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Such
specificity ages quickly, it is unlikely to be suitable in all conditions and often retards
progress. Hence, its proper place is in the manager’s code which can be changed rapidly if
improvement is desired. However, in Recommendation 12.1.4 (and also in Section 10.5.1) one of
the five principles listed as follows:
“..the support rule should be based on the best available knowledge and experience, and
should include the use of hydraulic props at prescribed densities;”
In my view the second part of the statement should be replaced by the following: “…and should
include the use of the best practicable support and support density
appropriate for the site;”. (The
underlined words represent my changes.) The prescription of particular support means and/or
density belongs to the manager’s code.
ORGANISATION OF THE MINE HEALTH AND SAFETY INSPECTORATE
Recommendations 12.2.1 to 12.2.15 and the whole of Chapter 11 deals with the organisation and
the structure of the MHSI. The recommendations contained here are all prescriptive. Little or no
room is provided for any deviation. I am not familiar with the duties and responsibilities of the
Inspectorate sufficiently intimately to feel comfortable with such a dogmatic set of
recommendations. A life time of experience suggests, however, that local conditions and
requirements often circumscribe the manner in which an institution can be structured. Also, I
venture to add that the input of the current managers into the plans for
re-organisation is usually
valuable and often essential.
There are a number of points in the recommendations that especially worry me:
* While the high level of qualifications and experience specified (Section 11.1.8 & 11.1.10) would
be ideal and desirable, these goals may not be achievable in South Africa today. Furthermore,
the wholesale importation of foreign mining engineers (who are unfamiliar with conditions in
South Africa and lack hard rock mining experience), as Principal or Senior Inspectors, is not an
acceptable solution. Thus, we can indicate the ideal, but the actual solution will have to be found
by the people who will have the responsibility to reorganise the Inspectorate.
* I am in full agreement with the notion that the intensity and frequency
of mine inspections
should be linked strongly to the frequency of accidents and health violations experienced by the
various mines and quarries. I am not convinced, however, that the establishment of the two tiers
Inspectorate (where the lower tier is a quarry inspectorate) is an appropriate part of the solution
of the problem (Recommendation 12.2.2). While this scheme appears to have worked well in
Great Britain, it may not be ideal in South Africa, where the country’s geography and the nature
(that is type, size etc.) of its surface mining operations are very different.
* In Recommendation 12.2.9 (see also Section 11.1.11) the opportunity
is provided for the
employment of twelve Assistant Inspectors and twelve Sub Inspectors. While this proposal
appears to open the door, the rigid requirements of high academic qualifications and recent
mining experience at a senior level seem to restrict the advancement of these persons.
I suggest, therefore, that it would be prudent to treat the organisational structure proposed in
Chapter 11 as an illustrative example of the desired goal and not as the blueprint for the new South
African Mine Safety and Health Inspectorate.”
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APPENDICES TO VOLUME 1
INDEX
APPENDIX
CONTENTS
PAGE
1.
List of Organisations
and Persons who submitted
Written
Representations
174
2.
List of Witnesses who gave Oral Evidence and
the Location of the Evidence in the Transcript.
175
3.
List of Exhibits handed in to the Commission
178
4.
List of Members of the Chamber of Mines of South
Africa
(April
1994).
182
5.
Standards of Accommodation in Bylaws of the City of
Johannesburg.
184
6.
Comparison of Remuneration Packages in Mine
Management
and
in
the
Inspectorate
Graph
186
7.
Further comments relating
to health matters in
existing
legislation.
187
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APPENDIX 1
THE FOLLOWING ORGANISATIONS AND PERSONS SUBMITTED WRITTEN
REPRESENTATIONS:
The Chamber of Mines
The National Union of Mineworkers
Western Platinum Limited
S A National Group of Rock Mechanics
Ergotech
Mr M R A Göllner
MAC
Performance Consulting
Council of Mining Unions
Mineworker’s Unions
S A Society of Occupational Health Nurses
NOSA - Mining Division
W C H Dobbin
SASOL
Mine Site Technologies
S A National Committee on Illumination
Mr P P Nyakane
Underground Official’s
Association of South Africa
Hallback & Braun S A (Pty) Ltd.
Mr H F du Toit
ASPASA (Sand Producers)
Underground Railway Association
Mr J J Kruger
Cemtec Mining Products
Mr B J Smith
National Productivity Institute
Mr Richard Spoor of Watters & Co.
(on behalf of Chemical Workers Industrial Union)
DMEA
NPI
ESKOM
SASOHN
NOSA
Highveld Steel and Vanadium Corporation Ltd.
Council for Nuclear Safety
The Mine Ventilation
Society of South Africa
Mine Medical Officers Association of South Africa
SGS South Africa (Pty) Ltd.