According to Nico Pienaar of surface mining industry association Aspasa, the provisions require positive interventions, risk assessments and meticulous record-keeping in order to remain compliant. 
Smaller-scale surface mining operations with limited access to resources, or skills, may be particularly prone to underestimate requirements and should therefore work with the association to become compliant.
Nico points out that no matter the size or scale of an operation, it remains the responsibility of the employer to take reasonably practicable measures to ensure that pedestrians are prevented from being injured as a result of collision between trackless mobile machines and pedestrians.

Industrywide requirement

As a result, the mine needs to undertake a physical assessment to look at each scenario critically, identify and assess the risks, make provision for ‘the impossible’ and identify what measures can be implemented.
“Traffic management is required wherever there is a hazard (something that can cause harm). Unwanted events are usually a consequence of a hazard and risk is the chance of something happening that will have an impact on objectives.
“Chance = exposure x likelihood x consequence.
Wherever there is a risk, controls should be put in place like a barrier that either prevents or mitigates an unwanted event. 
“A control therefore can only be a human act, an object (engineered device), a technical system or a combination of these. Traffic management deals with the safe movement of traffic and therefore also requires that historical data from Aspasa’s TMM Risk Evaluation reports, MOSH risk analysis and other information be incorporated to complete the mines’ own findings,” Nico advises.

Ongoing intervention

He adds that the compilation of a comprehensive traffic management plan is a difficult and ongoing task that is fraught with challenges, not least of which is the requirement to change behaviour of staff, contractors and customers in order to implement the required systems which takes resources and time. Thereafter the challenge is to ensure continued compliance with systems extended to satellite industries which requires the full commitment of the management team.
“This also extends to those who deliver and collect goods and people to and from the site.
“Although it is an intensive undertaking, it is a requirement by law and is well worth the time and effort wherever lives and the safety of humans are concerned. Although they should be common-sense and simple, such plans do require the commitment and effort of everyone on the mine in order to succeed,” Nico concludes.
Aspasa, Nico Pienaar, Tel: (011) 791 3327