Alcohol and drugs in mines
Mine operators have a duty to protect employees and mine visitors from the risks associated with the use of alcohol and drugs.
The duties referred to in this guidance are contained in Part 5.3 of the Occupational Health and Safety Regulations 2017 (OHS Regulations).
The requirement to develop and implement strategies in relation to alcohol and drugs at a mine is found in Regulation 409, which is a duty for all mine operators.
You must read the legislation in addition to this guidance.
Duties for mine operators
You must implement risk control measures that:
- control the presence of alcohol and drugs at the mine, and
- control the use of alcohol and drugs at the mine
You must also ensure:
- any person who is adversely affected by alcohol or drugs does not enter or remain at the mine, and
- a person can only use (legal) drugs at the mine if a registered medical practitioner has prescribed them and authorised their use at the mine
This guidance will explain:
- the effects and the risk factors associated with alcohol and drug use, and
- how to develop and implement an alcohol and drugs management plan
When does alcohol and drug consumption become a health and safety issue?
It is a health and safety issue if an employee's ability to exercise judgment, coordination, motor control, concentration and alertness at work is impaired, leading to an increased risk of injury to themselves or others.
Risks associated with alcohol and drug use
Impaired performance and inappropriate behavior are the main risks arising from alcohol or drug use. In mining, this can be dangerous due to the hazards typically present at a mine.
There may be hangover effects that continue several days beyond the initial period of consumption.
Prescription and over-the-counter medication can be just as dangerous as illegal drugs.
Impact on health and safety
The risk that employees impaired by alcohol or drugs pose to health and safety can increase depending on their job at the mine. For example, haul truck drivers, drill rig operators and employees who need to concentrate to perform effectively have the potential to cause serious injury or death as a result of being alcohol or drug impaired.
Impact on co-workers
Impaired employees can also impact on colleagues who may feel obligated to cover for their poor work performance while being unwilling to 'dob in' a mate, which can affect team morale as well as their own performance.
Frequent sickness and absenteeism
Alcohol or drug-affected employees are more likely to take frequent sick days or be absent from their shifts, which may impact the efficient and safe operation of the mine.
Factors that may increase the risks
Research has identified many factors that may either promote alcohol and drug use, or increase the risks associated with their use. The following are particularly relevant to mines:
- Patterns of consumption - different patterns of use can create different risks. For example, people who binge on alcohol or drugs may create different risks compared with those who are regular users.
- Workplace culture - a work culture that encourages or condones alcohol or drug use either at the mine or socially outside of work may be exposed to increased risks to health and safety.
- Isolation from family and friends - employees working in remote areas or separated from ‘normal’ life may turn to alcohol or drugs to deal with boredom, loneliness and a lack of social activities.
- Inadequate job design - increased alcohol and drug use has been associated with unrealistic performance targets or deadlines, monotonous work, low job satisfaction and excessive responsibility.
- Inadequate supervision - where employees are unsure about the requirements of their role, or are not given proper supervision, they may use alcohol or drugs
- Shift work/extended hours - the use of amphetamines or prescription stimulants is a prevalent issue amongst employees who work very long hours or engage in shift work.
- Personal pressures - employees dealing with personal stress, such as relationship problems, grief or bereavement, health issues, gambling or financial problems, and addiction may use alcohol or drugs to cope.
Understanding these factors is important as you may decide to address them in order to reduce or change employees’ consumption of alcohol and drugs.
How to create an alcohol and drugs management plan
Employers should develop a tailored alcohol and drugs management plan with supporting procedures that address specific circumstances at the workplace.
The plan should be developed by management in consultation with all affected employees, including any health and safety representatives, and independent contractors, working together. Workplaces that demonstrate good employee consultation have better safety outcomes.
Your plan should outline the workplace's aim to eliminate or reduce hazards and risks, so far as reasonably practicable, while the supporting procedures should provide strategies and action plans to achieve this.
Use a risk management approach
The more diverse and encompassing the representative group, the more likely the plan will be viewed as relevant and appropriate.
An existing health and safety committee may be used or a specific working group formed.
Larger companies may establish a steering committee to oversee the development of the plan and the associated implementation program.
Deciding what to do and how to do it should be a process developed through an open, participatory process that includes all employees. Consideration may also be given to consulting with employee and employer organisations.
Regular consultation, communication and meaningful feedback loops give employees' confidence that their views and circumstances are being considered and help to overcome anxiety among employees concerned about intrusion into their private lives.
Work together and agree on the steps you will take to develop the plan, such as:
- drafting processes that support effective controls, including education and communication strategies
- allocating the resources necessary to develop and implement the plan
- identifying all the hazards at the mine
- assessing the risk factors associated with alcohol and drugs
- deciding which risk control measures to adopt at the mine
- documenting the risk control measures to be adopted and communicating with employees why other measures were considered but rejected
When you start this piece of work, consider the following:
- Develop procedures and a timetable for implementation of the plan, starting with an education program.
- Develop a preliminary draft plan and have it reviewed by the representative group overseeing its development.
- Seek feedback on a draft plan from every employee at the mine.
- Where appropriate, feedback received should be incorporated into the document.
- Present a draft plan to the health and safety committee for consideration.
- Management should formally endorse and champion the final approved plan.
- Distribute copies of the plan to all employees and visitors to the mine. Ensure the plan is readily available, such as via the company notice board or intranet.
As agreed with employees, circulate the plan and implement all controls and procedures as written.
You should document the measures by which you will evaluate the plan's effectiveness.
Reviews of the plan should be conducted regularly. You should also document the incidents that might trigger a review, such as any incident involving employees impaired by alcohol or drugs, employee survey results indicating concerns over alcohol and drugs, or a request by Health and Safety Representatives.
Always consult with affected employees and Health and Safety Representatives when reviewing or making changes to the plan.
What to include in the plan
Including the following sections in your alcohol and drugs management plan will help to ensure it is a comprehensive and integrated strategy that protects employees and visitors to the mine.
Confidentiality
The credibility of your plan and also of a successful Employee Assistance Program (EAP) depends on a code of strict confidentiality. Consider whether the plan should include reference to the EAP program, or other appropriate services.
An employee can be referred to an EAP by a supervisor or can contact an EAP counsellor on their own initiative.
Workplace culture
Fostering a safety conscious workplace culture can be effective in ensuring employees maintain a responsible attitude towards alcohol and drugs.
Your plan should emphasise that your alcohol and drug management strategy is supported by the mine’s management and employees.
It must be clear how employees can self-assess for impairment and, without fear of recrimination, report those who they suspect may be impaired by alcohol or drugs.
Example statements of expected standards
- No persons can be impaired by alcohol and drugs while working at the mine.
- Only prescribed and authorised legal drugs can be used at the mine.
- Transport options will be always be provided for employees attending work-sponsored events where alcohol is served.
- Employees are expected to assess themselves for impairment and know what action they to take if they believe they may be impaired by alcohol or drugs.
Induction: raising employee and visitor awareness
Your alcohol and drug management plan should be distributed and its contents communicated to all mine employees and visitors. Site inductions are an opportunity to create understanding, set expectations and clarify what is meant by impairment so there are no grey areas.
Information, education and training
One way to influence the workplace culture is by providing information and ongoing education and training that increases awareness of the negative impacts of alcohol and drugs.
You might also offer alternative lifestyle/activity programs for employees between shifts and provide resources for helping your employees to deal with alcohol or drug issues.
It may be useful to provide refreshers for employees on their responsibilities stated in your plan.
Control the risk factors associated with the use of alcohol and drugs
The table below shows example risk control measures that address factors that may lead to alcohol and drug use.
| Risk factor | Example risk control measures |
|---|---|
| Isolation |
|
| Job stress |
|
| Personal stress |
|
Rehabilitation support
Ensure your employees know what resources and support are available, such as counselling via an employee assistance program (EAP) or any rehabilitation services provided to mine employees.
Return to work programs that support employee's rehabilitation should include suitable work alternatives for the program’s duration.
Prescription or over-the-counter medication
You may choose to have a separate section for legal drugs, which considers:
- an employee's ability to notify their manager/HSR about their possible impairment without having to disclose the illness for which the medication is required
- ensuring that the potential for impairment is considered when the mine's doctor/nurse prescribes medication, and whether employees should resume normal duties while on the medication
- assigning someone to monitor employees taking authorised medication to ensure they do not become impaired
- re-assigning employees taking authorised medication if they become unable to perform their usual work safely Reporting procedure
- How employees can report if a person is impaired.
Testing procedure
Testing, while not a regulatory requirement, can be an effective way to control the presence and use of drugs at the mine. An advantage of alcohol testing is that it is a reliable indicator of impairment as it measures the direct presence of alcohol in a person's system.
Possible disadvantages of testing include:
- In general, drug testing is not a reliable indicator of impairment as it does not indicate how much of a substance has been consumed.
- Drug testing can generate inaccurate results and false positives.
- Drug testing can be subject to legal challenge, which makes it important to schedule follow up tests by a quality assured tester following the initial positive result on-site.
- All forms of alcohol and drug testing may be intrusive and raise confidentiality and privacy issues that must be managed carefully.
Types of testing
- Impairment testing
This indicates whether someone is fit for work by measuring levels of impairment, such as by testing reaction times on a computer or responses to light signals. The effectiveness of this type of testing may be limited and it should only be used as part of a comprehensive plan.
- Alcohol testing
All of the above considerations for drug testing apply if you decide to test employees for alcohol.
Breathalysers are a cost-effective and least invasive means of alcohol testing. If used, you must state what the cut-off point is for a positive test, which may be different depending on roles. For example, a cut-off point of 0.005mg% may be appropriate for general staff while 0-0.002mg% could be applied to safety sensitive or designated jobs.
Seeking independent advice prior to implementing alcohol testing will address issues such as how to ensure breathalysers are properly calibrated to ensure accuracy is maintained.
- Drug testing
If you decide to implement drug testing the rationale for doing so should be communicated to employees along with how you will manage privacy and confidentiality issues, as well as the process for how and when tests are conducted, such as pre-employment or randomly.
If a person refuses a test you cannot assume it is because they are drug-affected. If someone does record a positive result, the plan should have clear procedures that determine what happens next.
You are strongly recommended to seek independent expert guidance on the appropriateness of drug testing and how to implement drug testing at the mine, which includes cut-off points for a positive result and a non-discriminatory selection process for deciding which employees will be tested.
Any testing regime should be documented with a grievance and complaints process built in.
Dealing with impaired persons
If a person is reported as being impaired by alcohol or drugs you need to confirm if this is true. If they are, you must arrange for their removal from the mine.
Your plan should designate which employees (e.g. managers or supervisors) are responsible for approaching employees believed to be affected by alcohol or drugs.
The designated employees should be trained in effective styles of approach and conflict resolution, as well as how to determine if someone is impaired by alcohol or drugs.
Once an impaired person has been removed from the mine, your plan should specify how they will be assisted to return to their place of residence.
Your enterprise bargaining agreement may include additional details of counselling or discipline procedures that should be followed.
Evaluation, monitoring and review procedures
In consultation with employees, develop the criteria and timelines for measuring the plan's effectiveness.
You should appoint someone at the mine to be responsible for monitoring these criteria and reporting to management if there are signs that alcohol and drugs are a problem at the mine.
The following factors should determine when you review the plan:
- An incident or near miss occurs.
- There is a perceived increase in risk.
- A Health and Safety Representative (HSR) requests a review.
- There is significant turnover of employees.
- There are significant changes at the mine, such as to employees' tasks, hazards, plant or other procedures.
When reviewing the plan, the following questions may help drive the activity:
- Have control measures been implemented as planned and documented?
- Are the control measures working – how do you measure success?
- How do you ensure employees can report issues regarding alcohol and drugs?
- Are you fully aware of whether there are issues with alcohol and drugs at the mine?
Always consult with affected employees and Health and Safety Representatives when reviewing or making changes to the plan.