Case Study: Strengthening Due Diligence and Mine Safety Management Systems
Background
In 2025, a Western Australian mining entrepreneur engaged Spring Safety Consultants to conduct an independent audit of their Work Health and Safety (WHS) governance and Mine Safety Management System (MSMS).
With the introduction of the WHS Act 2020 (WA) and the WHS (Mines) Regulations 2022 (WA), the client sought to:
- Strengthen officer due diligence practices in line with legislative expectations.
- Verify system compliance with current legal standards.
- Build a more proactive workplace health and safety culture.
Recognising that legal compliance now demands more than traditional lag indicators like injury rates, the client wanted a system that fostered leadership, visibility, and continuous improvement at officer and operational levels.
Approach
Spring Safety Consultants structured the audit across two critical streams:
WHS Officer Due Diligence Review
Focused on assessing officers’ responsibilities under Section 27 of the WHS Act.
Methodology
- Comprehensive document review (e.g., risk registers, WHS management plans, training records)
- Site specific area inspections
- Worker, supervisor, and officer interviews
- Leadership engagement sessions
- WHS culture and governance assessment aligned with due diligence frameworks.
Key Findings
- Knowledge: Strong operational expertise was evident, but officers’ formal WHS legislative training and structured learning opportunities were limited.
- Understanding: Operational risks were generally well-managed at the frontline, but executive-level understanding of critical risk exposures needed strengthening.
- Resourcing: WHS resourcing existed but lacked clear integration into strategic and financial planning.
- Monitoring: While incidents were reported, systemic hazard trending and officer oversight were inconsistent.
- Compliance and Verification: Compliance activities were underway but officer verification of system effectiveness was ad hoc.
Mine Safety Management System (MSMS) Review
Methodology
A desktop review assessed the MSMS against:
- The MSMS Code of Practice
- WHS (Mines) Regulations 2022 (WA)
Key Findings
- Core operational systems were active and contributed to safe site operations. However, documentation structure, completeness, and legislative alignment could have been strengthened to meet requirements.
Key Recommendations
Spring Safety Consultants provided the following improvement strategies to enhance compliance:
- Develop an integrated MSMS Manual aligned to the Code of Practice.
- Introduce a Compliance Assurance Framework supporting officer responsibilities across due diligence elements (knowledge, understanding, resourcing, monitoring, compliance, verification).
- Implement a Critical Control Verification (CCV) Program to move from reliance on incident data to proactive assurance.
- Formalise WHS reporting to the Board, focusing on leading indicators and safety capacity measures, not just incident outcomes.
- Increase Officer Engagement with the Frontline via structured site familiarisations, learning teams, and operational WHS reviews.
How Spring Safety Consultants supports organisations
We provide tailored health and safety solutions to help businesses enhance their risk management, improve compliance, and build a culture of safety.
We are proud to have partnered with this client on this critical step towards future-ready WHS governance.
Partner with us
Spring Safety Consultants understand the nuances of Australian WHS legislation and are ready to support you with tailored auditing and consulting solutions.
References
Occupational Health and Safety Act 2004 (VIC)
Work Health and Safety Act 2011 (QLD)
Work Health and Safety Act 2020 (WA)
Resources
Meeting your officer duty – YouTube
The health and safety duty of an officer – information sheet
Who is an officer? information sheet | Safe Work Australia
Who is an officer? Understanding your responsibilities
Work Health and Safety laws – Duties under the new Act – YouTube
