The impact of new technology and management of change
Underground mining is a complex high-tech industry. New technologies have removed a lot of the labour intensive work that was part of mining operations in the past and, in some cases, they have also improved safety. In 2003, at the International Association of Labour Inspectors annual meeting in Toronto, a tripartite panel identified three key factors in improved mining safety in Ontario and lower rates of lost-time injuries: improved technology, mandatory training and the development of tripartite mechanisms, such as the Mining Legislative Review Committee and the tripartite development of the Ministry of Training, Colleges and Universities training standards.
New technologies can play a significant role in improving performance and processes. In these times of continuous technological advances, mining operators see the potential for higher productivity and lower operating costs. However, each new technology represents a change in a mining operation and requires proper management of change strategies. Effective management of change can help identify and eliminate hazards, enhance equipment performance and improve the bottom line – while improper management of change can introduce new hazards into the work place. The Ham Commission Report (1976) noted that “trade-offs between productivity and occupational risks are inherent and rarely consciously made.” It is, therefore, imperative that the mining sector establish a means to evaluate and understand the implications of changes on health and safety, and implement adequate mitigation strategies.
What We Heard
During the Review, stakeholders discussed their concerns about the impact of new technology and improper management of change on worker health and safety. They stressed the critical importance of proper management of change processes including risk assessments when implementing new technology or processes. They talked about the need for greater worker participation in evaluating risk and in change processes, and clearer guidance on how to involve workers and joint health and safety committees in meaningful ways as opposed to just informing them. They also emphasized the importance of sharing information on new technologies introduced in the workplace and developing a method to communicate any operational issues related to a new technology.
Over the past several decades, Ontario’s mining sector has seen significant technological advances in areas such as underground communications, ergonomics, fire suppression, hoist automation, ground control, blasting materials, fall arrest, dust control and the delivery of training. When properly introduced, technological improvements have the potential to reduce all injuries, lost-time injury rates and fatalities.
On the issue of the impact of introducing new technology into underground mining workplaces, the Review heard from experts in risk management and management of change processes from organizations around the world. Resource people from labour, employers, academia and the health and safety system partners also provided their insights. Mining companies in Ontario were asked to submit their policies related to the management of change. The Review also had the opportunity to look at best practices in Ontario and other global leaders in mining, chemical industries and the nuclear industry. Diffusion rates of new technology were not readily available when the Review was exploring this issue.
A variety of new technologies intended to make the mining environment safer are currently being developed, including but not limited to:
- tier 4 engines that reduce emissions
- ventilation on demand systems that will improve air quality
- fire suppression systems to reduce risks associated with fires in ultra-deep mining situations or fires that occur as a result of new technology
- mobile equipment position and location monitoring devices to facilitate traffic control and prevent vehicular collisions
- proximity detection devices and cameras on equipment to reduce risks associated with mobile and other equipment.
While the introduction of safety-related technologies generally holds great promise, not enough research has yet been done on some of the safety technologies for the mining sector. It is imperative that appropriate, thorough study and risk assessments are conducted to ensure no new uncontrolled hazards are introduced as a result of new technologies entering the work environment.
Management of Change
Change can play a significant role in improving performance and processes. Change, which can be initiated either internally or by external industry trends, can also introduce new hazards unless reviewed by highly knowledgeable people, such as equipment specialists, management system specialists, engineers, and assigned operations and maintenance personnel. In an effective management of change process, experts work collectively to justify the need to make the change in the first place. They then verify that the change reduces or eliminates the current risk and does not introduce other risks.
Change can also be more hazardous when it is not communicated clearly to those who need to know, such as operators and maintenance people. Communication is critical to preventing hazards which arise out of "not knowing". Effective communication includes notifying and involving personnel and updating written documents, such as operating procedures, training modules and maintenance plans.
During the Review, the question of what would trigger a management of change policy was raised, and it was agreed that it would depend on the circumstance and would be determined collaboratively by the workplace parties, including the workers at risk and the relevant supervisors and managers. This management of change concepts appear to be reasonably straight forward; however, based on the Review’s analysis, the understanding and application of these concepts varies across the mining sector. These differences may be due to the fact that the requirements or key elements of a management of change process are not laid out in the current mining regulations. For example, Regulation 854 requires the employer to notify the joint health and safety committee or health and safety representative when there is a change in procedure or a change in the composition, design, size or arrangement of a material, object, device or thing. However, there is no requirement for the employer to engage knowledgeable persons and workers affected by the proposed change in a management of change process - just a requirement to inform them of the change.
The Regulation also currently requires that a written statement of proposed development, construction, introduction, alteration or use be given to the joint health and safety committee or health and safety representative. However, there is no requirement to engage affected workers and their representatives in reviewing the proposed change in order to identify hazards, and assure those hazards will be mitigated.
Based on the findings of the Review, the key elements of an effective management of change process include:
- Leadership Support: Leadership is key to effective management of change. To provide leadership support, new leaders need to understand the mine’s current initiatives and programs, and the rationale for them. Any organizational change would also be scrutinized using the same process as for a technology or process change.
- Worker Involvement: Workers and their representatives need to be involved in a meaningful way when any change is being contemplated or introduced. Without buy-in from labour and the joint health and safety committee, management of change processes will not be effective.
- Organizational Support: A management of change procedure cannot operate without organizational support and structure. That support includes providing adequate guidance in defining the various levels of change. For example, information should be provided on whether the proposed change is a "change in kind" versus a substantial change or an emergency change / short term measure. The organization must also ensure that any short-term or emergency change is not left in place beyond the appropriate timeline. Organizational support also includes a system to review the implementation and success of the management of change process as part of continuous quality improvement.
- Training for Participants: An effective management of change process requires training specific to each role in implementing the change. For example, the review team facilitator of the management of change process needs training on how to ensure the procedure is followed and the analysis is sufficiently detailed. Training is also required for key individuals who will manage the change process as well as for all participants, and it may be required for workers who are potentially affected by the change.
- Clear Procedure: The optimal way to introduce new technology and processes into the mining sector is through a clear management of change procedure. A well-defined procedure will adequately address any proposed change in technology, processes, mining plan or leadership or organizational change at the mine site. The procedure must be risk based and include both the current technology and the new technology. The management of change review team must adequately represent the depth and breadth of knowledge and experience required for a detailed review. The workplace parties must also develop a clear policy outlining the circumstances that would trigger the management of change process.
- 2.1 The Ministry of Labour to require mine operators to establish and implement a written management of change procedure, to include workers and the joint health and safety committee or health and safety representative.