SOUTHERN AFRICA REFERENCE REVISION PAGE

DIVISIONAL SERVICES H&S 060 2 1 OF 12

HEALTH & SAFETY SYSTEM OPERATIONAL ORIGINATOR H&S MANAGER
PROCEDURE
EVALUATION OF COMPLIANCE
DESIGNATION PRINT NAME SIGNATURE DATE

COMPILED BY SNR H&S OFFICER E JUNGMANN Original signed 05/10/09

REVIEWED BY SNR H&S OFFICER R TUPPER Original signed 05/10/09

AUTHORISED BY H&S MANAGER J SODEN Original signed 05/10/09

TABLE OF CONTENTS PAGE ADDENDA PAGE

1. PURPOSE 2 ANNEXURE “X” – DEFINITIONS AND ABBREVIATIONS 6 – 10
2. SCOPE 2 ANNEXURE “XX” - REFERENCES 11
3. DEFINITIONS AND
2 RECORD OF AMENDMENTS 12
ABBREVIATIONS
4. REFERENCES 2
5. RESPONSIBILITY /
2
ACCOUNTABILITY
6. EVALUATION OF COMPLIANCE 3
7. RECORDS APPLICABLE TO
5
THIS PROCEDURE

REVISION DESCRIPTION OF REVISION DATE

2 REVISION DUE TO SEPT ‘09 AUDIT REQUIREMENTS 03 OCTOBER ‘09

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1. PURPOSE

The purpose and objective of this document is to provide guidance to SA Divisional Services for
harmonisation and common understanding in terms of periodic evaluation of compliance with
applicable legal and other requirements.

2. SCOPE

The scope of this document deals with the measurement of compliance and evaluation of legal and
other requirements the organisation subscribes to and ensure continual improvement

3. DEFINITIONS AND ABBREVIATIONS

Refer to Annexure “X”

4. REFERENCES

Refer to Annexure “XX”

5. RESPONSIBILITY / ACCOUNTABILITIES

Designation Responsibilities and accountabilities

HOD • Ensure a process is in place that will evaluate legal compliance.
• Ensure a system is in place informing him / her of changes to
legislation.
• Ensure a communication process in place that will communicate
changes to legislation to relevant personnel.
• Over inspection of legal documentation / SADSSS documentation.
Management • Ensure availability of resources to implement the OH&S programme
Representative • Ensure that analysis is made of information pertinent to OH&S
• Compare information with objectives, evaluate effectiveness of
controls and where targets are not met change controls to achieve
desired results
• Ensure information is distributed and communicated to employees
relevant to the work they perform
• Ensure that personnel are aware of applicable legal and other
requirements
• Ensure H&S Officer (Systems) keep and maintain records
H&S Manager / Snr. • Determining legal and other requirements.
H&S Officer Identify the critical requirements for legal and other requirements and
ensure it is communicated to relevant personnel.
Develop audit protocol matrix and implement.
• Audit all requirements throughout the year for compliance.
• Update the protocol as and when legislation changes.
• Record the audit and discuss results with management at the
management review meeting.
• Inform relevant employees about changes to ensure procedures and
lesson plans are reviewed and updated.
Foreman / Supervisor • Over inspection of workplace declaration process
H&S Officers • Record deviations on the Safety report and report findings to
management
• Evaluate compliance on systemic issues

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Risk Owners and • Ensure compliance to legislation and other requirements and change
Assurors COP’s, Standards as and when required.
Full Time Health and • Daily evaluation of compliance of workplace and safety representative
Safety Steward process
ATDS • Ensure that all legal training required are updated as per legislation
and trained accordingly

6. EVALUATION OF COMPLIANCE

SA Divisional Services states in the H&S policy that they will comply with all legal and other
requirements. This process enables SA Divisional Services to audit and evaluate our level of
compliance to all legal and other requirements applicable to us. There are various different processes
we utilise in the evaluation process and is described below.

6.1 Audits to evaluate compliance to legal compliance:

AngloGold Ashanti has implemented an internal audit team to evaluate legal compliance.

• OHSAS 18001 internal system audits conducted by AGA.

• System and operational audits conducted by DMR where required. (Add Hoc)

6.2 Systemic evaluation of compliance audits

The systemic evaluation of compliance audits are done by the HOD in conjunction with the H&S
department to evaluate the level of compliance in the section / process driven systems, and to ensure
the legal aspects are covered.

6.2.1 HOD’s

The systemic evaluation audit is done monthly by the H&S officers on the legal system and consists of
the following:

SADSSS documentation that contains legal responsibilities i.e. Appointments, Analysis,

information and induction.

Each HOD is evaluated against a standard evaluation document and the results are displayed at
monthly Wellness in the Workplace Meeting. The deficiencies / shortfalls are highlighted and
discussed with the HOD for continual improvement.

6.2.2 Engineers

This compliance audit is done in a systemic evaluation (done monthly by the H&S Officer) and also the
legal operational evaluation (done at specific intervals by the Engineering Manager).

6.2.2.1 Systemic evaluation

The systemic evaluation audit is done monthly by the H&S officers on the legal system and consists of
the following:

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Logbook that contains Appointments, Special Instructions, Planned Inspections, Planned
Task Observations, Safety Topics, Green Area meetings, Incident Reports and IBRA,
Emergency drills, etc.

Over inspection of the Safety representative management system

The results of all the evaluation findings are discussed at the monthly safety session.

6.3 Operational evaluation of compliance

Refer to Inspection system guideline (H&S 005)

6.3.1 H&S Officer legal workplace inspections

The H&S Officer will inspect working places on 30, 45 or 90 day intervals as prescribed by the Snr
H&S Officer. A Workplace schedule is updated daily by the Snr H&S Officer to indicate all working
places that have been visited.
The H&S officer will conduct daily audits to evaluate compliance to standards, procedures, etc.

6.3.2 Full Time Health and Safety Representative

The Full Time Health and Safety Representative will conduct a daily evaluation audit on the
compliance of the functions of the workplace safety representative. Any other issues identified will also
be brought under the attention of the Snr. H&S Officer.

6.3.3 The Workplace Health and Safety representative:

The workplace H&S representative discusses any health and safety issues with the team. He/she also
conducts other inspections as per their appointments.

6.3.4 Continuous Risk Assessment

Continuous risk assessment documentation e.g. checklists, planned inspection and planned task
observations are also used to evaluate compliance. The findings of the continuous risk assessment
documentation are analysed and used to form action plans and to implement preventative action.
Recorded on a monthly basis in the month end reports and discussed in the WITW Meetings.

6.3.5 Emergency drills

Emergency drills are conducted to evaluate the compliance of the emergency evacuation procedure
and the emergency preparedness procedure.

6.3.6 Maintenance (Engineering)

SA Divisional Services (ESW) has a fully integrated maintenance system referred to as the
Computerized Maintenance Management Information System (CMMIS). The system flags units to be
serviced and record service history of the units. Ultimately the system produces reports on the
compliance of actual services against the required standard and also highlight critical areas where
maintenance are lagging or are not being done in the form of exceptional reports, break down reports,
critical few issues, etc.

6.3.7 Planned task observations

PTO is a process used where an individual is observed performing a task to identify whether the task
is being performed correctly or where deviations take place and the reasons therefore identified.

All critical tasks should on a rotation basis be observed to ensure compliance to standards.

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6.4 Occupational Hygienist evaluation of compliances

The occupational hygienist does evaluation of compliance on exposure levels to dust, noise,
illumination and radiation as well as evaluation of compliance to the use of hearing protection devices.
Additional evaluations may be done if required to do so by regulation or when a notice appears in the
Government Gazette, or after assessing risks in terms of MHSA section 11(1).

The occupational hygiene programme must –

Be appropriate, considering the hazards to which the employees are or may be exposed; and

Be designed so that it provides information that can be used in determining measures to
eliminate, control and minimise the health risks and hazards to which employees are or may
be exposed.

The occupational hygienist works in liaison with the Occupational Medical Practitioner appointed in
terms of section 13(3), to link as far as practicable the hygiene measurement made with each
employee’s records of medical surveillance.

6.5 Monthly feedback reports

The monthly H&S Month End Report consists of a mixture of qualitative and quantitative information
that gets analysed by the various departments. The content of these documents are of a dynamic
approach and changes constantly as the need arise. Since the report indicates on the effectiveness of
the controls, the controls itself or the approach might be changed at these meetings. The report shows
leading indicators (pro-active) as well as trailing indicators (Re-active).

6.6 Acceptable risk

As far as reasonable practical, the existing and recommended controls will reduce the consequences
and the probability/likelihood of an injury occurring. The main purpose is to reduce the risk to an
acceptable level. Acceptable level of the risk on the Risk Index Matrix is aimed to be indicated
between 27 and 1.Certain risks can however not be reduced to that acceptable level due to the
consequences of the injury should it occur. If e.g. the risk is 48 with no controls it means that it can
happen several times a day with multiple fatal consequences. If all actions have been implemented as
far as reasonably practicable the likelihood of the event should be lower, but if it would have
happened, the consequences will remain the same thus sliding the risk only down from 48 towards 32
on the Risk Index Matrix. Special management controls and focussing on these risks are put in place
to manage the likelihood of an event occurring.

7. RECORDS APPLICABLE TO THIS PROCEDURE

Records Location

Legal auditing documents H&S Department

Risk Management month end report H&S Manager
All records as per SADSSS requirements SA Divisional Services Legal register

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 Annexure X

DEFINITIONS AND ABBREVIATIONS

DEFINITIONS:

DOCUMENT
Information and its supporting medium (The medium can be paper, magnetic, electronic or optical computer
disc, photograph or master sample, or a combination thereof.)

RECORD
Document stating results achieved or providing evidence of activities performed

CONTROLLED DOCUMENT
Any document that needs to be controlled in terms of its distribution and use, such as the Policy and
documented procedures. These documents are either signed in original ink and/or signed for on a
distribution list. These documents will be signed off after evaluation has been done to determine that they
are adequate for purpose. The document will be signed off by the relevant members as depicted on the
distribution list.
Once copies are printed of the database, they are considered to be “uncontrolled”.

OBSOLETE DOCUMENTS
Documents that have been replaced by later revisions or those that is no longer relevant or valid, and has
been cancelled from the system. These documents will be identified either by crossing them out and writing
obsolete or rubber stamp obsolete document.

UNCONTROLLED DOCUMENTS
Any documents that have not been issued under the circumstances under “controlled documents” are
categorised as uncontrolled. This includes, but may not be limited to:
• Documents that do not need to be controlled such as the monthly safety topic.
• Documents not distributed by the authorised person as per the procedures “authority and
responsibility” table and signed for by the recipient.
• Documents printed from the electronic database. (Watermarked “uncontrolled document)
• Documents duplicated or photocopied from controlled documents.
• Photocopies of the Occupational Health and Safety policy as issued to the public or other
Interested and Affected Parties

It is not possible to judge from an uncontrolled copy whether it is the latest version. It is the responsibility of
the person holding the documentation to ensure that (s) he has the latest version.

INJURY
Physical harm or damage

OCCUPATIONAL HEALTH AND SAFETY

Conditions and factors that affect, or could affect the health and safety of employees or other workers
(including temporary workers and contractor personnel), visitors, or any other person in the workplace

OH&S MANAGEMENT SYSTEM

Part of an organization’s management system used to develop and implement its OH&S policy and manage
its OH&S risks

SEVERITY / CONSEQUENCE
Outcome of an event. There may be one or more consequences from an event. May be expressed
qualitatively or quantitatively may range from positive to negative (Speculative).

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FREQUENCY
Occurrence per unit time, (May be expressed qualitatively or quantitatively).

EXPOSURE
How often and for how long employees are exposed to a hazard/s.

LIKELIHOOD
Means the chance of an event occurring.

DUE DILIGENCE
Taking reasonable care to protect the health and safety of all employees. Provide equipment, maintain the
equipment, use equipment as prescribed, provide information relating to the equipment, and provide
competent supervision.

INCIDENT
An undesired event which under slightly different circumstances could result in harm to people. Damage to
property or loss to process or an undesired event that could or does result in a loss.

RISK MATRIX
A Risk index can be determined by plotting likelihood and severity indices on the y and x-axis respectively
and then using them to obtain a risk ranking.

HIRA
Process of recognizing that a hazard exists and defining its characteristics
• H = HAZARD
Anything around us that we can see as well as those energy sources we cannot see e.g. Gas and
radiation that can cause harm
• I = IDENTIFICATION
Identify the significant hazards (Process and recognition)
• R = RISK
Risk imagining (Likelihood and consequence if risk materializes)
• A = ASSESSMENT
Determine the magnitude of the risk if materialized

ROUTINE ACTIVITY
An activity which is performed on a regular basis (day to day)

NON ROUTINE
An activity performed on an adhoc basis

ACCOUNTABILITY
Principle that, individuals, organizations, and the community are responsible for their actions and may be
required to explain them to others.

RESPONSIBLE
Liable to be called to respond to a person for issues to be done.

ILL HEALTH
Identifiable adverse physical or mental condition arising from and/or made worse by a work activity and/or
work-related situation.

INTERESTED PARTIES
Person or group, inside or outside the workplace, concerned with or affected by the SADSSS performance.

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NONCONFORMITY
Non-fulfilment of a requirement – can be any deviation from:
Relevant work standards, practices, procedures, legal requirements.

SADSSS OBJECTIVES
SADSSS goals, in terms of OHS performance, that SA Divisional Services sets itself to achieve. Objectives
are quantified wherever practical.

SADSSS PERFORMANCE
Measurable results of SA Divisional Services management of its risks.
Note: Performance measurement includes measurement the effectiveness of controls.

OHS POLICY
Overall intention and direction which will be followed for the management of health and safety.

RECORD
Document stating results achieved or providing evidence of activities performed

HAZARD
A condition or practice with the potential to cause harm, or exposure to danger. (Immediate Causes,
Substandard Act or Substandard Condition)

RISK ASSESSMENT
Process of evaluating the risk(s) arising from a hazard(s), taking into account the adequacy of any existing
controls, and deciding whether or not the risk(s) is acceptable

PREVENTATIVE ACTION
Action to eliminate the cause of a potential nonconformity or other undesirable potential situation.

CORRECTIVE ACTION
Action taken to rectify a non-conformance or deviation

CONTINUAL IMPROVEMENT
To constantly improve on current Health and Safety standards

PROCEDURE
Specified way to carry out an activity or a process.

RISK ASSESSMENT
Process of evaluating the risk arising from a hazard, taking into account the adequacy of any existing
controls, and deciding whether or not the risk is acceptable.

WORKPLACE
Any physical location in which work related activities are performed under the control of SA Divisional
Services

AUDIT
Independent and documented process for obtaining “audit evidence” and evaluating it objectively to
determine the extent to which “audit criteria” are fulfilled.

SAFETY MONTH
Period from the 20th of a particular month up to the 19th of the following month.

EFFORT BASED OBJECTIVES

Objectives set to improve program related issues

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EFFECT BASED OBJECTIVES
Objectives set to improve severity or injury rates

MANCOM
Management Committee

EXCO
Executive Committee

SUPERVISOR
Within SA Divisional Services – One who supervise or has charge and direction of i.e. Foreman, Clerk of
works, Training Officer, Residence Manager, Security Officer etc.

EMPLOYEE
Person working under the control of the organisation and includes contractors.

MANAGEMENT REPRESENTATIVE
A Person appointed in writing ensuring that the OH&S management system is established, implemented
and maintained in accordance with this OHSAS Standard;
and ensuring that reports on the performance of the OH&S management system are presented to top
management for review and used as a basis for improvement of the OH&S management system.

VISITOR
Any person who enters the premises of the mine who is not a full time employee or Contractor paid by the
mine

CONTRACTOR
Any person who perform work for the mine and is paid for his/her service.

ACCEPTABLE RISK
Risk that has been reduced to a level that can be tolerated by the organization having regard to its legal
obligations and its own

HEALTH AND SAFETY COMMITTEE

A committee as required by law M H & S Act Section 25(2)

VERIFICATION
Verification is the act of reviewing, inspecting, testing, etc. to establish and document that a product, service,
or system meets the regulatory, standard, or specification requirements.

VALIDATION
Validation refers to meeting the needs of the intended end-user or customer to
prove the truth or to determine or test the accuracy. Also, validation is the process of checking if something
satisfies a certain criterion.

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ABBREVIATIONS:

M H & S Act - Mine Health & Safety Act

MA&R - Mineral Act & Regulations
OHASA - Occupational Health and Safety Act
DMR - Department of Mineral Resources
DOL - Department of Labour
SADS - Southern Africa Divisional Services
ESW - Engineering Services Workshops
WITW - Wellness in the Workplace
H&S - Health and Safety
LTIFPD - Loss Time Injury Free Production Days
IFPD - Injury Free Production Days
AGAH - AngloGold Ashanti Health
TMM - Trackless Mobile Machinery
COP - Code of Practice
ATDS - AngloGold Ashanti Training and Development Services
CRA - Continuous Risk Assessment
SADSSS - Southern Africa Divisional Services Safety System

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 Annexure XX

REFERENCES

• Roles and responsibilities are depicted in each system procedure and updated as and when
required in table format
• OHSAS 18001:2007 (Occupational Health and Assessment Series)
• The Mine Health and Safety Act 29 of 1996
• The Minerals Act 50 of 1991
• Occupational Health and Safety Act (Act 86 of 1993)
• COIDA
• AGA Strategic Objectives
• Implex Legal Register
• ATDS Training Matrix
• AGA RCAT
• Corporate Procedure Directive
• Health and Safety Agreement
• SAR/OESH/P/A/001.01 – AGA Incident reporting
• H&S 004 – Incident investigation
• H&S 006 – Emergency preparedness and response
• H&S 014 – Issue based risk assessment
• H&S 018 – Baseline risk assessment H&S 019 – Control of records
• H&S 023 – Control of documents
• H&S 027 – Competence, training and awareness
• H&S 028 – Continuous risk assessment
• H&S 029 – Communication, participation and consultation
• H&S 030 – Management review
• H&S 031 – Internal audit
• H&S 037 – Management of change
• H&S 055 – SA Divisional Services Scope
• H&S 058 – Legal and other requirements
• H&S 059 – Performance measurement and monitoring
• H&S 060 – Evaluation of compliance
• H&S 061 – Nonconformity, corrective and preventative action
• H&S 065 – Objectives and programme(s)
• H&S 067 – Resources, roles, responsibility, accountability and authority
• H&S 069 – Operational control
• H&S 070 – Documentation
• H&S 071 – H&S Policy

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 RECORDS OF AMENDMENTS

PROCEDURE DATE OF
CHANGES TO PROCEDURE
REVISION NUMBER APPROVAL
H&S 060 – Revision 1 Purpose, Scope, Definitions and 3 June 2009
abbreviations, references, Roles and
responsibilities, Typical audits, PTO’s
H&S 060 – Revision 2 Name Changes 3 October ‘09

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