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Appendix C – Overview of Stakeholder Input

  • Issued: September 10, 2014
  • Content last reviewed: September 2014
  • See also: Final Report

During the public consultations and in the written submissions, certain issues were consistently raised. The following is a summary of those issues, organized into the six issue areas identified by the Advisory Group as well as an "other" category.

Note: this is not a comprehensive list of all topics or opinions heard through the public consultation. However, the Review is considering all relevant comments and recommendations. Input that is outside of the scope of the Review will be shared with the appropriate parties for their consideration.

1. Capacity of the Health and Safety System Working Group

  • The importance of a well-trained, consistent inspectorate. Opinions on the role of inspectors differed: some stakeholders wanted more focus on enforcement; others wanted inspectors to play a stronger advisory role
  • The need for the Ministry of Labour to have access to the necessary technical expertise to support prevention and enforcement activities, especially expertise in areas such as ground control and ventilation
  • The importance of clarity and transparency, and the need for the Ministry of Labour to provide more information on its enforcement activities and guidance on the regulations
  • Strong support for the training provided by Workplace Safety North and the Workers Health and Safety Centre, and the need to address the ability of workplaces – especially those outside the Sudbury basin – to access training programs
  • The need to improve the Coroner’s Inquest process and requests for the Ministry of Labour to work with the Ministry of Community Safety and Correctional Services to investigate ways to improve the process.

2. The Internal Responsibility System

  • The importance of a common understanding of the term "Internal Responsibility System" and how it is implemented in the workplace, based on the principles set out in the Ham Commission report.
  • The need for an improved Joint Health and Safety Committee (JHSC) Certification Standard and quick implementation of the proposed JHSC Training Standards.
  • The important role of the front line supervisor in enabling a functioning IRS and the need for supervisor training that includes ways to enhance the IRS in the workplace.
  • The critical role that the working relationship between employees and employers in a workplace plays in determining the success of the IRS, and ways to promote better communication of health and safety issues as one way to improve that relationship.
  • Many submissions provided recommendations on how the IRS could be strengthened by providing workers and the JHSC with greater powers in the workplace to affect change
  • The importance of active senior management support for the IRS, and the need for more accountability and/or speciality training modules for senior managers.
  • The importance of all people working in mines being free from the fear of reprisals, and the need to enhance protection from reprisals.

3. Technology and the Management of Change

  • The need to develop a standard risk assessment model to be used in the mining sector including the possibility of a regulation requirement risk assessments
  • The critical importance of proper change management processes that include risk assessments when implementing new technology or processes
  • Greater employee participation in evaluating risk and in change processes, and clearer guidance on the involvement of employees and JHSCs (i.e. meaningful engagement/consultation rather than just informing worker members)
  • The importance of sharing information on new technologies introduced in the workplace and developing a method to share information on any operational issues related to a new technology.

4. Mining Hazards

  • The recognition that most underground mining hazards are known and are not new (i.e. the hazards of a decade ago are the same hazards today). Acknowledgement that ground control and mobile equipment hazards are major sources of risk in mines
  • The importance of workplace parties and the health and safety system addressing these known hazards/risks.
  • Concerns about proper mine ventilation, the control of occupational disease and ergonomics in underground mining. The need for the mining sector to put more focus on controlling occupational disease.
  • The critical importance of visibility in low light settings and the hazards associated with sight line issues posed by large moving equipment. The need to implement best practices such as providing Class 3/Level 2 high-visibility safety apparel.
  • The need for the Ministry of Labour to enhance its ability to regulate new mining hazards, including concern that regulatory change is too slow and regulations are not keeping pace with changes in the mining sector.

5. Training and Skills Development

  • Almost unanimous support for the Common Core concept and approach for the mining sector. Concerns focused mainly on the delivery of modules rather than the content. Some expressed need to develop better standards for trainers
  • Concerns about the training of new employees, including those from demographics not traditionally part of the mining sector. The importance of methods to evaluate the effective transfer of knowledge, with the key focus on competency
  • Despite overall support for the Common Core, the need to review some modules, especially those related to supervisors. If standards for trainers and evaluation tools are developed the importance of considering the differing lengths of time spent to complete the modules
  • Concerns that, once an employee completes the necessary modules, no further training is required and the need for mandatory refresher training
  • Some support for making mining a registered trade and developing the appropriate apprentice programs to ensure knowledge is transferred from the more experienced miner to the apprentice. However, also strong opposition to this idea from those who feel the current Common Core modular training model serves the sector well

6. Emergency Preparedness and Mine Rescue

  • Strong support for and pride in Ontario’s mine rescue system, and general satisfaction with the current way mine rescue is set up and operates
  • The need to evaluate the ability of mine rescue to respond to hazards created by new technologies and mining methods. Concerns about the ability to launch rescue operations as mines in Ontario get deeper and distances from the shaft increase.

7. Other

  • Comments on Coroner’s inquests and their recommendations. A desire for Coroner’s jury recommendations to be mandatory and for the process to include mechanisms to ensure Coroner’s jury members are knowledgeable about mining and mining practices as well as relevant legislation.
  • The need for better funding for research related to underground mining health and safety.
  • The need to improve the method of reaching out to stakeholders for the public consultations (e.g. using paid media advertising as well promoting the sessions through employers and unions).
  • Support for the Review but regret on the part of some that the provincial government did not strike an inquiry.