Inspection initiative results: Battery electric vehicles and mobile diesel equipment maintenance in mines
Results of a province-wide initiative that focused on battery electric vehicles (BEV) and mobile diesel equipment maintenance in mines from December 14, 2020 to March 31, 2021.
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From December 14, 2020 to March 31, 2021, the Ministry of Labour, Immigration, Training and Skills Development (MLITSD) conducted a health and safety initiative which focused on battery electric vehicles (BEV) and mobile diesel equipment maintenance in mines.
We began by focusing on education, outreach and awareness, in partnership with Workplace Safety North (WSN) to provide training and education to employers. The goal was to help employers comply with the requirements for BEV and mobile diesel equipment maintenance in mines under the Occupational Health and Safety Act (OHSA) and its regulations prior to focused inspections.
Beginning February 3, 2020, we conducted a focused inspection blitz at mines to check that employers were complying with the OHSA and Regulation 854: Mines and Mining Plants which focused on:
- maintenance of BEVs in mines
- risk assessment for operation of BEVs
- battery charging stations
- fire suppression systems
- LED lights
- procedures in place and awareness of operators and workers
In mines with no BEVs, the focus was on the diesel mobile equipment maintenance, fire suppression systems, LED lights, procedures in place and awareness of operators and workers.
- conducted 39 field visits with 1 support role activity
- visited 35 mining workplaces
- issued 69 orders and requirements, including 4 stop work orders
Battery Electric Vehicles (BEV) and mobile diesel equipment maintenance in mines
The use of BEVs in mines has raised several safety concerns including the risk of fire. The Mining Safety Review ranked mobile equipment in its top 10 hazards. Stakeholders, WSN and field staff feedback indicated increasing concerns about the use of BEVs in mines. Maintenance of mobile diesel equipment in mines was also an area of concern. Our health and safety initiative focusing on BEV and mobile diesel equipment maintenance in mines is one way we address the hazard of fires.
Workplace inspection initiatives
Inspection initiatives are part of our compliance strategy. We announce to the sector, in advance, that we will be conducting an initiative, although individual workplaces are not notified in advance. The results of the initiative are typically posted online within 90 days. Inspectors’ findings may impact the number and level of future inspections of individual workplaces.
Inspectors may also refer employers to health and safety associations for compliance assistance and training.
Focus of the initiative
We provided information on the initiative on December 16, 2020, at a webinar (PDF) co-hosted by the ministry and Workplace Safety North (WSN). The webinar offered details on what our inspectors would be looking for during the blitz, OHSA requirements for BEVs and mobile diesel equipment maintenance in mines, and gave attendees an opportunity to ask questions. Of the 81 people registered for the webinar, 36 attended.
Hazards involving BEVs and mobile diesel equipment maintenance in mines mainly involve:
- improper or lack of a mobile equipment maintenance program
- lack of adequate worker training for mobile equipment operation and maintenance
Inspectors focused on:
- procedures for vehicle pre-start checks and reporting deficiencies
- appropriate worker training for the vehicle in operation
- appropriate training for maintenance personnel
- scheduled maintenance in accordance with the manufacturer’s specifications
- battery charging stations are provided with safeguards to protect workers
- whether inspections are being carried out on a scheduled program and procedures
- whether defects are being identified and managed to minimize the hazard
- whether Mine Rescue provided adequate information and instruction to manage a battery fire event
- ensuring unattended vehicles are immobilized and secured against accidental movement
Inspectors took appropriate action if violations were found under the OHSA or its regulations. This included:
- writing orders to employers, supervisors and workers to have them comply with legal requirements
- issuing stop work orders requiring employers to comply before work could continue
Inspection activity summary
Visits to workplaces
- 39 field visits with 1 support role activity
- 35 workplaces visited
- 69 orders and requirements issued
- 67 orders issued for violations under the OHSA and its regulations, including 4 stop work order(s)
- 2 requirements issued to provide an inspector with workplace information
- an average of 1.97 orders and requirements issued per workplace visited
- an average of 1.77 orders and requirements issued per visit
Most frequently issued orders
Most of the orders issued under the Occupational Health and Safety Act (OHSA) were for the following reasons:
- an employer shall ensure that the equipment, materials and protective devices provided by the employer are maintained in good condition [s. 25(1)(b)] — 10 orders or 14.08% of the total orders and requirements issued during the initiative
- an employer shall take every precaution reasonable in the circumstances for the protection of a worker [s. 25(2)(h)] — 7 orders or 9.86% of the total orders and requirements issued during the initiative
- an employer shall provide information, instruction and supervision to a worker to protect the health or safety of the worker [s. 25(2)(a)] — 5 orders or 7.04% of the total orders and requirements issued during the initiative
- stop work order: the windshield and windows of the cab of a motor vehicle shall consist of safety glass and be maintained so as to provide unobstructed vision [s. 105(5)] — 1 order or 1.41% of the total orders and requirements issued during the initiative
The most frequently issued orders under Regulation 854: Mines and Mining Plants were for an employer’s failure to ensure:
- a machine that has an exposed moving part that may endanger the safety of any person shall be fenced or guarded unless its position, construction or attachment provides equivalent protection. [s. 185(2) — 3 orders or 4.23% of the total orders and requirements issued during the initiative
- a worker shall be trained in the appropriate common core modules before beginning training in a specialty module. [s.11.2(4)] — 2 orders or 2.82% of the total orders and requirements issued during the initiative
- the open side of a ramp haulage road in a surface mine shall be provided with a suitable protective barrier. [s. 116(2)] — 2 orders or 2.82% of the total orders and requirements issued during the initiative
The results of this initiative indicate that workplace parties need to improve compliance with respect to battery electric vehicles and mobile diesel equipment maintenance in mines.
- Interaction between mobile equipment and workers continues to be a very high hazard that can result in serious outcomes.
- Workers continue to be exposed to the potential hazard of fires from mobile equipment, whether it be battery or diesel powered.
- Heightened awareness of any hazard can bring change. All workplaces parties must continue to be diligent and not allow complacency to creep into their daily routines.
- The risk of collisions and mobile equipment fires can be prevented by raising awareness and taking proper precautions.
Conclusion and next steps
Ministry inspectors will continue to pay attention to the above areas related to mines.
The results of the initiative confirm our need to continue to focus on the interaction between mobile equipment and workers as well as on battery electric vehicles and mobile diesel equipment maintenance in mines.
A key to workplace health and safety in Ontario is the Internal Responsibility System (IRS). Workplace parties are encouraged to work together to identify and control all hazards.
Help for employers
Please contact our health and safety partners for more information.
- Regulations for mines and mining plants, E-Laws
- Mobile equipment, MLITSD resource
- Emergency response planning guideline for surface mines, WSN resource
- Emergency simulation guideline for underground mines, WSN resource
- footnote Back to paragraph Activities in which professional services staff (e.g., a hygienist, ergonomist, engineer, etc.) or another inspector accompanies an inspector on a field visit to provide professional support and/or expertise.