OSH&W Code, 2020, Coal Mines Regulation, 2017 and DGMS Circulars have provisions for protecting the safety and health of mine workers and those affected by mining operations. These statutes require that risks to safety and health from mining operations be identified and controlled to within acceptable limits and be as low as reasonably achievable (referred to as an acceptable level of risk). One of the primary ways to achieve this is that each mine develops a Safety and Health Management System (SHMS) or Safety Management Plan (SMP) that identifies hazards, examines attendant risks and ensures that these risks are controlled within acceptable limits. Under the legislation, the Owner/ Agent/ Managers are given separate but complementary obligations to ensure that this is achieved.

As required under Regulation 104 of CMR 2017, the owner, agent and manager of a coal mine has the obligation to develop and implement the SMP and to ensure the risk to persons from mining operations is at an acceptable level. It is also mentioned that the SMP must contain ways to measure, monitor and evaluate the performance of the safety management plan and to correct matters that do not conform with the safety management plan; and also, a plan to regularly review and continually improve the safety management plan.

One of the reasons for the ineffective implementation of the present system of risk-based safety management in Indian coal mines is the lack of suitable mechanisms or processes for auditing the SMPs at regular intervals. In view of the above, the committee constituted at ministry suggested that a system of regular auditing shall be adopted by the mine management for effective implementation of the Safety and Health Management system. The auditing shall be done by qualified auditors who are experienced in SHMS having domain knowledge and experience.

The detailed guidelines were issued by the ministry of Coal vide: F. No.51013/1/2020-MPS, dated 22.12.2023 for its implementation and mine management were mandated to audit their Safety and Health management system on yearly basis and submit the audit report to CCO by the end of March every year.