IRMA Standard for Responsible Mining (Draft 2.0)
Chapter 2.2 Occupational Health and Safety


Occupational health impacts related to the mining industry may include physical injuries; musculoskeletal disorders; noise-induced hearing loss; hand-arm vibration syndrome; skin cancer; dermatitis; heat exhaustion; hypothermia; eye disorders related to radiation exposure; asphyxiation; pneumonia; respiratory disorders; damage to internal organs and other effects related to chemical/metal exposures; decreased mental health and wellbeing; and others.[1]

In 1995, the International Labour Organization (ILO) adopted Convention 176–Safety and Health in Mines).[2] This convention set out international standards with respect to mine-related safety and health inspections, accident reporting, investigation, training, hazard assessment and management, and workers’ rights to participate in workplace health and safety decisions, be adequately trained in their tasks, be informed of occupational hazards, and remove themselves from dangerous workplace situations

Objectives/Intent of this Chapter

To identify and avoid or mitigate occupational health and safety hazards; maintain working environments that protect workers’ health and working capacity; and promote workplace safety and health.

Scope of Application

Chapter Relevance: This chapter is relevant for all mines applying for IRMA certification, however, requirements and e, and are only applicable for underground mining operations.


  • Moved general references to ILO such as “The operating company shall conform with the requirements of Part III of ILO Convention 176 on the Safety and Health in Mines, 1998”, and created IRMA-specific requirements that clearly lay out the information that was in the ILO materials. Where we drew on ILO Conventions we will reference it in Guidance for this chapter, so that companies and stakeholders will be able to see which requirements align with ILO.
  • Removed some of the prescription related to the OHS risk assessment process, and refer more generally to OHS risk assessment processes. We will add Guidance on the steps that should be included, such as hazard identification, etc.
  • Reorganized to try to group material more logically and removed duplicative requirements (i.e., once we laid out all ILO requirements instead of just referring to them, it became clear that there was overlap and duplication with some of the existing requirements).
  • Clarified requirements related to worker compensation for injuries (
  • The means of verification (MOV) have been removed from this version of the draft IRMA Standard. If you would prefer to review and comment on a version of the draft Standard that has the means of verification, you can download a pdf version of the Standard with MOV.

Occupational Health and Safety Requirements

2.2.1.  Health and Safety Risk Assessment and Management  The operating company shall implement an ongoing, systematic health and safety risk assessment process that follows a recognized risk assessment methodology for industrial operations.[3]  The health and safety risk assessment process shall consider, at a minimum, risks to health and safety associated with:

a.   The design, commissioning and operation of the workplace; mining-related processes; the physical stability of working areas; the organization of work; equipment and machinery; and waste and chemical management;

b.   All personnel, contractors, business partners, suppliers and visitors;

c.    Routine and non-routine activities, products, procedures, and services; and

d.   Planned or unplanned changes in duration, personnel, organization, processes, facilities, equipment, procedures, laws, standards, materials, products systems and services.  The operating company shall pay particular attention to identifying and assessing hazards to workers who may be especially susceptible or vulnerable to particular hazards.  The operating company shall develop and implement a risk management plan that includes strategies to manage risks in the following order of priority:  (1) Eliminate the hazard; (2) Control hazard at source; (3) Minimize risk by means such as design of safe work systems; and (4) In so far as the risk remains, provide for the use of personal protective equipment.  In particular, the operating company shall demonstrate that it has implemented measures to:

a.   Ensure that the mine has electrical, mechanical and other equipment, including a communication system, to provide conditions for safe operation and a healthy working environment;

b.   Ensure that the mine is commissioned, operated, maintained and decommissioned in such a way that workers can perform the work assigned to them without endangering their safety and health or that of other persons;

c.    Maintain the stability of the ground in areas to which persons have access in the context of their work;

d.   If relevant, whenever practicable provide two exits from every underground workplace, each connected to separate means of egress to the surface;

e.   If relevant, ensure adequate ventilation for all underground workings to which access is permitted;

f.    Ensure a safe system of work and the protection of workers in zones susceptible to particular hazards;

g.   Prevent, detect and combat accumulations of hazardous gases and dusts, and the start and spread of fires and explosions; and

h.   Ensure that when there is serious danger to the safety and health of workers, operations are stopped and workers are evacuated to a safe location.

2.2.2. Communication and Engagement with Workers and Others Workers shall be informed of their rights to:

a.   Report accidents, dangerous occurrences and hazards to the employer and to the competent authority;

b.   Request and obtain, where there is cause for concern on safety and health grounds, inspections and investigations to be conducted by the employer and the competent authority;

c.    Know and be informed of workplace hazards that may affect their safety or health;

d.   Obtain information relevant to their safety or health, held by the employer or the competent authority;

e.   Remove themselves from any location at the mine when circumstances arise which appear, with reasonable justification, to pose a serious danger to their safety or health; and

f.    Collectively select safety and health representatives.  In all cases a worker attempting to exercise any of the rights referred to in in good faith shall be protected from reprisals of any sort.  The operating company shall develop systems to effectively communicate with, and enable input from the workforce on matters relating to occupational health and safety.  The operating company shall develop and implement a formal process involving workers’ representatives and company management [4]to ensure effective worker consultation and participation in matters relating to occupational health and safety including:

a.   Health and safety hazard identification and assessment;

b.   Design and implementation of workplace monitoring and worker health surveillance programs;

c.    Development of strategies to prevent or mitigate risks to workers through the health and safety risk assessments or workplace and workers’ health surveillance; and

d.   Development of appropriate assistance and programs to support worker health and safety, including worker mental health.[5]  The operating company shall provide workers’ health and safety representatives with the opportunity to:

a.   Participate in inspections and investigations conducted by the employer and by the competent authority at the workplace;

b.   Monitor and investigate safety and health matters;

c.    Have recourse to advisers and independent experts; and

d.   Receive timely notice of accidents and dangerous occurrences.  Visitors and other third parties accessing the mining premises shall receive an occupational health and safety briefing, and be provided with relevant protective equipment for areas of the mine site that they will be entering.

2.2.3.  Measures to Protect Workers  Where workers are exposed to physical, chemical or biological hazards the operating company shall:

a.   Inform the workers, in a comprehensible manner, of the hazards associated with their work, the health risks involved and relevant preventive and protective measures;

b.   Take appropriate measures to eliminate or minimize the risks resulting from exposure to those hazards, and where adequate protection against risk of accident or injury to health including exposure to adverse conditions cannot be ensured by other means, provide and maintain at no cost to the worker suitable protective equipment and clothing; and

c.    Provide workers who have suffered from an injury or illness at the workplace with first aid, and, if necessary, prompt transportation from the workplace and access to appropriate medical facilities.  The operating company shall ensure that:

a.   Training and retraining programmes and comprehensible instructions on safety and health matters as well as on the work assigned are provided for workers, at no cost to them;

b.   Adequate supervision and control are provided on each shift to secure the safe operation of the mine; and

c.    If relevant, a system is established so that the names of all persons who are underground can be accurately known at any time, as well as their probable location.  If the risk assessment process reveals unique occupational health and safety risks for certain groups of workers (e.g., pregnant women, children, HIV-positive, etc.) the operating company shall ensure that additional protective measures are taken, and trainings and health promotion programs are available to support the health and safety of those workers.  The operating company shall provide workers with clean toilet, washing and locker facilities (commensurate with the number and gender of staff employed), potable drinking water, and where applicable, sanitary facilities for food storage and preparation. Any accommodations provided by the operating company shall be clean, safe, and meet the basic needs of the workers.  The operating company shall ensure that workers are provided with compensation for work-related injuries and illnesses as follows:

a.   In countries where workers’ compensation is not provided through the government schemes [6] or a collective bargaining agreement, the operating company shall compensate workers for work-related injuries or illnesses at a rate that, at minimum, covers the wages during the recovery and rehabilitation period. If a worker is not able to return to work due to the severity of the work-related injury or illness, the operating company shall compensate for lost earnings until the worker qualifies for an adequate pension (i.e., 2/3 or more of the salary they would otherwise normally receive if healthy and working).[7]

b.   In countries that do not provide for worker rehabilitation as part of their workers’ compensation schemes, the operating company shall ensure that workers have free or affordable access to rehabilitation programs to facilitate an expeditious return to work.

2.2.4.  Inspections, Monitoring and Investigations  The operating company and worker representatives of a joint health and safety committee, or its equivalent, shall perform regular inspections of the working environment to identify the various hazards to which the workers may be exposed, and to evaluate the effectiveness of occupational health and safety controls and protective measures.  The operating company shall carry out workplace monitoring and worker health surveillance to measure exposures and evaluate the effectiveness of controls as follows:

a.   Workplace monitoring and worker health surveillance shall be designed and conducted by certified industrial hygienists or other competent professionals;[8]

b.   Health surveillance shall be carried out in a manner that protects the right to confidentiality of medical information, and is not used in a manner prejudicial to workers’ interests;

c.    Samples collected for workplace monitoring and health surveillance purposes shall be analysed in an ISO/IEC 17025 certified or nationally accredited laboratory;

d.   Sample results shall be compared against national occupational exposure limits (OELs) and/or biological exposure indices (BEIs), if they exist,[9] or OELs/BEIs developed by the American Conference of Governmental Industrial Hygienists (ACGIH);[10] and

e.   If an OEL/BEI is exceeded, the affected worker(s) shall be informed, and controls shall be reviewed and revised to ensure that future exposure levels remain within safe limits.  Controls, protective measures, health risk assessments, risk management plans, and training materials shall be updated as necessary based on inspection and monitoring results.  The operating company shall ensure that all workplace injuries, fatalities, accidents and dangerous occurrences, as defined by national laws or regulations, are documented, reported to the competent authority, investigated and that appropriate remedial action is taken.

2.2.5.  Health and Safety Data Management and Access to Information  The operating company shall maintain accurate records of health and safety risk assessments; workplace monitoring and workers' health surveillance results; and data related to occupational injuries, diseases, accidents, fatalities and dangerous occurrences collected by the company and submitted to competent authorities. This information, except for data protected for medical confidentiality reasons, shall be available to workers’ health and safety representatives.  The operating company shall establish a data management system that enables worker health data to be readily located and retrieved, and data protected by medical confidentiality to be securely stored. Data shall be retained for a minimum of 30 years,[11] and responsible custodians shall be assigned to oversee the heath data management system.  The operating company shall allow workers access to their personal information regarding accidents, dangerous occurrences, inspections, investigations and remedial actions, health surveillance and medical examinations.


Many of the requirements in this chapter are based on International Labour Organization Convention C176 - Safety and Health in Mines. Where recommendations of ILO C176 have been integrated into IRMA requirements, the specific ILO C176 Article number will be referenced in the IRMA Guidance for this chapter (under development).

Training and Education: In this chapter, “training” shall be taken to refer to either training or education, as appropriate.

Cross Reference to Other Chapters



1.1—Legal Compliance As per Chapter 1.1, if host country laws address occupational health and safety, the company is required to abide by those laws. If IRMA requirements are more stringent than host country law, the company is required to also meet the IRMA requirements, as long as complying with them would not require the operating company to break the host country law.

Also, the operating company is responsible for ensuring that its contractors and subcontractors involved in mining-related activities comply with the requirements of this chapter of the IRMA Standard, i.e., contracted workers and any other workers who provide project-related work and services should be afforded a safe and healthful work environment.
2.1—Fair Labor and Terms of Work Note that there are some requirements in Chapter 2.1 that share the objective of protecting the health and safety of workers (such as those relating to child labor, and working hours).
2.3—Emergency Preparedness and Response Chapter 2.3 shares similar objectives to Chapter 2.2 of protecting the health and safety of workers, but 2.3 also addresses affected communities. Workers and their representatives are to be consulted in the development of the Emergency Response Plan as per 2.3.2.
2.3—Mining in Conflict-Affected or High-Risk Areas There may be particular risks to workers when projects are located in conflict-affected or high-risk areas. These risks may include potential impacts on health or safety, as well as risks to human rights. The conflict risk assessment should evaluate such risks to workers.
2.7—Community Health and Safety Chapter 2.7 shares similar objectives to Chapter 2.2 of protecting the health and safety of communities, of which workers are members. The community health and safety risk and impact assessment process includes collaboration with workers as per Criteria 2.9.5. Also, Criteria 2.7.4 has requirements that pertain to workers/employees that are triggered if there are significant risks to workers/communities related to HIV/AIDS, TB or malaria.
2.8—Community and Stakeholder Engagement Workers are stakeholders, and also often members of the affected communities. As such, the engagement process with workers shall align with the requirements in Chapter 2.8.



1. ICMM. 2009. Good Practice Guidance on Occupational Health Risk Assessment.

3. For example, the risk assessment methodologies found in: Risk Assessment - Recommended Practices for Municipalities and Industry prepared by the Risk Assessment Expert Committee of the former Major Industrial Accidents Council of Canada; the process outlined in ICMM’s Good Practice Guidance on Occupational Health Risk Assessment. p. 16; or other similar methodologies.

4. For example, a joint health and safety committee or its equivalent.

5. Canadian Standards Association and Bureau de normalisation du Québec. 2013. Psychological health and safety in the workplace – Prevention, promotion, and guidance to staged implementation.

6. E.g., A 2002 report suggests that 136 countries have worker compensation programs, meaning that approximately 60 do not. (Eleson, R. 2002. International Workers’ Compensation. Prepared for the Indiana Compensation Rating Bureau.)

7. If the government does not provide for an “adequate pension,” the operating company would be expected to supplement the government pension so that a worker was receiving equivalent to 2/3 or more of the salary he or she would otherwise receive; if no government pension program exists, the operating company would be expected to pay compensation equivalent to 2/3 or more of the salary the worker would otherwise normally receive if healthy and working. Normally, this requirement can be met by providing the appropriate public or private disability insurance coverage.

8. A competent person may be an occupational physician or clinical toxicologist with experience in assessing and diagnosing occupational diseases associated with hazardous substance exposures. (Government of Western Australia. 2008. Risk-Based Health Surveillance and Biological Monitoring. p. 5.)

9. Some countries have developed occupational hygiene standards for workplaces. The International Labour Organization website provides links to agencies responsible for establishing exposure limits in various countries.

10. The American Conference of Governmental Industrial Hygienists is a member-based organization composed of independent knowledgeable experts that advances occupational and environmental health. ACGIH develops Threshold Limit Values (TLVs) (akin to OELs) and BEIs through a committee process that involves review of peer-reviewed literature and public input.

11. The intention is not that the data should be destroyed after 30 years. Rather, where possible it should be retained indefinitely as the data may be important for future medical research or legal purposes. If a company is sold, provisions should be made for successor custodianship, i.e., transfer of records to the successor company. If a company ceases to operate, it is good practice to notify current employees of their right to access their records before the company goes out of business. (See:  U.S. Dept. of Labor. 2001. Access to Medical and Exposure Records)