Joint interaction management plans for overlapping operations

All overlapping coal and coal seam gas (CSG) operations require a joint interaction management plan (JIMP) to identify and control the hazards and risks of the overlapping operations.

This requirement is set out in the Coal Mining Safety and Health Act 1999 and the Petroleum and Gas (Production and Safety) Act 2004.

The requirement applies to all combinations of overlapping coal and CSG resource authorities (including those under the Petroleum Act 1923) where activities at an operating plant (other than a coal mining-CSG operating plant) could adversely affect the safe mining of coal in the overlapping area.

Relationship to safety management systems

An agreed JIMP becomes part of the safety and health management system of the coal mine and part of the safety management system for each applicable operating plant in the overlapping area.

Development process

The development of the JIMP is the responsibility of the:

• site senior executive (SSE) for the coal mine
  and
• the petroleum and gas resource authority holder (i.e. the operator of an authorised activities operating plant) in consultation with each operator of an applicable operating plant in the overlapping area.

The SSE and the operators must consult and agree on a JIMP that will apply at the coal mine and to the CSG operations in the overlapping area.

Either party can initiate the process by sending a copy of the proposed JIMP to the other party. The other party must respond with 20 business days. If agreement cannot be reached within 3 months, the dispute must be submitted for arbitration.

To ensure that all CSG hazards are identified and controlled, the CSG operators must coordinate their input into the JIMP before reaching agreement with the coal mine's SSE.

Application to a new overlapping operations

The JIMP must be developed before the start of operations.

If a JIMP cannot be agreed upon within 3 months of it being proposed to the other party, the matter must be submitted for arbitration.

Content of a JIMP

The JIMP must comply with all legislative and regulatory safety requirements.

It must contain at least the matters stated in:

• s. 705C of the Petroleum and Gas (Production and Safety) Act 2004
• s. 64F of the Coal Mining Safety and Health Act 1999.

Additional information requirements are detailed in s. 12BB of the Coal Mining Safety and Health Regulation 2017 and ss. 50, 52, 53 and 54 of the Petroleum and Gas (Safety) Regulation 2018.

Some of the content requirements for a JIMP is outlined below, however for the full list refer to the legislation.

The JIMP must identify:

• each initial mining area (IMA), rolling mining area (RMA) and simultaneous operation zone (SOZ), if any, in the overlapping area
• hazards and risks to be controlled and triggers or material changes to be monitored — requiring the JIMP to be reviewed
• response procedures and times and reporting procedures
• proposed or likely interactions with other persons in the overlapping area and associated risks from the interactions
• safety responsibilities of each person including the names of key safety persons.

The JIMP must describe how the SSE and the operators intend to communicate and coordinate their obligations about:

• emergencies
• incident response
• induction training
• information exchange
• vehicle safety
• any agreed alternative safety requirements applying to boreholes.

Reviews and revisions

The JIMP must be reviewed and revised through ongoing consultation if there are changes to operations in the overlapping area, or for other reasons, including if a risk control measure did not control the risk it was intended to control.

Also consider...

• Read about operating plant and safety management systems.
• Read about safety and health requirements for the mining industry and the petroleum and gas industry.