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Audit of RIDDOR Reporting at Large Coal Mines

First published 23 June 1998

Contents

Executive Summary

1. HM Chief Inspector of Mines instructed that an audit of accident reporting should be carried out by the Mines Inspectorate. The events which prompted this decision were:-

  1. concerns expressed by certain Mining Trade Unions following the review of safety at privatised coal mines conducted by the Mines Inspectorate, which reported in 1996;
  2. the results of the Labour Force Survey (Health and Safety Statistics 1995/96) in respect of Reporting of Injuries, Diseases and Dangerous Occurrence Regulations 1995 (RIDDOR) reporting levels;
  3. the results of internal audits carried out by a mine operator at two of its mines.

2. The audit was carried out by two Mines Inspectors, assisted where appropriate by relevant company nominees . The audit reviewed the period from 1 January to 30 November 1997 and was carried out at all operating mines previously owned by British Coal Corporation.

3. The audit evaluated the recorded accident information to determine the extent of compliance with RIDDOR. Interviewing of personnel was not carried out except where qualification of recorded information was necessary.

4. At each mine discussion took place with management, trade unions, or other workers representatives during which the reasons for the audit were explained. A composite list of accident records was prepared at each mine and evaluated to determine whether a RIDDOR notification was required. Accidents which should have resulted in a notification under RIDDOR and for which no notification had been received were recorded. The mine manager was advised to retrospectively submit F2508 forms (reports of an injury to HSE) for these accidents unless there were some other mitigating circumstances for which he could provide information. Finally, a list of accidents comprised as a result of the audit was prepared.

5. The report identifies several limitations of the audit but it should be noted that without the mine operators' retention of suitable records the audit would not have been possible. The limitations noted were:-

  1. RIDDOR Regulation 3(2) is not time limited with regard to the reporting of an over three day accident. For the purpose of the audit the review of an accident was not pursued further if the individual worked in his normal employment for a full shift on the day following the accident;
  2. Self certification and Doctor's certification for absence were not used as a primary prompt (see para 12(b));
  3. records of hospital treatment were sometimes imprecise because of the difficulties that the mine personnel experienced in obtaining information directly from the hospital;
  4. those arising from difficulties with contractors' records. Some had worked on short term contracts, and reported an accident on the last working day of the contract . There were other cases where the availability of records of payment (to indicate attendance) were limited.

6. The findings of the audit are contained in the report, and in summary reveal that:-

  1. two major injury accidents had not been notified;
  2. approximately 24 % of over three day accidents had not been notified.

7. Prior to the HSE audit some mines carried out their own internal reviews which resulted in late notifications. Combined with the audit findings this gave a total level of under-reporting of approximately 52%.

8. The report makes recommendations on the need:-

  1. to put in place systems which start evaluation of accidents at the time of each event;
  2. to ensure that contractors' personnel are included in these systems;
  3. to provide a process for utilising the information contained in either self certification or Doctor's certification of illness/injury;
  4. for the Mines Inspectorate to regularly audit a sample of mines and follow up by enforcement action as appropriate;
  5. to review some aspects of RIDDOR. In particular:-
    1. Regulation 3(2) which is not time limited for over 3-day accidents as compared with Regulation 4 which places a time limitation for fatal injuries.
    2. To expand the available guidance relating to the application of Regulation 3(2).
    3. "continental rota systems" (see para 28) which can give rise to particular difficulties. When an individual reports an accident on the last day worked and is not expected to attend for the next 4 days, - i.e.. non working days, the accident is automatically reportable unless the Manager takes steps to determine whether it has resulted in the person not being "...incapacitated for work ..." .

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Background to the Audit

  1. 1. In 1996 a Mines Inspectorate review team, met representatives from the industry to investigate concerns expressed of a possible change in the safety culture at mines which might have caused a reduction in safety standards following privatisation of the coal mining industry in December 1994. Their report, " A Review of Safety at Privatised Coal Mines", was published in June 1996.
  2. 2. One of the issues raised with the 1996 review team was that some accidents were not being reported as required by the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR). Although this criticism was levelled, the team concluded that all Major Injuries were being fully reported (Para 71, 1996 report). Evidence was requested on non reporting of over three day accidents but none was obtained from the interviewees (Para. 73, 1996 report). However the 1996 review team noted that there was a continued decline in the ratio of major injuries to over three day injuries (Para 74,1996 report) and considered that this required explanation. They also advanced some possible reasons for this.
  3. The Health and Safety Commission report of Health and Safety Statistics 1995/96 made reference to the use of the Labour Force Survey (LFS) as a source of information on workplace injury, to complement the flow of injury reports made by employers and others under RIDDOR . Essentially, the LFS is a view of workplace injury obtained by survey and is subject to sampling error. Comparison of the LFS and RIDDOR rates would suggest that RIDDOR reported injuries only account for 64% of the total injuries revealed by the LFS for industries contained within the description "mining of coal, lignite, etc". By inference, a potential under-reporting of accidents of 36%. This level of potential under-reporting was significantly better than the All industries under-reporting level of 59%.
  4. In the mining industry, where there are numerous naturally occurring hazards, accident statistics are commonly used as a yardstick to measure safety performance and to drive change to improve health and safety. Consideration of all the available accident information might have contributed to ensuring that the risks to employees' health and safety were more closely controlled.
  5. During October and November 1997 internal audits of accident reporting, undertaken by RJB Mining (UK) Ltd at two (2) of their collieries, revealed under-reporting of over three day accidents. This information was brought to the attention of HM Principal District Inspector of Mines (PDI), Scotland and East England District, by a Director of the company.
  6. In responding to these issues, HM Chief Inspector of Mines appointed a team of two HM Inspectors of Mines to undertake an audit of accident reporting at all working coal mines which were previously under the ownership of British Coal and which had passed into private ownership under lease or freehold arrangements.
  7. The Terms of reference for the audit are at Appendix 1.

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Protocol Adopted

  1. The procedures and methods of work adopted by the team to carry out the audit are detailed below.
  2. At each mine the reasons for the audit were discussed with members of management, trade unions or other workers' representatives (Appendix 2). These persons were informed:-
    1. of the procedures involved in the audit;
    2. that it was not the intention of the auditors to interview personnel;
    3. that anyone with information relating to specific cases could pursue these via the normal channels of communication with HSE;
    4. of the limitations of the audit and the reasons why these limitations had been determined by the auditors;
    5. that the results of the audit would be included in the report to the Chief Inspector and would not be relayed back to the mine by the audit team.
  3. The process for conducting the audit at each of the mines was as follows:-
    1. The audit reviewed the recorded accident information at each mine. It was not directed towards interviewing of personnel, except on the few occasions where clarification of recorded information was necessary;
    2. With the exception of one mine, the accident information used was a composite list of the Medical Centre Attendances (MCA) and the Accident Report Forms (AR1). The exception was one mine which used the B1 510 Accident Report book in place of MCA records. The auditors considered that these accident reports provided the raw data for accident reporting under RIDDOR;
    3. The composite list of accidents was then used as the basis for the audit. Each individual entry on the list was considered in relation to attendance records to determine on each occasion whether :-
      1. the employee had been re-deployed to "light duties" as a consequence of the injury for a period exceeding 3 days.
      2. the employee had not attended work for a period exceeding 3 days subsequent to the injury.

        or

      3. a combination of these two factors had occurred.
    4. Where non attendance at work occurred subsequent to the accident the reason for the non attendance was pursued to establish whether this absence was covered by :-
      1. holidays, which had been booked before the accident.
      2. holidays, which had been booked after the accident.
      3. a self certification of illness/injury or Doctor's certification, relating to the injury condition.
      4. the list of "reports of an injury to HSE " (F2508 forms) received by the Mines Inspectorate was compared with those held at the mine.
    5. the list of "reports of an injury to HSE " (F2508 forms) received by the Mines Inspectorate was compared with those held at the mine.
  4. On completion of the audit a list was made detailing any accidents which appeared to have resulted in an injury reportable under RIDDOR, for which notification had not been received by the Mines Inspectorate. This list was given to the mine manager (responsible person - RIDDOR, Regulation 2) and he was asked to consider it. He was asked to retrospectively submit F2508 forms for those accidents unless further investigation provided him with information which allowed him to exclude notification. In such cases he was asked to provide this additional information. The accidents on the list were allocated into one of five categories to demonstrate the reason for the injured person's absence or incapacity for work of a kind which he might reasonably be expected to do as follows:
    1. deployment to surface light duties;
    2. absence including weekends or statutory holidays;
    3. absence due to holidays applied for after the accident;
    4. absence due to a recurrence of an injury;
    5. absence following an injury with related self certification or Doctor's certification.

    The final stages of the audit concluded with Principal District Inspectors reviewing the content of the F2508 forms submitted and comprising accidents as reportable where appropriate.

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Limitations of the Audit

  1. A number of constraints were applied during the course of the audit to define boundary conditions for the investigation. There were also imposed limitations caused by the lack of documentation or information. These matters are detailed as follows:-
    1. RIDDOR Regulation 3(2) indicates that a period of absence, as a consequence of an injury sustained at work, for more than three days is reportable. The absence period need not necessarily immediately follow the accident. For the purposes of the audit, if a man had worked in his normal employment for a full shift on the day following the accident, the review of that event was stopped. It should be recognised, however, that there is an overall obligation on the responsible person to identify a delayed absence resulting from an injury;
    2. Neither self certification nor Doctor's certification were used as an initiating factor in the formation of the composite list of accidents. Any person who did not report an injury at work, but who subsequently filled in a self certification as a consequence of an injury at work, would not be identified in the audit. Typically these forms contain reference to illness or injury. Where reference was made to an injury the information was not always specific as to whether it was work related. To qualify the information it would have been necessary to conduct interviews of those persons who had submitted such forms. The audit protocol adopted excluded interview of personnel;
    3. Individuals who had been advised to go to hospital but for whom there was no follow up information were not interviewed. Some records of MCA indicated that the injured person had been advised to go to hospital or had been taken to hospital. In many cases there were no corresponding records of diagnosis or treatment to identify whether or not a major injury condition had been sustained. Mine management normally rely on the individual who suffered the injury informing them of the outcome of hospital attendance. If this is not done then it is possible that some major injury conditions could go undetected;
    4. In respect of contractors, it became apparent that, when a contract was nearing completion, injury reports by some contractors' employees on the last day worked were common. Additionally, there were examples where men employed on short term contracts, sometimes for only one day, reported an injury but were not scheduled to be working at the mine on the following day. These incidents were not pursued during the audit;
    5. Contractors are usually included in the mine personnel attendance recording systems. These identify, in the more sophisticated systems, attendance of the individual and place of work. Some computer based systems up-date on a monthly basis and unless a hard copy is retained by the mine, information is lost. Contractors typically make use of the mine attendance records but do not retain the hard copies provided to them, choosing instead to use their own simplified attendance records. Thus primary records could not always be checked when auditing accidents to contractors' employees. The audit team had therefore no recourse but to place reliance on information provided verbally by contractors;
    6. Holidays authorised following an accident could be for a number of reasons. Where no information was available to demonstrate that the absence was not due to the injury the absence was classified as an over three day accident.

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Resources

  1. The work of the audit team started in December 1997 and ended in April 1998. During this time two HM Inspectors were engaged on this work. Together with analysis and report writing this accounted for 0.9 inspector years. This does not include the resources expended by the mining companies.
  2. Additional resources used during the audit included the input from two Principal District Inspectors in the review of retrospectively submitted notifications; the extensive use made of office based personnel in the preparation of accident lists for each of the premises; and the consequential recording of amended accident data.
  3. Those persons assisting during the audit, and therefore comprising the audit team, are listed at Appendix 3.

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Results

  1. The audit was carried out at 21 mines owned by six different mining companies (Appendix 4). A total of 7,510 reports of injury were reviewed. Under reporting of accidents was found at 18 of the 21 mines audited. Five of the six operating companies had mines where under reporting was revealed. The operating company with no under reporting was a company operating a single mine.
  2. Appendix 5 summarises the results of the audit at individual mines and includes details of the numbered columns.
  3. The audit identified two major injury accidents which had not been reported:-
    1. One major injury occurred when a mine worker suffered heat exhaustion. The individual returned to work the following day to be employed on his normal duties;
    2. The second major injury was revealed by a deficit at one mine in the number of copies of F2508 forms which had been prepared compared to the number of F2508 forms received by the Mines Inspectorate. This related to a major injury accident report in which the injured person suffered a laceration of his ankle and had been detained in hospital for a period over 24 hours.
  4. The auditors identified two further potential major injury accidents which appear in the table of audit findings. Mine managers in both cases obtained and provided further information to the PDI to demonstrate that in both cases there was no major injury accident as detailed:-
    1. One accident identified was initially reported as a cut over the eye. The subsequent absence was covered by Doctor's certification which related to a fractured arm. The fracture was found not to have occurred at work.
    2. The other accident, initially reported as a penetrating injury to the eye, was subsequently discounted as a major injury when further medical evidence was considered.
  5. The other injuries revealed by the audit were all 'over three day notifications'.
  6. In summary, the audit data indicated under-reporting of 24% . Prior to the HSE audit some mines carried out their own internal reviews which resulted in late notifications. All of these late notifications were for over three day accidents. If the late reporting of accidents is viewed as a result of the impending Mines Inspectorate audit and the late reported accidents are included with the audit findings then the degree of under-reporting becomes 52%.
  7. The audit team were of the opinion that some of the injuries comprised as notifiable or reportable accidents could have been excluded if timely review had been actioned by the manager. For example, with some employees redeployed to lighter work following an accident, a review within three days could have indicated that they were able to be deployed back to their normal work.
  8. The audit has resulted in the audited mines having a more appropriate and consistent understanding of the requirements of RIDDOR. This should ensure more accurate reporting of accidents in the future.

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Comments

  1. Whilst not part of the audit's terms of reference, the auditors would wish to make the following general observations on the reasons for under-reporting:-
    1. There was an absence of suitable systems to follow up on injuries which could become reportable;
    2. Some mines had operated "back to work" schemes encouraging prompt return to work following an accident and consequential employment on light duties. Whilst laudable in the intention to rehabilitate workers, these schemes sometimes led to under-reporting of accidents. Additionally, from time to time, senior overmen or foremen arranged for the redeployment of workmen following an accident. This was normally on an ad hoc basis and the redeployment was not responded to by those responsible for the reporting of accidents under RIDDOR;
    3. Managers had differences in their interpretations of RIDDOR and these misunderstandings contributed to the degree of under-reporting. Some companies have now issued detailed guidance to their managers;
    4. In some cases under-reporting appeared to be a consequence of inadequate communication between personnel and lack of adequate appraisal of an event. For example , self or Doctor's certifications are normally reviewed by the personnel department as a justification for absence. Relevant information is not always communicated to those responsible for accident reporting under RIDDOR;
    5. With regard to the recording of accidents, assessments of injuries were not always accurately recorded. There were instances when potentially reportable injuries were referred to hospital but no further information was recorded. There were also occasions where the recorded information was not responded to by those responsible for reporting accidents under RIDDOR.

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Recommendations to Mine Managers (Responsible Persons)

  1. Those responsible for notifying in compliance with RIDDOR should put in place systems to follow up on injuries which could become reportable and which:-
    1. ensure that those responsible for making initial assessments of injuries accurately record their assessment of the injury on MCA's or AR1's. This information should be communicated to those responsible for reporting accidents under RIDDOR;
    2. review self certification and Doctor's certification to identify injuries not reported elsewhere;
    3. identify and analyse time off following injury;
    4. are capable of identifying reportable absences which occur some time later but are as a consequence of an accident;
    5. which incorporate positive measures for reviewing accidents to contractors' employees including securing information from persons on short term contracts and from those who report an injury on the last day of the contract.

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Recommendations to HSE

  1. RIDDOR Regulation 4 specifies a time constraint relative to fatal accidents (12 months) but no such time constraint applies to over three day accidents. This is an issue that is worthy of more detailed consideration during the next review of RIDDOR.
  2. During the course of the audit, discussion took place at each mine with regard to the application of RIDDOR. The problems of interpretation raised were usually of a similar nature and related to the five categories used in the audit. To supplement HSE's guidance, mining companies have developed their own detailed guidance. One particular problem found was that of interpretation of "normal duties". The auditors note that para 49 of the "Guidance for railways, tramways, trolley vehicle systems and other guided transport systems" on RIDDOR (ISBN 0 7176 1022 5,) incorporates further explanation, which does not appear in the general RIDDOR guidance, and which states that the accident is an over three day injury "....if a person is unable to perform the full range of their duties, then the injury must be reported.....". This explanation could usefully be incorporated in HSE's general guide to RIDDOR.
  3. At one mine a "continental rota" system had been introduced and existed for a period of months before being replaced. The effect of this was that an individual would work for four days and then not attend for the next four days. An injury reported on the last day at work would automatically result in an over three day absence because of the shift pattern. This can only be resolved by the responsible person determining whether the injury had resulted in the person being "......incapacitated for work of a kind which he might reasonably be expected to do ...". Such working arrangements place an onus on the responsible person to take steps to identify whether injured employees are incapacitated during their non-working days. No accidents were discovered as a consequence. The next revision of RIDDOR should consider or make reference to work patterns.
  4. Reference was made to the difficulty of obtaining sufficient information when an individual had been referred to hospital. Hospitals will not generally release information to persons other than family members and sometimes it is necessary to invoke the assistance of the nursing sister at a mine to obtain information. It would be advantageous if HSE was able to make general arrangements with hospitals to release only that information specific to identifying a major injury condition, including detention for a period exceeding 24 hours.
  5. Consideration should be given to auditing two mines each year , to ensure that a high level of consistency with regard to the reporting of accidents is maintained. The audit findings should, where appropriate, be followed up with enforcement action.

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Acknowledgements

  1. The auditors would like to record their appreciation of all employees, supervisory staff and management of the mining companies who provided assistance during the audit.

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Appendix 1 - Terms of Reference

  1. The audit team consisted of Mr P B Scott, HM Inspector of Mines, and Mr B V Parry HM Inspector of Electrical Engineering in Mines. They would be supplemented by other Inspectors as deemed appropriate. They would co-opt any expert assistance they required to assist them to complete an open and rigorous audit.

    The audit team would:-

    1. Conduct an audit at all working coal mines previously owned and operated by British Coal Corporation and which had subsequently passed into private ownership under lease or freehold arrangements;
    2. Select the order in which the mines are audited on the basis of geographical location and efficient working of the audit team;
    3. Audit records as necessary to determine the extent of compliance with the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 in respect of accidents which occurred at each mine during the period 1 January 1997 to 30 November 1997;
    4. Record the protocol used to conduct the audit at each mine;
    5. Record the names of each member of the audit team for each of the mines;
    6. Report their findings to HM Chief Inspector of Mines.

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Appendix 2 - Persons Consulted at Each Mine

Calverton Mine Clipstone mine
K Bancroft Manager C Daniels Manager
R Henderson Safety Engineer M Padley Safety Engineer
K Guy UDM Secretary S Walker UDM Representative
P Jackson NACODS President    
Daw Mill mine Ellington mine
K Williams Manager T Watson Manager
G Nelson Safety Engineer G Huitson Safety Engineer
T Gay UDM Branch Secretary S Bentley BACM
G Rhind NACODS Midlands Branch I Lavery NUM
G Douglas COSA    
Gascoigne Wood mine Harworth mine
J Whyatt Manager K Irving Manager
G Bickerton NUM Secretary N Brammer UDM
A Scholes NACODS I McGregor NACODS Midlands Branch
N Finney COSA C Shorthose NACODS
Mrs P Ross GMB and APEX K Humphreys Safety Engineer
Kellingley mine Maltby mine
D Vint Manager C Ponder Manager
W Dowty NUM J Stubbs NUM
M Dougan NACODS J Kelly NUM
S Hepworth NUM S O'Neil NACODS
K Shenton Safety Engineer
Prince of Wales mine Riccall/Whitemoor mine
P Myerscough Manager W Davies Manager
A Withington NUM A Carpenter Safety Engineer
G Scoffins NUM J Barker NACODS
I Johnson NUM M Spencer NUM Secretary, Whitemoor
G Foreman NACODS G Fereday NUM Secretary, Riccall
Rossington mine Stillingfleet/North Selby mine
W McGranaghan Manager W Tinsley Manager
I Wilson Safety Engineer S Hunter Safety Engineer
M Gibson Workmen's Representative B Fisher COSA, Stillingfleet
D Smith NACODS M Harrison COSA, North Selby
    D Griffith NACODS, Stillingfleet
    C Smith NACODS, North Selby
    S Kemp NUM, Stillingfleet
    G Gisby NUM, North Selby
Thoresby mine Welbeck mine
D Betts Manager R Hallam Manager
T Spurry Safety Engineer R Soar NACODS
P Thatcher NACODS, Midlands Branch D Nettleship UDM
J Clampett UDM G Kennedy COSA
J Benson CSSS    
Wistow mine Annesley/Bentinck mine
P Gwilliam Manager C Smith Manager
I Bickerton Deputy Manager M Marriott Former Secretary, UDM
P Fenner Safety Engineer M Machin 123 Inspector
R Walker NACODS C Graham Consultative Committee
K Rowley NUM    
Silverdale mine Tower mine
M Arthur Manager J Rosser Manager
E Whiston Workers Representative K Williams NUM Secretary
    K Davies NACODS
    M Howells BACM
Betws mine Longannet mine
M Cook Manager R Dow Manager
The Safety Committee
N Grice Safety Engineer    
J Walters NUM Secretary    
Hatfield mine  
D Nortcliffe Manager    
D Herriot Shift Manager    
P Mountjoy 123 Inspector    
L Carling NUM    

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Appendix 3 - Names of Audit Team Members

Calverton P Scott B Parry A Fynn A Smith
Clipstone P Scott R Stevenson A Fynn A Smith
Daw Mill P Scott B Parry A Fynn A Smith
Ellington P Scott B Parry A Fynn A Smith
Gascoigne Wood P Scott B Parry A Fynn A Smith
Harworth P Scott B Parry A Fynn A Smith
Kellingley P Scott B Parry A Fynn  
Maltby P Scott B Parry A Fynn A Smith
Prince Of Wales P Scott B Parry A Fynn A Smith
Riccall/Whitemoor P Scott B Parry A Fynn A Smith
Rossington P Scott B Parry A Fynn A Smith
Stillingfleet/North Selby P Scott B Parry A Fynn A Smith
Thoresby P Scott B Parry A Fynn A Smith
Welbeck P Scott B Parry A Fynn A Smith
Wistow P Scott B Parry A Fynn A Smith
Annesley/Bentinck P Scott B Parry S Sumnell R Towndrow
Silverdale P Scott B Parry S Sumnell L Hilton
Tower P Scott B Parry A Walker  
Betws P Scott B Parry N Grice  
Longannet P Scott B Parry J Brown  
Hatfield P Scott B Parry R Lucas  

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Appendix 4 - Mines Audited

Betws Anthracite Ltd Betws
Hatfield Coal Co Ltd Hatfield
Midlands Mining Ltd Annesley Bentinck Silverdale
Rjb Mining (UK) Ltd Calverton
  Clipstone
  Daw Mill
  Ellington
  Gascoigne Wood
  Harworth
  Kellingley
  Maltby
  Prince of Wales
  Riccall/Whitemoor
  Rossington
  Stillingfleet/North Selby
  Thoresby
  Welbeck
  Wistow
Scottish Coal Co Ltd Longannet
Tower Colliery Ltd Tower

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Appendix 5 - Audit Of Accidents

Table 1

MINE 1 2 3 4 5
Accidents reported Total
Accs
Reviewed
F MI +3
DAY		 LATE
1 0 3 6 0 115
2 0 3 3 0 90
3 0 2 13 11 175
4 0 4 12 10 148
5 0 2 11 0 216
6 0 7 31 0 766
7 0 8 23 44 400
8 2 10 14 30 339
9 0 8 20 29 266
10 1 12 29 28 762
11 0 2 16 10 255
12 0 16 32 41 1,027
13 0 4 13 13 379
14 0 5 12 0 499
15 0 6 30 12 526
16 0 9 14 37 461
17 0 10 5 4 258
18 0 2 1 0 87
19 0 3 10 0 100
20 0 3 31 0 486
21 0 3 10 0 155
TOTAL 3 122 336 269 7,510

Columns 1, 2 and 3 - refer to fatal, major injury and plus 3 day accidents which had been reported within the time constraints of RIDDOR.

Column 4 - refers to those accidents which the individual mines had identified during internal audits for which retrospective notification was given to the Mines Inspectorate. All figures relate to +3 day accidents.

Column 5 - refers to the total number of accidents identified at each mine for consideration during the review.

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Table 2

MINE 6 7 8
AUDIT FINDINGS;
Reasons for absence
or incapacity		 MI TOTAL F2508
recv'd		 Comprised
by M. Insp.
A B C D E
1 4 0 0 0 0 0 4 4 4
2 4 1 3 2 0 0 10 10 10
3 0 0 0 0 0 0 0 0 0
4 1 0 0 0 0 0 1 1 1
5 0 0 0 2 1 0 3 2 2
6 4 5 4 0 6 0 19 19 11
7 3 0 2 0 3 1 9 9 9
8 8 4 4 0 3 1 20 20 6
9 2 0 0 0 0 0 2 2 2
10 18 4 8 0 7 0 37 37 29
11 0 0 0 0 0 0 0 0 0
12 12 6 4 0 6 0 28 28 27
13 1 2 0 0 0 0 3 3 3
14 14 10 3 2 10 0 39 37 37
15 11 4 6 1 3 0 25 20 16
16 22 1 4 1 4 1 33 33 23
17 2 2 1 0 9 0 14 10 10
18 4 0 0 1 4 0 9 9 9
19 0 3 0 0 1 0 4 0 0
20 8 0 9 0 14 1 32 27 27
21 4 4 1 1 0 0 10 12 10
TOTAL 122 46 49 10 71 4 302 283 236

Reasons for absence or incapacity:

A = Surface light duties
B = Weekends and statutory holidays not counted
C = Holidays applied for after an accident
D = Recurrent injury
E = Self/Doctor's Certification of incapacity

Column 6 - refers to the findings of the audit, categorised as detailed in the footnote. All figures in columns A to E are +3 day accidents.

Column 7 - lists the number of F2508 forms submitted by the individual mines following the audit.

Column 8 - lists the number of accidents that were subsequently comprised following the evaluation of any additional information submitted by the mine.

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Table 3

MINE 9 10 11
TOTALS %
Audit/
Total		 %
Audit &
Late/
Total
F MI +3
DAY		 TOTAL
1 0 3 10 13 31% 31%
2 0 3 13 16 63% 63%
3 0 2 24 26 0% 42%
4 0 4 23 27 4% 41%
5 0 2 13 15 13% 13%
6 0 7 42 49 22% 22%
7 0 9 75 84 11% 63%
8 2 10 50 62 10% 58%
9 0 8 51 59 3% 53%
10 1 12 86 99 29% 58%
11 0 2 26 28 0% 36%
12 0 16 100 116 23% 59%
13 0 4 29 33 9% 48%
14 0 5 49 54 69% 69%
15 0 6 58 64 25% 44%
16 0 10 74 84 27% 71%
17 0 10 19 29 34% 48%
18 0 2 10 12 75% 75%
19 0 3 10 13 0% 0%
20 0 3 58 61 44% 44%
21 0 3 20 23 43% 43%
TOTAL 3 124 841 967 24% 52%

Column 9 - records the total accident information incorporating the results of the audit for the period 1 January 1997 until 30 November 1997.

Column 10 - records the percentage of accidents comprised following the audit (8) as a percentage of the total number of reported accidents (9).

Column 11 - records the number of accidents comprised following the audit (8) plus the late reported accidents (4) expressed as a percentage of the total accidents (9).