ADDENDUM The Expert Legal Assessment CMSHA, CMSHR and Recognised Standards Report conducted by the Minerals Industry Safety and Health Centre 8 November 2019 Additional Reasons for the Expert Report to be withdrawn.

Addendum The Expert Legal Assessment CMSHA CMSHR

Additional Reasons for the Expert Report to be withdrawn.

MISHC claiming being Expert and Independent needs some scrutiny.

MISHC in large part is funded by the Mining Companies.

MISHC also applies for ACARP research grants and research grants from Individual Mining Companies

One of the participants has for many years been involved in the creation of the Annual Safety and Health Report for the Queensland Mining Industry

1. None of the participants have ever been employed at an Underground Coal Mine. Two of the Three have never been a Coal Mine Worker at either an Open Cut Coal Mine. 

2. At least Two of the Participants have no recognised Mining Legislation Competencies 

3. There are no recognised competencies for Underground Coal Mining for any of the participants. 

4. Several of the Underground Recommendations obviously come from one of the participants involvement in the later stages of the heating, fire and explosions and emergency sealing at the surface from North Goonyella in 2018. 

5. The Mines Department despite it now being Two and a half years since North Goonyella sealing the Mines Department still refuses to make any sort of Investigation Report Public for Review. It is completely inappropriate for views of one of the participants to be making suggestions on changes to Underground Regulations. 

6. From my analysis, the majority of suggestions advanced by the Expert Study are just a resubmission of suggested changes to the Act and Regulations previously rejected by the Coal Mining Safety and Health Council prior to 2010. 

7. In essence many are attempts by individuals interviewed by the panel to have previously rejected amendments given a second chance to a new CMSHAC which has no members remaining who were on the CMSHAC when they were rejected. 

8. Many if not the majority of Regulations mentioned are Regulations that the Grosvenor Board of Inquiry and likely subject to Recommendations from the Grosvenor Inquiry 

9. There is One (1) Recommendation about Section 275 AA Protection from Reprisal (Newsom Clause)

COAL SAFETY REGULATIONS

 There are around suggestions on some 55 Regulations including 

1. One (1) about S366 Withdrawal of persons in case of danger
2. One (1) Accessing Standard Operating Procedures
3. Seven (7) General Regulation on Plant, Braking, Guarding, Safe Access and Prestart Checks
4. One (1) concerning Open Cut Examiner in the Open Cut Regulations
5. Five (5) General and Four (4) Underground Electrical Regulations
6. Four (4) Underground Methane Regulations
7. One (1) Mine Plans
8. One (1) Notices to Inspectors
9. Four (4) Ventilation System for atmospheric contaminants including S361

CHANGES PREVIOUSLY REJECTED BY CMSHAC

 A large number of the changes suggested to the MISHC Group and included in their Report, have previously been rejected by the Coal Mine Safety and Health Advisory Council between 2001 and 2010.

 I am personally aware of this due to

1. Being an Industry Safety and Health Representative between 1999 and 2006.
2. Serving on the Coal Mining Safety and Health Advisory Council between 2006 and 2010
3. Being on several CMSHAC sub-committees 2001 to 2006 that considered Recognised Standards existing and proposed, Coal Mine Dust and Diesel Particulate