

Systems and control measures for managing the works to be completed in a safe
manner

HSE responsibilities and authorities of management, supervisors and employees;

Procedure for the administration of HSE activities;

Processes for recording/reporting of HSE performance;

Safety management systems for the identification and management of potential

hazards;
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Interfaces with legislative requirements.

The plan is intended as a working reference and will provide both line management and
employees with the responsibilities and authorities necessary to achieve the objectives of the
companys HSE policy. This plan has been developed from industry standards and has regard
to the codes of practice that will form a minimum compliance requirement for STP.
Statutory requirements also apply to this plan and shall be adhered to at all times. Irrespective
of the source or application, standards, policies and codes of practice higher than those
outlined in this plan shall apply.
4.3. Responsibilities and Authorities
4.3.1. Managers
Managers shall be responsible and accountable for the implementation HSE and
rehabilitation policies and procedures.
The position carries the prime responsibility to demonstrate, through proactive measures, the
commitment of STP to all environmental and safety issues. Proactive measures shall include
management-initiated actions to improve the safety and environmental systems together with
prompt response to meaningful suggestions and/or recommendations from all employees
The Manager shall ensure that:

All employees are accountable for HSE performances within their area of
responsibility;

Appropriate safety standards are set through participation and consultation with all
personnel including employees and contractors.
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All quality, safety and environmental reports and inspections are reviewed and will
initiate appropriate rectification responses where necessary;

There shall be an active participation in all accident/incident investigations;

There shall be active participation in safety/environment meetings and programs;

Monitoring for compliance with environmental and safe work methods shall occur.

4.3.2. Supervisors
It is recognized by senior management that supervisors play an important role in the effective
implementation of the safety program. Every effort shall be made by senior management to
encourage feedback from the floor as a vital part of the Safety Management System.
Supervisors shall play an active role on the safety committee. Duties include:

Reporting to the Manager;

A working knowledge of Anglogold Ashanti HSE policies;

Ensuring planned safe working methods are implemented;

Identifying and eliminating safety and environmental hazards in the workplace;

Incorporating safety and environment instructions when allocating tasks;

Convening tool box meetings;

Attending safety and environment meetings;

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Participate incident investigations

Ensuring safety, quality inductions of all new personnel

Undertake safety and environment inspections of workshops and/or sites;

ACTIVITIES

FREQUENCY

Identify hazards in working areas

Daily

Attend safety toolbox meetings

Daily

Participate in monthly hazard inspections

Monthly

Participate in accident and incident investigations

As required

Authorize safe work permits

As required

Tab. 4.1. HSE activities for supervisors

4.3.3. Employees
STP believes that safety is our first value.
Employees shall:

Take reasonable care for their own safety and health

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Use all personal protective equipment that is issued to meet safety requirements

Report all identified hazards, defects in plant or equipment no matter how minor

Make all endeavors to warn other employees of known hazards

Comply with statutory, safety and environmental requirements for the workplace

Assist in achieving goals set by management

Actively support the project safety and environmental policies

Maintain a sound knowledge of safe work practices;

Comply with guidelines formulated and distributed through inductions, toolbox

meetings and site instructions.

4.3.4. Safety Officers

The Safety officer is required to:

Review, on a regular basis, all of the HSE policies and guidelines to ensure
compliance with statutory requirements and objectives

Assist with the proper implementation of the HSE Management Plan

Provide assistance and advice with the inspection and audit programs

Attend safety toolbox meetings and provide advice as required;

Assist with the preparation of accident/incident reports and investigations

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Assist management in maintaining a pro-active approach to safety, quality and

environment and advise on the adequacy of resources

Attend safety committee meetings as required

Assist in the preparation of Job Safety Analysis.

4.3.5. Contractors
Contractors are accountable for:

Safety performance in their respective areas of control;

Compliance with the HSE Management Plan where they have not already had a
system in place or current systems are below the standards set out by the Anglogold
Ashanti.

Provision and maintenance of safe systems of work.

The development and provision of Job Safety Analysis and safe work procedures for
their unique systems of work.

ACTIVITIES

FREQUENCY

Develop JSAs for their scopes of work

As required

Provide, where requested, representation to project safety meetings

As required

Conduct workplace hazard inspections (formal and informal)

Daily/weekly

Conduct toolbox safety meetings

Daily

Conduct pre-start meetings

Daily

Report and investigate accident/incidents within their area of control

As required

Tab. 4.2. Contractors HSE activities

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4.3.6. Safety Representatives

HSE representatives shall, where elected;

Be familiar with the statutory requirements applicable to the position;

Work with the respective supervisor to overcome day-to-day problems;

Attend scheduled meetings to discuss the safety program with Line Management;

Attend Safety Committee meetings as required

Carry out the normal duties for which they were originally employed.

4.4. HSE Management System

This HSE plan has been developed to properly document the HSE Management systems to be
implemented and maintained by STP in the execution of its scope of works.

4.5. Health
4.5.1. First Aid
First Aid facilities, equipped to a level commensurate with the risk shall be provided and will
be fully maintained at all times. Supplementary facilities or eye wash stations shall be located
at locations considered to be necessary.
All injuries treatments shall be entered into the STP first aid register and reported to the
Occupation Health Department. Injuries requiring medical attention or further consultation
may be referred to the Edwin Cade Memorial Hospital.
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4.5.2. First Aid Representatives

All qualified first aid personal shall be identified with an approved sticker depicting a white
cross on a green background on their safety helmets. Names of attendants shall be located on
safety notice boards.
All employees shall be made aware of the first aid post location and the identification of first
aid personal in specific work crews at the Area Safety Induction and Orientation session
4.5.3. Accidents and Incidents
All incidents that result in injuries or illness to any person, cause property damage, have an
adverse effect on the Environment or are classified as being a near miss event, shall be
reported to the HSE officer via the Anglogold Ashanti accident/incident report form.
This important component of the HSE System relies upon;

Immediate notification.

Ensuring that correct and responsible personnel are involved.

Providing detailed and true accounts of incidents.

Proper completion of the Incident/Accident Report Form.

Responsibility levels based on the severity or potential severity of the incident.

Results from Accident/Incident investigations may determine the need to review and improve
working procedures to prevent recurrence of a similar accident/incident occurring again.
4.5.4. Accident/Incident Reporting and Recording

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All STP employees and contractor personnel are required to report all accidents and/or
dangerous occurrences involving personal injury, plant or equipment damage and
environmental incidents directly following the occurrence.
It is the responsibility of the Safety Manager and Supervisors to fully investigate the
occurrence with personnel involved utilizing the standard Incident/ Injury Investigation
Report form and procedures.
4.5.5. Injury Management
In the event where any person is injured, then that person will be required to report the injury
as soon as possible to the immediate supervisor, and must promptly proceed to the nearest
First Aid Facility to be assessed and receive first aid treatment from the First Aid personal.
An Incident/Injury Investigation report form and the Workers Compensation forms shall be
completed in all cases where the persons injuries require First Aid assistance and or medical
treatment whether or not time off work has resulted from the incident. If the injury is of a
severe nature, the injured person shall be taken to the Edwin Cade Memorial hospital for
further treatment. The site ambulance shall be called if deemed necessary by the First Aid
personal.
4.5.6. Personal Protective Equipment
All clothing and protective equipment, essential to the protection of workers, shall be
provided for use by workers. This equipment may include:

Gloves

Hearing protection

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High visibility garments

Breathing apparatus

Eye protection (goggle)

Fall protection equipment

The minimum PPE requirements for entry onto the plant shall consist of:

Long trousers

Reflector jackets

Steel capped boots

Eye protection (goggle)

Safety Helmets.

During the development of all control measures, the JSA procedure shall be used to assist in
minimizing the reliance upon PPE.
4.5.6.1. Selection and Use of PPEs
GE shall ensure that all employees and sub-contract personnel are instructed and/or trained in
the correct use of each PPE item prior to use.

4.5.7. Material Safety Data Sheet (MSDS)

34

In the case of importing transporting storage and usage of hazardous chemicals, STP shall
receive MSDS from the suppliers. The MSDS shall be posted at the entrance of the storage
area and where the chemical is being used so that all workers can easily have access to these
information.
4.5.8. Medical Examination
There shall be pre-employment examination for every worker. Employee shall free medical
care and the medical expenses shall be borne by Anglogold Ashanti.
4.6. Safety
The main target for safety is zero injury that is no negative impact to people during the
operations of STP.
4.6.1. Communication
Regular structured safety meetings shall provide a base for communicating potential issues,
safety hazards, safety initiatives and programs.
4.6.2. Safety Meetings Site-Wide
The Safety Manager shall ensure that all site-wide safety meetings have minutes of the
meeting recorded. Meetings shall initially be held weekly.
4.6.3. Safety Toolbox Meetings
Safety meetings shall be held on a daily basis by each section. The HSE representative shall
chair the daily safety toolbox meetings. The purpose of these meetings will be to enable the
HSE representative and supervisors to discuss and where necessary provide explanations for
safety related subjects in a concise manner so as to ensure the understanding and interaction
35

of participants. Details of all safety meetings including attendees, topics or any concerns
raised from topic discussions and proposed actions shall be recorded using the standard
Anglogold Ashanti toolbox report form.
4.6.4. Safety Awareness
Safety bulletins, alerts, posters and signs shall be utilized to ensure employees are kept up to
date with current activities, trends or other promotional activities. Safety alerts issued
management shall be posted on specific notice boards and discussed at the next scheduled
site-wide safety meeting.
4.6.5. Dispute Settlement
If an employee has reason to believe that they are or will be exposed to a workplace hazard,
they shall report to and discuss the situation with their immediate supervisor and workplace
HSE representative. Employees shall be re-deployed to a safe working area. The situation
shall be dealt with in the following order;

If the matter is not resolved, the Work Place Supervisor and HSE

Representative shall jointly obtain the relevant technical data and safety advice in an
attempt to resolve the matter to the satisfaction of all concerned.

In the event that the matter is not resolved, the Supervisor, HSE Representative and
the HSE Committee (where applicable) shall discuss and attempt to resolve the matter
to the satisfaction of all concerned.

If the matter is not resolved the matter shall be referred to Senior Management for
resolution.

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4.6.6. Safety Inductions

Prior to any work commencing, new employees, including transferred and reclassified
persons are given an induction designed to promote awareness of safety rules and standards.
The supervisor shall be responsible for ensuring employees working under their direct control
are advised of the specific requirements relevant to their scope of work: It shall be the
responsibility of Plant Management to ensure that all of the employees competency
information is registered on a Skills Matrix and a copy is held on site so as to ensure that
all assignments are safely allocated and are commensurate with employee skill levels.
Prior to commencing of any major project, Supervisor/Manager or nominees will be
responsible for ensuring that all contractors are given a site safety induction and an area
specific induction designed to promote awareness of safety rules and standards.
4.6.7. Managerial and Supervisory Staff
STP shall ensure that managerial and supervisory personnel are competent and understand the
requirements in Occupational Safety and Health.
4.6.8. Safe Work Procedures
It shall be the responsibility of all Supervisors to identify their site and work specific safety
requirements. The procedures necessary for safe completion of the required work could be all
or any of the following, but is not limited to:

Safety tagging and isolation systems

Confined space entry;

37

Hot work permits;

Excavation (permit to dig);

Toxic substances;

Restricted access;

Special clothing;

Vehicle movement;

Crane/rigging activities;

Security.

4.6.9. Hazard Identification and Control

All individual work packages shall be fully evaluated to identify potential hazards inherent to
the proposed method of work or as a result of the local work environment. The following
section details the methods identified to suitably control and document the processes that
form the integrated systems approach to be used on site.
4.6.10. Job Safety Analysis
The Job Safety Analysis (JSA) process shall be used as one of the primary hazard
identification and control processes. Where practicable the JSA shall be utilized in lieu of a
detailed written procedure. The relevant supervisor shall be responsible for completing an
initial draft of the JSA and passing it to the Safety Manager for approval.

38

The Supervisor and work crew shall review the JSA and add final comment immediately
prior to commencement of the task.
4.6.11. Hazard Reporting and Identification
All employees shall be encouraged to correct hazards on a see and fix basis, providing it is
within their ability and it is safe to do so. Any hazard, that is outside their ability to handle or
cannot be rectified immediately, shall be isolated and made safe from general access through
the placement of barricades and warning signs and be reported to the immediate supervisor.
The Supervisor shall initiate an immediate and appropriate action. The employee should also
notify all persons who are present in the area of the hazard. Where an employee encounters
what they believe to be a HSE hazard or is allocated work to perform that they consider
unsafe, they shall immediately advise their Supervisor.
The work in question shall not be performed until such time as the matter has been finally
determined, except under such conditions as may be agreed between the parties.
Should the grievance remain unsolved, the supervisor and the employees HSE representative
shall meet and inspect the work area to determine a resolution to the safety grievance.
Should the parties be unable to resolve an issue, the HSE Officer shall be asked to assist in its
resolution. If the grievance is still not resolved, a representative of the regulatory authority
may be requested, by any of the parties, to advise on the application and interpretation of
relevant Acts, Regulations or site requirements.
All parties shall endeavor to maintain continuous and productive work for those workers not
in the immediate area. Their Supervisors shall, when required, allocate all employees who

39

have been removed from the area where a safety hazard is believed to exist, alternative work
in another area.
The Process for hazard reporting shall be discussed with all employees at the time of
induction.

4.7. Environmental Awareness

4.7.1. Protection of the Environment
All or any wildlife that enters the plant will be reported to the Environmental Protection
Officer and will be left undisturbed until arrangements can be made for safe removal in
accordance with approved procedures.
4.7.2. Storage and Disposal of Non-Toxic Waste Materials
All non-toxic waste materials will be placed into skip bins for removal by an authorized
waste removal company and will be taken by that company to a waste disposal facility in
accordance with the law.
Skip bins will not be permitted to be over loaded and shall be emptied as soon as they reach
bin height.
Disposal will be achieved by the use of authorized contractors who are licensed to accept the
particular categories of waste.
Disposal and destruction records will be kept of all hazardous waste materials that are
removed from site.
40

4.7.3. Spillage Contingency Plan

All employees will be advised during their pre-start inductions of the spill response procedure
and will be advised of the need to comply with these procedures.
Ongoing reminders will be provided as discussion components of pre-start and toolbox safety
meetings.

4.7.4. Reporting Requirements

Every incident that occurs, where there is potential for an impact to be made against the
environment, shall be covered by this procedure and will become a reportable event.
Every reportable event shall be recorded on the AGA Incident Report form and a copy shall
be forwarded to the Environment Department for review.
4.7.5. Spillage Control Requirements

Check and ensure that there will be no risk of personnel injuries occurring during the
"Clean-Up"

Immediately seek to Stop, Reduce or Control the flow/spread of a spillage.

Provide a soil based bund around the spill to prevent any flow towards sumps or
drains.

Notify management immediately so that the Environment Department can be

informed

41

Collect the entire spilt product and contaminated soil and place into hazardous
materials skip bin.

Any collection of the spilt product by use of spill kit pads will require that they shall
be properly bagged and placed into the hazardous waste skip for disposal.

The collection and disposal of contaminated wastes will be by licensed contractor and
delivery will be to an approved and licensed facility.

CHAPTER FIVE
5.1. Introduction
The aim of this project has been to develop an HSE plan for Anglogold Ashantis South
Processing Plant (STP). In this chapter, conclusion and recommendations are made base on
the findings of the study made during site visits and the interaction with workers about health
and safety awareness
5.2. Conclusion
From the study, site visits and discussions with workers, including managers, the following
conclusions were arrived at;

Workers were found being unconcerned with use of safety equipment.

42

PPEs are of inferior quality.

Incentives to motivate workers for a good health and safety record does not exist.

Workers do not use the provided PPEs in the right way.

At times workers work in conditions that might affect their health and safety.

Workers tend to take a lot of shortcuts.

Workers hesitate to report incidents and near misses for fear of being punished.

5.3. Recommendations
From the above conclusions, it is recommended that,

Awareness should be created about the why it is very important to use safety
equipment proper, and not tempering with it.

PPEs must be of good quality. It should conform to international standards.

Workers conform to health and safety standards must be recognized and motivated to
serve as fine example for others to follow.

There should be strong supervision.

Workers must be included in health and safety decision making that affects them
directly.

Adequate authority and resources to responsible parties should be provided.

Managers, supervisors, and employees must be held accountable for meeting their

43

health and safety responsibilities. Program operations must be reviewed at least

annually, to evaluate, identify deficiencies, and revise, as needed.

all employees understand the hazards to which they may be exposed and how to
prevent harm to themselves and others from exposure to these hazards.

5.4. References
Phil Hughes and Ed Ferret (2007). Introduction to Health and Safety at Work Third edition.
City of Richmond Department of Public Utilities (August 2008). Health, Safety, and
Environment Management Plan.
Health and Safety Executive for Northern Ireland (2011). Example health and safety plan; a
practical guide for the smaller contractor.
Lawrence Berkeley National Laboratory (July 2013). Integrated Environment, Safety, &
Health
Management Plan; Integrated Safety Management (ISM) System.
Engineer Ezzedine El Hamzoui. Occupational Health and Safety Management System
(OHSMS).
Organization for Victims of Violence and Human Rights Violations OMEGA Health Care
Center (Austria 2003). Developing an occupational health and safety plan for small
businesses and organizations.
Ian Dalling and Barry Holt (IIRSM) (March 2012). Management Integration: Benefits,
Challenges and Solutions.

44