We integrate SHE requirements into
all operational activities including
those undertaken by contractors.
We manage changes proactively.
We plan and initiative effective
responses to emergencies.
2. CLICK BETWEEN SECTIONS HERE CONTENTS
CONTENTS
06
WHAT IS THE OUTPUT
OF OPERATIONS?
01
OPERATIONS
02
OPERATIONAL
CONTROL
03
CONTRACTOR
MANAGEMENT
04
MANAGEMENT
OF CHANGE
07
REFERENCE TO
STANDARDS
05
EMERGENCY PREPAREDNESS
AND RESPONSES
08
HOW DOES
OPERATIONS
FIT INTO
THE REST
OF THE
SHE WAY?
01 | 02 | 03 | 04 | 05 | 06 | 07 | 08
USING THIS DOCUMENT
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We integrate SHE requirements into
all operational activities including
those undertaken by contractors.
We manage changes proactively.
We plan and initiative effective
responses to emergencies.
OPERATIONS
01 | 02 | 03 | 04 | 05 | 06 | 07 | 08
OPERATIONS
PLANNING
Compliance obligations,
risks and opportunities
PERFORMANCE
EVALUATION
Updates for practical execution
challenges, changes and learning
from real and simulated events
OPERATIONAL
CONTROL
CONTRACTOR
MANAGEMENT
EMERGENCY
PREPAREDNESS
AND RESPONSE
MANAGEMENT
OF CHANGE
4. OPERATIONAL
CONTROL
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Implementation of the
SHE management system
and integration into day to
day activities and operations
is where we deliver on our
SHE commitments. Whilst
operations can be dynamic
in nature, our pillars of
value: safety, environment,
social, people, production,
cost/margin and returns/
financial remain constant.
We achieve consistency
through establishing and
maintaining an effective
control environment.
Effective controls enable
us to manage the identified
risks and opportunities and
also monitor, report and
review performance and
operational decision making.
It is important that where
we find controls aren’t
working effectively that
we make improvements.
Why? How?
The identification,
design and implementation
of controls must be
undertaken in accordance
with the four-step ORM four-
step approach and the ORM
Standard and Specifications.
This includes implementation
and monitoring of critical
controls as per the Fatal
Risk Control Program
and to prevent Priority
Unwanted Events (PUEs).
Controls design must
be tailored to all levels of the
organisation cascading from
Anglo American business and
operations management to
on-site works and individual
teams. Controls design must
include worker participation
and consultation. It must also
take into account specific
adaptations and constraints
whilst ensuring the
effectiveness of the control.
Risk and control
owners must be assigned
to all SHE controls
within Isometrix. They
are accountable for the
verification that the control
is being implemented and
operated as designed and
that it manages the risk
or opportunity in the
manner intended.
Approved measures to
actively manage SHE risks
and opportunities and meet
SHE compliance obligations
must be integrated into the
Operating Master Schedule
(OMS) and work management
processes. This includes but
is not exclusive to critical
controls. It will also include
additional controls required
for vulnerable or susceptible
persons or environments.
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ISO TERMINOLOGY AND
ANGLO AMERICAN OPERATING MODEL
5. OPERATIONAL
CONTROL
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How?
The Anglo American
control hierarchy is
elimination, substitution,
engineering, separation,
administrative and PPE
or physical environmental
protection controls. Once
designed, controls must be
implemented, monitored,
verified and continually
improved in line with the
ORM Standard and
Specifications.
Implementation of controls
must include communication
and documentation of these
controls to embed them into
processes such as:
- Elimination or substitution
recorded within the relevant
governance documents
for the project in the form
of a policy document or
equivalent
- Engineering and separation
controls are captured in
design, operations and
maintenance documentation
with clear indication made on
the further required layers
of control or action in case
of failure of the control
- Administrative or
behavioural controls including
but not exclusive to policies,
disciplinary matters, site rules
and instructions, procurement
guidelines, supervision.
campaigns and initiatives are
widely communicated, trained
and verified as understood
by those operating them
including third parties
- In the very rare case where
PPE or physical environmental
protection controls are the
main type of control used,
the exploration of other
options must be documented
and approved; and controls
must be accompanied by
a training and awareness
programme on the control
and the risks it is managing
- Task level SHE controls
such as administrative
and PPE controls and
reliance on engineering or
separation controls must
be included in Work
Execution Documents.
Controls for low
frequency events or
long-term risks, such as
many long-term health and
environment risks may
include monitoring of trigger
actions and escalation points
or low frequency periodic
activities. These must be
built into schedules and
activities even if they are
infrequent in nature.
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CONTROLS HIERARCHY
FROM ORM
ESTABLISHING A
CONTROL ENVIRONMENT
PERMIT TO WORK
6. OPERATIONAL
CONTROL
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How?
For all PUEs (risk
assessed as level 4 or 5
as per Anglo American’s
ORM matrix) related to
processes, products,
services and activities,
control strategies are
defined as part of the Issue
Based Risk Management.
Control strategies must
manage SHE risks and
not increase or introduce
additional SHE risks.
Where additional risks are
unavoidable, additional
controls and measures to
mitigate and counter these
must be deployed to reduce
the SHE risk on an ‘as low
as reasonably practicable’
(ALARP) basis and in all
cases lower than the
original risk before the
control was applied.
Use of instrumentation,
equipment and immediate
feedback must be used where
feasible as real-time controls
or real-time monitoring for
SHE risks and opportunities.
For automation and feedback
loops to be relied upon they
must be regularly maintained,
tested and verified.
Each Anglo American
business or operations must
define processes to ensure the
effective review, at least on an
annual basis, of operational
control systems, measures, and
processes. This includes but it is
not limited to conducting regular
PTOs ensuring that outcomes of
these activities are captured; and
corrective actions implemented.
It is recommended that such
details are recorded in Isometrix
for increased ease of tracking.
SHE risks and opportunities
are continually assessed
and addressed during work
execution through the ORM’s
fourth layer of Continuous
Risk Management which
aims to have everyone ‘stop
and think’ and then proceed
with a task or activity only
if safe to do so. Continuous
risk management must be
used by everyone to manage
risk during task execution
and ensure that controls are
in place and appropriate to
complete the work in line with
SHE expectations. This must
consider workplace conditions,
behaviours and/or interactions.
Everyone must be trained
in Stop – Look – Assess –
Manage (SLAM) tool and
apply the practice as part of
work execution and whilst
they are on Anglo American
sites and locations. Worker
participation and consultation
in controls design and
implementation must be
enabled to enable success.
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DESIGNING CONTROLS
LEVERAGE EXISTING WORK
MANAGEMENT AND ORM PROCESSES
7. CONTRACTOR
MANAGEMENT
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Contractors undertake
key roles and activities
in our Anglo American
businesses and operations
and are critical to meeting
our SHE commitments.
To maintain efficiency and
clarify our expectations,
we must communicate
our requirements
effectively and monitor
SHE compliance by third
parties taking action
where necessary.
We seek to create mutually
beneficial relationships
with our customers,
contractors, suppliers and
other business partners,
built on safe, fair and
ethical practices.
Why?
In line with Contractor
Performance Management
Policy and Procedures,
SHE risks and opportunities
and the effective management
of these must be built
into the full contractor
management lifecycle
including Define and Plan,
Sourcing and Contracting,
Pre-commencement,
Contract Execution and
Performance Management
and Close Out.
This includes:
- Sharing information with
regards to compliance
obligations, SHE risks and
opportunities associated
with the contracted work
with the Contractors formally
- Including compliance
obligations and critical control
responsibilities within contract
documentation
- Maintaining the same
SHE standard for contracted
activities as for internal
Anglo American activities.
Roles and responsibilities
for and of contractors at Anglo
American sites and locations
must be clearly identified and
documented with notifications
of poor and non-compliance
performance escalated and
acted upon promptly.
How?
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CONTRACTORS –
INFLUENCE OR CONTROL?
CONTRACTOR
PERFORMANCE MANAGEMENT
8. CONTRACTOR
MANAGEMENT
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Additional SHE risks and
opportunities resulting from
the use of contractors must
be evaluated and appropriate
controls designed and
implemented. SHE critical
controls that are significantly
or wholly reliant on contractor
activities and performance
must be verified to confirm
that they are in place and
effective and updated in
Isometrix. This includes
contractor SHE reporting
responsibilities such as
emissions, incidents and
accidents, waste and
water management.
For new SHE compliance
obligations and SHE risks
and opportunities such as
environmental concerns and
health notifications, proactive
communication with third
parties must be activated
to inform and advise them
promptly and to engage in
collaborative identification
and implementation of
solutions to address the
requirements. Contractors
will be similarly expected to
notify Anglo American of any
emerging SHE issues from
their activities and operations,
along with actions undertaken
to mitigate and manage these
issues; and must be actively
encouraged to do so.
How?
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SHE CONTRACTOR
PERFORMANCE MANAGEMENT
9. A Management of
Change process must
be implemented in line
with the Management of
Change Standard that
takes into account the
different complexities
and types of change. This
includes Planning and
Design, Implementation
and Management and
Performance Monitoring of
Management of Change.
How?
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MANAGEMENT OF CHANGE
Why?
Anglo American business
and operations work in a
dynamic environment and
are continuously evolving and
this mean introducing change
to initial assumptions and
plans. The Management of
Change process enhances the
SHE management system by
planning for the introduction
of new safety and health
hazards and environmental
aspects and impacts so
that compliance obligations
continue to be met, risks
and opportunities managed
and adequate emergency
response is in place.
Changes which require
Management of Change can
occur throughout business
and operational activities
and at all levels of the
organisation, they can be
difficult to identify but if left
unidentified, they are likely to
be a major cause of multiple
fatality incidents due to lack
of control over new risks
introduced. Prompt and
systematic identification of
changes through a strong
process with relevant
responsibilities assigned
enable new risks and
opportunities to be controlled
promptly and effectively
before issues occur.
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MANAGEMENT OF CHANGE
OR REPLACEMENT IN KIND?
DIFFERENCE BETWEEN
MANAGEMENT OF CHANGE
AND CHANGE MANAGEMENT
10. In line with the
Management of Change
Standard, Management of an
identified Change requires at
a minimum a review of the
relevant risk and opportunity
assessment performed. In
many cases, this will result
in identification of new
safety and health hazards,
environmental aspects and
impacts and compliance
obligations so new or changes
controls or measures need
to be put into place.
The Management of
Change must be documented
using the tool in Isometrix. If
no amendments are deemed
required after Management
of Change review and re-
assessment, this result must
still be formally documented
and approved.
Appropriate approvals
must be obtained for updates
made to SHE documents
resulting from change
before the change is made,
this may include but is not
exclusive to: scope of the
management system, hazard
inventory, environmental
aspects and impacts register,
compliance register, WRAC or
other baseline assessment
additions, Risk and Critical
Control Register (RCCR), Risk
Control Management Plan,
WEDs, SOPs, performance
measurements, guidelines,
communication materials,
stakeholder engagement
plans and materials etc.
Management of Change
outputs must be communicated
and implemented including
replacement of previous
instructions, signs or guidance
that are no longer required.
This includes communication
to workers, contractors and
relevant stakeholders.
How?
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MANAGEMENT OF CHANGE
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TYPES OF MANAGEMENT OF CHANGE
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EMERGENCY PREPAREDNESS
AND RESPONSES
Anglo American
Business and Operations
must implement the
processes and activities
required as per the
Emergency Management
Standard and the
Technical Specification
for Emergency Plans,
Training and Simulation.
This includes Planning and
Design, Implementation
and Management and
Performance Monitoring for
emergency preparedness
and response.
How?
Why?
Anglo American businesses
and operations are highly
dynamic and function in
dynamic environments.
Where SHE related incidents
and accidents do occur
despite our planning and
actions taken, we need to be
ready to mitigate impacts
swiftly and in a co-ordinated
manner to protect lives,
health and the environment.
In all cases, we learn from
all previous events (real
or simulated) and plan
our emergency response
considering the context in
which we operate, immediate
and longer term response
requirements, our workers
and stakeholders and
effective communication
internally and externally.
Adaptive, informed upfront
planning enables us to
respond quickly, effectively
and in a co-ordinated manner
to reduce safety, health and
environmental impacts
from emergencies.
Emergency preparedness
and response processes and
emergency response plans
prepared in accordance with
the Emergency Management
Standard must leverage
the activities of the SHE
Way (Context and Planning
specification chapters)
including prevention or
mitigation of identified
environmental impacts, safety
and health emergencies,
compliance requirements
and stakeholder needs and
expectations. Appropriate risk
and opportunity management
must also be applied to
additional SHE risks generated
by the proposed response
itself to reduce such effects
as far as possible, this
includes considerations of
products and materials used
and their potential long-term
environmental impacts.
Plans must include
appropriate processes
and arrangements for
post incident medical care,
ensuring medical treatment
is available for work-related
injury or illness and, where
necessary, a rehabilitation
program based on medical
advice. Mental health
and wellness impacts in
particular, must be considered
and addressed including the
need for employee assistance
programs or similar in the
aftermath of an emergency.
Drills and simulations
must be undertaken at the
frequency set out in the
Emergency Response Training
and Simulation Specification
and documented as per
the requirements of that
Specification.
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EMERGENCY EVENTS
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EMERGENCY PREPAREDNESS
AND RESPONSES
Contractors, visitors,
relevant community
stakeholders, neighbours and
regulatory agencies must be
informed of the requirements
of the emergency situation
arrangements and of
their respective duties
and responsibilities in the
situation. MEMORANDUM
OF UNDERSTANDING
AGREEMENTS must be
made with organisations
critical to the response
that clarify the response
understanding and the
resources, information,
communication and
co-ordination to be provided
by both parties.
Workers must be advised
on the emergency response
processes and plans and
must participate in the design
of the emergency response
with the aim of increasing
its applicability and fitness
for purpose in practice. This
may be undertaken through
the SHE Representative
Committee or similar forum.
The defined emergency
processes, performance and
planned response actions
must be reviewed (at least)
annually to ensure they remain
relevant and appropriate and
to capture any improvements
required. Feedback processes
must be in place so that post
emergency events and incidents
including near misses, risk
and opportunity assessments,
emergency response planning
is updated for improvements
and new information.
All SHE practitioners,
occupational health
practitioners and responsible
operational people shall
have access to up-to-date
Safety Data Sheets (SDSs)
and HAZMAT documentation
and relevant information
shall be communicated
to contractors, visitors,
emergency response services,
government authorities,
affected stakeholders and,
as appropriate, the local
community relating to
emergency situations and
responses. This communication
is not just during or post an
event but also with regards
planned response.
Documentation must
be maintained and retained
documented information
on the processes and plans
for responding to potential
emergency situations, to the
extent necessary to have
confidence that the processes
are carried out as planned and
considering appropriate location
for such documentation in the
case of an emergency.
How?
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EMERGENCY MANAGEMENT
TOOLS AND TEMPLATES
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WHAT IS THE OUTPUT
OF IMPROVEMENT?
Click between the SHE
Way sub-element tabs
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Contractor Management Management of Change
Emergency Preparedness
and Response
Operational
Planning and Control
DELIVERABLES DOCUMENTED EVIDENCE
– Control strategies approved, identified and implemented – Risk and critical control register
– Work execution documents including key controls
– Job risk analysis and SLAM
– Policies, engineering drawings and SOPs
– Isometrix controls module
– Risk and control owner assignment and training
– PTO results and actions taken
– Corrective work orders
– Controls handover between lifecycle phases
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REFERENCE TO STANDARDS
In undertaking the activities in this section, the following internal
and external standards are applicable (this is not an exhaustive list). Click between the tabs:
INT = Internal References and Standards
EXT = External Standards
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Contractor Management Management of Change
Emergency Preparedness
and Response
INT EXT EXT EXT EXT
INT INT INT
EXT
Operational
Planning and Control
INT
– Social Way: 3C Social and Human Rights Impact and Risk analysis (SHIRA)
– Anglo American Operating Model: Work Management and Process Performance
– ORM Standard: 3.2.3 Task based Risk Management, 3.2.4 Continuous Risk
Management, Specification F
– Biodiversity Performance Standard and Biodiversity Guideline
– Energy and GHG Emissions Standard
– Rehabilitation Standard
– Air Quality Performance Standard and Air Quality and Emissions Guideline
– Hazardous Materials Standard
– Waste Management Standard
– Workplace Health Standard
– Effects of Blasting, Minimising Impact Standard
– Explosive Handling Standard
– Mineral Residue Facilities and Water Management Structures Standard
– Water Management Standard
– Mine Closure Standard
– Fatigue Management Programme Standard Guideline
– Hearing Conservation Programme Standard Guideline
– Medical Surveillance and Wellness Screening Guideline
– Individual Fitness to Work Assessment Guideline
– Noise & Hearing Conservation Technical Specification
– Inhalable Hazards & Respiratory Conservation Technical Standard
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HOW DOES IMPROVEMENT FIT INTO
THE REST OF THE SHE WAY?
LEADERSHIP
Leadership and
commitment drives
effective SHE
performance in
operations by all. The
Roles, Responsibilities
and Authorities assigned
in the SHE management
system inform who
is responsible in
Operational activities.
The position of
contractors with regards
adoption of the SHE
Policy influences how
they are management.
The Consultation and
participation of workers
informs how SHE is
executed effectively
in operations.
CONTEXT
Context setting and
the scope of the SHE
management system
directly impacts
the nature and how
SHE is managed at
Operational level
including relationship
with contractors,
management of
change and emergency
response and planning.
Stakeholders identified
during the context
process inform who
and what needs to be
considered on a day
to day basis including
the potential impact of
emergency situations.
To enable effective
operations, Resources
and appropriate
Competence are required.
Engagement and
Participation activities
includes those with
contractors and
with stakeholders.
Communication is also a
critical part of an effective
control environment and
to implement operations
processes.
Effective day to day SHE
management includes
appropriate and accurate
Documented Information
in the right place at the
right time.
PERFORMANCE EVALUATION
The output of controls is reviewed in
Monitoring, Measurement, Analysis
and Evaluation. Controls and contractor
management are used
to Demonstrate for Compliance.
The SHE Way Assurance and Management
Review may identify challenges with the
Operations processes: management of
change, contractor management, operational
planning and control and emergency response
and planning that need to be addressed.
IMPROVEMENT
Information from actual operations
and (actual and simulated)
events informs what is needed
for Incidents, Non-conformities,
Corrective and improvement
actions and Continual
improvement.
Improvement activities may include
changes to operational processes
post planning. And including
identified learnings / feedback
into future planning?
OPERATIONS
SUPPORT
PLANNING
Compliance obligations, environmental aspects and
impacts, safety and health hazards and risks and
opportunities that require operational and emergency
planning and control are identified and prioritised in
planning. Objectives set in Planning inform the key
priorities of Operations with regards to SHE.
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