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Introduction In 2011, the Chamber of Mines commissionedthe Centre for Sustainability in Mining andIndustry (CSMI) to evaluate the progress andeffectiveness of the rollout of the MineOccupational Health and Safety LeadingPractice Adoption System (MOSH). CSMI,based in the School of Mining Engineering atthe University of the Witwatersrand, is anindependent research centre conducting healthand safety research relevant to all majorstakeholders in the mining sector. The purposeof the evaluation was to identify the factorsthat enabled or hampered the adoption of newtechnologies or practices. The timing of theevaluation, two years before the deadline forthe 2013 safety and health milestones, allowedtime for adjustments to be made. This paper

summarizes the results of the evaluation andincludes further analysis and discussion of thenature of the programme and the conditionsthat act to advance it or it hold back.

Background Health and safety in the South African miningsector is governed by the Mine Health andSafety Act (MHSA). The MHSA reflects anoutcomes approach to regulation, based onrisk assessment and risk management. Itprovides for extensive dialogue and consul-tation between the Mine Health and SafetyInspectorate (MHSI), which representsgovernment, employers and organized labouron matters of policy, regulation, research, andthe state of health and safety in the sector. TheMHSA also authorizes the MHSI to enforce theprovisions of the Act through issuingdirectives to take corrective action, haltingactivities that pose imminent and high levelsof risk to health and safety, and administeringfines. In addition, the MHSI is charged withthe responsibilities of promoting health andsafety through investigations and inquiringinto the causes of accidents, initiatingresearch, making health and safety datapublic, and issuing advice.

Tripartite engagement is formalized in theMine Health and Safety Council (MHSC). Thisis a national structure established by theMHSA that considers the state of health andsafety in the sector, proposes policy andlegislation, commissions research, andprovides advice to the Minister of MineralResources. Through the MHSC, organizedlabour, government, and employers cometogether to undertake their mandated joint

Mine Occupational Safety and Health LeadingPractice Adoption System (MOSH) examined – thepromise and pitfalls of this employer-led initiative toimprove health and safety in South African Minesby M. Hermanus*, N. Coulson*, and N. Pillay†

SynopsisThis paper assesses the effectiveness of the Mine Occupational Health andSafety Leading Practice Adoption System (MOSH) and its potential toimprove mine health and safety in South African mines. Developed by theChamber of Mines, which represents the majority of the country's largescale mining employers, MOSH was devised to accelerate progress towardsachieving health and safety milestones, which were set by tripartiteagreement in 2003. The paper documents and builds on the findings of astudy conducted by the Centre for Sustainability in Mining and Industry(CSMI) in 2011 that evaluated MOSH strategy, structures, and process ofimplementation.

The study found that MOSH operated across the mining sector, wasdirected and dominated by experts and, despite best efforts to includeother stakeholders, was led by employers. Statutory worker health andsafety representatives and structures were not integrated into the complexchange process developed by MOSH. The Mine Health and SafetyInspectorate (MHSI) and organized labour were ambivalent about directinvolvement in MOSH and preferred regulatory measures to enforce theparticipation of mines. MOSH interventions were not targeted at mineswith a poor health and safety record, and MOSH lacked a baseline fromwhich to track impacts on sector-wide health and safety performance. Theleading practices most widely adopted by mines were designed to improve,rather than fundamentally alter, existing practice. Although the depth ofengagement with MOSH among stakeholders and on mine sites varied,mining companies, labour representatives, and the Mine Health and SafetyInspectorate (MHSI) saw the programme as significant.

Keywordshealth and safety, regulatory framework, best practice, milestones.

* Centre for Sustainability in Mining and IndustryUniversity of Witwatersrand.

† Independent Consultant.© The Southern African Institute of Mining and

Metallurgy, 2015. ISSN 2225-6253. Paper receivedMay 2014 and revised paper received Dec. 2014.

717The Journal of The Southern African Institute of Mining and Metallurgy VOLUME 115 AUGUST 2015 ▲

http://dx.doi.org/10.17159/2411-9717/2015/v115n8a8

Mine Occupational Safety and Health Leading Practice Adoption System (MOSH) examined

responsibilities, which include a biennial review of health andsafety. The review takes the form of a convention called theMine Health and Safety Summit. At the Summit of 2003, thetripartite partners agreed to establish targets for health andsafety, and intermediate milestones for the period 2003 to2013 (DMR, 2013) (Table I). The 2010 Summit launched aframework that included guiding principles, commitmentsand action points, to shift health and safety culture, referredto in the sector as the Culture Transformation Framework.

As seen in Table I, the goals for 2013 involved reducingthe number of fatalities to levels attained by the miningsectors of Australia, the USA, and the Ontario province ofCanada; and from 2013 onwards, eliminating new cases ofsilicosis and noise-induced hearing loss. The attainment ofthese milestones represented a considerable challenge.

Before MOSH began piloting leading practices to addresshealth and safety challenges in 2008, the sector relied solelyon the individual efforts of mining companies to achieve themilestones. MOSH represented a shift to collective andinformed effort, active promotion of promising interventions,and engagement of the entire sector, across all commoditiesand all regions of the country.

The MOSH Leading Practice Adoption SystemMOSH centred on the uptake of leading practices to addresshealth and safety priorities and included both improvedtechnology and procedures. The practices addressed fourchallenges in keeping with 2013 health and safetymilestones, namely falls of ground; transport and machinery,relevant to the reduction of mine fatalities; and dust andnoise, relevant to the elimination of silicosis and noise-induced hearing loss respectively. Table II summarizes sevenleading practices promoted through MOSH at the time of theCSMI process evaluation.

Leading practices promoted by MOSH were alreadyestablished in industry, not yet widely used across the sector,and judged to offer significant health and safety hazard

mitigation potential. Identifying leading practice was the firststep. The site at which a leading practice was first found wascalled the ‘source’ mine. The next major step involvedpiloting the leading practice in a second mine site, referred toas the ‘demonstration’ mine. To support piloting at thedemonstration mine, research into the knowledge, attitudes,and values of workers, supervisors, and managersresponsible for implementation was conducted, to informsubsequently developed behavioural communication andleadership plans. This research was referred to asunderstanding the ‘mental models’ of workers, supervisors,and management. The adoption process at the demonstrationmine site was carefully documented and recommendationsmade about the process of adoption based on this experience.Once successfully demonstrated, the leading practice wasthen actively promoted for adoption across the industry as awhole.

The MOSH leading practice adoption system was system-atically documented in a handbook which described thestructures required for driving the programme, provided toolsand advice for overseeing implementation, and documentedprocesses for conducting workshops and other key activities.Other materials were also developed to support the adoptionprocess, which included documentation on the MOSH portal,DVDs, and brochures.

The organizational structures of MOSHThe organizational structures for MOSH in 2011 (and whichwere still in operation at the time of writing of this paper)included Adoption Teams, a MOSH Task Force, a LearningHub, and communities of practice. These structures providestrategic and operational focus, enable learning within thesystem, and guide and encourage implementation at minesites. At the time of the evaluation the structures wereconstituted as follows:

➤ MOSH Adoption Teams existed for each area ofleading practice aligned with the four priority health

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Table I

2003 health and safety targets and milestones (DMR, 2011; Pienaar and du Plessis, 2009; van der Woude et al.,2004)Target: zero rate of fatalities and injuriesMilestoneIn the gold sector: by 2013, achieve safety performance levels equivalent to current international benchmarks for underground metalliferous mines at least.In the platinum, coal, and other sectors: by 2013 achieve constant and continuous improvement equivalent to current international benchmarks at least.Target: elimination of silicosisMilestonesBy December 2008, 95% of all exposure measurement results will be below the occupational exposure limit for respirable crystalline silica of 0.1 mg/m3(these results are individual readings and not average results).After December 2013, using current diagnostic techniques, no new cases of silicosis will occur amongst previously unexposed individuals (previouslyunexposed individuals are individuals unexposed prior to 2008, i.e. equivalent to a new person entering the industry at 2008).Target: elimination of noise-induced hearing loss (NIHL)The present noise exposure limit specified in regulation is 85 dB(A)MilestonesAfter December 2008, the hearing conservation programme implemented by industry must ensure that there is no deterioration in hearing greater than 10%amongst occupationally exposed individuals.By December 2013, the total noise emitted by all equipment installed in any workplace must not exceed a sound pressure level of 110 dB(A) at any locationin that workplace (including individual pieces of equipment).

and safety challenges. These were led by one or twotechnical specialists, often seconded to the Chamber ofMines by industry for a minimum of six months (at thetime of the evaluation). Rollout of leading practiceacross the industry proceeded under the leadership ofthe Adoption Teams

➤ The MOSH Task Force provided governance andoversaw the adoption activity. High-level industry

representatives served on the MOSH Task Force. Theresponsibilities included ensuring that Adoption Teamswere well aligned to industry needs, and that the needsof the teams were communicated to industry

➤ The MOSH Learning Hub, at the Chamber, wasresponsible for managing the MOSH Adoption Teamsto maximize industry ownership, exposure, and buy-in

➤ Communities of practice were ad hoc structures that


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Table II

Summary of the seven leading practices promoted by MOSH in 2011

Leading practice Summary

Quieter rock-drill THE HILTI ROCK DRILL TE MD20 is a quieter rock-drill to reduce noise exposure in underground mines.Even though the Hilti rock-drill is much quieter than pneumatic rock-drills, it must be used together with aneffective hearing protection device (HPD) if noise exposure is to be reduced to a level below the occupationalexposure limit of 85 dBA.

Fogger dust suppression system The Fogger is an installation to capture airborne respiratory dust. This is an atomized water dust-suppression system. It reduces the risk of airborne respirable crystalline silica (RCS) dust and other dustthrough engineering out the hazard. It offers dust control at the points where dust is generated. Onceoperational, it reduces the exposure of a large number of employees when applied together with other silicadust controls.

Footwall and sidewall treatment This is a dust suppression technique to reduce airborne dust in underground mines. It is a technique thatinvolves wetting the footwall and sidewall with water and surfactants by means of a spray car or a hand pump.In trackbound mines, spray cars are pulled by locomotives and as the solution is sprayed dust that has settledon the foot and sidewalls is coagulated. This prevents the dust from becoming airborne. The treatment must berepeated at appropriate time intervals to be effective. The frequency of treatment depends on the operatingenvironment, and is determined at the mine site.

Nets with bolts A method for reducing fatalities and injuries caused by falls of ground (FoG) in underground mines.Bolts and nets are required and are installed in the hangingwall in the stoping areas of underground mines. Tobe effective the installation must:• Be as close to the hangingwall as possible and attached to mechanical props at the face• As close to the face as possible• Wide enough to provide coverage for most of the activities in the panel• Be held in place with roofbolts installed in a regular pattern• Have multiple attachment points to reduce the span of unsupported net• Where temporarily installed, be cleared of rockfalls, removed before the blast, and stored away from the

blast area.Hearing protection device (HPD) A selection and education package aimed at reducing noise exposure. selection tool and training and awareness The tool is in two parts. The first supports the selection of HPDs and the second provides educational material

to encourage compliance. The selection tool utilizes Excel™ software. It enables occupational hygienists onmines to choose the correct HPD for workers in different occupations based on noise exposure. Noise andfrequency measurements for all occupations in the mining industry are presented, together with information onall the HPDs available in South Africa and the purpose for which they are fit. The educational package aims toraise awareness of the hazard, and encourage the wearing of appropriate (but at times uncomfortable) HPDs. Itincludes two DVDs, training manuals for trainers, and comic-strip booklets. The booklets are available in fourlanguages.

Proximity detection device Preventing moving machinery from injuring people and collisions between vehicles. A proximity detectionsystem employs devices that sense the presence of nearby objects or people without needing to make physicalcontact to do so. Many types of devices are available and these use different means of signalling, such as wi-fi(radio waves), magnetic fields, or sonar for different ’targets’. The systems promoted by the MOSH leadingpractice initiative include devices for use in:• Hard rock mines with railbound equipment. These have loco–to-loco devices that give both visual and

audible warning to the operator to slow down, and if the operator does not respond, the device stopsthe locomotive

• Hard rock mine with trackless equipment. These have machine–to-machine OR machine–to-peopledevices, which give audible warnings

• Soft rock mines with trackless equipment. These have machine–to-people devices, which warn, slowdown the machinery/vehicle, and stop it if necessary.

Entry examination and making safe. A process of entry examination and making safe of current underground working places in order tominimize and eliminate fall-of-ground accidentsEntry examination and making safe procedures are legally required to be carried out regularly in undergroundmines, on the basis of a risk assessment, typically at the start of a new shift entering a working place. Thispractice is critical to safety in stope panels and development ends, but in and of itself carries high risk.

met to disseminate information on leading practices.Management, technical, and health and safety stafffrom mine sites were invited to attend a specificcommunity of practice (also known as COPA) for aspecific adoption practice. COPAs were facilitated inmining regions and often involved participants fromacross different mining companies and operationslearning together.

Methodology of the evaluation studyLeading practices were largely piloted in demonstration minesin 2008 and rolled out across the industry from 2009onwards. Although MOSH was designed to increase uptakethough the active promotion and guided adoption of leadingpractices, the programme progressed slowly and unevenly,prompting the evaluation study conducted by CSMI. Theevaluation was conducted between August and November2011 by a multidisciplinary team of researchers from CSMI,including researchers with backgrounds in miningengineering and geology, health and safety regulation, publichealth, and sociology. The team included an experiencedresearcher fluent in indigenous languages.

The evaluation was a three-tiered study of the MOSHintervention. Data was collected and organized under threemain themes: (i) oversight and governance, (ii) resourcingand capacity, and (iii) operational or mine-site levelintervention. The study involved the collection of qualitativedata through key informant interviews and focus groupdiscussions. Data was collected from all levels of the MOSHintervention from senior industry leaders and technicalexperts through to teams of employees involved with theimplementation of specific adoption methodologies.Underground/on-site visits at operations were also conductedto explore the specific context for leading practice adoption.The evaluation included an extensive review of MOSHdocumentation, including reports, minutes of meetings, andeducation and communication tools. In total fifteen peoplewere interviewed about oversight and governance, andtwenty individuals were interviewed about resourcing andcapacity. The majority of these interviews involved officialsand representatives from industry and the Chamber of Mineswith direct responsibility for MOSH. Representatives fromorganized labour and the MHSI were also engaged for theirperspectives on the governance of MOSH. Eight site visits tomines were conducted involving discussions with 119individuals. Of this number, a total of 55 workers were

reached through focus group discussions. Three of the seven leading practices promoted by MOSH

were selected for in-depth investigation by the research team.This was because they represented leading practices wherethere was greater uptake, documentation, and access to sitesthat could be followed from source to adoption mines. TableIII summarizes in generic terms the selection of mines forparticipation in the evaluation. However, it also shows that atthe time of the evaluation, only two of these practices actuallyfollowed the MOSH process to conclusion, from the sourcemine to the adoption mine.

The key evaluation questions and sub-questionsconsidered by the research team are listed below.

How is the process of MOSH adoption happening at a sitelevel? With a focus on:

➤ Understanding the MOSH process as it unfolds inpractice from the source mine through to implemen-tation at the adoption mine

➤ Assessing the key factors which facilitate and/or limitadoption

➤ Understanding how the process is currently monitoredand evaluated

➤ Understanding the rollout of leading practices acrossindustry using the adoption teams.

Assess the appropriateness and success of the existingMOSH structures, with a focus on:

➤ Assessing the performance to date of the LearningHub, other key role-players, and other componentstructures

➤ Evaluating the governance and accountabilitystructures of the Learning Hub

➤ Understanding the Learning Hub’s relationships withkey stakeholders and other bodies in the implemen-tation of the MOSH leading practice system

➤ Understanding the division of labour between all thekey role-players with regard to the implementation ofthe MOSH adoption system.

➤ Reviewing the capacity of the Learning Hub, other keyrole-players, and other component structures within achanging mining environment for meeting the MOSHmandate in future.

A limitation of the study was that the sample of leadingpractices examined largely represented the success stories ofthe MOSH leading practice adoption system. The motivation


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Table III

Mines selected for the evaluation of leading practice

Leading practice Source mine Demonstration mine Adoption mine

Dust: foggers Gold mine 1 Gold mine 2 Coal mine 1Noise: Hilti rockdrill Gold mine 3 Gold mine 4 Not applicable (Hilti rockdrill was not

rolled out beyond the demonstration mine)

Falls of ground Platinum mine 1 Gold mine 5 Coal mine 2Entry examination and making safe

and resources at participating mine sites may not berepresentative of the sector as whole. Mines that were notparticipating in the MOSH intervention were not included inthe evaluation and hence their accounts are absent from thefindings and analysis.

Findings of the evaluation studyThe findings of the evaluation point to MOSH success at amine-site level with some serious gaps at other levels of theprogramme, including in some cases mine-site level gaps. Thefindings are presented under five headings, with quotes takenfrom the research interviews to illustrate the points made.

Success at mine-site level relied on interpretation and acustomized fit

Successes at mine-site level were found to rely on both theability of Adoption Team Leaders, as well as minemanagement to interpret, distil and tune the MOSH AdoptionSystem for site-specific conditions (see Table IV).

At the level of mine site implementation, when mines hadsuccessfully committed to the adoption process there wasoften genuine engagement with the MOSH process. At themines visited it was clear that management had investedsignificant resources in meeting the implementationrequirements. This involved:

➤ Addressing problems arising during implementation➤ Seeking, listening to, and acting on feedback➤ Being prepared to go back to the drawing board when

initial efforts failed➤ Collecting data to support whether a leading practice

was working or not➤ With the exception of one site included in the

evaluation visits, the communities of practice weredescribed as a useful structure through which to shareexperiences.

It was at the level of the mine-site that the expertise andwisdom of the Adoption Team Leaders were widelyappreciated. One of the key findings at mine-site level wasthat workers, supervisors, and mine management acceptedand embraced the MOSH leading practices.

Responses to particular leading practices varied acrossmine sites as indicated in the accounts in Table IV. Certainleading practices were much easier to introduce. Entryexamination and making safe far outstripped the progressmade with other leading practices with respect to the numberof mines adopting a leading practice. Investments intechnology such as the Fogger dust suppression system orproximity detection systems presented much more complexchallenges, both in terms of capital outlay and alignment withexisting systems of risk management.

A gap in the MOSH process at the time of the evaluationwas that MOSH did not provide guidance on when and howto engage with suppliers and original equipment manufac-turers (OEMs). This was found to be particularly problematicwhen only one or two suppliers are available for a particulartechnology (‘… there are not enough technicians to attend toits failures’) and when technologies are being transferredacross commodities and the supplier or OEMs are workingout of their normal context.

The MOSH process was overly technical and complex

The overly technical and complex process of adoptionimplementation attracted a fair measure of criticism. The 48steps of the MOSH adoption process captured in a complexhandbook that includes 16 sections and 52 two worksheets andreference documents resulted in many individuals, even thoseintimately involved with the intervention, being unable to stateclearly ‘what is MOSH?’ The various elements and stepsclouded the central objective as the statements below attest.


The Journal of The Southern African Institute of Mining and Metallurgy VOLUME 115 AUGUST 2015 721 ▲Table IV

Successes and lessons of leading practices at mine sitesEvaluation report: case studiesMaking safe - implementer perspectives‘Up to now it has been a positive experience. Since the adoption of this leading practice we have less accidents, not just fall of ground accidents but areduction in other types of accidents as well. We have developed a better understanding between the workers and supervision, and they realize that we areserious about preventing accidents and looking after the workers’ wellbeing’ (miner and shift boss).‘Previously we would not all go into the workplace and do an examination. Only a miner would go into the workplace and the whole gang would be leftbehind at the waiting place. But right now we all participate and there is a difference. We can all pick up things that need to be fixed. We would fix things …we think it is a good system. … because we meet as a team and advise each other when we see something wrong.’ (Underground work team). The Hilti TE MD20 electric drill - what did the implementers learn?The evaluators noted that the introduction of the Hilti drill as a means to address excessive exposure to noise could not be supported if a compellingeconomic case could not also be made. This was the rationale at the source mine, where the Hilti rockdrill was introduced primarily for economic reasons.As the continued operation of the mine depended on the Hilti, everyone on the mine had an interest in seeing the change in drilling technology succeed. Thefact that management and workers freely shared information and concerns also helped. The direct benefits of the Hilti included reduced incidence of NIHL, areduction of 40% in compensation payable, reduced shift losses, and cost savings of R67 434.00 per panel (2008 costs).Attempts to transfer the Hilti rockdrill to mines where problems in production did not dictate the need for a change in drilling technology were notsuccessful. Commitments to solving the problem of noise alone proved insufficient to disrupt well-established drilling practice, especially as the change alsointroduced new risks associated with the weight of the Hilti drill and the speed of start-up. The Fogger - what did the implementers learn?The Fogger had the potential to reduce exposure to dust. The source mine reported a decreasing respirable dust trend and occupational exposure levels(OELs) of silica dust consistently below 0.1 mg/m3. At the demonstration mine, by the end of the project 59% of employees were aware that the fogger unitwas making a difference to their lives. The transfer of the technology to the demonstration coal mines presented new challenges due to different miningconditions to those associated with gold or platinum mines, at which Foggers were first employed.


‘It’s too many steps and the challenge is to make it muchsimpler. Mining people are simple people – we don’t needlaborious procedures. Decide what we are going to do andwe do it and measure our progress. We are adding toomuch complexity to a simple matter.’‘The management steps can be put in a nutshell. We didthis and did not fixate on a piece of paper.’The complex process also meant that common-sense

steps in a change management process, such as ‘buy-in’ for anew initiative, did not happen optimally. Rather,‘engagement’ tended to be codified in the process ofunderstanding ‘mental models’ and the preparation of‘communication and leadership plans.’

‘Is it possible to use other terms than mental models“getting understanding of how people think” or“perception survey”?’

Workers and other role-players felt marginalized by theMOSH processCodification also meant that labour representatives and otheractors felt left out or excluded from important activities.

‘With hindsight we should have involved the engineeringand health/medical sections of our mine in the MOSHproject.’‘I would say buy-in from underground teams is critical.This was made clear to me in the failure in … leadingpractice. There is sometimes a fine line between consul-tation and buy-in. A pilot shouldn’t be in one area butrather in a shaft or across a level because this is a betterplatform to roll out from. I don’t have a recommendationto the MOSH process other than don’t rush it and don’tforce feed … we followed the steps but we did not use thetemplates. Actually we used a mass meeting to kick-startthe whole process.’On paper, a strength of the MOSH process is its

commitment to worker involvement; however, in practice thiscommitment and the activities designed to foster involvement(such as mental models referenced above) did not alwaystranslate into a whole-hearted experience of participation.Workers were prepared for the introduction of changesthrough MOSH through a combination of demonstration, oneor more days of training, and on-the-job coaching. Workersdid not recognize the informal on–the-job coaching astraining.

‘Demonstration for one day! You can’t call that training!’ ‘We train ourselves … I talk to my team mate.’ Evaluation respondents used the term ‘resistance’ fairly

loosely to describe all the concerns, fears, and objections tothe MOSH process. The basis for this resistance could bewell-founded. For example, leading practices can interferewith the pressure to meet production targets. Entryexamination and making safe can and did result in longerperiods of time spent securing the work area at the start of ashift, as the following quote from an underground supervisorindicated.

‘Although we were not very supportive at theintroduction stage of the practice, as it affected ourproduction rate, we can see the benefits now: it gives aclear message to the workforce that we care for theirsafety. The unions and associations are supportive.’

There was an absence of a cogent strategy

The MOSH Task Team, constituted by industry represen-tatives, was considered as the primary structure involvedwith MOSH governance.

Respondents reported that MOSH did well in breakingdown traditional hierarchical and inter-company barriers andhelped to raise the profile of occupational health and safetyissues in the workplace. However, elsewhere in theevaluation findings it was also reported that the biggestobstacle to widespread support for MOSH was the ‘notinvented here’ mentality that results in disinclination at lowerlevels to implement the strategy.

‘The silo mentality is starting to disappear; we are in thisas an industry together.’ ‘At least the CEOs are starting to sing from the samehymn sheet – we face the same challenges and arestarting to get solutions.’Given the scope of the programme and the tasks involved,

the evaluation team found, surprisingly, that MOSH lacked acogent strategy. Dissimilar ideas about the intention(s) ofMOSH surfaced in the responses of individuals at differentlevels of the programme to the question, ‘what is MOSH?’ Atthe operational site level, MOSH practitioners talked about’finding leading practice’ or ‘sharing leading practice.’ Incontrast, role-players at the level of governance and oversightplaced more emphasis on the change management componentof MOSH.

‘MOSH is a comprehensive change management system.’ ‘MOSH changes the occupational health and safetyculture in the industry.’Although most respondents agreed that the MOSH

initiative was in part a response to the 2013 milestones andthat the impact of MOSH should be benchmarked againstthem, no hard success measures were applied to MOSH at thetime of the evaluation. The ‘number of mines adopting’ wasthe most frequently quoted measure of MOSH progress, withlittle or no reference to the limitations of such a measure.Other potential measures quoted by interviewees werereducing fatalities, creating a single industry standard,enhancing the skills of workers, and serving as a culturetransformation framework.

The absence of a well-articulated strategy also meant thatthe Adoption Teams were faced with issues that they wereunable to resolve. For example, it was acknowledged by theDust Adoption Team that some of the leading practicetechnologies promoted through MOSH sat low down in thehierarchy of controls and posed a dilemma for practitionerswho understand first principles. Over-simplifying the strategyor target setting for MOSH could result in leading practicesbeing taken off-the-shelf rather than being an integralcomponent of a well-reasoned health and safety riskmanagement system at a specific mine site. If the adoption ofleading practice was not based on risk managementprinciples, MOSH could be accused of simply ‘selling’ leadingpractice. The inclusion of MOSH in the amended 2010 MiningCharter (refer to the Discussion section) was cited as anillustration of this problem.

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‘Mining Charter both a driver and now a threat(compliance thereof). Not based on risk management butexpectations of implementing a leading practice.’The lack of cogent strategy also meant that decisions

about targeting priority environments and/or miningcommodities for leading practice were not made. TheTransport and Machinery Adoption Team had anoverwhelming task demonstrating the proximity device inthree different setting: coal and hard rock trackless and hardrock railbound machinery.

‘We felt people will respond negatively to us if we justselect hard rock and railbound transport, although this iswhere the number of fatalities are found – we haven’ttargeted our intervention.’It was striking how little power the existing structure felt

it had to influence strategy. MOSH governance could beconcluded to be ‘everybody else’s business.’ Problemcompanies with poor health and safety records could not betargeted by the existing MOSH structures; a point that isreturned to in the discussion below.

‘There is no process for targeting problem companies.’The most constructive suggestions regarding the way

forward were that the tripartite MHSC should developstrategy and that the 2013 milestones could be used as abasis to set further targets for the next decade.

MOSH was industry- and expert-led rather than led bytripartite partners

While MOSH made provision for the input of government andlabour representatives at all stages of the MOSH process,such involvement was patchy and particularly superficial inplanning workshops and decision-making structures of theprogramme. This underpined the observation that theChamber of Mine largely drove the programme on its own.Consequently, technical expertise and employer leadershipcharacterized the MOSH intervention, and this steered theevaluation team to describe the intervention as ‘expert-led.’

‘As labour we were brought in very late. Labour neededto be part of the research process.’‘… has been searching for experts, a range of expertswho can bring different expert dimensions to bear.’‘If a person is not a recognized leader in the industrythen you can’t succeed.’The MHSI expressed ambivalence about MOSH for a

number of reasons. First, it would prefer to engage with theprogramme though the MHSC, and secondly it wasuncomfortable with the idea of promoting practices low downthe hierarchy of controls. The MHSI also felt that theChamber of Mines should act against its members with theworst health and safety performance. The fact that theChamber of Mines is not representative of all mines was alsoa challenge to the MHSI.

Organized labour regarded the impact of MOSH assignificant at some mine-site levels but negligible in themining sector as a whole. Trade unions regarded theinvolvement of workers in making informed decisions as animportant outcome of MOSH. Labour felt they had animportant role to play at all levels of the MOSH intervention,but recognized their limited capacity to do this. Like the

MHSI, they also felt unable to resolve and articulate theirown role within MOSH and that the MHSC is the correct placefor strategic discussions about MOSH.

Discussion What is the ‘promise’ MOSH represented? Evidence at a sitelevel is that MOSH leading practices would be transferredbetween different sites, and where successfully transferred,could have beneficial effects. However, as shown in theevaluation, not all practices were easily replicated on differentmines, and relevant leading practices or technologies were notnecessarily taken up where they were most needed. Thismeant that the potential of MOSH was not fully realized. TheMOSH evaluation study found that the programme did nottarget specific mines where improvements in health and safetyperformance would be of most significance for the entiresector. Thus the fundamental logic that runs through MOSH –change your health and safety culture, introduce effectivetechnology and procedures, and improve the sectors’ healthand safety performance – seemed to falter at the first post.

This begs the question as to whether there were gaps inthe underlying or prevailing wisdom that were pertinent tothe prospects of MOSH as a premier vehicle for improvinghealth and safety. This is particularly important in the light ofthe new health and safety milestones that were set for theSouth African industry in 2014. In addition, what otherconsiderations would make MOSH worthy of continuedsupport and investment of time and resources?

The discussion here explores these questions byconsidering three areas that represent both the promise andthe pitfalls of MOSH. These are the contribution of MOSH inthe present climate of health and safety improvement; theexercise of leadership for MOSH within the health and safetyregulatory framework; and readiness for change and workerparticipation in MOSH at the mine-site level.

The contribution of MOSH to sector-wide health andsafety performanceThe data in Table V summarizes the fatality data at the start,mid-term, and the year preceding the end of the period forwhich the milestones apply. It was estimated that the safetyperformance of the South African mining industry, measuredas fatality rate per million hours worked, must haveimproved by at least 20% per year to reach the averagecombined fatality rates of Australia, the USA, and Ontario(Canada) by 2013, (DMR, 2011; van der Woude et al., 2004,


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Table V

Fatality rate per million hours worked – SouthAfrican mining vs. average combined rates formining in Australia, the USA, and Canada (Ontario)(Msiza, 2013)

Year Significance Actual Benchmark

2003 Initiative starts 0.30 0.072008 MOSH Leading Practice starts 0.15 0.052012 Penultimate milestone year 0.10 0.03


p. 6). While the South African mining sector had significantlyclosed the gap between itself and the benchmark countries interms of fatality rates, the actual number of fatalitiesremained high, at 112 in 2012; and the year-on-yearimprovements were more modest than planned. The mostsignificant reductions in the actual numbers of fatalities wereachieved on coal mines (-30%) followed by gold mines (-18%).

Figure 1 shows how the rate of fatalities in South Africanmines improved over time relative to the benchmark over theperiod 2003 to 2012 (Msiza, 2013).

Fatality figures were the starting point for the riskassessments that illustrated the importance of specific leadingpractices. Using fatality figures from 2009 for falls of ground,it was estimated that appropriate interventions could save upto 129 lives per year. However, although the goal of MOSH isto impact on industry-wide health and safety performance,the improvements that have been achieved across the sectorhave not been attributed (other than in general terms) by theChamber of Mines or the MHSI to any specific interventionspromoted through MOSH, such as netting and bolting safetysystems (Creamer, 2013; DMR, 2012).

Data of similar detail was not available for health, butprogress was described as follows. Exposures to crystallinesilica reported to the MHSI were all less than the occupationalexposure limit of 0.01 mg/m3, but cases of silicosis continuedto be diagnosed among miners. Whether the target of no newcases among previously unexposed individuals was achievedwas unclear. In 2012, 1075 miners were diagnosed withnoise-induced hearing loss of occupational origin, and thelargest numbers were associated with gold and platinummining (422 and 368 respectively). According to the MHSI,there was ‘no significant improvement on occupationaldisease’ (Msiza, 2013).

The difficulty of attributing safety improvements toMOSH was compounded by the fact that other majordevelopments were unfolding at the same time, such as aninitiative to change the culture of the mining sector, efforts toincrease training of safety representatives, pressure fromMHSI on mines to implement the outcomes of researchundertaken through the MHSC, and the MHSI’s more forcefulapproach to enforcement (Vogt, et al., 2011; Creamer, 2012).In addition, various companies had embarked on their owninitiatives to improve health and safety (Faurie, 2011).Without an established baseline and mechanisms to trackimprovements at site level, the impact of MOSH could not beascertained reliably against this backdrop. The problem wasidentified in the evaluation study and persists, although othermeasures of MOSH progress have subsequently beenembraced.

For example, the indicator for the number of adoptingmines was poorly selected and the reach of the programmeinto the industry could not be assessed. The underlyingreasoning for this was that individual mine sites were atdifferent stages of adoption, some of which were complex andtook months, if not years, to resolve, rendering the indicator‘number of mines adopting’ meaningless over time. Anexception was the leading practice for ‘entry examination and

making safe’, which far outstripped other leading practices interms of its spread into the industry. Notably, this practicenecessitated a change in procedure rather than theintroduction of new technology.

In addition to parallel initiatives and the absence ofbaseline data, the impact of MOSH was also obscured bychanges in reporting requirements in the amended MiningCharter in 2010 (DMR, 2010), the subsequent 2012 IndustryMining Charter Health and Safety Report (Chamber of Mines,2012), and an ’Adoption Scorecard’ introduced by theAdoption Teams within MOSH. Mines were required to reportat first the number of mines adopting leading practice, andthereafter the proportion of adopting workplaces relative tothe number of workplaces at which leading practices shouldbe adopted.

However neither the Charter and nor the scorecardprovided the necessary baseline to support meaningfulmeasures of outcome and impact. The number of work sitesadopting, number of teams trained, and units installedamong others were the only measures of progress withinMOSH. Appropriate outcome measures could be expected toinclude relevant health and safety leading indicators, andimpact measures relevant lagging indicators of health andsafety performance. However, none of this was possiblewithout a baseline that enables tracking.

MOSH and the exercise of leadership within thehealth and safety regulatory framework

The inception, implementation, and growth of MOSH shouldbe understood within the context of health and safetyregulation in the mining sector in South Africa.

South Africa’s health and safety legislative environmentin the mining sector is guided by outcomes-based legislationthat embodies general responsibilities for employers toprovide safe and healthy workplaces, self-regulation, andparticipatory arrangements, allowing employers throughengagement with workers to determine how particularoutcomes are to be achieved. ‘A performance standardspecifies the outcome required but leaves the concretemeasures to achieve that outcome up to the discretion of theregulated entity.’ (Coglianese et al., 2002, p. 3) In other

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Figure 1 – Fatality rates per million hours worked, since agreement onthe targets and milestones (adapted from DMR data, Msiza, 2013)

words, it is not prescriptive. ‘In contrast to a design standardor a technology-based standard that specifies exactly how toachieve compliance, a performance standard sets a generalgoal and lets each regulated entity decide how to meet it’(Coglianese et al., 2002, p. 3). Outcomes-based legislationcreates space for national health and safety strategy. The2013 health and safety milestones are an example of this.

South Africa is not alone in adopting an outcomes-basedapproach to health and safety legislation. The Mine Healthand Safety Act (MHSA) 29 of 1996 is shaped by theapproach to health and safety accredited to the British‘Robens Committee’ (Robens, 1972) that concluded that‘apathy’, both on the part of employers and employees, wassignificantly contributory to poor health and safety outcomes.The recommendations of this Commission ushered in an eraof health and safety practice that arises from the idea thethere is a ‘natural identity of interests between employersand employees’ (Robens, 1972, p. 21) on issues of healthand safety. The main features of the Robens model are thatemployers have primary responsibility for risk management,and that workers are party to decisions about how best toaddress health and safety risks through elected health andsafety representatives and structures such as employer-employee health and safety committees. All of these arefeatures incorporated into the MHSA. Although widelyapplied, the Robens model is also criticized as being toobusiness-friendly, institutionalizing of the concept of self-regulation, and glossing over fundamental social conflict(Tombs and Whyte, 2012). The last point, about overlookingconflict, seems to have particular relevance for the SouthAfrican mining sector, in which both class and racialdivisions, often coinciding, play out.

To elaborate, South African outcomes-based health andsafety legislation was introduced into a mining contextshaped by apartheid and a skewed economic system thatmarginalized and divided people on racial grounds. Miningwas at the heart of the apartheid economy, and mining-related legislation until the late 1980s formally discriminatedagainst black South Africans, who make up the majority ofthe population, by restricting them to manual work at thebottom of the employment hierarchy. Black mineworkerswere confined to hostels and inferior rates of compensationwere paid to black miners for occupational injury or ill-health. Estimates are that over 70 000 black miners died inmine accidents since the inception of mining, and an evenlarger number contracted silicosis. The 1994 LeonCommission of Inquiry into Safety and Health in the MiningIndustry (Leon Commission, 1995) and the subsequentMHSA were early advancements associated with the post-apartheid Mandela government. Sector-wide studies showthat the apartheid legacy is still felt by workers (Hermanus etal., 2010; Shaw et al., 2010, 2011), especially with respect toracism, the practice of bonus payments, and a culture ofblame. It is within this context that the South Africanexperience of health and safety outcomes-based legislation isoperative.

The MOSH initiative is in essence a voluntary industry-level action, which the Robens Committee regarded as havinghigh potential for improvements:

‘Progressive employers recognise that firms within anindustry should work towards higher standards collec-tively, so that progress is not impeded by fear of unfaircompetitive advantage. There is virtually unlimited scopefor practical work by industry-based safety bodies whichcan collate and interpret statistics, publish information,undertake technical surveys and research, and provideadvisory services to individual firms, and liaise withgovernment departments and inspectorates. Throughthese means each industry can work towards the solutionof its own special problems.’ (Robens, 1972, p. 15)However, in the South African context, as MOSH sought to

shift industry practices, it required the support and cooperationof labour and the state. Yet the initiative was conceived andpromoted outside of the tripartite forums that enablegovernment, labour, and the employers to work together. Bothorganized labour and the MHSI expressed a desire for MOSHstrategy to be resolved through the MHSC, although this couldchange the voluntary status of the initiative. Nevertheless, asconceived in legislation, the MHSC’s functions are consistentwith Robens Committee’s ideas.

The insistence of both labour and MHSI, that participationin MOSH should not be voluntary, was subsequent to the2011 evaluation, and achieved by incorporating MOSHleading practices into the Mining Charter. The Charter is aregulatory instrument for ‘transforming’ the mining sector inSouth Africa. The scorecard and associated reporting templaterequire companies to report on both the consideration anduptake of MOSH leading practices (DMR, n.d. (a), (b)). Thusthe problem posed by the voluntary nature of MOSH ofuptake at poorly performing mines was offset bydevelopments in the regulatory environment.

The translation of a voluntary initiative into a regulatoryrequirement underscores a difficulty at the heart of the SouthAfrican tripartite system, namely that the main employerbody is not trusted (Shabangu, 2011) and has difficultytaking forward major voluntary initiatives without theexpressed endorsement of stakeholders. Changes to themandate of the MHSC, in which the role of the Minister ofMineral Resources (rather than the tripartite MHSC) is centralto policy-making, reflect these dynamics (Odendaal, 2013).In addition, stakeholders prefer an arms-length relationshipwith employers, as one way of being seen to preserve theirown integrity. This has meant that MOSH is endorsedthrough enforcement rather than ongoing engagement overthe content and impact of the programme.

Subsequent to the completion of the CSMI evaluation, theLearning Hub established, in addition to MOSH Task Team,the ‘MOSH Advisory Group’ to specifically include represen-tatives from labour and the MHSI. However, this does notnecessarily strengthen engagement. MOSH needs to deal withthe problem of engagement and involvement of otherstakeholders within the MHSC, rather than bypass it throughestablishing non-mandatory advisory structures.

Readiness for change, worker participation, andMOSH at the mine-site levelThe MOSH initiative reflects the Robens Committee’sassertion that ‘The primary responsibility for doing




something about present levels of occupational accidents anddisease lies with those which create the risks and those whowork with them’ (Robens, 1972, p. 7), but runs intodifficulties to those experienced elsewhere in respect of fullyengaging the workforce. This is evident at both the nationallevel of MOSH leadership (as discussed above) and at mine-site implementation level as reflected in the findings. It is thelatter that is discussed here.

One of the underlying assumptions of MOSH was that theMOSH process of engagement could induce a process ofchange. Numerous steps and templates in the MOSHhandbook codified a process of engagement that encouragedpractitioners to get in touch with what workers specificallywere thinking and to ensure that mine-site leadership carriedan appropriate message. However, findings in the evaluationpoint to the difficulty of achieving this without reference tothe specific environment in which MOSH was beingintroduced. The contexts of each mine site varied, and hencethe call by mines themselves for guidance about basicprinciples, and not ever-increasing detail. Therefore moreflexibility was required which allowed mines to interface withthe MOSH process differently, based on the level of readinessto embrace change.

Readiness is shaped by a number of factors (Hopkins,2012; Novatis et al., 2012) It is shaped by whether managersat every level in an organization recognize the importance ofdealing with health and safety risks and make this a priority;whether organizations have properly engaged workers toobtain their support and cooperation for efforts aimed atimproving health and safety; and whether the experience andknowledge of workers of health and safety risks isunderstood and appreciated. It further extends to ensuringthat processes are in place to secure and maintain theappropriate skills that are important in addressing health andsafety risks. This also applies to different levels in an organi-zation, so that workers, supervisors, managers, and technicalsupport teams have complementary and integrated responsi-bilities for health and safety. Related factors that are equallyimportant to an organization’s ability to address health andsafety risks are quality of leadership, culture (especially asense that organizational culture is just), trust, engagement,and worker participation (Gunningham, 2008; Dekker,2008). These have specific relevance in South Africanmining, as discussed earlier.

Although MOSH embodied tools to address leadershippractice, communication, worker perceptions, and attitudes,the problem of deep-rooted mistrust and all that flows from itwere not specifically acknowledged or addressed. This couldbe achieved by linking to the industry-wide ‘CultureTransformation Framework’ (MHSC, 2011) which supportsinitiatives to shift the culture of the industry.

Linked to the issue of organizational readiness for changeis the observation that the MOSH process did not incorporatethe role of workers in health and safety as envisaged by theMHSA. At the site level, the expert-led paradigm of MOSHkept labour at the edge rather than central to improved healthand safety. Worker health and safety representatives andemployer-worker health and safety committees were notcentral to the MOSH process at the site level. Engagementwith the site level health and safety committee and/ortraining of health and safety representatives specifically werenot a feature of MOSH activities on site, but could be. Duringthe evaluation, respondents from organized labour reported

being brought into the MOSH process at a late stage. Meetingwith the health and safety committee should be at an earlystage of engagement and a key step in establishing buy-in ata mine.

MOSH collapsed the process of engagement with workers,to focus mainly on the collection of data to support thedevelopment of mental models about specific health andsafety concerns and interventions. These models profile theknowledge, attitudes, and perceptions of workers and areused to shape behavioural communication and leadershipbehaviour plans. These types of studies can be time-consuming and require that interviewers are properly trainedto conduct interviews. One of the recommendations of theevaluation was that this type of study could be commissionedat a national/regional and/or commodity level rather thanhaving to be repeated at each mine site. Communication andleadership plans could be adapted for specific mine sites.However, more importantly this type of approach isfundamentally focused on building a process for changethrough understanding individual behaviour, when in facthealth and safety is fundamentally about building aneffective system (in which, obviously, consideration ofindividual behaviour has a role, but is not the driver).

Without sufficient integration into the existing health andsafety system, MOSH effectively minimised the opportunityfor engagement with labour. Engagement with workersshould include active engagement with health and safetyworker representatives and labour structures at the mine site,as well as with regional and national labour structures.

The extent to which the present MOSH initiative misreadthe process of engagement is further evidenced in theintroduction to MOSH, subsequent to the 2011 evaluation, of‘simple leading practices.’ Simple leading practices areexamples of technology changes that can be made withoutneeding to engage, such as winch covers to minimize dust.This new focus was presented as ‘quick wins’, but alsoperpetuated a legacy of an industry unable to resolve issuesof engagement and fundamental change, albeit in a difficultand complex environment.

ConclusionsMOSH is an ambitious initiative with complex technical,structural, and procedural elements. It was clear the miningindustry as a whole engaged with MOSH to various degrees,and labour and the MHSI saw MOSH as significant.

The full impact of MOSH and its sustainability across themining sector was not clear. It was evident that where MOSHworked well, mines usually considered and implementedseveral leading practices simultaneously. This was partic-ularly the case when a mine subscribed to a broad strategy ofimprovement and culture change. In these instances thereappeared to be greater capacity to absorb the processes andtechnologies of the MOSH adoption system. Difficulties inassessing the impact of MOSH arose from many quarterswithin the MOSH programme itself, which did not clearlydefine and measure its impact, and the fact that MOSH wasone of many initiatives to improve health and safety in SouthAfrican mines. Many of these were launched and operatedsimultaneously, and the effect of one on the other was neverconsidered. An example of this was how a tough newregulatory approach, the culture transformation framework,and the MOSH processes could be expected to interact.

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There are also factors that hamper MOSH which arespecific to the operational environment of South Africanmines and the nature of the Chamber of Mines.

➤ Although the Chamber represents the majority of mineemployers, it is unable on its own to take forwardnational-scale decisions even when these may be in thebest interests of the workers and people affected bymining. Thus one of the unspoken challengesassociated with MOSH at the time of the evaluationwas that it was championed by an employer body withprimarily an advocacy role, which relied solely onvoluntary uptake by mining companies

➤ As found in the evaluation, the Chamber, as avoluntary organization representing employers, couldnot set hard performance targets for mines.Consequently the costs and resources necessary tosustain MOSH over time were likely to havediminishing returns because the initiative could nottarget companies with the poorest health and safetyrecords, which in turn could chose not to adopt MOSHfor their own reasons

➤ While the MHSI chose not to participate in the designand planning of MOSH, or actively lead the uptake ofleading practices, two years after MOSH’sestablishment it provided indirect support throughregulation. The incorporation of MOSH into the MiningCharter and related scorecard introduced pressures tocomply, something that the Chamber was unable to do.The effect of this might still be, ironically, to mask anddiminish the problem of not being able to target mineswhere performance is wanting.

Another factor that affects MOSH was that theprogramme did not formally recognize that different organi-zations were not able to initiate and absorb change in thesame way. However, in the Adoption Teams and on minesites, the organizational context of health and safety didcome into play, and found expression in the concerns raisedover the complexity and highly-structured nature of theprocess, and the adaption of the process on site.

Finally, it is apparent that the MOSH process unfoldedoutside the formal health and safety system described in theMHSA. Whether mines can find ways of drawing health andsafety committees and health and safety representatives intothe programme is a matter worthy of further consideration.

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