Proximity Detection Systems legislation: what do we need to know?
The current regulations for diesel machines, specifically for opencast mines, are only a warning mechanism. The PDS needs to warn the driver that there’s another machine in its proximity.
The December 2015 promulgation of the mandatory use of proximity detection systems (PDSs) by South Africa’s Department of Mineral Resources (DMR) has raised concerns within the opencast mining sector, especially among quarry operators.
In September 2014, the quarrying industry became involved, for the first time, with the Mining Industry Occupational Safety and Health (MOSH) initiative, led by the Chamber of Mines’ Learning Hub. The MOSH study was initially aimed at underground mining only, but recently shifted focus to opencast operations and used DMR data from 2008 to 2013 to analyse the risks and prevalence of accidents at opencast mines.
Quarry operators feel hard done by this legislation. Their argument is that a one-size-fits-all approach to eliminating fatalities on mines is not necessarily useful unless proper studies are done across the full spectrum of mines and quarries in specific focus areas. The number and types of machines used in quarries are very different to those found in the MOSH studies. For example, fewer machines operate in typical sand and stone quarries, and the sizes of these machines tend to be smaller than on a mine. Operators are more aware of their surroundings and can more easily detect objects in their work areas. The quarrying sector is also concerned that in this sector there are far more one-man businesses, with limited resources, and it is not ideal to compel a first world leading practice to a one-man operation. They rather feel that there are cheaper ways than the ‘leading practice’.
While these concerns have been raised, the regulator maintains that this legislation is here to stay. It further advises relevant mines concerned understand exactly what the regulation says. So, what does the legislation really say? The current regulations for diesel machines, specifically for opencast mines, are only a warning mechanism. The PDS needs to warn the driver that there’s another machine in its proximity, which the mine itself must’ve identified as unwanted or risky.
The regulation says, in a separate paragraph, if the driver of the vehicle does not respond to the warning, the vehicle needs to come to a slowdown or standstill. However, that specific part has not been promulgated yet. The regulation says it will be promulgated at a time when the technology is mature enough. The general belief in the industry is that the second part is premature. As a result of these inputs, the regulator (DMR) said it will only be promulgated at a later stage.
As quarry operators argue, is there any value if the regulations or leading practice differentiate between mines and quarries because of different risks, and resources? The regulation, if you read it verbatim from the government gazette says, “where a significant risk exist”. In other words the regulator has left it up to the specific company to assess whether the risk exists.
The regulation does not define that risk. This implies that there is a way for the industry to deal with the uniqueness of operations. It now lies in the hands of industry to compressively assess its risks. For example, the probability of a vehicle to be in an accident in a quarry, because of berms and dedicated lanes, is extremely small. I believe one is able to justify that they don’t have that risk, and therefore they do not need to install PDS technology. If one looks at the intent of the regulation, it is good. The industry now really needs to apply their minds on how they are going to deal with it.
For me, what this legislation is saying is that operations should develop leading practice for traffic management. Identifying risk and applying ways to address the particular risk means that mines can implement other ways, such as pedestrian walkaways that have been implemented across a number of quarries, which prevents them from spending millions on PDS technology. If mines apply these practices, the probability of them having to rely on a PDS, would be very low. They would be in a position to put to the regulator a very strong case that they have addressed the risk sufficiently and therefore do not need a PDS.