By Zablon Oyugi
The revised Code of Practice (COP) for Road and Rail Safety in Mining introduced by South Africa’s Department of Mineral Resources and Energy (DMRE) comes at a time when transport-related incidents remain a leading cause of injuries and fatalities in the mining sector.
Indeed, the updated regulations are intended to force the industry to confront its long-standing tendency to treat transport safety as a compliance checkbox rather than a core operational risk.
According to Louise Woodburn, General Manager at KBC Health and Safety, the new regulations mark both a regulatory turning point and a practical opportunity for mining operations to fundamentally rethink how they manage transport risks.
“While legislation is written in black and white, the reality is that we are still experiencing far too many accidents across the country and the continent, with transport remaining one of the leading causes of fatalities in mining thus the new requirements are specifically aimed at addressing that reality,” said Woodburn in an exclusive interview with First Mining DRC – ZAMBIA.
What the new COP changes in practice
The revised COP, now legislated under the Mine Health and Safety Act, significantly raises the bar for accountability. Unlike previous guidance documents, it carries legal weight and applies across the entire transport value chain — from mine-owned roads and rail sidings to contractor vehicles and interfaces with public infrastructure.
“There is now greater accountability across the supply chain, meaning mines can no longer operate in silos and must engage with road authorities, rail network operators, private road owners and contractors, because transport safety is complex and requires the involvement of all stakeholders,” explained Woodburn.
Importantly, the COP has “teeth”, she adds. “It’s no longer a recommendation. It’s been legislated, which means non-compliance puts mines outside the law.”
Closing the gap between compliance and competency
One of the most significant themes emerging from the revised COP is the distinction between compliance and competency — a gap Woodburn says many operations still struggle to bridge.
“Compliance is one thing, competency is another,” she says. “You can tick a box to say someone has a licence, but that doesn’t mean they are competent to operate in a specific mining environment.”
The COP places strong emphasis on driver readiness, route-specific knowledge and human factors such as fatigue. Operators must now demonstrate that drivers are medically fit, understand mine-specific road geometry, level crossings and interfaces, and are trained for the conditions they actually face.
“You cannot assume that because someone is licensed, they’re ready,” Woodburn notes. “Competency must be tied back to context — the route, the gradient, the weather conditions and the vehicle type. All of that changes the risk.”
From tick boxes to risk ownership
The revised COP also demands a shift in safety culture — away from checklist-driven systems toward real risk ownership.
“We have to move away from tick-box compliance, because transport and logistics are major risks, and without properly analysing them and implementing meaningful controls, safety will not improve,” Woodburn says.
The code strengthens requirements around vehicle design, braking systems, maintenance records, pre-use inspections and route integration. Road geometry, stopping distances, visibility, signage, illumination and interaction with public roads must all be incorporated into formal risk assessments.
“We can’t just say, ‘Yes, we checked the road’; drivers must understand those conditions as part of their training and ongoing risk management,” she says.
Human factors are another major focus. “Fatigue, alcohol and drug testing now play a much bigger role. from a transport and logistics perspective. If we don’t address human behaviour, we won’t reduce accidents,” said the general manager.
Practical steps for mines
According to Woodburn, the most effective starting point for mines — regardless of size — is a transport gap audit.
“My recommendation to all mines is to start with a gap audit, which identifies their current position and allows them to develop a realistic roadmap to close any gaps,” she says.
A key early action is developing a transport competency matrix that maps all driver and operator categories, from passenger vehicles to haul trucks and rail operations. This should define minimum licence requirements, medical fitness, route knowledge and refresher training.
“A small mine can’t spend millions on technology, so the focus must be on practical, risk-based solutions that understand the intent of the COP and implement controls that genuinely reduce risk,” she said while acknowledging that junior mining operations face resource constraints.
The Biggest Challenge: Behaviour
Despite advances in systems and technology, Woodburn believes the biggest obstacle to compliance remains human behaviour.
“You can have all the systems in the world,” she says. “If you’re not driving behaviour and accountability — seatbelts, speed, fatigue — then the systems won’t save you. Humans will always be the biggest risk if culture doesn’t change.”
Her message to the industry is clear: “Let’s move away from tick-box compliance to real risk ownership. Empower supervisors to enforce standards, not just monitor them. And link real competency to operational capacity — not just licences.”
With the COP compliance deadline approaching, mines that embrace this shift early may not only meet regulatory requirements, but also take a meaningful step toward safer, more sustainable operations.
