Reference: RS22, Section 4, Application of Framework.

The Management Structure for the implementation of a SHMS must be developed from a whole mine site risk assessment. The purpose of the risk assessment is to identify principal and fatal hazards which may affect the safety and health of mine workers, and the requirements for a Management Structure to control the hazards under the SHMS.

The rationale sets the threshold for which items from the BBRA warrant the highest level of attention and therefore, will be included as Material Unwanted Events (MUEs) to be considered in the context of Recognised Standard 22. These are the risks for which the SSE needs to designate a Risk Owner and then define competencies for persons on the Management Structure to fulfil SHMS roles with respect to these MUEs.

It is critical to define this rationale, so there is a documented reasoning as to how the MUEs were identified and defined, how risk responsibilities are allocated and competency requirements determined (as these may adjust based on site and industry incident data, changes to the Management Structure, updates to available training, or changes in risk appetite or approach by the SSE).

Note: A Material Unwanted Event (MUE) is defined as an unwanted event in relation to which the potential or real consequence to safety or health exceeds a threshold defined by the coal mine operator as warranting the highest level of attention. (Resources Safety and Health Legislation Amendment Bill 2024 Part 2 Amendment of Coal Mining Safety and Health Act 1999 ). The term MUE is an international and widely accepted term.

Rationale: RS22 requires the SSE to define the threshold a risk must exceed before being considered an MUE. This is then able to define the RS22 MUE Matrix. Generally, these risks should be identified, and the criteria applied at the Layer 1 – Mine Baseline / Broad Brush risk assessment. (RS02 Draft v2).

Reference: RS22, Section 4, Application of Framework.

The Management Structure for the implementation of a SHMS must be developed from a whole mine site risk assessment. The purpose of the risk assessment is to identify principal and fatal hazards which may affect the safety and health of mine workers, and the requirements for a Management Structure to control the hazards under the SHMS.

The rationale sets the threshold for which items from the BBRA warrant the highest level of attention and therefore, will be included as Material Unwanted Events (MUEs) to be considered in the context of Recognised Standard 22. These are the risks for which the SSE needs to designate a Risk Owner and then define competencies for persons on the Management Structure to fulfil SHMS roles with respect to these MUEs.

It is critical to define this rationale, so there is a documented reasoning as to how the MUEs were identified and defined, how risk responsibilities are allocated and competency requirements determined (as these may adjust based on site and industry incident data, changes to the Management Structure, updates to available training, or changes in risk appetite or approach by the SSE).

Note: A Material Unwanted Event (MUE) is defined as an unwanted event in relation to which the potential or real consequence to safety or health exceeds a threshold defined by the coal mine operator as warranting the highest level of attention. (Resources Safety and Health Legislation Amendment Bill 2024 Part 2 Amendment of Coal Mining Safety and Health Act 1999 ). The term MUE is an international and widely accepted term.

Rationale: RS22 requires the SSE to define the threshold a risk must exceed before being considered an MUE. This is then able to define the RS22 MUE Matrix. Generally, these risks should be identified, and the criteria applied at the Layer 1 – Mine Baseline / Broad Brush risk assessment. (RS02 Draft v2).

Reference: RS22, Section 4, Application of Framework.

The Management Structure for the implementation of a SHMS must be developed from a whole mine site risk assessment. The purpose of the risk assessment is to identify principal and fatal hazards which may affect the safety and health of mine workers, and the requirements for a Management Structure to control the hazards under the SHMS.

The rationale sets the threshold for which items from the BBRA warrant the highest level of attention and therefore, will be included as Material Unwanted Events (MUEs) to be considered in the context of Recognised Standard 22. These are the risks for which the SSE needs to designate a Risk Owner and then define competencies for persons on the Management Structure to fulfil SHMS roles with respect to these MUEs.

It is critical to define this rationale, so there is a documented reasoning as to how the MUEs were identified and defined, how risk responsibilities are allocated and competency requirements determined (as these may adjust based on site and industry incident data, changes to the Management Structure, updates to available training, or changes in risk appetite or approach by the SSE).

Note: A Material Unwanted Event (MUE) is defined as an unwanted event in relation to which the potential or real consequence to safety or health exceeds a threshold defined by the coal mine operator as warranting the highest level of attention. (Resources Safety and Health Legislation Amendment Bill 2024 Part 2 Amendment of Coal Mining Safety and Health Act 1999 ). The term MUE is an international and widely accepted term.

Rationale: RS22 requires the SSE to define the threshold a risk must exceed before being considered an MUE. This is then able to define the RS22 MUE Matrix. Generally, these risks should be identified, and the criteria applied at the Layer 1 – Mine Baseline / Broad Brush risk assessment. (RS02 Draft v2).

Reference: RS22, Section 5 Management Structure.

There are three (3) positions or categories of position identified in the Management Structure under Section 55 of the CMSH Act:

• SSE
• Senior positions (includes contractors’ manager and service providers)
• Supervisory positions

Each of these positions have a role in developing, implementing, applying, and monitoring the SHMS dependant on their level of responsibility.

Rationale: There are several roles which must be on the Management Structure (SSE, EEM, and the Person responsible for contractors and service providers + additional for Underground Coal Mines). All roles that comprise the CMSH Act s55 Management Structure should only be listed if they have been explicitly allocated an SHMS role against one or more MUEs (as defined from the BBRA / Risk Register).

Note: It is important to recognise and clarify that the s.55 Management Structure for the coal mine, is not the same as the Organisation Structure in place to run the operation.

Reference: RS22, Section 5 Management Structure.

There are three (3) positions or categories of position identified in the Management Structure under Section 55 of the CMSH Act:

• SSE
• Senior positions (includes contractors’ manager and service providers)
• Supervisory positions

Each of these positions have a role in developing, implementing, applying, and monitoring the SHMS dependant on their level of responsibility.

Rationale: There are several roles which must be on the Management Structure (SSE, EEM, and the Person responsible for contractors and service providers + additional for Underground Coal Mines). All roles that comprise the CMSH Act s55 Management Structure should only be listed if they have been explicitly allocated an SHMS role against one or more MUEs (as defined from the BBRA / Risk Register).

Note: It is important to recognise and clarify that the s.55 Management Structure for the coal mine, is not the same as the Organisation Structure in place to run the operation.

Reference: RS22, Section 5.2 Senior Position for Managing Contractors and Service Providers.

The Management Structure document must state "the name of the person who is responsible for establishing and implementing a system for managing contractors at the coal mine" (reference CMSH Act s55(2)(d).

Rationale: This is the person that is responsible for the integration of contractors and services providers into the site (single) SHMS, not the day to day management of the contracts. This person is identified in the Management Structure as a Senior Position.

Reference: RS22, Section 5.4 Competencies.

The competencies required for positions in the Management Structure must be stated. The competencies must be consistent with responsibility of the position and relevant to the levels of responsibility described in the Australian Qualifications Framework, the RII Training Package or other relevant competency for the risk at the mine.

In determining position competence requirement, an SSE must consider the Australian Qualifications Framework to determine the appropriate level of competency and the Resources and Infrastructure Industry training package, mine site-specific training and competency content, and experience of the worker etc.

Reference: 5.6 Areas of Competence

To be assessed as competent, a person should have a range of competency across a spectrum of required knowledge. These areas of competence should include:

• Knowledge of legislative or procedural requirements;
• Knowledge of safety and risk management practices;
• Knowledge of controlling hazards relevant to the activity and the position’s responsibilities; and
• Knowledge of emergency management.

Note: The RII Training Package makes allowance for units from other industry training packages to be adopted (such as AUR for Tyre Handling).

Rationale:

Senior (RISK OWNER) roles will typically be allocated AQF6 units of competency, Supervisory - Implement (CONTROL IMPLEMENTER) AQF5 and Supervisory - Apply & Monitor (CONTROL MONITOR) AQF4.

There are challenges with the identification of units that meet the AQF alignment with RS22 roles, such as no units at AQF 5 or 6 for Confined Space as an MUE - the SSE must consider and apply a suitable process to determine competence regardless and record this rationale.

The experience of the person must be considered in the determination of competence and allocation of any specific MUE risk responsibility.

Reference: RS22, Section 5.4 Competencies.

The competencies required for positions in the Management Structure must be stated. The competencies must be consistent with responsibility of the position and relevant to the levels of responsibility described in the Australian Qualifications Framework, the RII Training Package or other relevant competency for the risk at the mine.

In determining position competence requirement, an SSE must consider the Australian Qualifications Framework to determine the appropriate level of competency and the Resources and Infrastructure Industry training package, mine site-specific training and competency content, and experience of the worker etc.

Reference: 5.6 Areas of Competence

To be assessed as competent, a person should have a range of competency across a spectrum of required knowledge. These areas of competence should include:

• Knowledge of legislative or procedural requirements;
• Knowledge of safety and risk management practices;
• Knowledge of controlling hazards relevant to the activity and the position’s responsibilities; and
• Knowledge of emergency management.

Note: The RII Training Package makes allowance for units from other industry training packages to be adopted (such as AUR for Tyre Handling).

Rationale:

Senior (RISK OWNER) roles will typically be allocated AQF6 units of competency, Supervisory - Implement (CONTROL IMPLEMENTER) AQF5 and Supervisory - Apply & Monitor (CONTROL MONITOR) AQF4.

There are challenges with the identification of units that meet the AQF alignment with RS22 roles, such as no units at AQF 5 or 6 for Confined Space as an MUE - the SSE must consider and apply a suitable process to determine competence regardless and record this rationale.

The experience of the person must be considered in the determination of competence and allocation of any specific MUE risk responsibility.

Reference: RS22, Section 5.4 Competencies.

The competencies required for positions in the Management Structure must be stated. The competencies must be consistent with responsibility of the position and relevant to the levels of responsibility described in the Australian Qualifications Framework, the RII Training Package or other relevant competency for the risk at the mine.

In determining position competence requirement, an SSE must consider the Australian Qualifications Framework to determine the appropriate level of competency and the Resources and Infrastructure Industry training package, mine site-specific training and competency content, and experience of the worker etc.

Reference: 5.6 Areas of Competence

To be assessed as competent, a person should have a range of competency across a spectrum of required knowledge. These areas of competence should include:

• Knowledge of legislative or procedural requirements;
• Knowledge of safety and risk management practices;
• Knowledge of controlling hazards relevant to the activity and the position’s responsibilities; and
• Knowledge of emergency management.

Note: The RII Training Package makes allowance for units from other industry training packages to be adopted (such as AUR for Tyre Handling).

Rationale:

Senior (RISK OWNER) roles will typically be allocated AQF6 units of competency, Supervisory - Implement (CONTROL IMPLEMENTER) AQF5 and Supervisory - Apply & Monitor (CONTROL MONITOR) AQF4.

There are challenges with the identification of units that meet the AQF alignment with RS22 roles, such as no units at AQF 5 or 6 for Confined Space as an MUE - the SSE must consider and apply a suitable process to determine competence regardless and record this rationale.

The experience of the person must be considered in the determination of competence and allocation of any specific MUE risk responsibility.

Reference: RS22, Section 5.4 Competencies.

The competencies required for positions in the Management Structure must be stated. The competencies must be consistent with responsibility of the position and relevant to the levels of responsibility described in the Australian Qualifications Framework, the RII Training Package or other relevant competency for the risk at the mine.

In determining position competence requirement, an SSE must consider the Australian Qualifications Framework to determine the appropriate level of competency and the Resources and Infrastructure Industry training package, mine site-specific training and competency content, and experience of the worker etc.

Reference: 5.6 Areas of Competence

To be assessed as competent, a person should have a range of competency across a spectrum of required knowledge. These areas of competence should include:

• Knowledge of legislative or procedural requirements;
• Knowledge of safety and risk management practices;
• Knowledge of controlling hazards relevant to the activity and the position’s responsibilities; and
• Knowledge of emergency management.

Note: The RII Training Package makes allowance for units from other industry training packages to be adopted (such as AUR for Tyre Handling).

Rationale:

Senior (RISK OWNER) roles will typically be allocated AQF6 units of competency, Supervisory - Implement (CONTROL IMPLEMENTER) AQF5 and Supervisory - Apply & Monitor (CONTROL MONITOR) AQF4.

There are challenges with the identification of units that meet the AQF alignment with RS22 roles, such as no units at AQF 5 or 6 for Confined Space as an MUE - the SSE must consider and apply a suitable process to determine competence regardless and record this rationale.

The experience of the person must be considered in the determination of competence and allocation of any specific MUE risk responsibility.

Reference: RS22, Section 5.4 Competencies.

The competencies required for positions in the Management Structure must be stated. The competencies must be consistent with responsibility of the position and relevant to the levels of responsibility described in the Australian Qualifications Framework, the RII Training Package or other relevant competency for the risk at the mine.

In determining position competence requirement, an SSE must consider the Australian Qualifications Framework to determine the appropriate level of competency and the Resources and Infrastructure Industry training package, mine site-specific training and competency content, and experience of the worker etc.

Reference: 5.6 Areas of Competence

To be assessed as competent, a person should have a range of competency across a spectrum of required knowledge. These areas of competence should include:

• Knowledge of legislative or procedural requirements;
• Knowledge of safety and risk management practices;
• Knowledge of controlling hazards relevant to the activity and the position’s responsibilities; and
• Knowledge of emergency management.

Note: The RII Training Package makes allowance for units from other industry training packages to be adopted (such as AUR for Tyre Handling).

Rationale:

Senior (RISK OWNER) roles will typically be allocated AQF6 units of competency, Supervisory - Implement (CONTROL IMPLEMENTER) AQF5 and Supervisory - Apply & Monitor (CONTROL MONITOR) AQF4.

There are challenges with the identification of units that meet the AQF alignment with RS22 roles, such as no units at AQF 5 or 6 for Confined Space as an MUE - the SSE must consider and apply a suitable process to determine competence regardless and record this rationale.

The experience of the person must be considered in the determination of competence and allocation of any specific MUE risk responsibility.

Reference: RS22, Section 5.1 Management Structure Positions.

It is the obligation of the SSE to consider each supervisory position and determine their role in the implementation and application of the SHMS. Where supervisors are appointed to undertake safety inspections as part of their roles, they must be competent and authorised to do so. They also need to consider the various ways in which direction may be given in determining supervisory roles (See hierarchy of positions 5.5).

The SSE must then ensure that the competencies required for each supervisory position:

• are documented as a part of the notification;
• are relevant to the hazards and activities associated with the tasks to be supervised;
• include any competencies required by the CMSHAC; and
• include competencies as identified by the SSE to ensure that the supervisor is competent in the task that they are authorised to supervise with regards to the implementation, application, and monitoring of the SHMS.

When appointing supervisors in the Management Structure the SSE must consider the relevant skills and experience of the appointee, their understanding of the work to be supervised and what their responsibilities are in implementing, applying and monitoring the SHMS.

The supervisor’s responsibilities must be communicated to the persons appointed when they are authorised to carry out the responsibilities of the position. A record of the acceptance of these responsibilities should be maintained.

Note: Is typical industry custom and practice to provide all persons appointed to the Management Structure with some form and record of the Appointment, such as a Letter of Appointment (LoA).

Rationale: Each person on the Management Structure should have a customised Letter of Appointment that clearly details their role(s) on the Management Structure, MUE related risk responsibilities, the expectations / responsibilities of the role, and either competencies required or reference to the site TNA. For Senior Persons, the site is also required to identify gaps in competencies required and develop a plan to close any gaps. This detail is included in the site section 55 Management Structure.

A process should be established for what happens if a person is to be appointed into a Management Structure role but they do not have 100% compliance for competencies required by the SSE.

Reference: RS22, Section 5.1 Management Structure Positions.

It is the obligation of the SSE to consider each supervisory position and determine their role in the implementation and application of the SHMS. Where supervisors are appointed to undertake safety inspections as part of their roles, they must be competent and authorised to do so. They also need to consider the various ways in which direction may be given in determining supervisory roles (See hierarchy of positions 5.5).

The SSE must then ensure that the competencies required for each supervisory position:

• are documented as a part of the notification;
• are relevant to the hazards and activities associated with the tasks to be supervised;
• include any competencies required by the CMSHAC; and
• include competencies as identified by the SSE to ensure that the supervisor is competent in the task that they are authorised to supervise with regards to the implementation, application, and monitoring of the SHMS.

When appointing supervisors in the Management Structure the SSE must consider the relevant skills and experience of the appointee, their understanding of the work to be supervised and what their responsibilities are in implementing, applying and monitoring the SHMS.

The supervisor’s responsibilities must be communicated to the persons appointed when they are authorised to carry out the responsibilities of the position. A record of the acceptance of these responsibilities should be maintained.

Note: Is typical industry custom and practice to provide all persons appointed to the Management Structure with some form and record of the Appointment, such as a Letter of Appointment (LoA).

Rationale: Each person on the Management Structure should have a customised Letter of Appointment that clearly details their role(s) on the Management Structure, MUE related risk responsibilities, the expectations / responsibilities of the role, and either competencies required or reference to the site TNA. For Senior Persons, the site is also required to identify gaps in competencies required and develop a plan to close any gaps. This detail is included in the site section 55 Management Structure.

A process should be established for what happens if a person is to be appointed into a Management Structure role but they do not have 100% compliance for competencies required by the SSE.

Reference: RS22, Section 5.1 Management Structure Positions.

It is the obligation of the SSE to consider each supervisory position and determine their role in the implementation and application of the SHMS. Where supervisors are appointed to undertake safety inspections as part of their roles, they must be competent and authorised to do so. They also need to consider the various ways in which direction may be given in determining supervisory roles (See hierarchy of positions 5.5).

The SSE must then ensure that the competencies required for each supervisory position:

• are documented as a part of the notification;
• are relevant to the hazards and activities associated with the tasks to be supervised;
• include any competencies required by the CMSHAC; and
• include competencies as identified by the SSE to ensure that the supervisor is competent in the task that they are authorised to supervise with regards to the implementation, application, and monitoring of the SHMS.

When appointing supervisors in the Management Structure the SSE must consider the relevant skills and experience of the appointee, their understanding of the work to be supervised and what their responsibilities are in implementing, applying and monitoring the SHMS.

The supervisor’s responsibilities must be communicated to the persons appointed when they are authorised to carry out the responsibilities of the position. A record of the acceptance of these responsibilities should be maintained.

Note: Is typical industry custom and practice to provide all persons appointed to the Management Structure with some form and record of the Appointment, such as a Letter of Appointment (LoA).

Rationale: Each person on the Management Structure should have a customised Letter of Appointment that clearly details their role(s) on the Management Structure, MUE related risk responsibilities, the expectations / responsibilities of the role, and either competencies required or reference to the site TNA. For Senior Persons, the site is also required to identify gaps in competencies required and develop a plan to close any gaps. This detail is included in the site section 55 Management Structure.

A process should be established for what happens if a person is to be appointed into a Management Structure role but they do not have 100% compliance for competencies required by the SSE.

Reference: RS22, Section 5.1 Management Structure Positions.

It is the obligation of the SSE to consider each supervisory position and determine their role in the implementation and application of the SHMS. Where supervisors are appointed to undertake safety inspections as part of their roles, they must be competent and authorised to do so. They also need to consider the various ways in which direction may be given in determining supervisory roles (See hierarchy of positions 5.5).

The SSE must then ensure that the competencies required for each supervisory position:

• are documented as a part of the notification;
• are relevant to the hazards and activities associated with the tasks to be supervised;
• include any competencies required by the CMSHAC; and
• include competencies as identified by the SSE to ensure that the supervisor is competent in the task that they are authorised to supervise with regards to the implementation, application, and monitoring of the SHMS.

When appointing supervisors in the Management Structure the SSE must consider the relevant skills and experience of the appointee, their understanding of the work to be supervised and what their responsibilities are in implementing, applying and monitoring the SHMS.

The supervisor’s responsibilities must be communicated to the persons appointed when they are authorised to carry out the responsibilities of the position. A record of the acceptance of these responsibilities should be maintained.

Note: Is typical industry custom and practice to provide all persons appointed to the Management Structure with some form and record of the Appointment, such as a Letter of Appointment (LoA).

Rationale: Each person on the Management Structure should have a customised Letter of Appointment that clearly details their role(s) on the Management Structure, MUE related risk responsibilities, the expectations / responsibilities of the role, and either competencies required or reference to the site TNA. For Senior Persons, the site is also required to identify gaps in competencies required and develop a plan to close any gaps. This detail is included in the site section 55 Management Structure.

A process should be established for what happens if a person is to be appointed into a Management Structure role but they do not have 100% compliance for competencies required by the SSE.

Reference: RS22, Section 5.1 Management Structure Positions.

It is the obligation of the SSE to consider each supervisory position and determine their role in the implementation and application of the SHMS. Where supervisors are appointed to undertake safety inspections as part of their roles, they must be competent and authorised to do so. They also need to consider the various ways in which direction may be given in determining supervisory roles (See hierarchy of positions 5.5).

The SSE must then ensure that the competencies required for each supervisory position:

• are documented as a part of the notification;
• are relevant to the hazards and activities associated with the tasks to be supervised;
• include any competencies required by the CMSHAC; and
• include competencies as identified by the SSE to ensure that the supervisor is competent in the task that they are authorised to supervise with regards to the implementation, application, and monitoring of the SHMS.

When appointing supervisors in the Management Structure the SSE must consider the relevant skills and experience of the appointee, their understanding of the work to be supervised and what their responsibilities are in implementing, applying and monitoring the SHMS.

The supervisor’s responsibilities must be communicated to the persons appointed when they are authorised to carry out the responsibilities of the position. A record of the acceptance of these responsibilities should be maintained.

Note: Is typical industry custom and practice to provide all persons appointed to the Management Structure with some form and record of the Appointment, such as a Letter of Appointment (LoA).

Rationale: Each person on the Management Structure should have a customised Letter of Appointment that clearly details their role(s) on the Management Structure, MUE related risk responsibilities, the expectations / responsibilities of the role, and either competencies required or reference to the site TNA. For Senior Persons, the site is also required to identify gaps in competencies required and develop a plan to close any gaps. This detail is included in the site section 55 Management Structure.

A process should be established for what happens if a person is to be appointed into a Management Structure role but they do not have 100% compliance for competencies required by the SSE.

Reference: RS22, Section 10 Elements of the Management Structure Notification.

The SSE must include the Management Structure in the Mine Record. The notification to an inspector is expected to include an organisation chart showing the Management Structure for the development and implementation of the SHMS.

This section continues by defining all the components required of the notification. Note: RS22 Section 12, Appendix 2 gives a sample Management Structure Diagram

Reference: RS22, Section 10 Elements of the Management Structure Notification.

The SSE must include the Management Structure in the Mine Record. The notification to an inspector is expected to include an organisation chart showing the Management Structure for the development and implementation of the SHMS.

This section continues by defining all the components required of the notification. Note: RS22 Section 12, Appendix 2 gives a sample Management Structure Diagram

Reference: RS22, Section 9. Changes to the Management Structure.

The details of the change must be recorded in the Mine Record within 7 days and notified to an Inspector within 14 days.

Note: Examples of triggers for a new notification within 7/14 days:

• BBRA update, rerating, new MUE on or off
• Change to a person in a senior position
• Change to org structure, e.g. new role, role removed, reporting lines
• Change to SHMS roles - e.g. Risk Owner changed, MUE exposure changes
• Significant contractor change, new contractor, shutdown

Reference: RS22, Section 9. Changes to the Management Structure.

The details of the change must be recorded in the Mine Record within 7 days and notified to an Inspector within 14 days.

Note: Examples of triggers for a new notification within 7/14 days:

• BBRA update, rerating, new MUE on or off
• Change to a person in a senior position
• Change to org structure, e.g. new role, role removed, reporting lines
• Change to SHMS roles - e.g. Risk Owner changed, MUE exposure changes
• Significant contractor change, new contractor, shutdown

Reference: RS22, Section 8. Absences.

When a person who is:

• mentioned in the Management Structure; and
• actively supervises coal mine workers where there is a risk to the worker; and
• is temporarily absent from duty.

The SSE must appoint another competent person to perform the person’s duties while the person is absent.

The requirement to appoint another person to the position should be relevant to the level of risk and the duration of the absence.

Note: Absences may require relief coverage for a role. Relief capability may require succession planning (training and development targeted to specific MUE's, competencies and experience requirements).

Reference: RS22, Section 8. Absences.

When a person who is:

• mentioned in the Management Structure; and
• actively supervises coal mine workers where there is a risk to the worker; and
• is temporarily absent from duty.

The SSE must appoint another competent person to perform the person’s duties while the person is absent.

The requirement to appoint another person to the position should be relevant to the level of risk and the duration of the absence.

Note: Absences may require relief coverage for a role. Relief capability may require succession planning (training and development targeted to specific MUE's, competencies and experience requirements).

Recognised Standard 22 is risk-based rather than prescriptive - that is, it leaves most of the decisions to the SSE so that the solution is tailored for each individual coal mine.

It is recommended that the SSE records the decisions and the logic that was used, using a recognised risk process. Generally this should be in a risk assessment format, using a small focus group (typically SSE, HS&T Manager and an RS22 expert).

The risk assessment should include:

• Rationale of what constitutes a Material Unwanted Event from the BBRA
• Overarching direct supervisory experience and MUE-specific time-based experience for all roles on Management Structure
• Process to appoint a person who does not have all required competencies (e.g. Competency Gap Plan, or similar)
• Absence and Succession planning policy