1. 1 Occupational Hygiene Practice Legal Compliance from a Health and Safety Auditor’s Perspective 25 November 2015 Mike Valentine ERM Southern Africa SAIOH Gauteng Branch Workshop

2. ERM is a Global Environmental and Health & Safety Consultancy ERM Southern Africa has around 150 offices in main centres throughout the world, employing around 4000 staff 2 Background - ERM

3. Offices in Johannesburg, Cape Town and Durban (around 150 staff) Performance & Assurance and Transactional Services (PATS) Team:  Team of around 15, including environmental lawyers, certified H&S auditors, an occupational hygienist, registered safety practitioners, many with extensive industry experience  EHS legal compliance, risk and MS audits  EHS MS system development  Sustainable development assurance  IFC Compliance  Waste management consultancy  Occupational health and hygiene consultancy  EHS Due Diligence and Transactions 3

4. ERM conducts many EHS audits during the course of a year, both in South Africa and throughout sub-Sharan Africa Assesses many occupational health and hygiene programmes Has opportunity to view many occupational hygiene reports Often have audit findings relating to occupational hygiene  Most due to gap in employer’s responsibilities  Do have findings relating to occupational hygienist’s work This presentation is a summary of the findings for audits I have been involved in as relates primarily to occupational hygienist’s work 4 Background

5. Have conducted over 100 H&S audits since 2009 Including mining and non-mining industries For this exercise:  Looked at non-mining industries only  46 occupational hygiene reports  Reports covering 2009 – 2015  12 different occupational hygiene consultancies 5 Scope and Approach

6. Focus primarily on scope of occupational hygienist’s responsibility (as opposed to employer’s responsibility) Have not included findings around the basis for the types of surveys done (ie output of risk assessment, whether to sample for respirable dust, Cr(VI), noise etc etc) as in many cases occupational hygienist is directed by the employer for this Reviewed contents of occupational hygiene reports (where available) and the findings in our audit reports Results will be skewed a little towards audit findings as in many cases the occupational hygiene reports aren’t available and haven’t always included results from reports which had no findings 6 Scope and Approach

7. 46 Occupational hygiene reports:  Asbestos surveys (2)  Thermal stress (6)  HBA survey (1)  HCS survey (13)  Illumination (6)  Noise (11)  Ventilation (7) 7 Sample Size

8. Reports with findings: 29 (63%) Reports without findings 17 (37%) Note previous comments – not an accurate reflection of overall picture for occupational hygiene performance in SA 8 Results

9. 42 Findings 9 Findings - General

10. 13 reports, 12 have findings 22 Findings total relating to HCS Surveys 10 HCS Surveys - Results

11. 11

12. 12 HCS Surveys - Results

13. 13

14. 11 reports, 7 have findings 10 Findings total relating to Noise Surveys 14 Noise - Results

15. 15

16. 7 reports, 5 have findings 5 Findings total relating to Ventilation Surveys 16 Ventilation - Results

17. Asbestos: 2 cases where “Suspected asbestos material not identified or excluded in report” Heat stress: 2 cases where heat stress measurements performed during cooler months 17 Others - Results

18. 18 General Comments - Reports Many different people scrutinise occupational hygiene reports Sites are heavily audited The quality of the report in terms of technical content, attention to detail, grammar, relevance of recommendations, etc gives a good indication of the quality of the work done on site A poorly written report and work not conducted in accordance with legal requirements has a number of implications for operations

19. 19 Questions?

20. ER  Team 20 Thank you!