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OCCUPATIONALHEALTHMANAGEMENTGUIDELINES

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ii AA Occupational Health Guidelines - Issued 7 November 2002

Preface

This set of guidelines has been produced by a team of occupational health physicians drawnfrom Anglo American (AA) companies and the members of the AA Labour and EnvironmentalLaw Unit. The Guidelines are not intended to be a complete treatise on occupational healthand should not be read as such. It is recognised that there is a great deal of untappedexpertise in AA and it is hoped that the Guidelines will create seed for feedback. TheGuidelines will then be used to inform international best practice at AA operations.

The intention is to suggest an approach rather than a rigid management system.

Each guideline has a number of measurable outcomes that may be used for audit purposesand which summarise the approach suggested by the guideline.

The first chapter "Introduction to the AA Occupational Health Management Guidelines"describes the aims and objectives for occupational health in AA companies. All the guidelinesshould be read in conjunction with these aims and objectives.

FH FoxDF BarnesJZ EloffDB de VilliersCJ LotterCD DixonTL Chabana

Disclaimer:

The guidelines contained herein are for the consideration and use of the parties to whom they refer.

They shall not be interpreted to impose any legal duties on such parties neither shall they be used to

attach any liability to such parties. The material contained in these guidelines is based on information

believed to be reliable. However, no representation or warranty is made as to the accuracy or

completeness of the information.

Neither AA nor any company in the AA Group accepts responsibility to any third party in respect of these

guidelines which are indicative only and are for the assistance of operating companies within the

AA group in formulating their approach to occupational health risks. Such operating companies are

individually responsible for managing the safety, health and environmental (SHE) matters associated

with their own operations and assets.

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iii AA Occupational Health Guidelines - Issued 7 November 2002

CONTENTS

Preface iiDisclaimer iiList of tables viList of figures viList of acronyms used in the text vii

Introduction to Anglo American Occupational Health Guidelines 1Aims and Objectives 1

1 Scope of application 12. Introduction 13. Aims 24. Assistance and information 2Occupational Health Management Systems 3

1. Introduction 32. Definition 33. Proprietary systems or standards 44. Management systems 55. Measurable outcomes 6Occupational Health Risk Management 7

1. Scope 72. Introduction 73. Occupational health risk management 74. Measurable outcomes 8Occupational Hygiene 9

1. Introduction 92. Definition 93. Organisational principles 94. Functional perspective: risk management 115. Data acquisition and analysis: practical considerations 126. Communication 157. Professional status and accreditation 158. Measurable outcomes 16

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iv AA Occupational Health Guidelines - Issued 7 November 2002

CONTENTS (continued)

Occupational Exposure Limits (OELs) 17

1. Scope 172. Introduction 173. OELs 174. Recommendations 185. Measurable outcomes 19Biological Monitoring 20

1. Scope 202. Introduction 203. Biological exposure indices (BEIs) 204. Use of BEIs 205. Recommendations 216. Measurable outcomes 21Risk-based Medical Surveillance 22

1. Scope 222. Introduction 223. Risk-based medical surveillance 224. Measurable outcomes 27Occupational Health and Contractors 28

1. Introduction 282. Definition 283. Suggested approach 284. Measurable outcomes 29Emergency Preparedness 30

1. Introduction 302. Planning and resources 303. Rehearsal 314. Measurable outcomes 31

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v AA Occupational Health Guidelines - Issued 7 November 2002

CONTENTS (continued)

Audit 32

1. Introduction 322. Definitions 323. Recommendation 324. Reporting 335. Measurable outcomes 33Ethics 34

1. Introduction 342. Principles 343. Code of ethics 354. Measurable outcomes 35Reporting and Key Performance Indicators 36

1. Introduction 362. Reporting at business unit level 363. Reporting to group 364. Key performance indicators (KPIs) 375. Measurable outcomes 37Information Systems and Record Keeping 40

1. Introduction 402. Information systems 403. Record keeping 424. Measurable outcomes 42

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vi AA Occupational Health Guidelines - Issued 7 November 2002

LIST OF TABLES

Table 1: A Stepwise Approach to Developing a Medical Surveillance Programme 26

Table 2: Occupational Health KPIs (lag indicators) 39

LIST OF FIGURES

Figure 1: Occupational Health Framework 3Figure 2: Elements of a Management System 4Figure 3: Functional Organisation of an Occupational Health Programme 10Figure 4: Links Between Industrial Hygiene, Medical Surveillance

and Human Resources Information Systems 41

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vii AA Occupational Health Guidelines - Issued 7 November 2002

List of acronyms used in the text

Acronym DescriptionALARA As low as reasonably achievableACGIH American Conference of Governmental Industrial HygienistsBEI Biological exposure indexHAZMAT Hazardous materials programmeHEG Homogenous exposure groupICOH International Commission on Occupational HealthILO International Labour OrganisationMSDS Material safety data sheetOEL Occupational exposure limitOES Occupational exposure standardOSH Occupational safety and healthOREP Occupational risk exposure profileSHE Safety, Health and EnvironmentSIMRAC Safety in Mines Research Advisory Committee of South AfricaSTEL Short-term exposure limitTLV Threshold Limit Value™ (ACGIH)TWA Time-weighted averageWHO World Health Organisation

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Aims and Objectives

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Introduction to Anglo American Occupational Health Guidelines

AIMS AND OBJECTIVES

1. Scope of application

1.1 These guidelines are designed to assist all operating companies and Divisionsas well as joint ventures in which AA or a subsidiary have no less than a 50 percent interest in formulating their approach to occupational health risks.

1.2 Contractors are encouraged to adopt these guidelines.

1.3 Joint ventures and other companies in which AA has an interest shouldconsider the guidelines for application.

2. Introduction

2.1 Occupational health was defined by the ILO/ WHO joint committee onoccupational health in 1950 as the “promotion and maintenance of thehighest degree of physical, mental and social well-being in all workers in alloccupations …” This ideal has been carried through into numerous ILOconventions, occupational health and safety legislation in most countries andrecently into the ILO guideline on occupational health and safety managementsystems “ILO OSH 2001”.

2.2 AA has made a commitment to occupational health in its statement ofbusiness principles (published in April 2002) and its SHE policy (published inSeptember 1999). In both these documents the stated aim is to “prevent orminimise work-related injuries and health impairment of employees andcontractors”.

2.3 As a multinational company AA strives to maintain high standards ofoccupational health and safety and seeks to apply them consistently across alloperations and in all the countries in which it operates.

2.4 In all countries the absolute minimum standard must be legal compliance butwhere local legislation does not meet the standard implicit in these guidelines,it is recommended AA companies use these guidelines to assist them inachieving good occupational health practices.

1 AA Occupational Health Guidelines – Issued 7 November 2002

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2.5 This document is intended to provide guidelines to good occupational healthpractice and is a living document that will grow with experience gained overtime.

3. Aims

3.1 In keeping with the stated objective of OTTO (which for occupational healthshould be taken as zero tolerance for health risks and target zero foroccupational illness) the aim for AA companies is to reduce all occupationalexposures to a level at which the risk to health is minimal. This is in contrastto the concept of a “safe level” which may still result in ill-health over a longperiod of exposure. A change in focus in the risk management process frommere legal compliance to a strategy aimed at the prevention of risk to healthis necessary.

4. Assistance and information

4.1 To assist in the application of the Guidelines, information, assistance andexamples of best practice are available from the SHE Policy Unit.

2AA Occupational Health Guidelines – Issued 7 November 2002


OccupationalHealth

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Occupational Health Management Systems

1. Introduction

1.1 The objective of this section is not to describe in full detail an occupationalhealth management system, but rather to highlight salient points.

1.2 Occupational health cannot be managed in isolation. It must be part of anintegrated occupational safety and health (OSH) or safety, health andenvironment (SHE) management system or any sustainable developmentinitiative. This, in turn, must be seamlessly integrated into the generalmanagement system of the company. The primary responsibility for health andsafety lies with a particular operating company's management (hereinafterreferred to as "management"), who should ensure that the systems andresources are adequate to meet the occupational health needs of the company.Occupational health and safety professionals provide specialist input asrequired. The system should be a dynamic one built around clear objectives, adefined approach to acceptable risk, clear communication and a commitmentto continuous improvement. The occupational health service provider, whetheroutsourced or internal, should have a direct line of communication to the chiefoperating officer or equivalent of the company concerned.

2. Definition

2.1 Occupational health is taken to mean the discipline that involves bothoccupational hygiene and occupational medicine and wherever the term is usedin these guidelines it should be read as such.


AA SHE policy

SHE policy andmanagement atoperational level

AA occupationalhealth guidelines

OHS legislation/national andinternational guidelines

Figure 1: Occupational Health Framework


Continuous improvement

Policy

Evaluation

OrganisingManagement review

Action forimprovement

Planning &implementing

Risk assess-ment

3. Proprietary systems or standards

3.1 There are a number of international standards or guidelines available onsuitable structures for an OSH or SHE management system. Examples of theseare the British Standards Institute (BS8800) “Guide to Occupational Healthand Safety Management Systems”, the joint Australia/New Zealand standard(AS/NZ 4801) “Occupational Health and Safety Management Systems –Specification with guidance for use”, OHSAS 18001 and the ILO document(ILO-OSH 2001) “Guidelines on occupational health and safety managementsystems” are the reference documents of choice. All of these have a verysimilar approach and the choice of any particular standard for the individualoperation would be determined by the fit with the existing managementsystem and the local legislation.

3.2 The ILO guideline is generic and has been written to cross national boundariesand will be used to illustrate the recommended approach.

3.3 Occupational health and safety legislation is under constant review and notwo countries are ever at the same stage in this process. Figure 1 shows theframework for this. Companies are encouraged to strive towards the higheststandards, so there is consistency across the entire organisation.


Figure 2: Elements of a Management System


4. Management systems

4.1 Figure 2 shows the main elements of an OHS management system. Theseelements are common to the guidelines mentioned in the introduction and toISO 14001. They also reflect the principles outlined in the AA plc SHEManagement Guidelines. Some elements from figure 2 are extracted forfurther emphasis below.

4.2 Policy: It is recommended that SHE policy at a local level is developed inconsultation with employees informed by AA policy and incorporating therequirements of the relevant national legislation (figure 1). This spells out thecommitment by both management and employees to safeguard health andsafety and provides the skeleton upon which the system is built. The languageshould be simple and concise. Signature of the policy by an appropriate seniormanager indicates the requisite management commitment to OHS.

4.3 Risk assessment is central to the management of occupational health. Thisshould not be seen as a complex process and may involve little more thansimply considering the consequences of one's actions before starting work;the more complex the task, the more complex the risk assessment process. Inorder for this to be achieved, risk assessment must be integrated into the dailymanagement processes of the business. Competent risk assessment providesthe starting point and defines the scope of further action. This will be dealtwith in more detail in the guideline on risk management, (see Guideline on Occupational

Health Risk Management) but in short, risk assessment should take place at threelevels. The first is an initial status review (baseline) of all possible healthrisks. This involves the listing of all potential health hazards and a preliminaryassessment of the health risks. The second level is a more detailed look at thespecific risks (issue-based). The final level is the implementation ofcontinuous (ongoing) risk assessment. This may involve one or both of regularoccupational hygiene monitoring and a medical surveillance programme. On apersonal level, continuous risk assessment is the state in which every risk isassessed as and when work is done.

4.4 Continuous improvement is an integral part of any management system. Toachieve this, measurable objectives should be set and performance againstthese measured. The results of these measurements can then be fed back intothe system to ensure that standards of practice are constantly improved. Goodcommunication and a system of internal controls are essential to this process.Audit, both internal and external, is part of the road to continuousimprovement. External audit, performed by a competent person, adds valuablecredibility to the management system.



4.5 Management review is essential if an occupational health management systemis to improve. Since the primary responsibility for occupational health lies withmanagement, the active involvement of management in occupational healthissues cannot be too highly stressed. Periodic management reviews should beconducted to evaluate the overall strategy of the OH management system.The frequency and scope of periodic reviews by the most senior accountableperson in the operating company will depend on local circumstance, but it isrecommended that as a minimum, such a review is carried out annually. Thefindings of the management review should be recorded and formallycommunicated for action to the persons responsible for the relevant elementsof the OH management system and to employees.

4.6 Employee participation: Employees and where appropriate, their electedrepresentatives, should (to the extent reasonably practicable) be consulted onmatters affecting the health of employees in the workplace. This appliesparticularly to the formulation of a health policy in the workplace and to theinitiation, development, promotion, maintenance and review of measuresnecessary to ensure a healthy working environment. All employees must workin such a way that they protect their own health and that of others.

5. Measurable outcomes• The company has a signed policy committing to the management of

occupational health practice that is informed by AA plc policies and guidelinesand relevant National Legislation.

• Risk assessment is central to the management of occupational health in thecompany.

• Adequate occupational health resources are available to effect policycommitments.

• Communication, education and training on occupational health aspects is evident.

• The process of continuous improvement is integrated into the occupationalhealth risk management system.

• Management review of the occupational health management system is evident.

• Employees participate in occupational health at all levels, from policydevelopment through to review of practice.

• Regular audit of occupational health practice occurs.



OccupationalHealth Risk

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Occupational Health Risk Management

1. Scope1.1 This guideline forms the basis on which to approach the concept of

occupational health risk management.

2. Introduction2.1 Occupational health hazards are present in most work places. Identification of

these hazards, assessment of their risk to employee health and the treatmentof this risk is the cornerstone of good occupational health practice.

3. Occupational health risk management3.1 Hazard identification, risk assessment and risk treatment comprise risk

management.

3.2 Three different, but inter-related, hazard identification and risk assessmentprocesses are commonly described:

• Baseline hazard identification and risk assessment, the purpose ofwhich is to determine the current status of occupational health risk;

• Issue-based hazard identification and risk assessment, the purpose ofwhich is to conduct a detailed risk assessment of a particular issue; and

• Continuous (on-going) hazard identification and risk assessment; thepurpose of which is to promptly address hazards that are encounteredduring day-to-day operational management. This will includereassessment whenever there is a process change or an emergencysituation arises, resulting in abnormal operating conditions.

3.3 Once hazards have been identified and risks assessed, the risk may be treated by:

3.3.1 eliminating the risk;

3.3.2 controlling the risk at source;

3.3.3 minimising the risk; and in so far as risk remains;

3.3.4 providing personal protective equipment (PPE); and

3.3.5 introducing a programme of risk monitoring.

3.4 This risk treatment process requires ongoing review and this is where occupationalhygiene measurement and medical surveillance results play a critical role.



Example

It is useful to illustrate this risk treatment process by example, such as the noisefrom a pneumatic rock-drill that may result in noise-induced hearing loss. The riskmay be treated as follows:

Eliminate : Replace pneumatic rock drills with other technologysuch as hydro-power drills.

Control at source : Reduce the noise level by better cylinder design (muffler).Minimise : Reduce employee access to noise areas.Remaining risk : PPE, hearing protective devices.Monitor : i) Noise measurement

ii) Audiometry


3.5 The specific order of priority for the treatment of risk (as mentioned on theprevious page) is contained within Article 6 of the ILO Convention 176.

3.6 The risk treatment process needs to be effective in ensuring that the risk isrendered tolerable.

3.7 Tolerable risk, itself, depends on societal values. The AA approach in thisregard is to strive for international best practice and meet all applicable lawsand regulations as a minimum.

3.8 It is recognised that there are different approaches used in addressing each of:hazard identification, risk assessment and risk treatment. It is theresponsibility of AA companies to demonstrate that their approach to riskmanagement is consistent with the principles detailed above.

3.9 Auditing a company’s approach to risk management against these genericrequirements will provide a way of measuring occupational health input.

4. Measurable outcomes

• A structured approach to management of occupational health hazards is present.

• The company’s approach to occupational health risk management incorporatesthe concepts of baseline, issue-based and continuous risk assessment.

• The order of priority in which risk is treated (eliminate, control at source,minimise, PPE and monitoring) is evident in the management of occupationalhealth risk.


OccupationalHygiene

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Occupational Hygiene

1. Introduction

1.1 The distinguishing features of all realistic occupational health programmes arethe existence of two main operational arms, namely occupational hygiene andoccupational medicine. The former deals with the prevention of exposure tooccupational health hazards, whereas the latter is concerned with the earlydetection of exposure consequences i.e. occupational disease, and subsequentmanagement.

2. Definition

2.1 Occupational (or industrial) hygiene is ‘the science and art devoted to theanticipation, recognition, evaluation and control of those environmental factorsor stresses, arising in or from the workplace, which may cause sickness,impaired health and well-being, or significant discomfort and inefficiency amongworkers or citizens of the community’.

2.2 The organisational implications of subscribing to the above definition are setout below.

3. Organisational principles

3.1 In translating the definition of occupational hygiene into practice, the keyelements to be observed are listed below.

• The various environmental factors or stresses may be classified as:

° chemical e.g. airborne mists, vapours, gases, or solids;

° physical, e.g. electromagnetic radiations, noise, vibration,pressure and temperature extremes;

° biological, e.g. bacterial contamination; and

° ergonomic, notably the physiological and psychological stresses ofdifferent tasks.

• ‘Anticipation’ implies a thorough understanding of the operation in itsentirety, as well as of its processes and procedures, to the extent thatany potential risk can be predicted, identified and listed. This is theprimary input to the assessment of risk.

• ‘Recognition’ represents the qualitative assessment of risk. To beeffective, the process must be systematic, sensitive and ongoing.



• ‘Evaluation’ is the quantitative assessment of risk and must beconducted to satisfy both local and international standards. Theemphasis falls on technical competency and methodology, includingstatistical analyses appropriate to the data. Employee exposure is ratedin terms of internationally recognised limits (e.g. occupational exposurelimits (OELs) or threshold limit values (TLVs)) and linked to medicalsurveillance, providing input to the management of such risks.

• ‘Control’ can be equated with risk treatment. Specifics cannot beprescribed but the hierarchy of control to be exercised is, in order ofpreference:

° elimination;

° control at source (e.g. design, maintenance, shielding andsilencing);

° minimising exposure (shift system design, adjustment of rosters,job rotation, work/rest cycles, etc.); and

° personal protection or receptor control (personal protectiveequipment, medical and physical fitness assessments, medicalsurveillance).(See Guideline on Occupational Health Risk Management.)


Potential riskNo significant risk

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Significant risk

Measure exposure:• airborne – OELs

Personal protective equipment

Start

Monitoring programme:• methodology• design• implement• link to medical surveillance

Maintain,Inspect, andTest controls

Review if:• significant changes• new information• legislation changes

Medical surveillance:• pre-exam• periodical exam• biological – BEIs• exit exam

Source (engineering) controls

Minimise (administrative) controls

Elimination, substitution & isolation

Ensure the use of:• information, instruction, training• rules and procedures• supervision

Workplace Risk Assessment

Select or design controls of:• exposure, and• spread of contamination

Figure 3: Functional Organisation of an Occupational Health Programme


• The anticipation-recognition-evaluation-control axis is an ongoing cycleof events and must be subjected to a system of monitoring that issufficiently sensitive to prompt a realistic programme of regular review.The basis of such reviews, and the ultimate criterion of success, is thedose-response (exposure-consequence) relationship.

• The term ‘inefficiency’ in the definition implies strong links withproduction and productivity. The system of review therefore, needs tocater for such correlations to ensure that the focus of the occupationalhealth programme remains relevant to the company’s core business.

• As can be seen from the definition, occupational hygiene ismultidisciplinary (engineering, physics, chemistry, biology, etc.) and itis unlikely that all of the qualifications, skills and experience would bevested in one individual. AA companies are accordingly urged toestablish teams drawn from in-house expertise (specialist support canbe contracted in as required). The team should ideally be headed by anoccupational hygienist qualified in terms of either local and/or AAguidelines.

• The objectives of occupational hygiene are not restricted to employeesbut also to ‘citizens of the community’ [In Sir Ernest Oppenheimer’swords: “the communities in which we operate”]. As a matter of bestpractice the risk management process also needs to cover this sector.

• In the consideration of airborne pollutants in the occupational healthprogramme (see Figure 3) it is suggested that the definition of“significant risk” be >10% of the OEL for particulates and >50% ofthe OEL for gases.

4. Functional perspective: risk management

4.1 From the definition presented in Section 2 (above) it would be evident thatoccupational hygiene embraces both risk assessment (anticipation, recognitionand evaluation) and risk treatment (‘control’). Functionally, therefore, theintegration of risk assessment (problem definition) and risk treatment(problem resolution) constitutes occupational hygiene (See Guideline on Occupational

Health Risk Management).



4.2 The most critical outcome of the risk management process is the extent towhich occupational disease is contained. Medical surveillance statistics arefundamental whenever risk management is subjected to review. In turn theefficacy of medical surveillance depends significantly on the quality ofemployee exposure data, i.e. risk assessment. These aspects are reiteratedbelow (paragraph 5). Safety statistics should also be considered as part of theexposure data and, especially where medical conditions may be suggested ascauses for accidents, used to fine tune medical surveillance. The rationale isthat safety is not unrelated to sickness, impaired well-being, discomfort andinefficiency.

5. Data acquisition and analysis: practical considerations

5.1 Purpose-developed data sets

5.1.1 The primary purpose of risk assessment is to identify health and safetyhazards and provide information meaningful to eliminating orcontrolling the hazard at source. This is accomplished throughengineering practices and, as such, represents a significant componentof risk treatment. Under circumstances where the hazard cannot beeliminated or controlled to within acceptable levels, risk assessmentneeds to be extended to take cognisance of employee exposure. Thisinformation is fundamental as it allows for the next level in thehierarchy of risk treatment to be introduced, i.e. minimising exposureby using shift systems, adjustment of rosters, job rotation etc. Medicalsurveillance is also informed by employee exposure and, in turn, (See

Guideline on Risk-based Medical Surveillance) provides important feedback into theoverall risk management process.

5.1.2 Two distinct sets of data should therefore be generated through the riskassessment process. Firstly, a data set to serve the purpose of effectingelimination or control at source; the origin or source of the hazard needsto be identified and the extent of the hazard quantified. An example isa rock drill (source) operating at peak levels of 115 dBA. (Thisinformation is irrelevant to medical surveillance because it gives noindication of actual employee exposure.) Secondly, an exposure dataset, normally expressed as a time-weighted average (TWA) for anominal shift duration of eight hours, quantifies the health risk andprompts efforts to minimise employee exposure and risk-based medicalsurveillance. This will typically be based upon personal dosimetry for thehazard in question. (See Guideline on Risk-based Medical Surveillance.)



5.1.3 For example, the efficacy of noise control engineering can quiteobviously be expressed in terms of reduction in sound pressure levels.However, the overall success of the entire risk management programmecan only be judged by the outcome of medical surveillance, i.e. theaudiometric status of exposed employees.

5.2 Data acquisition

5.2.1 Employee exposure data should be expressed in relation to recognisedoccupational exposure limits (OELs).(See Guideline on OELs.)

5.2.2 The data acquisition protocol or monitoring frequency should be basedon sound statistical methods. The consistency of instruments, includingcalibration, is of fundamental importance. The underlying objective isthat sampling should be ‘representative’. In this respect, professionaljudgement is of paramount importance.

5.2.3 The term ‘representative’ needs qualification. Where exposures aregenerally less than the OEL, the homogenous exposure group1 (HEG)concept could be applied, irrespective of the specific occupation. Wherethe OEL is exceeded, or where indicators of occupational disease arepresent, the HEG-based approach should be revised to focus on high-risk occupations. In this respect ‘representative’ would apply to specificoccupations and may even be extended to ‘task’ level under exceptionalcircumstances.

5.2.4 Although sampling frequency is dictated primarily by statisticalrepresentativeness, it is practice in some instances to increase thefrequency of sampling the closer the exposure levels become to theOEL in question. The purpose here is to increase the responsiveness tothe heightened risk. However, increasing the frequency of sampling,without addressing the problem through appropriate interventions,serves no useful purpose in itself.

1 The concept of an homogenous exposure group entails dividing employees into groups with similarexposure. Typically this might involve categorisation of exposure as shown below.

The sampling strategy for each group is determined by the level of exposure. The number of samplesand frequency of sampling should be greater in category A than category C. Similarly, the categoryof exposure drives the urgency and extent of corrective action.

Source: Simrac Handbook of Occupational Health Practice in the South African Mining Industry

Category Personal exposure levelA Exposure exceeds the OEL

B Exposure between 50% and 100% of the OEL

C Exposure between 10% and 50% of the OEL




5.3 Risk matrix indices

5.3.1 The use of a risk matrix is a useful way to prioritise risk despite theelement of subjectivity inherent in such estimates. The rating is basedon the combined impact of consequence (or severity) and probability.

5.3.2 Safety risk ratings are more common than the health counterpart and toan extent, less problematic. For example, the long lead times associatedwith health outcomes mean that direct comparison of health and safetyrisks require circumspection.

5.4 Database applications

5.4.1 The data sets described above should be combined into a database, theultimate design of which will depend on the needs of its users but willneed to permit specific analyses and re-arrangement of raw data. Someof the more pertinent needs are:

• identification of potentially excessive exposures during normalroutines and periodic out-of-routine operations;

• analyses of trends, e.g. over time (hourly, daily, weekly,seasonally, ‘long-term’)and in relation to variations in productionrates and work schedules;

• demonstration of the efficacy of risk management programmes(system of review);

• comparisons of exposure data with the outcomes of medical(disease) surveillance;

• facilitating epidemiological studies, both retrospective andprospective;

• generation of periodic reports, including annual company reports toshareholders;

• providing the basis for policy review; and

• compliance reporting. (See Guideline on Reporting and Key Performance Indicators.)


6. Communication

6.1 As a matter of best practice clear lines of communication should beestablished between occupational hygiene and other key structures.

• The occupational hygiene-occupational medicine (medical surveillance)link, as already inferred, is fundamental to the integrity of the overalloccupational health programme, as well as to policy review andimplementation at both corporate and/or company level.

• To ensure transparency, communication with employee representativeorganisations (e.g. ‘Health and Safety Committees’) is necessary.

• Education and training (awareness) programmes are often effected byother departments (e.g. Training Departments) who, for all practicalpurposes represent an extension of the risk management process.Formal links into these departments should be established.

• Risk management is an integral part of any company’s core businessand, therefore, a responsibility of line management. Monitoring, on theother hand, is an occupational hygiene function and this defines the lineof communication required.

• Health and safety cannot be dealt with as separate entities. The degreeof integration cannot be prescribed but there needs to be soundcommunication lines and co-ordination of effort.

• A strong line of communication should be established with the publicauthorities and regulators.

7. Professional status and accreditation

7.1 The basic qualifications of any occupational hygienists and ancillary staff willbe determined primarily by the nature of the operation and at a level satisfyinglocal regulations.

7.2 Professional registration, inclusive of adherence to the prescribed code ofethics, is necessary. (See Guideline on Ethics.)




• A purpose-developed organisational structure with good communication lineswill be established.

• The infrastructure is appropriate to the risk.

• Appropriately qualified staff.

• Sampling equipment and methodology complies with recognised local and/orinternational standards.

• Data acquisition and analysis complies with recognised local and/orinternational standards.

• An appropriate system of formal Quality Assurance (QA) and Quality Control(QC) is in place and maintained.

• Data bases will satisfy the needs of the end users.

• Two distinct sets of data will be available. The first serves the purpose ofmanaging and measuring efforts made with respect to elimination or controlof risk at source. The second is a personal exposure data base whichquantifies health risk.

• Industrial hygiene data is linked to and prompts risk-based medicalsurveillance.

• The most important measurable outcome is to demonstrate significantimprovements in the workplace environment, notably with respect to primaryhazards, and an associated reduction in the incidence of occupational diseaseto levels at least on par with recognised and comparable centres of excellence.



OccupationalExposure Limits

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Occupational Exposure Limits (OELs)

1. Scope

1.1 This guideline sets out the basis on which to approach the concept of OELs.

2. Introduction

2.1 Most occupational health hazards have a “threshold level” at which it isassumed that the human body and its metabolism can cope and no adversehealth effects will follow. Depending upon the hazard, this applies to bothacute, high level exposures as well as long-term low level exposures.

2.2 When interpreted and applied by persons trained in occupational hygiene, OELsform an important part of occupational health programmes.

2.3 However, it must also be noted that OELs are not intended to be a finedividing line between safe and unsafe practice. Continuous effort should bemade to reduce hazardous work exposures to those as low as reasonablyachievable (ALARA).

3. OELs

3.1 For many occupational health hazards there are no set OELs – it is estimatedthat over 1 million chemicals and preparations are traded but only about one thousand have assigned OELs.

3.2 OELs are based on toxicology and epidemiology studies and, as knowledgechanges, it has become apparent that many health hazards are more harmfulthan originally thought. This has led to reduction in many OELs: – asbestos,benzene and ionising radiation all have lower OELs today than 20 years ago.

3.3 OELs are usually listed as:

• parts per million for gases and vapours;

• milligrams per cubic meter for gases, vapours and dusts or;

• fibres per millilitre of air for fibrous dusts; and

• other units for physical hazards such as radiation, heat etc.



3.4 OELs are usually consistent with the general terminology listed below:

• Time-weighted Average (TWA) exposure: the TWA concentration for anormal eight hour working day and 40 hour working week, to whichnearly all workers may be repeatedly exposed, day after day, withoutadverse effect.

• Short-term Exposure Limit (STEL); this is applied to chemicals with acute effects and is usually a maximum allowable exposure for a15 minute period, for no more than four times per day and with at least60 minutes between successive exposures.

• Ceiling Limit: a concentration that should never be exceeded.

3.5 Some countries (or groupings of countries) have approached their derivationof OELs in different ways and an OEL for the same substance may even bedifferent from one country to the next.

3.6 The European Union has Indicative Occupational Exposure Limit Values butwithin the EU different countries also still have their own approaches:

• United Kingdom – Occupational Exposure Standards (OESs)

• Netherlands – MAC Waarden

• Germany – Maximale Arbeits-platzkonsentrationen (MAKs)

The most widely used OELs are the Threshold Limit Values (TLVs) publishedannually by the American Conference of Governmental Industrial Hygienists(ACGIH).

4. Recommendations

4.1 Since Anglo American plc is listed in London, it is recommended that whereappropriate the United Kingdom (UK) OESs should serve as the point ofreference. However, it is acknowledged that standards across the world maydiffer widely and may be less stringent than the UK OESs. Where this is thecase, it is recommended that AA companies work towards achievement ofthese in addition to meeting local national limits.

4.2 Where there are no UK or local national limits then the limits recommended bythe ACGIH should be considered.




• OELs are used by operating companies in the management of occupationalhealth risk.

• The OELs used are consistent with those recommended in paragraph 4.Specifically, in addition to meeting local standards the Company is applying orworking towards the achievement of the UK OESs where local standards areless stringent.

• Those responsible for using OELs as part of occupational health riskmanagement should be appropriately knowledgeable with respect to:

° measurement techniques;

° measurement frequency;

° limitations that may result from individual susceptibility; and

° the application of OELs to the occupational health risk managementprogramme.

• Occupational hygiene records are made available to any party who may havea legitimate interest, but especially to employees.



BiologicalMonitoring

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Biological Monitoring

1. Scope

1.1 This guideline describes the role that biological monitoring may play inassessing occupational exposure and health risk to employees.

2. Introduction

2.1 Biological monitoring may be used to complement exposure assessment madeby air sampling. Measuring the concentration of chemical determinants in urine,blood or exhaled air of exposed workers provides an indicator of substanceuptake. If this measured level is below the biological exposure index (BEI), it isassumed that most workers would not experience adverse health effects.

3. Biological exposure indices (BEIs)

3.1 As with OELs, there are well recognised BEIs that can be used in occupationalhealth programmes, for example, lead measured in air and blood lead levels.

3.2 BEIs are often, but not necessarily, consistent with a level that would be found inurine, blood or exhaled air after exposure of healthy workers to levels equivalentto the OEL. Where other routes of absorption are possible (e.g. skin or ingestion)biological monitoring also forms a useful adjunct to industrial hygiene.

3.3 It must be noted that levels measured in individuals are influenced by manyfactors other than workplace exposure such as individual physiology, healthstatus, non-occupational exposures and the effectiveness of personalprotective equipment.

3.4 Collection times for biological specimens are determined according to differentchemical retention times. The collection of the appropriate specimen at the correcttime (before, during or after shift) into suitable clean containers is important.

3.5 Quality control of this process, as well as laboratory analysis, is necessary.

4. Use of BEIs

4.1 Any BEI programme should clearly indicate action that will be taken if levelsabove the BEI are measured in an individual or group of employees. Theseactions are dependent on the chemical concerned, levels measured and risk tohealth.



4.2 However, it must be noted that BEIs should not be used to determine thedividing line between hazardous and non-hazardous exposure. They areintended to provide an early warning of potentially harmful exposure.

4.3. Ethical considerations should be addressed in the biological-monitoringprogramme.

5. Recommendations

5.1 Where appropriate, biological monitoring is used to complement themanagement of occupational exposures.

5.2 Since Anglo American plc is listed in London, it is recommended that whereappropriate the United Kingdom (UK) BEIs should serve as the point ofreference. Where the United Kingdom standards are more stringent than thelocal limits it is recommended that as well as meeting local limits. AAcompanies work towards achievement of the UK limits.

5.3 Where there are no UK or local national limits then the limits recommended bythe ACGIH should be considered.


• Biological monitoring is used (where appropriate) to complement managementof occupational exposure.

• If biological monitoring is used, a documented approach is followed.

• Employees are appropriately informed and involved in the biological monitoringprogramme.

• Ethical considerations are taken into account in the biological-monitoringprogramme.



Risk-based Medical

Surveillance

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Risk-based Medical Surveillance1. Scope

1.1 This guideline provides the basis to establish a schedule for medicalsurveillance. It applies to any employee who has been identified, during thecourse of risk assessment, as significantly exposed to any risk in the workenvironment.

2. Introduction

2.1 Medical surveillance programmes run as an adjunct to risk assessment processesand are an integral part of risk management. Medical surveillance should beperformed by impartial and appropriately qualified occupational health personnel.One of the main objectives of medical surveillance is to ensure a healthy, fit,safe and productive workforce. This process should begin with placement ofthe new employee, continue throughout employment and end with terminationof the employment relationship or risk. Ideally, where indicated by the risk,follow up should continue beyond the workplace and into retirement.

3. Risk-based medical surveillance

3.1 The concept of ‘fitness to work’ implies that an occupation has inherent healthrequirements that need to be met by a person in that occupation in order tominimise the risk of injury or illness. The standard of fitness is thus closelyassociated with the level of risk. Occupational risks fall into two categories,risks associated with exposure to hazards in a particular occupation (e.g.noise, dust) and risks associated with failure to meet the attributes (physicalor psychological) required in a particular occupation. Medical evaluation offitness to work has to cover both types of risk.

3.2. The objectives of medical surveillance are therefore:

3.2.1 to ensure that employees are fit to undertake the proposed workwithout undue risk to their health and safety or the health and safetyof others;

3.2.2 to assess the health status of employees by collecting relevant healthinformation on a regular basis so as to detect adverse health effects atthe earliest opportunity and to ensure continued fitness to work in aparticular occupation;

3.2.3 to enable management to take appropriate and timely corrective actionin order to safeguard the health and well-being of individual employees;



3.2.4 to improve risk management by identifying adverse health effectsamong employee groups similarly exposed to occupational hazards;

3.2.5 to enable employees to be fully informed of the risks associated withtheir work and of procedures to minimise those risks, therebypreventing occupational related disease; and

3.2.6 to identify occupational disease from previous or current occupationalexposure and to refer for confirmation of diagnosis, treatment whereappropriate, and rehabilitation/placement. Applications for anycompensation that may be due would also expedited.

3.3 The desired outcome of the medical surveillance examination is to ensure thatthe employee is fit for his/her OWN occupation, i.e. that the employee meetsthe requisite physical and psychological attributes expected of a person in thatoccupation, and to ensure that the employee can safely be allowed into theworking environment. Following a medical surveillance examination, anemployee is issued with a Certificate of Fitness (COF) with respect to his/her‘fitness to work’ in a particular occupation and work environment.

3.4 It is recommended that the COF contain as a minimum, the following detail:

• the occupation;

• fit, ‘YES’ or ‘NO’;

• comments; if there are conditions to be met or if accommodation isrecommended (see below);

• date of examination;

• expiry date of certificate; and

• hazards which were considered when the employee was examined.

3.5 Examples of conditions or accommodation may be: an employee who is fit towork as a locomotive operator in an underground mining environment providedhe/she wears spectacles OR an employee who is fit to work as a labourer onan industrial site provided there are ramps because he/she cannot climb stepsdue to a previous injury.

3.6 The fact that the employee is in possession of a valid COF does not absolvethe employer of responsibility for ensuring a safe work environment.



3.7 Employers should ensure that the employee attends the medical surveillanceexamination. Employees should be referred with the following information athand:

• name and identification;

• occupation; and

• significant risks that the employee will be exposed to in the workenvironment. This is sometimes referred to as an ‘occupational riskexposure profile’ (OREP), or also known as ‘person-job specifications’,and should cover both the inherent requirements of the occupation andthe expected work environment exposures (two examples are attachedas addenda). Anglo Gold man-job spec.xls, Mondi man job spec.doc

3.8 The use of an OREP allows the occupational medical practitioner to ensure thatthe medical surveillance examination is risk-based, i.e. the content andfrequency of medical examination is tailored to the risk profile of thatemployee. Risk-based medical surveillance, as opposed to a generic approach(i.e. ‘one type fits all’) is preferable, as it informs continued risk managementand risk treatment. A risk-based approach also results in appropriate medicaltesting, efficient use of medical resources and medical surveillance focused onidentified risk. Risk-based medical surveillance is also inherently fairerallowing for more appropriate placement of people in work.

3.9 The content of the medical examination should be appropriate to the OREP.Depending on the OREP the content may include some or all of the following:x-rays, lung function testing, physical examination (blood pressure, urineanalysis, etc.), vision screening, audiometric screening, biological monitoring,physical examination and other appropriate tests.

3.10 Table 1 below is suggested as a practical approach to developing a medicalsurveillance programme.

3.11 Different types of medical examination are performed at various stages duringemployment. These may include:

• Initial (pre-employment/pre-placement) medical examination

Employees are examined prior to placement to ensure that they meetwith the minimum standards of fitness required for their specificoccupation.



• Periodical medical examination

Employees are re-assessed at intervals determined by the occupationalmedical practitioner based on the risks that they are exposed to.

• Transfer medical examination

Employees are re-assessed when transferring to an occupation with adifferent (higher or lower) risk profile.

• Exit medical examination

Employees leaving the employer are examined to detect anyoccupational injury or disease that may be present. This protects boththe employee and the employer.

• Out-of-cycle medical examination

Employees may need to be re-assessed due to medical conditions thatdevelop in between scheduled examinations and which impact on their fitness to work. Referral sources may be any of, the employeehim/herself (i.e. self-presenting), supervisors, the medical fraternity orthe human resources department.

3.12 Dependent upon risk, cognisance should be taken of the possible requirementfor medical surveillance to be extended after exposure ceases and intoretirement. In these circumstances, it is recommended that companies shouldendeavour to maintain contact with ex-employees.



Step 1: What is the result of the risk assessment process? If risk exists, proceed to prioritisation of risk.

Step 2: What are the target organ health effects (e.g. blood forming organs, nervous system, kidneys) associated with exposure to the particular risk?

Step 3: Identify the appropriate tests which have a high degree of validity (sensitivityand specificity) to make the assessment e.g. questionnaire, specific neurologicalexamination, blood specimen, X-ray. The availability of a valid test must beregarded as a prerequisite irrespective of the importance of the hazard.

Step 4: Ensure that the requirements for conducting and analysing tests in a reliablemanner are fulfilled:

• machine specifications;

• calibration of equipment;

• qualifications of persons conducting the tests; and

• accreditation of laboratory for analysis.

Step 5: Standardise methodology for conducting tests at appropriate time intervals eg.:

• Questionnaires

• X-ray examination protocol.

Step 6: Decide beforehand what action criteria will be used to define an abnormaltest.

Step 7: Outline the process of referral to confirm diagnosis, remove the employeefrom exposure, initiate treatment where appropriate and submit acompensation claim should there be disability due to the disease.

Step 8: Outline the procedures for notification of employer, employee andenforcement agency (for example, notification to government body or annual report to Inspectorate).

Step 9: Arrange for post-employment examinations and exit certificate ontermination of employment at a particular mine. Store historical medicalsurveillance records at facility for the period of time that is reasonabledepending on the risk and/or that is required by local legislation.

Step 10: Ensure evaluation and audit of the programme on a regular basis. Use information obtained through medical surveillance to assess theeffectiveness of existing control measures.


Table 1: A stepwise approach to developing a medical surveillance programme.

Source: Simrac Handbook of Occupational Health Practice in the South African Mining Industry



• Accessible, impartial and appropriately qualified occupational health personnel.

• OREP or person-job specification in place.

• Risk-based medical examinations.

• Initial, periodical, transfer, exit as well as out-of-cycle medical examinations.

• Standards of fitness appropriate to risk, and employee found fit for OWNoccupation.

• Certificates of fitness for work issued.

• Relevant health information collected and reported in an appropriate manner tomanagement.

• Early identification of occupational diseases.

• Feedback to risk management process.

• Employees fully informed of the risks and of procedures to minimise risks.

• Management takes appropriate and timely corrective action.



AngloGold

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2/0950 -health manual pages 22/11/02 11:31 Page i

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2/0950 -health manual pages 22/11/02 11:31 Page ii

AngloGold


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2/0950 -health manual pages 22/11/02 11:31 Page iii

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2/0950 -health manual pages 22/11/02 11:31 Page iv

MONDI


JOB SPECIFICATION

TITLE: �� DEPARTMENT: ��Rate all aspects on a scale 0-4 depending on importance. (see overleaf for instructions)Importance: (sections 1, 3, 4, 5 & 6) 0 = none, 1 = low, 2 = average, 3 = high, 4 = very highWork load: (section 2) S = sedentary, L = light, M = medium, H = heavy, V = very heavyThe description overleaf will give some assitance with this.

1. Physical Requirements 4. Special Skillsa. Climbing stairs or hills a. Drive a light vehicleb. Climbing ladders b. Drive a heavy vehiclec. Handling delicate equipment c. Drive a special vehicled. Operation of small knobs and switches d. Operate a computere. Lifting or carrying heavy objectsf. Working bent over 5. Working Environmentg. Use of arms a. Shift workh. Standing b. Outdoorsi. Sitting c. Indoorsj. Bending d. Heightsk. Walking on uneven ground e. Confined spacesl. Walking on flat, even ground f. Abnormal positionsm. Running g. High temperaturesn. Use of legs and feet (eg. operation of pedals) h. Low temperatureso. Vision (distant) i. Wetp. Vision (reading) j. High humidityq. Vision (fine work eg. electronics) k. Noiser. Vision (colour) l. Radiations. Vision (depth perception) m. Vibrationt. Eye/hand/foot coordination n. Dustu. Hearing o. Gasesv. Talking/ speech p. Fumesw. Smell (detect odours) q. Hazardous substances

2. Work Load 6. Safety Equipmenta. Hard hat

3. Education b. Safety glassesa. Read/ write/ speak English c. Ear plugs/muffsb. Read/ write/ speak Zulu d. Glovesc. Read/ write/ speak Other (specify) e. Safety boots/shoesd. Numeracy f. Gum bootsBriefly describe the type of work done by the employee g. Leg protectors

h. Breathing apparatusi. Other (specify)

MondiLtd.

2/0950 -health manual pages 22/11/02 11:31 Page v

MONDI


JOB SPECIFICATION (continued)

Importance

The importance of a requirement depends upon its relation to the job and does not necessarilymean the frequency of performing this aspect of the job. If a condition is not a frequent functionbut the job cannot be performed without it, then it is very important. If however, the job canbe performed by rearranging the work so that the condition is not necessary, then it is of lowimportance. If a condition is met very frequently in a job, then it is of high importance.

Where possible, specific requirements for hearing and speech should be set. Examples of thetype of work involving these senses will help in medically assessing them.

Work Load

Sedentary Work: Lifting a maximum weight of 4.55 kg and occasionally lifting and/ orcarrying articles such as dockets, ledgers and small tools. Althoughsedentary means sitting, most sedentary jobs require a certain amount ofwalking and standing. Walking and standing should, however, be a minorpart of the job.

Light Work: Lifting a maximum of 9.1 kg with frequent lifting or carrying of objectsweighing up to 4.55 kg. Even though the weight lifted may only be a smallamount, a job is in this category if it involves a lot of walking or standingor pushing with the arms and legs while seated eg. for operation ofcontrols on a machine.

Medium Work: Lifting a maximum of 22.75 kg and frequent lifting or carrying of objectsweighing up to 11.38 kg.

Heavy Work: Lifting a maximum of 45.5 kg with frequent lifting or carrying of objectsweighing up to 22.75 kg.

Very Heavy Work: Lifting objects in excess of 45.5 kg and frequent lifting or carrying ofobjects weighing 22.75 kg or more.

These descriptions are based upon the energy use needed to perform the tasks and are a littlearbitrary, other factors which increase energy consumption such as climbing hills, rough terrain,forces to operate pedals and controls, posture while working need to be taken into account.However, the rough guide is useful in the assessment of a task.

MondiLtd.

2/0950 -health manual pages 22/11/02 11:31 Page vi

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OccupationalHealth andContractors


Occupational Health and Contractors

1. Introduction1.1 The occupational health approach to contract labour is widely regarded as a

grey area and difficult to manage. One of the aims stated in the AA SHE policyis to "prevent or minimise work-related injuries and health impairment ofemployees and contractors."

1.2 Management need to gain assurance that the Contractor is managingoccupational health and safety in accordance with local legislation andcompany SHE Policy or guidelines. This applies particularly if arrangements foroccupational health services for contractors are different from that ofemployees.

1.3 Medical examinations should be tailored according to the occupational riskexposure profile (OREP), detailing occupation, hazard profile, workenvironment and duration of the anticipated risk.

1.4 In this context “risk,” means taking account of:

• occupation and its inherent requirements; and

• workplace exposures on company sites, such as chemical, physical,psychosocial stress factors, etc.

2. Definition2.1 For the purposes of this guideline a contractor is defined as any individual who

undertakes work on site at an operation, in a part-time or full-time capacity,but is not an employee of that operation.

3. Suggested approach3.1 The degree of medical surveillance to be applied to contractors is determined

by risk assessment. This risk assessment should be conducted by a teamconsisting of both the management of the operation concerned and thecontractor.

3.2 The manager, advised by an occupational medical practitioner, is responsiblefor deciding on the approach to medical surveillance. Alternatively, themanager can seek assurance that the contractor has adequately assessed andis competent to deal with the occupational health risks identified above.

3.3 Medical surveillance may be performed by the in-house service or by anoutside occupational health service provider. In the case of an outsideoccupational health service provider the Manager needs to ensure that theprovider is informed of the results of any risk assessment.



3.4 Various degrees of medical surveillance may be appropriate dependent uponthe risk assessment conducted in terms of paragraph 3.1 above. A suggestedapproach is given below.

3.5 No surveillance: This would typically apply to people entering the officeblock outside a mine / plant area or doing deliveries, who are not exposed toany risk.

3.6 Questionnaire: This would apply to people performing work on the premisesfor a very short period and not significantly exposed to risk associated with amine/plant.

3.7 Medical examination: The need for a medical examination is determined bythe risk assessment. (See Guideline on Risk-based Medical Examination.) The content of themedical examination will also be based on this and may vary considerably. Asa general approach the following is suggested:

• Basic medical examination: This would apply to short and medium-term employment, possible exposure to risk, but biological effect isvery unlikely. It is understood that the occupational medical practitionermay advise and implement further tests at his discretion.

• Full initial examination: This would apply where employment at amine/plant will result in a risk profile where:

° biological effect may be possible; or

° the inherent occupational requirements necessitate medical surveillance.

3.8. In order to adequately meet the requirements of 3.7 above, the occupationalmedical practitioner should be furnished with occupational risk exposureprofiles (OREPs).


• Is a formalised medical surveillance programme available for contractors?

• Is there reference to this matter in the procurement documentation?

• Are satisfactory OREPs for contractors in use?

• Are outsourced medical service providers conversant with the risk?



EmergencyPreparedness

EM

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PR

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Emergency Preparedness

1. Introduction

1.1 Although emergency preparedness is regarded primarily as a safety issue, it isimportant that occupational health staff should be involved at the earlieststages of any emergency plan. One of the aims stated in the Anglo AmericanSHE policy is to "prevent or minimise work-related injuries and healthimpairment …". In keeping with this commitment, employers need to takecognisance of potential hazards in their respective industries and be preparedfor emergencies that may arise.

2. Planning and resources

2.1 It is recommended that company directives are issued to ensure thatemergency plans, first aid training, spillage clearing, etc. are in place, bearingin mind legal considerations and risk-based needs. The management ofemergency situations should not only be directed to the source and control ofcontaminants, but also deal with the results of dangers created. As a matterof best practice, it is suggested that the following issues are dealt with indetail:

2.1.1 Alert: Establish proper communication channels and make availableinformation such as call-out lists in all strategic areas. Involveoccupational health personnel in the early stages, even if there are noapparent casualties.

2.1.2 Competent staff: Inform staff of the risks in the operation and provideappropriate training to deal with emergencies that may occur.

2.1.3 Source control: Make availabe a detailed HAZMAT (HazardousMaterials) programme and complete up-to-date Material Safety DataSheets (MSDSs). Inform repair crews of the risks of unplannedbreakdowns.

2.1.4 First aid: Prepare procedures detailing the numbers of people and thelevels of expertise required in the event of emergency. Address thesite-specific risks and make available appropriate PPE.

2.1.5 Evacuation: Where appropriate (e,g, if local management facilities areinsufficient), reach agreement with rescue services and other medicalfacilities to ensure prompt evacuation to an appropriate level of care.

30 AA Occupational Health Guidelines - Issued 7 November 2002


3. Rehearsal

3.1 The effectiveness of the emergency plan should be regularly tested by meansof emergency drills. Particular attention should be paid to occupational healthaspects during these drills.


• Is an emergency plan in place for all significant risks?

• Were occupational health personnel involved in the development of theemergency plan?

• Are alert procedures sufficient?

• Do occupational health personnel have access to the most recent MSDSs andHAZMAT documentation?

• Are evacuation arrangements adequate?

• Are procedures regularly rehearsed?

31AA Occupational Health Guidelines - Issued 7 November 2002


A

U

D

I

TAudit


Audit

1. Introduction

1.1 The AA SHE Policy includes as one of the management principles the need forevaluation. This involves monitoring, reviewing and confirming "theeffectiveness of management and workplace performance against divisional andcompany standards, objectives, targets and applicable legal requirements. Key tothis process is a system of appropriate audits and progress reports to divisionalmanagement coupled with regular reporting to the Board of Directors."

1.2 In order to determine whether the occupational health management systemand all its elements adopted by management is being properly followed,periodic audits should be conducted by the company.

2. Definitions

2.1 "Internal audit" means an audit carried out by the company itself.

2.2 "External audit" means an audit carried out by auditors external to theoperating company or by an independent third party.

3. Recommendation

3.1 As a matter of best practice, it is suggested that the following be done:Conduct periodic audits or reviews that are of an internal nature at leastannually. Conduct external audits at least every 3 years. Conduct morefrequent audits if indicated by risk assessment or legislation.

3.2 Develop an audit policy and programme which addresses scope, frequency,methodology, reporting and auditor competency.

3.3 Communicate audit results and conclusions to those responsible for correctiveaction as well as to employees.

3.4 Evaluate the measurable outcomes of the following guidelines:

• Occupational Health Management System;

• Occupational Health Risk Management;

• Occupational Hygiene;

• Occupational Exposure Limits (OELs);



• Biological Monitoring;

• Risk-based Medical Surveillance;

• Occupational Health and Contractors;

• Emergency Preparedness;

• Audit;

• Reporting and Key Performance Indicators;

• Ethics;

• Information Systems and Record Keeping;

• Quality Control of the various elements of the medical surveillanceprogramme; and

• Any other audit criteria or elements that may be appropriate.

3.5 Determine in the audit conclusion whether the implemented managementsystem:

• responds to the results of occupational health performance evaluationand previous audit; and

• fulfils the goal of continual improvement and best occupational healthpractice.

4. Reporting

4.1 Include audit findings and recommendations in a written report, andcommunicate this to Senior Executives of the company and to employees.

4.2 Mechanisms need to be in place to ensure that audit findings are addressed ina timely manner.


• Audit programmes are in place.

• Audits are conducted, and actions agreed with responsibilities and timeframes.

• Action items are followed up timeously.



Ethics

E

T

H

I

C

S


Ethics

1. Introduction

1.1 Professional ethics are codes of conduct that reflect the sense of correctbehaviour for a profession based on the social mores of society. These, inturn, are affected by the religious beliefs and culture in each society. AA, asa global natural resources company, operates across a wide spectrum ofindustry and in many countries and should have a consistent approach toprofessional ethics. Occupational health as a discipline has arisen out ofoccupational medicine but now encompasses a number of other professionalgroups. This has created a complex ethical environment with many conflictingdemands.

2. Principles

2.1 Since occupational health has roots in occupational medicine, its code of ethicshas been strongly influenced by the medical model which is consistent acrossmost countries.

2.2 Traditional medical ethics are based upon four principles: autonomy,benevolence, distributive justice and non-maleficence. These can very easilybe carried across into occupational health.

2.3 Transparency and informed consent are essential components of anoccupational health programme. All workers should be fully informed about thehazards to which they are exposed and should give informed consent for anytests that might have to be carried out in the name of medical surveillance.The right to privacy is part of autonomy and confidentiality of medical recordsneeds to be absolute. Information should only be released in an aggregatedform that protects the confidentiality of the individual or with the informedconsent of the individual. However, the primary objective of occupationalhealth programmes is to protect the health of the employee and someinformation must flow back to management to enable preventive measures tobe taken when signs of occupational disease are discovered. It is in thissituation that ethical guidelines become important and the involvement andconsent of the employee must be sought.

2.4 Distributive justice is essentially fairness and it must be recognised thatoccupational health services must be impartial. This responsibility falls on boththe occupational health professional and management. Management must allowthe occupational health professional room to act in a fair and impartial manner.



2.5 Benevolence and non-maleficence (the principle of doing no harm) areessentially two aspects of the same principle and flow from the three previousprinciples. It goes without saying that the objective is to act in the bestinterests of the health of the individual and the entire workforce.Unfortunately, conflict can occur between these two principles, particularlywhen considering fitness for work. Good risk assessment and detailed personjob specifications (that are agreed upon by all role players) are essential toolsto protect both the worker and the company.

3. Code of ethics

3.1 It has been recognised that traditional medical ethics are not sufficient toprovide guidance to the entire spectrum of occupational health professionalswho come from a number of different disciplines and have to cope with amultifaceted and changing workplace. The difficulty of dealing with complexdemands from employees, unions, employers and the State has created theneed for a cross-disciplinary set of ethical guidelines.

3.2 The International Code of Ethics for Occupational Health Professionalspublished by the International Commission for Occupational Health (ICOH2000) provides specifically for this need and AA subscribes to this.

3.3 Guidance can also be obtained from ethical guidelines published by the variousoccupational health societies in each country.

3.4 For more detailed and specific guidance the reader is referred to the ICOH codeof ethics.


• Ethical medical examinations

• Ethical medical surveillance process

• Placement of employees

• Education of employees

• Confidential record keeping

• Confidential (as far as possible) management information and reporting

• Fair handling of incapacitated employees



Reporting and Key

PerformanceIndicators

RE

PO

RT

IN

G

AN

D

KE

Y

PE

RF

OR

MA

NC

E

IN

DI

CA

TO

RS


Reporting and Key Performance Indicators

1. Introduction

1.1 The reporting requirements of each operation will differ (as they vary withrisk) however, there are two basic areas where reporting is common toeveryone. The first is day-to-day reporting of business unit level managementinformation for operational control and the second is for the purposes ofassurance to the shareholders (corporate governance). Obviously, there maybe some overlap between the two.

2. Reporting at business unit level

2.1 Reporting at the level of the business unit is concerned with the day-to-daymanagement of occupational health and is largely determined by the level ofrisk. These reports should inform management about the process of riskmanagement and provide information about the successes and failures of theprogramme. Management should be able to make informed decisions aboutany changes to the process, plant or workflow that may be necessary toreduce occupational health risk to a minimal level. In short, managementshould be able to answer the following five questions:

2.1.1 What are the occupational health risks?

2.1.2 Have the risks been adequately assessed?

2.1.3 What has been done to treat the risk?

2.1.4 Is there an appropriate programme of monitoring (occupational hygieneand medical surveillance)?

2.1.5 Can more be done?

3. Reporting to group

3.1 The purpose of reporting to group management is twofold; firstly, informationis required for corporate governance purposes, secondly, data is needed for thepurposes of internal and possible public reporting.

3.2 Good corporate governance requires that the Board of Directors seeksassurance from operational management that the company is being operatedin line with the principles outlined in the group SHE policy and statement ofbusiness principles. This is provided through a letter of assurance.



3.3 The data set to support the above assurances and ultimately for the purposesof public reporting is based upon the predominant health risks in the group andmay vary from time to time.

4. Key performance indicators (KPIs)

4.1 There are two types of performance indicators: leading indicators and lagindicators. Leading indicators in occupational health are concerned with theprocess rather than outcomes. Success in occupational health (as in allpreventive fields) is measured in the cost of not doing something or to put itanother way, the amount saved by the preventive action. Continuousmanagement, review and audit to provide assurance that risks are adequatelyassessed and managed in the present is required. The lag indicators are thedisease statistics that provide a measure of the failure of past and presentcontrol systems. However, due to the long lead-times of most occupationaldiseases, these lag indicators are often not immediately apparent. Lagindicators are however useful as a measure of the present cost of past actionsor omissions and are an important driver of preventive measures going intothe future.

4.2 The data-set for disease statistics is determined by the predominantoccupational health risks in the group and will change from time to time. Atable showing this is appended at the end of this section. The objective is toreport only occupational disease and at a certain level, definitions for reportingpurposes can be found in the AA SHE database.

4.3 Occupational hygiene provides the source for leading indicators and these arecurrently being developed. Pending finality on these indicators an attempt hasbeen made to quantify risk through inclusion of the number of employeesexposed to above the OEL in table 2.


• Management reports address the approach to risk management advocated inthese guidelines, that is:

° baseline risk assessment;

° issue-based risk assessment; and

° continuous risk assessment.

• Adequate information is kept to enable reporting on the management ofoccupational health risks.




• Reporting of occupational health information enables management to takeappropriate and timeous preventive action.

• Reporting to the group is in line with group requirements.

• Audits are reported upon and appropriate action taken.



Tabl

e 2:

Occ

upat

iona

l Hea

lth

KPI

s (l

ag in

dica

tors

)

Han

d ar

m

Occ

upat

iona

l O

ccup

atio

nal

vibr

atio

n M

uscu

lo-

NIH

LPn

eum

ocon

iosi

sCO

AD

Tube

rcul

osis

Ast

hma

synd

rom

esk

elet

alO

ther

Tota

l

No. o

f em

ploy

ees

expo

sed

to ri

sk

No. o

f new

cas

es

No. o

f exi

stin

gca

ses

No. o

f em

ploy

ees

com

pens

ated

Com

pens

atio

n pa

id

No. o

f occ

upat

ion

chan

ges

Fata

litie

s


InformationSystems and

Record Keeping

IN

FO

RM

AT

IO

N

SY

ST

EM

S

AN

D

RE

CO

RD

K

EE

PI

NG



Information Systems and Record Keeping

1. Introduction

1.1 Record keeping in occupational health falls into three main areas, occupationalhygiene, medical surveillance and human resources. The purpose of recordkeeping is to provide a record of the employees' work, exposure and medicalsurveillance history during his time with the company. This information is usedto improve the risk management process, to assist with compensation wherenecessary and may be useful to defend the company against spurious claims.Good information may also be used on an industry-wide basis inepidemiological studies and to assist in the determination and review of OELs.

2. Information systems

2.1 The information system should be designed in such a way as to provide a linkbetween occupational hygiene data, medical surveillance data and the recordof service kept by the personnel department. The three sources of informationare managed by three different departments and are often kept in threedifferent record systems.

2.2 Occupational hygiene: the monitoring of hazards takes place for two reasons.

Firstly, sampling is carried out for the purposes of elimination and control atsource and thus ensure compliance with OELs.

Secondly, the information obtained is used to establish the exposure ofindividual employees and provides input into risk-based medical surveillance.The aim is to reduce the employee's exposure to a level regarded as “withouthazard to health”. In order for the maximum benefit to be obtained from theoccupational hygiene monitoring programme the information obtained must belinked in some way to the employee. In the case of personal sampling this isrelatively simple in that an employee number can be attached to the sample.With other sampling strategies (e.g. area sampling or homogenous exposuregroups) the process may be a little more complicated in that there must besome description in the personnel records of where an employee works.



Medical record

General health, medicalsurveillance results

(employee no. OREP)

Occupational hygieneHazard exposure data(site/department,exposure groups,employee no. OREP)

Personnel record(occupations, how long,employee no. OREP)

Links:Area/dept. codeemployee no.

Links:employee no.

Links:Area/dept. codeemployee no.Job description(OREP)

2.3 Medical surveillance: these records contain personal information and arekept in confidential medical files. However, since medical surveillance is basedon exposure to risk, feedback of relevant information provides important inputinto the management of risk. There should be a way of linking the occupationalmedical record to the personnel record and the industrial hygiene record.

2.4 Personnel records: the human resources department information systemcontains the record of an employee’s movement during his time with thecompany and, when combined with industrial hygiene data, should provide arecord of exposure and dose.

Figure 4: Links between Industrial Hygiene, Medical Surveillance and Human Resources Information Systems



3. Record keeping

3.1 Records should be kept for an appropriate length of time. For occupationalhealth information (occupational hygiene sampling data and medicalsurveillance data) this is often determined by legislation and may be as longas 40 years. However, for the purposes of standardisation AA policy is to keepoccupational health information for at least 30 years after exposure ceases oraccording to legislative requirements, whichever is the longer. Since theemployee’s work history forms part of the exposure profile, provision shouldbe made to keep that portion of the personnel file, which contains details ofjob history and movement within the company for the same length of time.The employee's medical record should remain confidential and where this iskept off site the responsible occupational medical practitioner should besatisfied that this is in accordance with good medical practice and ethics. It isessential that the links between exposure data, the work history and themedical record be maintained for the full length of time. In the ideal situation,one database will house all the information with appropriate securitiesprotecting the confidentiality where necessary.


• Links exist between medical surveillance data, industrial hygiene data andpersonnel records.

• Records are kept for an appropriate length of time.

• Medical confidentiality is maintained.

• The company can establish the exposure history of any employee.


Audit pro forma

AU

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Anglo American plc


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Compliance

Severity of Non-

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Continued

2/0950 -Occ. health tables 22/11/02 11:32 Page 43

Anglo American plc


9Em

ploy

ees

part

icip

ate

in o

ccup

atio

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ealth

at

all l

evel

s, f

rom

po

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ealth

pra

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curs

2O

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1A

str

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appr

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e co

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3Th

e or

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of p

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whi

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is t

reat

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1A

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n ap

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ase

whi

ch q

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ifie

s he

alth

ris

k.

Continued


Anglo American plc


9In

dust

rial h

ygie

ne d

ata

is li

ned

to a

nd p

rom

pts

risk-

base

d m

edic

al

surv

eilla

nce

10Th

e m

ost

impo

rtan

t m

easu

rabl

e ou

tcom

e is

to

dem

onst

rate

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gnific

ant

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not

ably

w

ith r

espe

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o pr

imar

y ha

zard

s, a

nd a

n as

soci

ated

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uctio

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th

e in

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of o

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isea

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w

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ecog

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d co

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4O

ccup

atio

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xpos

ure

Lim

its

(OEL

s)1

OEL

s ar

e us

ed b

y op

erat

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com

pani

es in

the

man

agem

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of

occu

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2U

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ose

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as p

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kno

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re

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–M

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tions

tha

t m

ay r

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t fr

om in

divi

dual

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ibili

ty

–Th

e ap

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atio

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OEL

s to

occ

upat

iona

l hea

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isk

man

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prog

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me

4O

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atio

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ecor

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vaila

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to a

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ay h

ave

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gitim

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ally

to

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5Bi

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Mon

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1Bi

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mon

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use

d (w

here

app

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) to

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here

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onito

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is u

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ocum

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d ap

proa

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is f

ollo

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ploy

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are

appr

opria

tely

info

rmed

and

invo

lved

in t

he

biol

ogic

al m

onito

ring

prog

ram

me

Continued


4Et

hica

l con

side

ratio

ns a

re t

aken

into

acc

ount

in t

he b

iolo

gica

l m

onito

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prog

ram

me

6Ri

sk-b

ased

Med

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veill

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1A

cces

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part

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qua

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ased

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exa

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4In

itial

, pe

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, ex

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exam

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are

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of f

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e ap

prop

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to

risk,

and

em

ploy

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ound

fit

for

OW

N o

ccup

atio

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6Ce

rtific

ates

of

fitn

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issu

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7Re

leva

nt h

ealth

info

rmat

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colle

cted

and

rep

orte

d in

an

appr

opria

te m

anne

r to

man

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ent

8Ea

rly id

entif

icat

ion

of o

ccup

atio

nal d

isea

ses

wou

ld b

e ap

pare

nt

9M

edic

al s

urve

illan

ce f

eedb

ack

to r

isk

man

agem

ent

proc

ess

10Em

ploy

ees

are

fully

info

rmed

of

the

risks

and

of

proc

edur

es t

o m

inim

ize

risk

11M

anag

emen

t ta

kes

appr

opria

te a

nd t

imel

y co

rrec

tive

actio

n in

the

ev

ent

of m

edic

al s

urve

illan

ce f

lagg

ing

an o

ccup

atio

nal h

ealth

issu

e

7O

ccup

atio

nal H

ealt

h an

d C

ontr

acto

rs1

Form

alis

ed m

edic

al s

urve

illan

ce p

rogr

am is

ava

ilabl

e fo

r co

ntra

ctor

s

2Is

the

re r

efer

ence

to

med

ical

sur

veill

ance

mat

ter

in t

he

proc

urem

ent

docu

men

tatio

n?

3A

re s

atis

fact

ory

ORE

Ps f

or c

ontr

acto

rs in

use

?

4A

re o

utso

urce

d m

edic

al s

ervi

ce p

rovi

ders

con

vers

ant

with

the

oc

cupa

tiona

l hea

lth r

isk?

Anglo American plc


Continued


Anglo American plc


8O

ccup

atio

nal H

ealt

h In

volv

emen

t in

Em

erge

ncy

Prep

ared

ness

1Is

an

emer

genc

y pl

an in

pla

ce f

or a

ll si

gnific

ant

risks

?

2W

ere

occu

patio

nal h

ealth

per

sonn

el in

volv

ed in

the

dev

elop

men

t of

the

em

erge

ncy

plan

?

3A

re a

lert

pro

cedu

res

suff

icie

nt?

4D

o oc

cupa

tiona

l hea

lth p

erso

nnel

hav

e ac

cess

to

the

mos

t re

cent

MSD

Ss a

nd H

AZM

AT d

ocum

enta

tion?

5A

re e

vacu

atio

n ar

rang

emen

ts a

dequ

ate?

6A

re p

roce

dure

s re

gula

rly r

ehea

rsed

?

9A

udit

1A

udit

prog

ram

mes

are

in p

lace

2A

udits

are

con

duct

ed,

and

actio

ns a

gree

d w

ith r

espo

nsib

ilitie

s an

d tim

efra

mes

3A

ctio

n ite

ms

are

follo

wed

up

timeo

usly

10Et

hics

1Et

hica

l med

ical

exa

min

atio

ns a

re p

erfo

rmed

2Et

hica

l med

ical

sur

veill

ance

pro

cess

3Pl

acem

ent

of e

mpl

oyee

s

4Ed

ucat

ion

of e

mpl

oyee

s

5Co

nfid

entia

l rec

ord

keep

ing

6Co

nfid

entia

l (as

far

as

poss

ible

) m

anag

emen

t in

form

atio

n an

d re

port

ing

7Fa

ir ha

ndlin

g of

inca

paci

tate

d em

ploy

ees

11Re

port

ing

and

Key

Perf

orm

ance

Ind

icat

ors

1M

anag

emen

t re

port

s sh

ould

add

ress

the

app

roac

h to

ris

k m

anag

emen

t ad

voca

ted

in t

hese

gui

delin

es,

that

is:

Continued


Anglo American plc


–ba

selin

e ris

k as

sess

men

t

–is

sue-

base

d ris

k as

sess

men

t an

d

–co

ntin

uous

ris

k as

sess

men

t

2A

dequ

ate

info

rmat

ion

is k

ept

to e

nabl

e re

port

ing

on t

he

man

agem

ent

of o

ccup

atio

nal h

ealth

ris

ks

3Re

port

ing

of o

ccup

atio

nal h

ealth

info

rmat

ion

enab

les

man

agem

ent

to t

ake

appr

opria

te a

nd t

imeo

us p

reve

ntiv

e ac

tion

4Re

port

ing

to t

he g

roup

is in

line

with

gro

up r

equi

rem

ents

5A

udits

are

rep

orte

d up

on a

nd a

ppro

pria

te a

ctio

n ta

ken

12In

form

atio

n Sy

stem

s an

d Re

cord

Kee

ping

1Li

nks

exis

t be

twee

n m

edic

al s

urve

illan

ce d

ata,

indu

stria

l hyg

iene

da

ta a

nd p

erso

nnel

rec

ords

2Re

cord

s ar

e ke

pt f

or a

n ap

prop

riate

leng

th o

f tim

e

3M

edic

al c

onfide

ntia

lity

is m

aint

aine

d

4Th

e co

mpa

ny c

an e

stab

lish

the

expo

sure

his

tory

of

any

empl

oyee


Disclaimer As contributors of this information, Anglo American plc or any of its Group companies or their servants, agents or contractors, (generally referred to as the Company), are not responsible for any actions (or lack thereof) taken as a result of the information contained herein and the Company cannot be held liable for any damages resulting from reliance on or use of this information. Without limiting the above, as contributors, the Company shall have no responsibility for any act or omission of any other contributor. It is recorded that this material is presented for information purposes only, in the interests of sharing good practice. Whilst the information may be regarded as indicative of good practice, and effort has been made to ensure that it is accurate, no representation or warranty, express or implied, is made as to the accuracy, currency or completeness thereof. It is provided solely on the basis that users will be responsible for making their own assessments of the information. Users are accordingly advised to obtain independent advice before acting on the information contained herein, and to take specific advice from a qualified professional when dealing with specific situations. The Company will accordingly not accept any liability for any loss or damage of any kind whatsoever (including consequential loss), suffered by any person acting in reliance upon the information, howsoever such loss or damage may have been caused or sustained. The Company expressly disclaims liability for any such loss or damage. By accessing the information presented on the terms and conditions indicated, the user hereby indemnifies and holds the Company harmless against all such loss or damage.

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