Your SHMS is impeccable. Your documents and procedures are current, your risk management framework addresses every hazard with stringent controls, and you’re confident the whole system would hold up under audit. That confidence may be entirely justified.
Your SHMS says hazards will be reported. Are they? It says controls will be verified and supervisors will inspect every work area. Is that happening, every shift, on every site?
A permit requiring five managers’ signatures is unlikely to be obtained by your maintenance team on a Sunday. The plant still needs to run. A crew completing a short task at 2am in the rain signs on to a thirty-page risk assessment. Did they read it?
The legislation sets the standard. It doesn’t set the page count. Mineshield’s effectiveness audits find where the gap between the two has become a problem.