White Paper: Is Compliance Really Enough?

MANAGING YOUR FIRE RISKS AT MINING AND INDUSTRIAL FACILITIES

Prepared by
AARON HARRIS

BE(HONS) MIEAUST CPENG NER RPEQ PE(VIC) APEC ENGINEER INTPE(AUS)

EXECUTIVE SUMMARY

Mining and Industrial facilities face significant fire risks, which can have catastrophic consequences not only for the safety of personnel but also for the operational, financial, and reputational standing of the organisation. Despite the prevailing mindset that achieving compliance is sufficient, this white paper challenges that notion and suggests compliance alone does not meet the duty of care owed to stakeholders.

Industrial facility with yellow conveyor systems and large rock piles, illustrating fire risk management in mining environments.

The purpose of this white paper is to challenge the commonly held belief that achieving compliance is a sufficient objective to strive for. Obligations to stakeholders far surpass compliance.

Beyond Compliance: Managing Fire Risks in Mines & Industry

“Just tell me what I need to do to make it compliant”.

“I just need you to make this compliant to get management off my back”.

Much is said about ‘compliance’ at mining and industrial facilities, but is this really an acceptable benchmark, particularly when the consequences of fire can be so significant? And does this discharge one’s duty of care?

The purpose of this white paper is to challenge the commonly held belief that achieving compliance is a sufficient objective to strive for. Obligations to stakeholders far surpass compliance.

WHO ARE THE STAKEHOLDERS

The operators of mining and industrial facilities must balance the demands of many stakeholders, including the following (just to name a few):

  • Asset owner

  • Asset operator

  • Employees, contractors and visitors

  • Shareholders

  • Government

  • Regulators

  • Insurers

  • Suppliers

  • Customers

  • Media

  • Neighbours and general public

Any of these stakeholders can be impacted by the consequences of a fire event at one of these facilities, so they all have an interest in how these risks are managed.
Mining trucks transporting materials on a dirt road in an open-pit mining site, highlighting industrial operations and potential fire risks in mining environments.

WHAT ARE SOME OF THE FIRE RISKS?

Common fire risks at mining operations include:

  • Mobile plant – the most common fire occurrence at mine sites

  • Conveyors – pulleys, idlers, belt, fines

  • Fuel storage and refilling points

  • Lube Oil Systems and Hydraulic Power Packs

  • Transformers and substations

  • Hot works and maintenance activities

  • Poor housekeeping

Lithium-Ion Battery Energy Storage Systems (BESS) are a relatively new fire risk starting to appear at mine sites. These present a major challenge in terms of fire risks, and it is generally accepted that it is not possible to sustainably extinguish a fire in a BESS enclosure once it has reached thermal runaway. There are ways to manage the fire risks associated with BESS systems, however that is a separate topic all on its own.

IS COMPLIANCE MANDATORY?

Compliance, in the context of mining and industrial facilities, refers to the adherence to the relevant mandatory legislation, regulations, standards and codes. But does it also include recommended (or voluntary) practices, policies and guidelines?

Compliance is often a legal requirement and a contractual obligation for asset owners and operators, and it aims to ensure the safety of personnel, property, and the environment from fire risks. However, compliance does not necessarily achieve an optimal level of fire protection or risk management, as it may not account for the specific hazards, challenges, and needs of each facility. Therefore, compliance should be seen as the minimum standard, rather than the end goal, and asset owners should strive to achieve best practices and continuous improvement in fire protection.

The regulatory framework for mining operations in Australia is complex, with each state and territory applying their own take on it. Fundamentally, the regulations are generally underpinned by Australian Standards to set out the fire protection requirements. In this context, these cover areas relating to the design, installation, commissioning, operation, and maintenance of fire protection systems and equipment.

The problem frequently arises that Australian Standards, and other relevant codes and standards, are largely written in the context of the built environment, i.e. suburban and metropolitan centres, where access to associated infrastructure and emergency response is a base assumption. These standards therefore have limited applicability or practicality when applied to a mining operation or industrial facility. The mining safety legislation generally allows for this reality, by requiring risks to be managed to an acceptable level. This concession places the onus back on the operator to ensure they have identified and managed risks accordingly.

It is important to consider how this applies in practice; compliance with standards could be either under- or over-designing, and this can depend on many other contributing factors which need to be taken into account.

Flames and thick smoke billowing, illustrating fire risk in industrial and mining contexts, relevant to fire risk management and safety compliance discussions.

MANAGING FIRE RISKS

The standards written from the perspective of the built environment almost exclusively (and rightly so) focus on managing life safety risks. Managing risks under other risk categories such as asset protection or loss of production are only secondary considerations, if at all.

This is further evidenced by the interest that Insurer’s take in these operations – they are concerned about the potential exposure to losses and want to drive outcomes that lower these risk levels.

When identifying and assessing fire risk scenarios in mining and industrial facilities, it is common to find that health and safety is not necessarily the governing risk category, but in fact driven by others such as:

  • Loss of production

  • Asset protection

  • Legal/Regulatory

  • Reputational

  • Environmental

The lower risk level under health and safety can be due to many factors, including:

  • Mining and industrial facilities generally implement higher and more stringent safety rules at their operations, exceeding those applicable to a more ‘standard’ type of workplace and driving awareness and a culture of safety.

  • Fit and able-bodied workforce (not impaired) minimises complications when required to evacuate from a fire risk scenario.

  • Trained and competent workforce means the personnel on site are aware of the hazards and are more likely to take the correct action in response.

  • Low occupancy levels in the location of the fire risk scenario meaning low likelihood of health and safety consequences arising from a fire event.

  • Certain scenarios may be unlikely to cause significant or acute harm to a person but can have a much more serious impact on operations, e.g. fire in switchgear.

  • Health and safety consequence levels are consistently applied across businesses and industry; however, each operation or organisation sets their own risk tolerance levels for each risk category which can vary considerably.

Open-pit mining site showcasing layered earth and machinery, emphasizing fire risk management and safety in industrial operations.
These same factors often contribute to the higher level of risk under those other categories. For example, if the health and safety risk is considered low due to the low likelihood of a person being in the area, then the next question becomes: what are the chances of someone being alerted to a fire in that location and being able to provide rapid response to prevent escalation to a more serious event? This is where fire consequences can reach Major or Catastrophic levels.
 
Often the value of lost production for mining operations exceeds 7 figures per day, so the losses can mount up rapidly. This is why early intervention during the incipient stages is so critical – it is considerably easier to control and limit the scale of damage or loss.
 
Management of fire risks at mining and industrial facilities must consider the consequences of asset loss, including the value of the asset and cost to replace, what redundancy is in place around the asset and how critical it is to continued production. How much of the facilities production will be impacted? Are there short-term work arounds available? How long will it take the facility to get repairs completed and back operating?
 
Taking that one step further – how quickly can the fire protection system be reinstated once activated? It’s one thing to ensure critical spares or redundancy of process equipment are held on site, but if the risk of running the facility without the fire system is too great and it is difficult to obtain supplies to recommission the system, then this can be the oversight that ends up delaying the return to production.

THINK FIRE, THINK OMNII

At Omnii, we take a holistic view to assessing fire risks at mining and industrial facilities and identifying appropriate control measures. Whilst designing and installing fire protection systems can sometimes be the appropriate response, this is not always the case. Some facilities have existing controls in place which already address the risks.

CONCLUSION

It can certainly be argued that one’s duty of care at mining and industrial facilities extends well beyond that of merely achieving ‘compliance’. When the consequences (losses) can reach $10M’s+ in a matter of days, it pays to take your fire risk management obligations seriously and ensure they’re not just being treated as a box-ticking exercise.

Give Omnii a call today to discuss how we can assist in managing your fire risks!

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